POLICY & GOVERNANCE / MANDATORY DISCLOSURE
UK SRS & CSRD
UK Sustainability Reporting Standards and the EU Corporate Sustainability Reporting Directive
The mandatory reporting regimes that are reshaping what large companies must disclose — and creating the supply chain data demands that flow down to everyone they buy from.
In 30 seconds
The UK and EU have both adopted mandatory sustainability reporting regimes for large companies. UK SRS (based on ISSB standards) applies to large UK-listed companies from 2026. CSRD (based on ESRS standards) applies to large EU companies from 2024 onwards, with scope widening each year.
Neither regime directly applies to most SMEs. Both regimes create significant indirect pressure on SMEs through their Scope 3 requirements — large companies filing these reports need verified sustainability data from their suppliers, which means the data demand flows down the supply chain.
The pattern: UK SRS is the container. CDP, SBTi, TNFD, and SBTN are the methodologies that fill it. A company filing UK SRS draws on all of these frameworks to produce its report.
The key conceptual difference: double materiality
The most important substantive difference between UK SRS and CSRD is materiality scope. This is not a technicality — it determines what a company must disclose.
How sustainability issues affect the company's financial performance, cash flows, and enterprise value — now and in the future. This is what ISSB and UK SRS prioritise.
Example: A farm's exposure to physical climate risk (drought reducing crop yields) is financially material because it directly affects revenue.
How the company's activities affect people and the environment — whether or not those impacts flow back to the company financially. This is what CSRD's double materiality adds.
Example: The same farm's pesticide use may harm local pollinators and water quality — an impact on nature and communities, even if it does not immediately affect the farm's own financial position.
ISSB — the global baseline
The International Sustainability Standards Board published IFRS S1 and S2 in June 2023. These form the global baseline that both UK SRS and many other jurisdictions are adopting. CDP Climate submission substantially satisfies IFRS S2 requirements.
Governance, strategy, risk management, and metrics/targets for all sustainability-related risks and opportunities. The general framework on top of which S2 sits.
Climate-specific disclosures — physical risks, transition risks, Scope 1/2/3 emissions, and climate targets. Directly aligned with TCFD. CDP Climate submission substantially satisfies IFRS S2 requirements.
UK SRS rollout
UK SRS is being phased in for UK-listed companies and FCA-regulated entities. The FCA is the primary driver; BEIS is developing requirements for large private companies. Supply chain data pressure begins from 2026 as the first filings appear.
CSRD and the ESRS standards
CSRD is the EU regulation; ESRS (European Sustainability Reporting Standards) are the detailed standards that specify what to disclose. ESRS 2 (general disclosures) is mandatory for all reporters. The topical standards (E1–E5, S1–S4, G1) apply based on materiality assessment.
CSRD: original scope vs Omnibus simplification
The EU Omnibus package (February 2025) cut the number of companies directly subject to CSRD by roughly 90%. Here is what changed — and what did not.
ORIGINAL CSRD (2019 design, first reports 2024)
POST-OMNIBUS DIRECTION (2025–26 amendments)
What this means in plain English: If you are a UK mid-market company not directly caught by CSRD, the Omnibus makes it very unlikely you ever will be under the current framework. The supply chain data pressure does not go away — it flows from the 5,000 companies that do remain in scope, who are your largest corporate buyers and investors. Build the data foundation for their Scope 3 requests, not for your own CSRD filing.
CSRD rollout timeline
Why this matters if you're not filing
UK SRS and CSRD directly apply to large listed companies. The indirect effect reaches every organisation in their supply chains.
Scope 3 creates the data demand
When a large listed company files UK SRS or CSRD, its Scope 3 emissions disclosure covers its entire value chain — purchased goods and services, upstream transport, downstream use of products. To report accurately, it needs emissions data from its suppliers. Those suppliers are you. A farm supplying a listed food manufacturer, or an estate supplying a listed housebuilder with timber, will face data requests flowing down from the buyer's Scope 3 obligations.
Nature risk amplifies this
Under ESRS E4 (biodiversity and ecosystems) and TNFD-aligned disclosures, large companies will also need to map their supply chain nature exposure. A food company must assess whether its agricultural suppliers are located near protected areas, operate on degraded land, or use water-stressed aquifers. This creates a pull for landscape-level data — the kind that Hampton Estate, HISAGEN, and similar organisations generate but currently do not monetise.
The timing is now
FTSE 350 companies are filing UK SRS from 2026. Their procurement teams are already working backwards through supply chains to build the data they need. SME suppliers that can provide verified, structured sustainability data — a CDP submission, a Pasture for Life record, a BNG baseline, a WCC registration — have a commercial advantage over those that cannot.
The Pandion view
UK SRS is the container. CDP, SBTi, TNFD are what fills it.
When a FTSE 350 company files its UK SRS report, it draws on CDP for climate disclosure data, SBTi for its validated climate targets, TNFD for its nature risk assessment, and SBTN for its nature targets. UK SRS is the regulatory vehicle; the voluntary frameworks are the methodologies that generate the inputs. Understanding this relationship explains why voluntary frameworks matter even to organisations not directly subject to UK SRS.
Double materiality is the substantive difference between CSRD and UK SRS.
UK SRS follows ISSB — financial materiality only. CSRD follows ESRS — double materiality (financial AND impact). For a supplier to a large EU company, this means the EU corporate needs impact data (how your operations affect nature and communities), not just financial risk data. EU supply chains are therefore more demanding than UK-only supply chains on the nature and social side.
The Omnibus simplification changes the CSRD picture materially.
EU Omnibus I came into force on 18 March 2026. It raised the CSRD threshold to companies with more than 1,000 employees and over €450M turnover, removing roughly 80% of prior reporters, and it raised CSDDD thresholds. This reduces direct CSRD exposure for many mid-market companies. It does not reduce the indirect supply chain pressure, which flows from the large companies that remain in scope. And it does not affect UK SRS at all.
Building the data foundation once satisfies both regimes simultaneously.
A Scope 1 carbon footprint, a water account, a biodiversity baseline, and a traceability record for your key products satisfies 70–80% of what UK SRS reporters will need from their supply chains. It simultaneously underpins a CDP submission, a TNFD LEAP assessment, and the starting data for an SBTi target. There is no need for separate projects per framework.
Where to go next
CDP
CDP Climate substantially satisfies IFRS S2 — the most efficient single step for UK SRS alignment
TNFD & LEAP
ESRS E4 biodiversity disclosure aligned with TNFD — the nature disclosure requirement in CSRD
Corporate reporting
How UK SRS and CSRD connect to corporate sustainability strategy and management systems