Legislation: what the law requires, and who it catches
Most small and medium-sized businesses have no legal duty to report carbon. The duties sit mainly with larger companies, public sector bidders, traders in heavy goods and packaging producers. Here's who is caught, in plain words. Rules change, so we always check the current position for your business.
Company size
Larger UK companies
SECR
Streamlined Energy and Carbon Reporting means putting energy and carbon figures in your annual report. It applies to all quoted companies, and to other companies and LLPs (limited liability partnerships) over two of: £36m turnover, £18m balance sheet and 250 staff. These limits didn't change with the April 2025 company-size changes, so some "medium-sized" firms still have to report. We check whether you're in scope and prepare the figures.
ESOS
The Energy Savings Opportunity Scheme is an energy audit every four years for organisations with 250 or more staff, or over £44m turnover and over £38m balance sheet, tested on 31st December 2026, with compliance due by 5th December 2027. We check whether you're caught and arrange the audit, then turn the findings into energy-saving projects.
Tenders
Public sector and NHS buying
PPN 006
Under this government buying rule (Procurement Policy Note 006, formerly PPN 06/21), bidders for central government contracts worth over £5m a year must publish a Carbon Reduction Plan. It's pass or fail, so without one a bid can be knocked out before price is read, and many other public buyers ask for the same. We prepare a compliant plan in time for your bid.
NHS net zero supplier roadmap
Every new NHS tender above the procurement thresholds asks for a Carbon Reduction Plan, and NHS Supply Chain tenders have needed Evergreen Level 1 since 6th April 2026. From 1st April 2027, contracts of £5m or more a year and all new NHS frameworks need the fuller NHS plan. We help you get ready before your next framework comes round.
Imports and exports
Carbon border taxes
EU CBAM
The EU Carbon Border Adjustment Mechanism (CBAM) has charged importers for the carbon in steel, aluminium, cement, fertiliser, hydrogen and electricity since 1st January 2026, and the charge rises every year until 2034. If you export these goods, your EU buyer will ask for the carbon figures for your products.
UK CBAM
The UK's own version starts on 1st January 2027 for imported aluminium, cement, fertiliser, hydrogen, and iron and steel. Importers bringing in £50,000 or more a year must register with HMRC, and the first return and payment are due by 31st May 2028.
EU
EU laws, after the 2026 cuts
CSRD
The EU's Corporate Sustainability Reporting Directive now covers only very large companies: EU firms with over 1,000 staff and €450m turnover, and non-EU groups with over €450m EU turnover and a large EU subsidiary or branch. Most UK firms meet it only when an EU customer asks for data, and from financial years starting 1st January 2027 those customers can't ask suppliers with 1,000 or fewer staff for more than a simple standard set. We prepare that pack for you.
CSDDD
The EU's Corporate Sustainability Due Diligence Directive makes the very largest companies (over 5,000 staff and €1.5bn turnover) check their supply chains for harm to people and the environment, from 26th July 2029. UK suppliers may receive questionnaires and contract clauses, though the law limits what can be asked of smaller partners. We help you answer proportionately.
Listed
UK listed companies
UK SRS for listed companies
The Financial Conduct Authority (FCA) requires UK-listed companies to report against the UK Sustainability Reporting Standards on a "comply or explain" basis for accounting periods starting on or after 1st January 2027. No decision has been made yet for private companies. If you supply listed firms, expect more carbon data requests, and we'll help you answer them.
Packaging
Packaging
EPR for packaging
Under Extended Producer Responsibility (EPR), businesses handling over 25 tonnes of packaging a year with £1m or more turnover must register and report, and those over 50 tonnes and £2m also pay towards recycling household packaging. We flag it and point you to a compliance scheme.
Plastic Packaging Tax
A tax of £228.82 a tonne (from 1st April 2026) on plastic packaging with less than 30% recycled plastic, for businesses that make or import 10 tonnes or more in 12 months. We flag it and point you to your accountant.
Buildings and marketing
Buildings and green claims
MEES
Under the Minimum Energy Efficiency Standards (MEES), landlords in England and Wales can't let commercial buildings rated below an EPC (Energy Performance Certificate) E. The government has proposed EPC B from 2031 for rented buildings over 1,000 m², but this isn't law yet. We flag it and point you on, and we can help with the efficiency and solar projects that raise your rating.
Green claims (consumer law)
Claims to consumers such as "eco-friendly" or "carbon neutral" must be accurate and backed by evidence, and since April 2025 the Competition and Markets Authority (CMA) can fine businesses directly, up to 10% of global turnover. We flag risky claims and point you to the right advice, and a proper footprint and plan give you the evidence.
What we're watching
A government review of SECR and ESOS planned for later in 2026; a possible UK–EU carbon market link that could ease EU CBAM for UK exporters (not yet in force); and the proposed MEES change. We'll update this page when each is confirmed.
Not sure what you need?
Book a free call and we'll tell you which of these apply to your business and what can wait.
General guidance only, not legal advice. Rules and dates as at October 2026. We check the current requirements for your business before you act.