How does UK GDPR differ from EU GDPR?

While largely similar, UK GDPR has diverging adequacy requirements, different ICO guidance, and the UK is proposing reforms. Cleo tracks both regimes and highlights divergences.

What is the FCA Consumer Duty?

The Consumer Duty requires firms to deliver good outcomes for retail customers. Cleo maps its requirements alongside MiFID II and other financial regulations.

🇬🇧United Kingdom

CSRD compliance in the UK

The UK is not subject to the CSRD but has its own sustainability disclosure framework. UK-listed companies must comply with TCFD requirements, and the UK is adopting ISSB (IFRS S1/S2) standards. Non-EU companies with significant UK operations may still be caught by CSRD Phase 4.

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Enforcement authority

FCA (for listed companies) + FRC (Financial Reporting Council) + BEIS/DBT for SECR

Maximum sanctions

FCA can impose fines for non-compliance with listing rules. Companies Act sanctions for SECR non-compliance. No CSRD-equivalent EU-level penalties.

Key obligations

What CSRD requires from organizations operating in the UK.

Comply with TCFD-aligned disclosure requirements for premium-listed companies

Prepare for UK Sustainability Disclosure Standards (UK SDS) based on ISSB

Report under Streamlined Energy and Carbon Reporting (SECR) framework

Comply with Modern Slavery Act reporting for companies with GBP 36M+ turnover

Local context in the UK

The UK is adopting ISSB standards (IFRS S1/S2) which differ from EU ESRS in scope and approach. Companies operating in both UK and EU must navigate dual sustainability reporting frameworks. The UK Transition Plan Taskforce provides guidance on climate transition plans. CSRD Phase 4 (FY 2028) may capture UK-headquartered companies with EUR 150M+ EU revenue.