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ESRS-40a: What UK Businesses Need to Know About the Emerging Reporting Framework for Non-EU Groups

Sep. 8 2026

Recent changes to the Corporate Sustainability Reporting Directive (CSRD) have reduced reporting obligations for some organisations. However, the sustainability reporting landscape continues to evolve.

While much of the recent discussion in the UK has focused on UK Sustainability Reporting Standards (UK SRS), organisations with significant EU operations should also be monitoring ESRS-40a, the proposed reporting framework for non-EU parent companies. Together, these developments mean businesses need to understand not only which requirements may apply, but also how to build reporting processes that can adapt to an evolving regulatory landscape.

A More Connected Reporting Landscape

The sustainability reporting landscape is becoming increasingly interconnected:

ESRS-40a (expected to apply from reporting periods beginning on or after 1 January 2028) is being developed for non-EU parent companies with significant EU operations and could bring additional UK-headquartered groups into scope of European sustainability reporting requirements.

UK SRS (expected to apply from reporting periods beginning on or after 1 January 2027) will expand sustainability disclosures beyond climate, building on IFRS Sustainability Disclosure Standards and increasing the focus on investor-grade reporting.

Stakeholder expectations continue to grow, with investors, customers, lenders and regulators seeking robust, comparable and decision-useful sustainability information.

Rather than dealing with entirely separate requirements, organisations are increasingly navigating an ecosystem of overlapping frameworks that rely on many of the same underlying capabilities.

What Effective Preparation Looks Like

Regardless of whether organisations are preparing for ESRS-40a, UK SRS or wider stakeholder expectations, the foundations remain similar:

Expand data infrastructure to capture material sustainability information beyond climate-related metrics.
Strengthen materiality assessments to identify sustainability issues with genuine financial relevance.
Integrate sustainability, finance, risk and audit teams to support consistent and efficient reporting.
Develop auditable systems and controls capable of producing reliable and verifiable disclosures.
Start early by building reporting readiness and monitoring regulatory developments.

Organisations that invest in these capabilities now will be best positioned to respond as reporting requirements continue to evolve.

Getting Ahead of the Curve

According to Lauren Brewster-Hyatt, Senior Sustainability Consultant at Bureau Veritas:

"While the reporting landscape continues to evolve, the direction of travel is clear. Whether organisations are preparing for ESRS-40a, UK SRS or responding to wider stakeholder expectations, strong governance, reliable data and integrated reporting processes remain the foundations of effective sustainability reporting."

Amy Larsen, Senior Sustainability Consultant, Bureau Veritas Adds:

"The organisations best positioned for success will be those that start preparing now. Building robust governance, controls and reporting processes today makes it far easier to respond as sustainability reporting requirements continue to evolve.”

Bureau Veritas supports organisations through materiality assessments, reporting gap analyses, governance reviews, sustainability reporting readiness programmes and assurance services, helping businesses build reporting frameworks that are resilient, auditable and adaptable to future requirements.

Learn More

Join Bureau Veritas and guest speaker Sage, which published its first CSRD-aligned Non-Financial Statement last year, for an in-depth discussion on ESRS-40a, UK SRS and what these developments mean for UK-headquartered organisations.