Five years ago the UK officially left the European Union (EU). “Brexit” was added to the dictionary, and EU Law ceased to apply. Can the EU Corporate Sustainability Reporting Directive apply to UK companies if so?

In short, yes. The EU CSRD does apply to certain UK companies.

Which UK companies have to comply with the EU CSRD?

UK companies will have to submit EU CSRD reports if they have:

• Listed securities, such as stocks or bonds, on a regulated market in the European Union
• Annual revenue within the EU exceeding €150 million or an EU branch with net revenue of more than €40 million
• A large EU subsidiary company that meets at least two of these three criteria: (i) More than 250 EU-based employees, (ii) a balance sheet above €20 million, or (iii) local revenue of more than €40 million.

Learn more about what companies outside of Europe will be affected by the EU CSRD.

When will UK companies have to comply?

UK companies will have to adhere to the following timeline:

• 2025 (based on 2024 data) – UK companies with EU stock listings and more than 500 employees in the EU
• 2026 (based on 2025 data) –  UK companies with EU stock listings and 250 to 500 employees in the EU
• 2027 (based on 2026 data) – UK companies with EU stock listings and under 250 employees in the EU 
• 2029 (based on 2028 data) – UK companies not listed in the EU but subject to other criteria

How does it compare to other UK climate regulations?

The EU CSRD is the most advanced sustainability reporting directive to date. This means there is a clear overlap between the CSRD and its regulatory counterpart, but some key differences exist.

TCFD vs. EU CSRD 

The Taskforce of Climate-related Financial Disclosure (TCFD) was the first climate reporting framework adopted by the UK. The purpose of the TCFD and CSRD is the same, to help investors assess the risks of their funds. 

However, the EU CSRD goes further than the TCFD. To comply companies must report on all areas of ESG. So while the TCFD requires companies to report on climate-related risks e.g. emissions, the CSRD requires companies to report on wider environmental-, social-, and governance-related risks. 

This means affected companies can repurpose TCFD reports, but must also report on any other categories outlined by the European Sustainability Reporting Standards deemed material.

SECR vs. EU CSRD

Compared to the EU CSRD, the Streamlined Energy and Carbon Reporting (SECR) only requires companies to disclose their energy usage and greenhouse gas emissions. The EU CSRD requires a double materiality assessment, whereas the SECR requires single materiality.

Supporting your customers through climate regulation

Navigating climate reporting is a difficult, laborious, and arduous task. This is why UK companies affected by climate regulation are turning to their ERP (Enterprise Resource Planning) partners for help. By partnering with Lune, these ERP companies can enrich their data with emissions reporting, and support their customers through climate compliance. 

To learn more about what climate regulation affects your customers, and when, download our free infographic: Climate regulation around the world in 2025