UK HM Treasury Sustainability Reporting Guidance 2026-27 (FReM) 1.9-1.13: Scope and de minimis thresholds: departments always in scope, executive agencies and NDPBs in scope above 500 FTE or 500 million pounds of operating income and funding or when instructed, and every other entity still assesses materiality with its audit committee

What does 1.9-1.13 require?

Who must report: every ministerial and non-ministerial department, and any executive agency or non-departmental public body that averages more than 500 full-time-equivalent staff over the period, or whose total operating income and funding (grant-in-aid included) tops 500 million pounds, or that its sponsor department has told to report. Neither the thresholds nor the other exemptions touch the TCFD-aligned disclosure duties or the general duty to give users material information. A body below the thresholds still has to ask whether its circumstances, including its environmental and social impacts, generate sustainability information that is material to its primary users; it should bring its audit committee into that assessment and may find it useful to record the reasoning behind key judgements. Preparers in departments should talk to their select committee about what the annual report is for and how it is used.