Treasurers need to prepare for greater clarity on sustainability disclosure requirements (SDR), an umbrella term for the raft of initiatives considered in a recent consultation, according to PwC’s Will Jones.
Jones, a director of ESG assurance at the Big Four firm, explained at ACT’s Tomorrow’s Treasury event in November that a key development is the expected adoption of sustainability reporting standards (SRS).
These contain IFRS (International Financial Reporting Standards) S1, which refers to sustainability, and S2, which is climate-focused.
In a session called ‘ESG reporting update’, Jones described three UK consultation processes from June to September 2025, of which treasurers needed to be aware. He said a breadth of stakeholders would be asking questions about them, “despite the appetite for sustainability reporting dropping a little bit in the current economic and political environment”.
He added: “One was on the adoption of SRS, and within that the adoption of S1 and S2, but they did not set out the timeline for that, nor did they set out which companies would be caught by it. They were simply referred to as economically significant companies which we’re likening to public interest entities, but that is still a little bit to be confirmed.”
Within that context, the Financial Conduct Authority intends to consult on updating the Listing Rules to require mandatory reporting for UK listed companies in line with UK SRS. Jones said he expected to see this early next year.
A second consultation, on transition plans, focused on FTSE 100 companies and financial institutions, with two possible directions of travel. “One was going to be on a comply and explain basis as to why you are not responding and reporting the relevant transition plan requirements set out in the future regulation,” said Jones.
“The alternative was mandating it for all those companies and setting out the clear disclosure requirements that companies need to follow.
“I would encourage companies to enhance the robustness of these transition plans. If you’ve got a net zero target, think about how you might be achieving that. Think about the costs and the strategy you’re going to need and the decisions you’re going to need to make to get there,” he added.
The third consultation, on the proposals to introduce a voluntary registration regime for ‘sustainability assurance providers’, has been put on hold as new regulator ARGA (Audit, Reporting and Governance Authority) has yet to start work.
In addition, the UK government has confirmed it has terminated plans for a green taxonomy to define what constitutes a sustainable economic activity.
A non-financial reporting review, addressing the UK’s non-financial reporting regulations, may take shape in the coming months after an Action Plan was published in October 2025. Jones said: “There should be more detail coming out next year.”
Lawrie Holmes is a business and financial journalist
