What does D.5-D.8 require?

Most bodies will find that the emissions they report under this guidance are the same as those in their commitment returns. The exception is a body whose operations give rise to material Scope 1, 2 or 3 emissions in places or categories the commitments do not measure. Two examples are fugitive releases beyond refrigeration and air conditioning (leaks from joints, seals, packing and gaskets, coal piles, wastewater treatment, pits, cooling towers, gas processing), which should be calculated with widely recognised independent standards, and emissions from overseas operations. Such a body shall disclose the extra GHG emissions that the commitment framework does not collect, keeping them disaggregated from the Scope 1 and Scope 2 totals that are measured against commitment targets, so that readers can understand them without losing sight of commitment performance; the disclosure may sit with the other emissions information or in a separate note. Where no factor or method exists, a widely recognised independent standard should be used: the GHG Protocol, ISO 14064, the former Climate Disclosure Standards Board material now within the ISSB, or the GRI sustainability reporting guidelines.

UK HM Treasury Sustainability Reporting Guidance 2026-27...

Other controls in Chapter 5 and Annexes A to D: TCFD-aligned disclosure, UN SDG policies, materiality of other topics, sustainable procurement, nature recovery, and the differences from GGC reporting (paragraphs 5.1 to 5.17, A.1 to D.21) – UK HM Treasury Sustainability Reporting Guidance 2026-27 (FReM)

5.11-5.12 Sustainable procurement: where material, report the systems in place and the action taken to buy sustainably, including the steps taken to embed the Government Buying Standards in contracts and to understand and reduce supply chain impacts and risks
5.13-5.16 Nature recovery and biodiversity: where the body holds significant natural capital or landholdings, signpost the Natural Capital Plan or Nature Recovery Plan and report performance against it in the annual report, and report biodiversity considerations in projects and programmes where material
5.4-5.6 TCFD-aligned disclosure: provide climate-related financial disclosures in the annual report in line with the TCFD Application Guidance on a comply-or-explain basis, consulting that guidance on which recommendations apply, with the emissions element handled under Chapter 2
5.7-A.16 UN Sustainable Development Goals: name the significant policies pursued on sustainability or environmental matters as the FReM requires, give a short description of each policy or a link to its specific GOV.UK page, and identify where activities contribute to relevant SDGs
5.8-5.10 Other material topics: assess whether further sustainability topics are material to primary users across the value chain and sphere of influence, report them on a comply-or-explain basis, and optionally add sections on how strategy delivery depends on economic, environmental and social factors and on influence through procurement and public policy
D.14-D.17 Transmission and distribution losses: no recalculation or separate categorisation is required because the factors include them, and an organisation that chooses to separate the losses should not impair users' ability to track performance against the commitment targets
D.19-D.21 Other KPIs material to strategic policy objectives: reporting them is mandatory on a comply-or-explain basis, with other GGC metrics and Defra's environmental KPI guidance as sources, and the entity responsible for identifying any further regulatory, legislative or policy reporting requirements
D.9-D.11 Nitrogen trifluoride: report NF3 emissions where material, since the Climate Change Act GHG definition now includes it even though the current GGC commitments do not

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MCP endpoint All UK HM Treasury Sustainability Reporting Guidance 2026-27 (FReM) controls