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UK Sustainability Disclosure Requirements (SDR)

4 min read

Description of Characteristics:

  • UK Regulatory Framework: The SDR is a set of proposed regulations in the United Kingdom aimed at enhancing the quality and consistency of sustainability-related disclosures by companies and financial institutions.
  • Mandated Disclosures: The SDR will introduce mandatory disclosure requirements for certain large companies and financial institutions operating in the UK.
  • Double Materiality: The SDR adopts the concept of double materiality, requiring disclosure of information on both the impact of sustainability matters on the company (financial materiality) and the company’s impact on people and the environment (impact materiality).
  • Building on Existing Frameworks: The SDR builds on existing frameworks such as the TCFD recommendations and the UK Green Taxonomy, aiming to create a unified and comprehensive disclosure regime.
  • Alignment with International Standards: The SDR is being developed in alignment with international sustainability reporting standards, such as the ISSB standards and the TCFD recommendations, to promote global consistency and comparability.
  • Focus on Decision-Useful Information: The SDR aims to provide investors and other stakeholders with decision-useful information about companies’ sustainability performance, risks, and opportunities.
  • Phased Implementation: The SDR is being implemented in phases, with initial focus on climate-related disclosures and plans to expand to other ESG topics in the future.

Targeted Audience:

  • In-Scope UK Companies and Financial Institutions: Listed companies, large private companies, asset managers, asset owners, and certain regulated financial institutions operating in the UK.
  • Investors and Stakeholders: The SDR aims to provide investors and other stakeholders with the information they need to make informed decisions about the sustainability performance of companies and financial institutions.

Specific Criteria:

  • Scope:
    • Listed companies
    • Large private companies
    • Asset managers and asset owners
    • Certain regulated financial institutions (e.g., banks, insurance companies)
  • Reporting Requirements:
    • Sustainability Statement: A comprehensive report on the company’s or financial institution’s sustainability performance, including information on its strategy, governance, risks, and opportunities.
    • Alignment with UK Green Taxonomy: Disclosures should be aligned with the UK Green Taxonomy, which classifies environmentally sustainable economic activities.
    • Inclusion in Strategic Report: For listed companies, the sustainability statement must be included in the company’s strategic report.
    • Digital Tagging: Sustainability information must be digitally tagged using a machine-readable format.
  • Entity-Level Disclosures:
    • Sustainability Statement: A comprehensive report on the company’s sustainability performance, including information on its strategy, governance, risks, and opportunities related to sustainability matters.
    • Integration into Strategic Report: The sustainability statement must be included in the company’s strategic report (for large companies) or annual report (for listed companies).
  • Product-Level Disclosures:
    • Sustainability Labels: A set of standardized labels to categorize investment products based on their sustainability characteristics.
    • Product Disclosures: Detailed information on the sustainability features of investment products, including their environmental and social objectives and how they are measured.

Reporting Principles:

  • Double Materiality: Companies and financial institutions must report on both their impacts on the environment and society and how sustainability issues create financial risks and opportunities.
  • Proportionality: The level of detail in reporting should be proportionate to the size and complexity of the organization and the materiality of the sustainability matters.
  • Comparability: Disclosures should be prepared in a way that allows for comparison over time and between companies.
  • Understandability: Disclosures should be clear, concise, and understandable to a wide range of stakeholders.
  • Reliability: Information in the report should be accurate, reliable, and verifiable.

Reporting Process (Proposed):

  1. Identify Material Sustainability Matters: Conduct a double materiality assessment to determine which sustainability matters are material.
  2. Collect and Analyze Data: Gather and analyze data related to the identified material sustainability matters.
  3. Prepare Sustainability Statement: Prepare the sustainability statement in accordance with the SDR, addressing both impact and financial materiality.
  4. Obtain External Assurance: External assurance requirements are still being determined, but likely to be mandatory for certain in-scope entities.
  5. Include in Strategic Report (for listed companies): Include the sustainability statement in the strategic report.
  6. Digitally Tag Information: Tag the sustainability information using a machine-readable format.
  7. Publish and Communicate: Publish the sustainability statement and/or strategic report and communicate it to stakeholders.

Connections to Other Frameworks:

  • Builds on TCFD and UK Green Taxonomy: The SDR incorporates and builds upon the TCFD recommendations and the UK Green Taxonomy.
  • Alignment with International Standards: The SDR is being developed in alignment with international sustainability reporting standards, such as the ISSB standards and the TCFD recommendations.

Challenges:

  • Evolving Framework: The SDR is still under development, with ongoing consultations and refinements to the specific requirements.
  • Data Availability and Quality: Gathering reliable and comparable data on sustainability impacts and risks can be challenging.
  • Greenwashing Concerns: The SDR introduces an anti-greenwashing rule to address concerns about misleading sustainability claims.

Compliance Guidance:

  • UK Government Consultations and Policy Papers: The UK government has published several consultations and policy papers on the SDR, providing guidance on the proposed requirements.
  • FCA Policy Statements: The Financial Conduct Authority (FCA) has published policy statements on the SDR and investment labels, providing additional guidance for financial market participants.
  • Future Implementation Guidance: Detailed implementation guidance is expected to be provided once the SDR is finalized.

Usability Evaluation:

  • Level of Adoption: Adoption will be mandatory for in-scope companies and financial institutions in the UK once the SDR is finalized and implemented.
  • Ease of Use: The ease of use will depend on the finalization of the regulations and the availability of implementation guidance.
  • Focus Areas: Focuses on material ESG factors that could impact a company’s or financial institution’s financial performance and long-term value creation, as well as their impact on people and the environment.
  • Data Availability: Data availability will depend on the company’s or financial institution’s existing ESG data management practices and the requirements of the final regulations.

SyncFrame Compatibility:

  • Alignment: SyncFrame’s focus on impact measurement, double materiality, stakeholder engagement, and alignment with international standards (including the ISSB and TCFD) makes it highly compatible with the objectives of the SDR.
  • Data Integration: SyncFrame’s technology platform can facilitate the collection and analysis of data required for SDR reporting.
  • Expert Guidance: SyncFrame advisors can provide support in conducting double materiality assessments, aligning with the UK Green Taxonomy, and preparing SDR-compliant disclosures.

Reference Links/Resources:

  • UK Government – SDR: [invalid URL removed]

SyncFrame’s alignment with the SDR and its focus on data-driven insights and expert guidance can help UK companies and financial institutions navigate the evolving regulatory landscape and demonstrate their commitment to sustainability.

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