Understanding your obligations after Brexit
Even after Brexit, UK companies may still face CSRD obligations
If your company operates a subsidiary in the EU that meets CSRD size thresholds (large company criteria), your parent company may face indirect CSRD requirements through consolidation rules.
UK companies listed on EU-regulated markets (not just UK exchanges) are covered by CSRD and must report according to ESRS standards.
Companies generating substantial revenue within the EU (above certain thresholds) may qualify as large undertakings under CSRD scope, particularly if they have significant EU operations or supply chain relationships.
The UK is developing its own Sustainability Reporting Standards (UK SRS) separately. Companies may eventually have UK-specific reporting requirements in addition to or instead of CSRD.
Use this decision tree to determine if CSRD may apply to your organization
| Assessment Point | CSRD Trigger | Action Required |
|---|---|---|
| Do you have EU operations? | Subsidiary, branch, or joint venture in any EU member state | Assess if the EU entity meets large undertaking criteria |
| EU revenue level | More than €150M annual net turnover within EU | Likely CSRD scope if you meet other thresholds |
| Listed on EU markets | Traded on any EU-regulated market (even if HQ is UK) | Mandatory CSRD reporting and ESRS compliance |
| Supply chain footprint | Significant suppliers, manufacturers, or customers in EU | Indirect exposure through value chain requirements |
| Group consolidation | Part of a larger group with EU entities meeting CSRD thresholds | May require consolidated sustainability reporting |
How different industries typically encounter CSRD obligations
| Sector | Typical EU Exposure Points | Key Reporting Challenges |
|---|---|---|
| Manufacturing | EU factories, supply chains, export markets, subsidiaries | Scope 1&2 emissions, supply chain traceability, circular economy compliance |
| Financial Services | EU branches, regulated subsidiaries, customer base, lending exposure | Financed emissions (Scope 3), climate risk metrics, governance structures |
| Retail | EU stores, distribution centers, supplier networks, franchises | Labor standards, supply chain due diligence, product compliance |
| Technology | EU data centers, R&D facilities, service delivery infrastructure | Data center energy use, supply chain conflict minerals, labor practices |
Key dates and reporting waves
CSRD applies to large EU companies (>500 employees). Wave 1 companies begin reporting.
Wave 2 starts (250+ employees). UK Sustainability Reporting Standards consultation ongoing.
Omnibus I proposal may postpone Wave 2 reporting to FY2027. UK SRS expected to be finalized.
UK companies may face parallel UK SRS requirements alongside or instead of CSRD.
Pricing for UK companies
Understand your CSRD obligations and readiness gap
Comprehensive audit and strategic planning
Questions specific to UK companies
No, CSRD primarily applies to companies within the EU. However, UK companies with EU subsidiaries, EU listings, or significant EU revenue may face indirect CSRD obligations through their operations or parent-subsidiary relationships. The UK is developing its own Sustainability Reporting Standards (UK SRS), which may create parallel requirements.
If your EU subsidiary is a "large undertaking" (>250 employees, >€50M revenue, or >€25M total assets), your group may face consolidated reporting requirements under CSRD. The UK parent company would need to ensure group-level sustainability reporting covers the EU subsidiary's performance.
The UK Government is currently consulting on UK Sustainability Reporting Standards (UK SRS) as an alternative to CSRD. Legislation is expected between 2026-2027, with potential reporting requirements following. Companies should monitor FCA and Government Office guidance for updates.
Once UK SRS is mandated, UK companies will likely be required to use UK SRS unless they have EU listings or significant EU operations. Companies with CSRD obligations (due to EU presence) must comply with CSRD regardless of UK SRS requirements.
Conduct a supply chain mapping exercise to identify EU-based suppliers, manufacturers, and customers. Companies with significant EU supply chain footprint may face due diligence obligations under CSRD's double materiality and value chain risk assessment requirements. This is a key part of readiness assessment.
Our CSRD readiness assessments help UK companies understand their obligations and plan strategically.
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