Key takeaways from our UK government sustainability consultations workshop

At ICAS we play many roles and organising a way for members to directly liaise with government is one of them.

On 8 September 2025, we organised an exclusive forum with 22 ICAS members who joined a workshop where colleagues from the Department for Business and Trade (DBT) and the Department for Energy Security and Net Zero (DESNZ) shared more about the thinking behind the three UK sustainability consultations, listed below, and members could ask questions and feedback their views.   

The conversation was under Chatham House Rules so that a full and open dialogue could be had.    

To give you a sense of the key issues around the consultation proposals, here are some high-level takeaways from the discussions:  

The first half of the workshop covered two of the consultations: UK Sustainability Reporting Standards (UK SRS) and Transition plan requirements.  

• There was enthusiastic support of the government’s overall approach in proposing minimal changes to the ISSB standards to ensure the UK SRS are suitable for UK use while also facilitating international comparability.   
• There’s a need to create a coherent and proportionate sustainability reporting regime including transition plan disclosures; smart sequencing of the implementation of changes is one vital part of this.   
• Although SMEs won’t be directly in scope of any requirements, providing additional support is also critical. There’s interest in voluntary standards tailored for SMEs to support them in meeting supply chain demands.  
• There’s a strong argument for the scope of UK SRS reporting to include very large private companies (as well as listed companies) given their importance to the economy and UK decarbonisation goals. Any disclosure requirements must factor in potential unintended consequences like making UK markets less attractive for listing or motivating delisting. Regarding the scope of transition plans, there was a unanimous interest to have more clarity on what is meant by “economically significant entities” and indeed if a better approach was to target high emitters.  
• Disclosures must be driven by materiality, otherwise disclosures would be too long and obscure truly material issues, an approach which could be considered a form of greenwashing. Detailed guidance, practical examples and taking a principle-based rather than a prescribed approach may help produce quality disclosures. 
• Disclosures must be meaningful around governance, the financial impact of climate risks, and the challenges faced in effecting transition plans – independent assurance may play a role in achieving this. The government is considering further reviews of current practices. 
• The transition plans are recognised to involve some complex areas, including the importance of companies flagging dependencies and systemic challenges. There was also discussion around the need for a transition plan for UK-registered entities if a plan exists at global consolidated level.      
• There’s recognition that separate transition plans, and reporting progress against them, may provide useful disclosures in addition to those provided by UK SRS, however there’s a need for striking a balance between providing helpful disclosures for users and overly burdening reporters.     

The second part of the workshop covered the third consultation: Developing an oversight regime for assurance of sustainability-related financial disclosures. The consultation is different in nature from the other two, as it concerns a new regime to recognise profession-agnostic sustainability assurance providers distinct from financial auditors.  

• The market for assurance services for sustainability disclosures was described as being in its "infancy," characterised by a wide variety of providers and standards.  
• There is recognition of a significant skills gap since assurance of disclosures against frameworks such as TCFD, ISSB, UK SRS or ESRS standards encompasses a broader range of qualitative and judgmental data than traditional financial auditing.  
• It was recognised that registered sustainability assurance providers would need to demonstrate appropriate training, skills, and experience, with accountability placed on firms to maintain competence across the broad scope of sustainability topics.  This will be a challenge for the FRC (or its anticipated successor ARGA) the overseeing body, given the evolving nature of sustainability standards and reporting and the likely involvement of other professions. 
• Concerns were expressed around the recognition of those who can assure sustainability disclosures. This could cause issues nationally and internationally.  For example, if individuals were registered to assure financially related sustainability disclosures only, could they assure impact reports or reports where double materiality has been applied? The scope of the assurance provided would be a related factor.  
• On whether assurance requirements should be considered in the long term for reporting against UK SRS, concerns were raised on the cost of assurance, noting that even limited assurance will incur significant costs for businesses and would that be justifiable for the users of sustainability information. Another concern is that assurance would add to and not reduce administrative burdens on companies, the latter being a goal of the UK government.  DBT clarified that if assurance was mandatory under UK law, then it would not be included in the fee cap.  
• It was emphasised that a key objective is to foster a competitive market without picking winners or losers. The regime aims to be light touch initially, evolving over time as market capacity and regulatory needs develop, and provide transparency, credibility and choice. 

Want to find out more - Read our response to the three UK government consultations