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.

ISSBESRSDouble materialityScope 3Supply chainTCFD-aligned

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.

Financial materiality (inside-out)

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.

Impact materiality (outside-in)

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.

CSRD requires both. UK SRS and ISSB require only financial materiality.

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.

IFRS S1General Sustainability Disclosures

Governance, strategy, risk management, and metrics/targets for all sustainability-related risks and opportunities. The general framework on top of which S2 sits.

IFRS S2Climate-related Disclosures

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.

2026
UK SRS S1 and S2 published (25 Feb 2026), ISSB-derived; voluntary at first
UK-listed and AIM companies above threshold
2026
FCA CP26/5 confirms mandatory path: UK SRS replaces the TCFD listing rules
Listed issuers
2027
Mandatory climate disclosure (S2) for listed issuers from 1 January 2027
FTSE 350 and large AIM companies first
2028+
Scope widens to large private companies; supply chain data demands intensify
Large UK private companies above FCA/BEIS thresholds; Scope 3 pressure on SMEs

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)

Threshold: 2 of 3 criteria — 250+ employees OR €40M turnover OR €20M balance sheet
Estimated scope: ~50,000 companies across the EU
Listed SMEs: Included from 2027 under simplified standards
Non-EU companies: In scope at €150M+ EU net turnover
ESRS: Full set of environmental, social, and governance standards; double materiality throughout

POST-OMNIBUS DIRECTION (2025–26 amendments)

Threshold: Raised to 1,000+ employees (single criterion)
Estimated scope: ~5,000 companies — a 90% reduction
Listed SMEs: Deferred; likely removed from mandatory scope
Non-EU companies: Threshold raised to €1.5bn EU net turnover
ESRS: Simplified; several “shall” requirements moved to “may”; sector-specific standards deferred

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.

ESRS 1
Cross-cutting
General requirements
Materiality assessment, due diligence, value chain scope, reporting period and entity.
ESRS 2
Cross-cutting
General disclosures
Governance, strategy, impacts/risks/opportunities management, and metrics baseline. Mandatory for all CSRD reporters.
ESRS E1
Environment
Climate change
GHG emissions (Scope 1/2/3), transition plan, physical and transition risk. Aligns with TCFD and partially with ISSB S2. Most companies will prioritise E1 first.
ESRS E2
Environment
Pollution
Air, water, soil pollution from operations. Relevant for manufacturing, agriculture, extraction.
ESRS E3
Environment
Water and marine resources
Water withdrawals, consumption, and discharge. Marine resource use.
ESRS E4
Environment
Biodiversity and ecosystems
Nature dependencies and impacts, aligned with TNFD LEAP and Kunming-Montreal GBF targets.
ESRS E5
Environment
Resource use and circular economy
Waste, resource use, product design, and circular economy commitments.
ESRS S1–S4
Social
Social standards
Workers (S1), supply chain workers (S2), affected communities (S3), consumers and end-users (S4).
ESRS G1
Governance
Business conduct
Corporate culture, anti-corruption, lobbying, payment practices, supplier relationships.

CSRD rollout timeline

2024
First CSRD reports filed
Large EU public-interest entities already subject to NFRD (approx. 11,700 companies)
2025
Large EU companies not previously subject to NFRD begin
Companies with 500+ employees OR over €40M turnover OR over €20M balance sheet (two of three)
2026
EU Omnibus I in force (18 Mar 2026): CSRD scope cut to 1,000+ employees and over €450M turnover
Roughly 80% of prior reporters removed; CSDDD thresholds raised
2026
Revised ESRS + voluntary VSME for SMEs (EC draft, 6 May 2026)
Mandatory datapoints cut 60%+; value-chain cap protects suppliers of 1,000 or fewer employees
2028+
Non-EU companies with significant EU operations
Non-EU companies with >€150M EU turnover and EU subsidiary or branch

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.