Sustainability for Housing (SfH) has submitted formal responses to two separate consultations from the UK Government:
- The Government’s draft UK Sustainability Reporting Standards (UK SRS), based on the International Sustainability Standards Board’s (ISSB) internationally recognised sustainability reporting standards
- The Government’s proposal for greater regulatory oversight of third-party assurance services for sustainability-related financial disclosures
This blog aims to explain the background and objectives of these consultations, their relevance to the social housing sector and SfH’s responses to them.
Both consultations closed on 17th September 2025.
Why do these consultations matter to SfH and the social housing sector?
Launched in 2020, the Sustainability Reporting Standard for Social Housing (SRS) was created by and for the social housing sector to enable it to report on its ESG progress in a consistent, transparent and credible way. The SRS now has over 130 housing association adopters who have committed to reporting against the framework each year.
SfH is tasked with stewarding and evolving the SRS so that it remains useful to housing providers and their funders amidst an evolving sustainability reporting landscape. To succeed in this mission, SfH must engage meaningfully with UK Government and international bodies on key sustainability reporting developments and policies.
In this case, SfH has identified that the incoming UK Sustainability Reporting Standards (UK SRS) will have ripple effects throughout the social housing sector. While housing associations are unlikely to be subject to mandatory reporting requirements themselves, they will likely be indirectly affected by new reporting expectations on their funders. In a scenario where large funders and investors are required to report against the new UK SRS framework, they will almost certainly be knocking at their borrowers’ doors for additional ESG information. SfH aims to influence policy, as well as evolve the SRS, in a way that minimises reporting burdens for housing associations and builds upon the unique value of the SRS.
A regulatory regime for sustainability assurance providers, if introduced, will affect the social housing sector too. Many housing associations voluntarily seek 3rd party assurance of their sustainability data, yet many report difficulties with identifying qualified providers. Through the consultation, SfH shared its views on how an oversight regime could be developed to support the social housing sector and the UK’s sustainable finance ambitions.
What was the UK SRS consultation about?
The first consultation sought views on the UK’s draft UK Sustainability Reporting Standards (UK SRS), a set of sustainability reporting disclosures which are based on IFRS S1 and IFRS S2 – the international sustainability reporting standards introduced by the International Sustainability Standards Board (ISSB) in 2023. The UK is considering adopting the ISSB framework with six minor changes for the UK context. These new disclosures will be known as UK SRS S1 and UK SRS S2.
In November 2024, the Government set out the steps it is taking to establish a credible and internationally respected sustainable finance framework as part of its Mansion House package. The Government intends for the UK SRS to serve as the foundation for this framework.
In addition to seeking views on the six minor changes to IFRS S1 and IFRS S2, this consultation also sought views on the costs and benefits associated with implementing UK SRS. The responses will help inform the Government’s decision about whether to adopt the draft UK SRS, as well as whether to require some companies to report against it.
If adopted – and especially if reporting requirements are established for some UK entities – the UK SRS will become the bedrock of sustainability reporting in the UK. As such, a large portion of UK entities will be directly and indirectly impacted.
What was the sustainability assurance consultation about?
A high-quality and competitive market of sustainability assurance providers will be critical to the UK’s stated mission to become the sustainable finance capital of the world.
The second consultation asked for views on the Government’s proposal to introduce a voluntary regulatory regime for 3rd party sustainability assurance providers, to be overseen by the Audit, Reporting and Governance Authority (ARGA). The aim of this proposed regime is to increase trust in the UK sustainability assurance market and help companies easily identify qualified sustainability assurance providers.
The consultation requested opinions on the introduction of its proposed regime, the merits of an opt-in versus mandatory approach, whether sustainability assurance is desirable in the long-term and more.
What did SfH say in the consultations?
SfH firmly believes in the power of transparent, credible and comparable sustainability reporting. As such, SfH is supportive of the Government’s proposal to adopt the IFRS S1 and IFRS 2 for use in the UK and is mostly in agreement with the six minor amendments.
SfH believes that a stronger national sustainability reporting regime will help channel greater investment into the UK and lead to better sustainability outcomes for people and the planet. SfH is also of the opinion that a national sustainability reporting framework will complement the social housing sector’s SRS, with both frameworks working alongside each other to provide high-quality ESG information throughout the UK.
In the consultation, SfH emphasised its belief that housing associations should not be placed under mandatory reporting requirements for UK SRS S1 and UK SRS S2. Because a large segment of the social housing sector already reports against its own comprehensive ESG framework that aligns closely with TCFD (and is working to align better with ISSB S1 and S2), SfH believes that the costs associated with housing associations reporting against the new framework on a mandatory basis would not outweigh the benefits.
SfH is also broadly supportive of the Government’s proposal to introduce a sustainability assurance regulatory regime. SfH believes that, if executed well, regulatory oversight of the sustainability assurance sector would assist housing associations with selecting qualified providers of sustainability assurance. It could also help attract new entrants to the sector, encourage healthy competition and place the assurance sector on solid footing to compete in the international sustainability assurance market.
SfH also expressed its view that entities that are not subject to mandatory UK SRS reporting, but choose to report against UK SRS anyway, should not be required to obtain sustainability assurance.
Speaking about the consultations, Piers Williamson, SfH’s Chair, said: “At one level, these consultations can seem a bit dry. But for a sector that has borrowed over £100Bn, transparency and accountability to stakeholders is vital for its continued credibility. If we can harmonise our reporting standards with proposed accounting disclosure and assurance then we can keep Housing Associations ahead of the game and attractive as a target for long term investment, in a cost-effective manner.”
