E3G is pleased to provide feedback to the Department of Business and Trade’s ‘Consultation on UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2‘, ‘Consultation on developing an oversight regime for assurance of sustainability related financial disclosures’, and the Department of Energy Security and Net Zero’s (DESNZ) consultation on transition plan requirements. The three consultations closed on 17 September 2025.
In its 2024 general election manifesto, Labour set out its ambition to make the UK the green finance capital of the world. Delivery of this pledge is crucial to building a competitive, high-growth and resilient future for the UK economy. With over $2 trillion invested globally in clean tech last year, the UK’s clean transition could boost GDP up to £149 billion per year – a £104 billion increase in inward investment by 2040.
To date, the UK has been an international leader in attracting global green and transition capital, with London ranked as the top green finance centre globally. The opportunity is clear: the UK’s clean economy is a major driver of growth, innovation and productivity, growing by over 10% last year. However, without ambitious action to make its regulatory regime future-fit, the UK’s global competitiveness is at risk.
Making it easier for investors to allocate capital into the UK and building market confidence in the credibility of the UK’s transition market requires government action to meet the growing need for credible, accessible non-financial information to inform decision-making.
Success will depend on strengthening the UK’s attractiveness as both a destination for inward investment and an outward centre for sustainable finance. This requires the UK to ensure a reliable and transparent flow of sustainability information to aid decision making. The UK can benefit as a leader in this space by building market confidence in the credibility of the UK transition finance market, and by embedding interoperability in its regulatory regime to reduce barriers to international finance flows.
Meeting market needs and accelerating investment requires the government to move swiftly. Alongside adoption of the IFRS S1 and S2 reporting standards and establishing the Audit, Reporting and Governance Authority (ARGA) as the authority for assurance of sustainability-related disclosures, the government should implement its manifesto pledge on transition plans, making it a mandatory requirement for all large companies to:
- Develop: All large listed and private companies should be required to develop climate transition plans.
- Disclose: To ensure global interoperability and the availability of relevant information for decision-making, all developed plans should be disclosed in line with the TPT Disclosure Framework. Requirements should come as part of the ISSB roll out in the UK.
- Align (with the 1.5C goal of the Paris Agreement): Companies must be required to set entity-level targets that align with a credible, science-based pathway.
- Implement: Companies should be required to make best efforts to implement their plan. The government must work with regulators and the market to develop mechanisms to penalise failure to do so.
For more information, please contact:
Joe Dillon, Policy Advisor – UK Sustainable Finance, joe.dillon@e3g.org
