The sustainability reporting landscape

The sustainable finance market in the Crown Dependencies continues to gain significant momentum, despite mixed sustainability reporting developments in the European Union (EU), United States of America (USA) and United Kingdom (UK).

The European Commission has published an omnibus proposal that aims to reduce significantly the sustainability and due diligence reporting burden for entities.  Key elements of the proposal are related to the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD) and simplification of the Taxonomy Disclosures. Despite the developments, the EU remains at the forefront of sustainability reporting and continues to drive progress.

In the USA, the Securities and Exchange Commission’s (SEC) Climate-related Disclosures Rule was adopted in March 2024 and was immediately met with legal challenge resulting in delayed implementation. A year later, the SEC officially voted to end the legal defence of the rule, halting sustainability reporting requirements at the national level. Focus has shifted to multi-jurisdictional US entities that may have international reporting requirements, most notably in the European Union, and states like California and Colorado that are considering their own reporting mandates.

The UK government has launched a consultation on the UK Sustainability Reporting Standards (SRS), which are based on the ISSB standards, and for climate-related transition plan requirements (Exposure drafts: UK Sustainability Reporting Standards - GOV.UK). At the same time, the UK government has published a consultation document for greater regulatory oversight of third-party assurance services for sustainability-related financial disclosures (Assurance of sustainability reporting - GOV.UK).All consultations are open until 17 September 2025.

• The consultation on the UK SRS seeks views on the draft standards, which are based on IFRS S1 and IFRS S2, with six minor amendments to the standards for application in a UK context. The consultation also seeks evidence on the costs and benefits of using the UK SRS. This evidence will inform future government decisions when it considers whether to require entities to report information using the standards.
• The consultation on the climate-related transition plan requirements delivers on the UK government's commitment to mandating “UK-regulated financial institutions (including banks, asset managers, pension funds and insurers) and FTSE 100 companies to develop and implement credible transition plans that align with the 1.5°C goal of the Paris Agreement”. The consultation seeks views on how the government should take forward this commitment in a way that:
  • supports an orderly transition in line with global climate goals;
  • enhances transparency for investors and promotes efficient capital allocation;
  • supports companies in capturing the opportunities from the global net zero transition; and
  • supports the growth of the UK’s financial services industry by ensuring its sustainable finance framework is internationally competitive and maintains the UK’s status as a global financial hub. 
• The consultation on the greater regulatory oversight of third-party assurance services for sustainability-related financial disclosures seeks views on a proposal for the planned Audit, Reporting and Governance Authority (ARGA) to be given responsibility for creating a voluntary registration regime for entities that offer third-party assurance services for sustainability-related disclosures. The proposed regime aims to drive trust in the UK sustainability assurance market and support entities to easily identify appropriately qualified sustainability assurance providers.

Crown dependencies ESG outlook

Update on listed Crown Dependencies investment funds reporting under TCFD and obtaining assurance on these disclosures

Deloitte performed an analysis of the Crown Dependencies company data as of Q2 2025.  The data indicates 69 London Stock Exchange listed investment funds incorporated in the Isle of Man, Guernsey and Jersey are voluntary reporting under the TCFD framework, a 15% increase from Q2 2024. Of those entities reporting under TCFD, 19 obtained assurance on their ESG metrics, this represents a 27% increase from the same time last year. The steady rise in reporting and seeking of assurance reflects the continued development and momentum within the Crown Dependencies sustainability reporting landscape.