Reporting
10 min

Our Response to the ISSB Exposure drafts: UK Sustainability Reporting Standards

The UK is moving closer to endorsing the ISSB Standards, reinforcing its commitment to international sustainability reporting alignment. At WeeFin, we've responded to this consultation, drawing on our expertise with sustainability and climate reporting. Explore our responses in this blog and learn more on how the ISSB Standards will be adopted in the UK.
Written by
Posted on
Sep 22, 2025

Nowadays, 17 jurisdictions have now adopted the ISSB Standards. 14 jurisdictions target a full adoption of ISSB standard, 2 are adopting climate requirements and 1 partially incorporates the standards. 16 others are in the midst of adopting it. The UK being one them. 

Please check this Deloitte work, Adoption of IFRS Sustainability Disclosure Standards by jurisdiction from the end of August 2025 to have a glimpse where all the jurisdictions stand today. 

This UK consultation marks the final step in assessing whether the ISSB Standards are suitable for adoption in the UK. Ensuring international comparability has been a key priority throughout the process, and the government has sought to keep divergence from the ISSB Standards to a minimum. It then proposes six minor amendments for their application.

What is the consultation about?

The UK government launched a consultation on 25 June 2025, seeking views on the draft UK Sustainability Reporting Standards (UK SRS), which are based on the two standards published by the ISSB in June 2023. Open for 12 weeks until 17 September 2025, the consultation was published alongside two other initiatives: the government’s transition plan manifesto commitment and proposals for the oversight of sustainability assurance providers.

The consultation comprises 20 questions covering endorsement of the standards in their current form, the costs and benefits they could bring, the government’s proposed amendments based on the TAC’s recommendations, as well as their applicability to large private companies and non-listed entities. It also explores practical aspects such as the rationalisation of reporting requirements, the treatment of calculations, transition relief, reporting frequency, and the role of carbon credits.

The purpose of this consultation is to gather evidence on whether and how the UK should adopt the draft UK SRS. The responses will inform the government’s decision on endorsement, with a view to publishing the final UK SRS S1 and S2 in autumn 2025. Importantly, any decision to introduce legal or regulatory requirements linked to the UK SRS will be assessed separately. This exercise represents the first phase in modernising the UK’s corporate reporting framework, with the government working closely with the FCA and the FRC to ensure coherence in sustainability reporting and assurance.

Our proposal

1. Flexibility and emphasis on existing processes
We advocated for flexibility in the implementation of the UK SRS, emphasising alignment with existing processes and practices. 

WeeFin agreed with the climate-first approach and phased transition relief proposed, as these allow entities to consolidate internal processes, reduce operational pressures, and encourage voluntary adoption. These are consistent with current TCFD practices and mirror phased strategies adopted in other jurisdictions such as Canada, Australia, and Singapore, where reporting beyond climate disclosures is encouraged but not mandatory.

Flexibility also extends to the use of classification standards, for instance, we support the removal of the mandatory requirement to use the Global Industry Classification Standard (GICS), allowing entities to rely on internally used frameworks. Similarly, in line with SASB materials, entities should have discretion in how they approach sustainability reporting rather than being prescribed a single framework or method.

2. Streamlining of reporting
We highlighted the importance of reducing duplication and simplifying reporting processes. The UK SRS could serve as a single, comprehensive standard for climate and sustainability information, replacing or aligning with existing TCFD reports. 

For financial actors, this reduces the need to collect data from multiple reporting regimes. Harmonising formats and methodologies, including scopes and inclusions, would further simplify the reporting burden and allow existing information to be integrated efficiently.

3. Advocacy for more transparency
We emphasised the need for greater transparency in sustainability disclosures. This includes advocating for voluntary reporting, improving data freshness, and ensuring clarity on the treatment of carbon credits, which currently present reporting barriers. 

We also suggested removing the transition relief in IFRS S1 that permits delayed reporting in the first year, as aligning reporting with financial statements and existing practices strengthens quality and consistency without imposing disproportionate burdens on UK entities.

4. Clarifications on data and formulas
We stressed that revising comparative data for prior periods may not provide meaningful or decision-useful information. Repeated revisions create confusion and additional burden, as entities must track changes and assess implications across their reports. Moreover, most other disclosures do not require retroactive revisions. 

Clarification from the ISSB is also necessary regarding the application of financed emissions requirements, exclusions of specific categories of Scope 3 emissions, and reporting of carbon credits. Ensuring data transparency and guidance on formulas will improve comparability and reliability of reporting.

5. Support for more guidance from ISSB
Finally, we expressed strong support for the ISSB providing additional globally-aligned guidance, which would help ensure consistency, comparability, and reliability of sustainability reporting. 

Clear guidance reduces uncertainty, supports high-quality disclosures, and would help entities implement the UK SRS effectively.

Conclusion

Building on our responses, we emphasised the need for flexibility, alignment with existing processes, simplification of reporting, greater transparency, clarification on data, and additional guidance from the ISSB to ensure consistent and high-quality sustainability disclosures. These measures aim to make implementation practical and meaningful for entities while supporting a climate-first approach.

We believe that adopting UK SRS S1 and S2 would bring significant benefits, including enhanced comparability across entities, reduced reporting burdens through streamlined disclosures, increased credibility and investor confidence, market advantages, strengthened the UK strategic positioning, and improved risk management. 

At the same time, the adoption will involve costs such as staff training, familiarisation with the standards, new processes, data management, and third-party assurance. These costs are expected to be higher in the first year but could be mitigated through the use of functional technology platforms such as WeeFin’s.

The next steps will involve clarifying which entities will be required to publish the standards in the UK, establishing the timing of reporting obligations, and ensuring a smooth and practical implementation process for all reporting entities.

To read our full response to the consultation, click here.

Monthly newsletter
Subscribe to our newsletter to receive our latest publications.

Discover the benefits of ESG Connect

Subscribe to the newsletter
Subscribe to our newsletter to receive our latest publications.
Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.