ESG Toolkit 

Climate-related Financial Disclosures (CFD)

Requires captured companies to provide information in their Annual Report and Accounts on how they are responding to the risks and opportunities of climate change and the transition to a low-carbon economy.

All UK companies that are currently required to produce a non-financial information statement, being UK companies that have more than 500 employees and have either transferable securities admitted to trading on a UK regulated market or are banking companies or insurance companies (Relevant Public Interest Entities (PIEs)).

UK registered companies with securities admitted to AIM with more than 500 employees.

UK registered companies not included in the categories above, which have more than 500 employees and a turnover of more than £500m.

Large LLPs, which are not traded or banking LLPs, and have more than 500 employees and a turnover of more than £500m.

Traded or banking LLPs which have more than 500 employees.

Companies should include a disclosure in line with the recommendations and guidelines of the Taskforce on Climate-related Financial Disclosures. This should be included in what was previously the Non-Financial Information Statement, now the Non-Financial and Sustainability Information Statement in the Strategic Report.

Energy Saving Opportunities Scheme (ESOS)

Requires captured companies to measure and manage energy consumption.

Large undertakings, i.e., those having either at least 250 employees, or an annual turnover of more than £44 million and an annual balance sheet total of £38 million.

Ensure that at least 90% of total energy consumption is subject an ESOS compliant energy audit or have a Display Energy Certificate, a Green Deal Assessment or a certified ISO 50001 Energy Management System.

Submit an action plan of planned reduction activities and then report on annual progress.

Streamlined Energy Carbon Reporting (SECR)

Requires captured companies to report on their Scope 1 and 2 emissions in their Annual Report and Accounts, including energy-saving activities.

Companies meeting two or more of the following:

• £36m annual turnover
• £18m balance sheet total
• 250 employees

Includes greenhouse gas emissions, energy use, an intensity metric and narrative around energy efficient actions. It should be included in the Annual Report and Accounts, covering natural gas and electricity consumption, all other fuels used (including stationary uses and transport), refrigerants.

Equality Act 2010
(Gender pay gap reporting)

Reporting on the difference between the average pay of men and women.

Any employer with 250 or more employees

To be submitted to the gender pay gap service and made available to employees via website or intranet.

FCA UKLR 6.6.6(9)

Gender and ethnic minority representation on the board of directors

All commercial companies with a listing on the Main Market.

In their Annual Report and Accounts, companies are to include a piece on gender and ethnic minority representation on the board of directors, including numbers and percentages, a description of diversity policies and whether the FCA-set targets have been met.

Companies Act Section 172

UK companies must include information on stakeholder engagement and inclusion in decision-making in their Annual Report and Accounts.

UK companies

Section 172 sets out the consideration that directors of companies must give to the impact of their decisions on the success of the company, its employees, the community and the environment. They must also consider the need to build relationships with suppliers, customers and others.

Modern Slavery Act 2015

Captured companies must publish a Modern Slavery Statement.

Businesses supplying goods or services with a turnover of £36 million or more.

The Modern Slavery Statement must be publicly available and must cover how the company deals with the risks of modern slavery in its business and its supply chain.

Packaging Waste (Data Reporting) (England) (Amendment)
Regulations SI 2024/359

Mandates that captured companies collect and report data on the packaging they introduce to the market. This will then feed into EPR (Extended Producer Responsibility).

There are separate regulations for small and large producers, defined as:
Small: annual turnover of £1-2 million, and responsible for handling and supplying more than 25 tonnes of empty packaging or packaged goods through the UK market; or
annual turnover over £1 million, and it is responsible for handling and supplying between 25 and 50 tonnes of empty packaging or packaged goods through the UK market.
Large: annual turnover over £2 million and responsible for handling and supplying more than 50 tonnes of empty packaging or packaged goods in the UK in a calendar year (January to December).

Effective from 1 April 2024, these Regulations apply exclusively to England. They modify the Packaging Waste (Data Reporting) (England) Regulations SI 2023/219, which mandate that packaging producers collect and report data on the volume and type of packaging they introduce to the market. This data determines the fees producers will pay under the Extended Producer Responsibility for packaging scheme starting in 2025.

Extended Producer Responsibility (EPR)

Businesses that place packaged goods onto the market will be responsible for the full cost of recycling and waste management.

If the following are met:

• responsible for importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year
• an individual business, subsidiary or group (but not a charity)
• an annual turnover of £1 million or more
• carry out any of the packaging activities

Deferred from October 2024 to October 2025

Plastic Packaging Tax

A tax on plastic packaging, where the amount imported or manufactured by a company exceeds a certain threshold.

Companies that have manufactured or imported 10 or more tonnes of plastic packaging in the last 12 months or expect to import into the UK or manufacture in the UK 10 tonnes or more of finished plastic packaging components in the next 30 days, may need to register for the tax.

Companies need to keep records regarding the manufacture or import of plastic packaging to prove whether or not the thresholds are met. Includes plastic packaging manufactured in the UK, imported plastic packaging and imported filled plastic packaging.

EU legislation:
Corporate Sustainability Reporting Directive (CSRD)

Companies are required to report on material ESG topics in their Annual Report and Accounts.

FY24 reporting: EU-listed companies
FY25 reporting: other large EU companies
FY26 reporting: EU SMEs
FY28: non-EU companies with revenue over €150 million in EU

Large means at least two of the following: 250 employees, €50 million revenue, €25 million balance sheet
SME means at least two of the following: 50 employees, €8 million turnover, €4 million balance sheet

Reporting on all material topics integrated into annual reports and accounts. There is detailed and extensive guidance on what must be covered for each topic and indicator, as well as what to consider when conducting the double materiality assessment.

EU legislation:
Carbon Border Adjustment Mechanism (CBAM)

Carbon tax on products produced outside the EU to ensure spending on decarbonisation is not at a price disadvantage to cheap, carbon-intense products from abroad.

Covers: cement, iron & steel, aluminium, fertilisers, electricity, hydrogen (and derivatives of the above)

Enhanced data collection of all products imported into EU; data on manufacturers and their Scope 1, 2 and 3 emissions.

Pricing: certificates based on weekly average auction price of EU ETS allowances.

Data capture from 01 OCT 23
Data requirements strengthened from 01 JAN 25
Permanent system from 01 JAN 26