The package of consultations covers UK Sustainability Reporting Standards, transition plans, and assurance of sustainability-related disclosures.
On 25 June 2025, the UK government published a package of three consultations relating to the UK sustainability reporting framework. These much-anticipated consultations mark the first step towards creating a long-term UK framework and will impact a range of entities, including regulated financial institutions and listed companies.
UK Sustainability Reporting Standards (UK SRS)
The first consultation seeks views on the exposure drafts of UK SRS, which are based on the International Sustainability Standards Board (ISSB) Standards that were published in June 2023.
The consultation proposes six minor amendments to the ISSB Standards, to reflect their use in a UK context. The government considers all of these amendments to be necessary, rather than “nice to have” amendments. They include changes to the applicability of transition reliefs, amendments to certain references to other standards and materials, and the removal of “effective date” clauses so that the standards may be applied on a voluntary basis prior to any mandatory reporting obligations. In addition, the consultation seeks views on the costs and benefits of UK SRS, and on whether entities may require additional guidance to the already existing information.
Following this consultation, the UK government will make a final decision on whether to endorse the drafts of UK SRS. If it decides to endorse them, it will aim to publish the final standards in autumn 2025, after which they will be available for voluntary use. The decision on whether to introduce any mandatory reporting obligations in relation to UK SRS will be assessed separately. The FCA has stated that it plans to consult on how to adjust its current TCFD-aligned reporting requirements for listed companies to reference UK SRS later this year, while the government will consider whether to introduce sustainability disclosure requirements for economically significant entities outside the FCA’s regulatory perimeter “in due course”.
Transition Plans
This consultation explores the design of future requirements to implement the government’s commitment to mandate UK-regulated financial institutions and large companies to develop and implement credible transition plans that align with the 1.5°C goal of the Paris Agreement.
In particular, the government is considering whether to introduce a “comply or explain” regime, or a mandatory regime, likely based upon the Transition Plan Taskforce (TPT) Disclosure Framework. It is particularly keen to understand the role of transition plans alongside UK SRS. The government is also considering whether it should introduce an obligation on entities to take future actions consistent with their transition plan disclosures. Further, the government seeks views on whether and how climate resilience and nature could be incorporated over time to ensure a holistic approach to transition planning by companies.
Other issues raised in the consultation include the degree of legal risk associated with the publication of transition plan-related information, and what guidance and support would be most useful for companies to inform effective transition planning.
The government indicates that the focus of any new requirements it introduces will be on economically significant entities, including pension funds; small to medium-sized companies are not expected to be in scope. However, it notes that the FCA has independent powers to apply rules to the entities it regulates.
At this stage, the government is not seeking stakeholder views on the potential accountability mechanisms for any future requirements, nor on the implications of disclosing commercially sensitive information. It intends to address these issues in a future consultation once the preferred approach to transition plans has been confirmed. In the meantime, the FCA intends to consult on strengthening its expectations for listed companies’ transition plan disclosures, with reference to the TPT Disclosure Framework, as part of its consultation on the adoption of UK SRS by listed companies (referenced above).
Oversight Regime for Assurance of Sustainability-Related Financial Disclosures
Lastly, the government is consulting on the proposal to create a registration regime for providers that offer assurance services for sustainability-related financial disclosures in the UK. This would be operated by the Audit, Reporting and Governance Authority (ARGA), once established. The proposed regime would recognise assurance providers as being capable of assuring information disclosed against UK SRS, European Sustainability Reporting Standards (ESRS), and any jurisdictional standards that are aligned to the ISSB Standards.
The government indicates that any future consultation on requiring UK SRS disclosures will also consider whether to mandate assurance for entities subject to disclosure requirements.
Next Steps
Responses to all three consultations are requested by 17 September 2025. Further phases of consultation will cover additional proposals on sustainability reporting and assurance. The exact timeline for the finalisation of any reporting requirements and application dates remain unclear at this stage. However, the FCA requirements for listed companies will likely be finalised in advance of any government measures, as the latter will require legislative change.
The government has stated that, subject to future decisions, it intends to provide a roadmap of any future requirements as part of the subsequent phases of consultation. The FCA has also said that, as next steps under its Sustainability Disclosure Requirements (SDR) and investment labels regime, it will consider updating the disclosure requirements for asset managers to reflect UK SRS and the TPT Disclosure Framework.
