What ESG reporting is, and which rules reach a UK manufacturer

What ESG reporting covers

The environmental part covers energy use, greenhouse gas emissions across Scopes 1, 2 and 3, pollution, water and waste. The social part covers your workforce: headcount, health and safety, pay and conditions, and human rights in your supply chain. Governance covers business conduct, policies and how decisions are overseen.

The readers vary. Investors, regulators and the public read the reports of large companies. For a smaller manufacturer, the reader is usually a customer's procurement team, a tender panel or a bank.

The reasons to report follow from that. Clear figures help you answer customers and tenders, support conversations with lenders, and show where energy and material costs sit. Evidence behind each claim also protects you from making statements you cannot support.

Frameworks and standards are different things

A framework is principles-based guidance on what to report and how to structure it. The Task Force on Climate-related Financial Disclosures (TCFD), for example, organised climate reporting into four areas: governance, strategy, risk management, and metrics and targets.

A standard sets out specific, detailed requirements for each topic, so that reports can be compared. The Global Reporting Initiative (GRI) Standards and the International Sustainability Standards Board (ISSB) standards, IFRS S1 and S2, are examples. In practice the terms overlap, and each body describes itself in its own way.

Either kind can be voluntary or mandatory. A voluntary standard becomes mandatory when a regulator adopts it. The UK has adopted the ISSB standards as the UK Sustainability Reporting Standards (UK SRS), finalised in February 2026. The Financial Conduct Authority (FCA) has consulted on requiring listed companies to use them from 1 January 2027.

The mandatory rules and who they cover

Most mandatory ESG rules in the UK and EU are written for large organisations. The table below gives the main ones and who each one covers.

Streamlined Energy and Carbon Reporting (SECR) size tests changed for financial years beginning on or after 6 April 2025. An unquoted company is now medium-sized, and outside SECR, if it meets two of these: turnover up to £54 million, balance sheet up to £27 million, up to 250 employees. The Energy Savings Opportunity Scheme (ESOS) and the Corporate Sustainability Reporting Directive (CSRD) apply their own tests, shown in the table.

Our regulations map sets out each rule in more detail, by country.

The voluntary standards customers ask about

These are the names that tend to appear in questionnaires and tenders sent to smaller manufacturers.

• VSME, the Voluntary Sustainability Reporting Standard for SMEs, published by EFRAG, the body that advises the European Commission on sustainability reporting standards, in December 2024 and recommended by the European Commission in July 2025. Its Basic module has 11 disclosures, and the Comprehensive module adds 9 more for when a bank or customer asks.
• CDP, a global disclosure system run through an annual questionnaire. Many large customers send it to suppliers through its supply chain programme.
• The Science Based Targets initiative (SBTi), which checks company emissions targets against climate science. Some large buyers ask suppliers to set one.
• GRI, a widely used standard for reporting a company's impacts on the economy, environment and people.
• ISO 14001 and ISO 50001, management system standards for environment and energy, often requested in tenders and certified by an accredited body.

How the rules reach a smaller firm

Large companies get much of their data from suppliers, so a firm outside every threshold in the table above can still be asked for figures. The request comes as a questionnaire, a tender question or a condition in a supplier code.

The EU has put a limit on this. Under the Omnibus I Directive (Directive (EU) 2026/470), companies in CSRD scope may not ask suppliers with 1,000 employees or fewer for more than the voluntary standard sets out. That makes a VSME report a proportionate answer for UK suppliers to EU customers.

Public contracts work in a similar way. Some Tier 1 contractors on central government work ask their subcontractors for a Carbon Reduction Plan in the same format.

Build one set of records, then answer each request

Different customers ask in different formats. If you answer each one from scratch, your figures drift apart and follow-up questions become hard to answer. Keep one set of records, with the activity, source document, factor and calculation behind every figure, and answer every request from it.

• List who has asked you for what over the past year.
• Check which rules name you directly. For many smaller firms the answer is none.
• Choose a reporting year, usually your financial year.
• Measure your Scope 1 and 2 first, using our footprint guide.
• Gather the policies and workforce data you already hold for the social and governance questions.

How ESGen helps with ESG reporting

The ESGen platform holds one set of records with the evidence and calculation log behind every figure. From it, the platform's lenses cover SECR, the Carbon Reduction Plan and VSME for UK firms, and the Business Responsibility and Sustainability Report (BRSR) and BRSR Core in India. Our team prepares the reports and plans themselves, along with questionnaire answers and policy documents.

CSRD, CBAM, SBTi and EcoVadis work is a team service rather than a platform feature. UK SRS and ISSB lenses are on our roadmap. ESGen helps prepare structured reporting evidence; no software makes an organisation compliant on its own, and we do not audit or certify anything. See ESG reporting for more.

Send us the last ESG request a customer sent you, or book a demo and we will walk through it with you.