CLLS Company Law, ESG, and Planning & Environmental Law Committees' Response to UK SRS Consultation

The comments focus on the legal, governance, and implementation issues most likely to affect entities in the event that the UK SRS was adopted (including whether subject to such reporting on a mandatory or voluntary basis).

The CLLS argues that fragmentation of requirements across the Companies Act 2006, FCA Listing Rules, FCA ESG Sourcebook, SECR, potential transition-plan regulation, and now UK SRS risks potentially inconsistent disclosures and disproportionate compliance costs.

It recommends that the UK Government, in collaboration with relevant regulators, develops and maintains a unified framework or guidance document that clearly sets out the expectations pursuant to, and/or interaction of, sustainability-related disclosure obligations.

The CLLS recognises policy arguments for extending high-quality disclosures beyond listed issuers, yet remain concerned that investor information asymmetry is narrower for many private companies.