2025-26 sustainability reporting requirements guidance
HM Treasury published guidance setting out sustainability reporting requirements for central government entities. Central government bodies who issue annual reports and accounts are required to meet the requirements included in the guidance. Requirements include reporting of Scope 1 and Scope 2 greenhouse gas emissions, water consumption, waste management, and carbon offsets if used. Scope 3 emissions need to be reported only if material. The guidance also clarifies exemptions, thresholds, and differences from the Greening Government Commitments (GGCs).
Publication of final Extended Producer Responsibility base fees and eco-modulation policy
In June 2025 PackUK published the final Extended Producer Responsibility (EPR) base fees which will be used to calculate. producers' EPR disposal fees for the first year of the EPR scheme. In most cases, the final base fees have reduced from the illustrative fees published by DEFRA in December 2024. Whilst the reductions will provide some relief for businesses, the overall EPR disposal fees are still likely to be significant - particularly for brands placing large volumes of branded products on the UK market. The publication of the base fees provides some certainty to producers on their financial exposure under EPR in the first year of its operation. The first invoices under the scheme are due in October 2025.
Separately, PackUK also published its Modulated Disposal Fees policy statement which sets out how it will adjust EPR fees from the second year of the scheme depending on the recyclability of packaging placed on the UK market.
Find out more (base fees and modulation statement)
Extended deadline for reporting recyclability assessments for EPR
In June 2025, the four UK environmental regulators published a Regulatory Position Statement giving packaging producers an additional 6 months to report their recyclability assessments under EPR. The original reporting deadline for packaging placed on the UK market in the period 1 January to 20 June 2025, has been 1 October 2025, however this has now been pushed back to 1 April 2026 due to concerns from liable packaging producers around the timeframe and resources required to comply with these reporting requirements.
CMA's new powers under the Digital Markets, Competition and Consumers Act
The CMA's new consumer protection enforcement powers under the Digital Markets, Competition and Consumers Act 2024 (DMCCA) came into effect on 6 April 2025. The CMA has increased powers to investigate and enforce breaches of consumer law under the Act and has indicated that tackling greenwashing will be an enforcement priority. With these new powers the CMA can now directly enforce UK consumer protection laws, including misleading environmental claims, and issue significant fines of up to 10% of global annual turnover.
UK Government consults on UK Sustainability Disclosure Requirements
The UK government has recently consulted on draft UK sustainability reporting standards (UK SRS). The UK SRS are a set of disclosure standards setting out the sustainability information that companies should include in their annual reports. They are based on the global ISSB sustainability disclosure standards, of which there are currently two: IFRS S1 (general disclosure requirements) and IFRS S2 (climate-related disclosures). The UK SRS effectively mirror the ISSB standards subject to minor amendments.
The consultation closed on 17 September and the UK government will publish finalised versions of the UK SRS for voluntary use later this year. Following this, the government will consider introducing amendments to the Companies Act 2006 to require certain UK companies to report against the UK SRS. The exact timings for this remains unclear. If implemented through the CA 2006, the UK SRS will require certain companies (scope tbc) to include much more granular disclosures in their annual reports about the material sustainability risks to their business – for example across topics such as climate change, biodiversity, water usage, packaging, diversity, human rights etc.
ISSB consults on amendments to SASB Standards and IFRS S2 guidance
The International Sustainability Standards Board (ISSB) has recently published two exposure drafts. The key proposals include a comprehensive review of nine priority industries, metric alignment across 41 additional industries, and updates to IFRS S2 industry-based guidance. Organisations in the affected sectors should monitor developments, as changes will influence sustainability reporting requirements and climate-related disclosures under IFRS S2. Stakeholder feedback will shape the final amendments, so engagement in the consultation process is recommended. Final amendments anticipated in 2026, subject to stakeholder feedback and additional exposure drafts for three further SASB Standards are to be published before the end of 2025.
New rules online marketplaces to cover the costs of waste electronics
On 12 August 2025 changes to the UK's Waste and Electrical and Electronic Equipment (WEEE) regulations came into force. The changes require online marketplaces to report to the environmental regulator all household electrical goods sold by non-UK suppliers via their platforms and to pay fees to contribute to the costs of recycling those products at the end of life. Those costs will be phased in over the next two years.
Welsh government publishes consultation on deposit return scheme for drinks containers
The Welsh Government has launched a 12-week consultation on the DRS in Wales to inform how the scheme will be implemented. The consultation closes on 10 November. The Welsh Government is proposing to introduce a DRS for plastic, aluminium and steel drinks containers (volume 150ml – 3l) which will be aligned with the rest of the UK plus a (limited) DRS for single-use glass. Alongside this, the Welsh Government proposes to introduce a regulatory framework requiring the proportion of reusable drinks containers made available for sale to increase over time, starting from 2030. The full consultation document is here.
FCA publishes full-page update to reflect current work on climate change and sustainable finance
The FCA has published a recent update on climate change and sustainable finance. The new regulatory actions and rules include an anti-greenwashing rule, sustainability disclosure requirements, mandatory climate-related disclosures, and bringing ESG rating providers into regulation.
The FCA's regulatory approach aims to manage risks associated with the transition to a sustainable economy and the impacts of climate change, while working to improve the availability and reliability of sustainability-related information and promote fair competition. It is contributing to the development of internationally aligned standards and supporting the UK Government's ambition to establish the UK as a global centre for sustainable finance.
Environment Agency publishes EA2030 environmental strategy
The Environment Agency has released its EA2030 strategy, outlining its priorities and operation direction. The strategy sets out three overarching ambitions: enhancing the quality of air, land, and water to aid the restoration of nature, advancing sustainable economic development, and bolstering the nation's resilience to the effects of climate change. It also introduces six core principles to guide the Agency's activities throughout the next five years. The strategy further explains how the Environment Agency will assess and monitor its performance.
