This article is part of a suite of charity law updates on the Autumn 2026 Charity Commission guidance. 

SORP 2026 introduces a dedicated sustainability reporting requirement for the first time. For Tier 3 charities with income above £15m, it is mandatory. For all others, it is optional but worth considering. This section explains what is required, what trustees should think about, and the key actions to take now.

What's changed?

Sustainability reporting is defined under the Charities SORP 2026 as "the practice of disclosing performance across environmental, social and governance areas, sometimes referred to as ESG." For charities in Tiers 1 and 2 (income up to £15m), sustainability reporting is optional. For Tier 3 charities (income above £15m), it's mandatory and the report must include a summary of how the charity is responding to and managing these matters.

SORP 2026 is deliberately non-prescriptive on the content of sustainability reporting, leaving scope for charities to consider how best to present their reports in their particular context.  

What this means for Tier 1 and Tier 2 charities

Sustainability reporting is optional for smaller and mid-sized charities, but trustees shouldn't ignore it. 

Key considerations include: 

• Where sustainability sits within the charity's governance framework.
• Whether there are appropriate reporting lines for ESG risks and board-level engagement.
• Proportionality - links between sustainability reporting and key risks.
• The narrative presented to external stakeholders.
• Not making claims unsupported by evidence.
• Recognising that the first year of reporting is unlikely to be perfect.

With the first reporting periods under SORP 2026 now underway for some charities, trustees should begin considering how sustainability, governance and risk management are reflected in existing structures and reporting processes. 

Key action points

• If your charity is Tier 3 (income over £15m), sustainability reporting in the trustees' annual report is now mandatory. Ensure a process is in place and that the board has sight of the draft sustainability section before sign-off.
• If your charity is Tier 1 or 2, consider whether a short statement on sustainability would be useful and appropriate for your stakeholders, even though it is not required.
• Ensure that ESG-related risks are captured within your charity's risk register (see Section 5 on risk management).
• Do not overstate your charity's sustainability credentials. Only include claims that are supported by evidence.