ESG Compliance in Liverpool
Serving Liverpool and the wider Merseyside area, including Birkenhead, Bootle, Wallasey.
ESG compliance in Liverpool starts with one question: do you legally have to report?
For a Liverpool business, ESG compliance is not a single certificate you either hold or you don’t. It is a stack of overlapping duties, and the first job of a specialist is to tell you honestly which of them actually bind your company. The headline duty for most mid-to-large firms in the city is Streamlined Energy and Carbon Reporting (SECR), which requires quoted companies, and large unquoted companies and LLPs, to disclose their energy use and greenhouse gas emissions in the directors’ report filed with the annual accounts. “Large” is the Companies Act test: you are caught if you meet at least two of three thresholds — 250 or more employees, turnover over £36 million, or a balance-sheet total over £18 million. Merseyside’s logistics, retail and property groups routinely cross that line after a good year or an acquisition without ever thinking of themselves as “reporters”, which is exactly where the surprises start.
Sitting above SECR for the largest companies are mandatory TCFD-aligned climate-related financial disclosure under the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022, and, increasingly, a Carbon Reduction Plan to win major public-sector contracts under Procurement Policy Note 006. On the horizon are the UK Sustainability Reporting Standards (UK SRS S1 and S2) — the UK’s version of the ISSB baseline, which the government finalised for voluntary use in early 2026 but has not made mandatory, and which remains under active consideration by government and the FCA. We build a Liverpool company’s programme on the duties that bind it today, structured so that adopting UK SRS later is an extension rather than a rebuild. Anyone telling you UK SRS is already compulsory is overstating it.
This page sets out how that plays out for a company headquartered in, or operating across, the Liverpool City Region — the regional net-zero policy your customers and your council are working to, the port and logistics economy that shapes the local footprint, and how our ESG compliance programme for Liverpool firms applies from a first SECR baseline through to a net-zero roadmap.
The Liverpool City Region’s 2040 net-zero target and what it means for local reporters
The Liverpool City Region was first out of the blocks on climate governance in England, and that raises the bar on ESG expectations for every business here. The Liverpool City Region Combined Authority (LCRCA), led by Mayor Steve Rotheram, was the first combined authority in the country to declare a climate emergency, in 2019, and has committed the six-borough region — Liverpool, Wirral, Sefton, Knowsley, St Helens and Halton — to being net zero carbon by 2040, ten years ahead of the UK’s statutory 2050 target. It is delivered through its Pathway to Net Zero and a Five-Year Climate Action Plan of immediate measures; the combined authority’s own analysis has found that energy use across the region needs to roughly halve to hit the 2040 date. Liverpool City Council carries its own climate emergency declaration beneath that regional target.
For a company sitting inside that policy environment, the direction of travel is one-way. A regional 2040 target does not itself create a legal reporting duty on your business — SECR and TCFD-aligned disclosure are national regulations, not local ones — but it shapes the commercial context in three concrete ways. It drives the region’s anchor institutions to push carbon requirements down their supply chains (see the tender section below). It underpins a genuine local support ecosystem for the decarbonisation half of the job, including the combined authority’s net-zero and innovation funding. And it means Liverpool City Region customers, investors and lenders increasingly probe whether your reported numbers, and the plan behind them, are credible. Getting ahead of that is a hedge, not a gamble.
We are clear about the boundary between that support and what a reporting-obligated company actually has to file. The combined authority’s climate funding and the decarbonisation reliefs attached to the Liverpool Freeport are genuinely useful for planning a decarbonisation programme, but they do not produce the assurance-ready SECR disclosure, the TCFD-aligned climate statement, or the PPN 006 Carbon Reduction Plan that a reporting-obligated Liverpool company actually has to file. Those are delivered professional services, and that is the half of the job we own.
Who actually has to report in Liverpool
The clearest way to understand SECR and TCFD scope in Liverpool is to look at the companies headquartered here that are unambiguously caught. Liverpool anchors the Merseyside economy, and its business base runs from a major port and logistics cluster through to national retail and property groups for whom carbon reporting is not optional.
B&M European Value Retail, the FTSE-listed discount retailer, runs its business from The Vault at Estuary Commerce Park in Speke, alongside a large distribution centre; as a quoted company it falls squarely within SECR — reporting its global energy and emissions — and within the mandatory TCFD-aligned disclosure regime. Peel Ports Group, headquartered in Liverpool, is one of the UK’s largest port operators and runs the Port of Liverpool and a national network of terminals, exactly the kind of substantial, energy-intensive private group the SECR “large company” test is designed to catch. The Very Group, the online retailer and financial-services business, is one of the city’s largest private employers and runs a major operation on Merseyside. Around them, the office towers of the Liverpool Commercial District on Old Hall Street and the emerging Liverpool Waters / Princes Dock quarter host the regional headquarters of professional, financial and property firms, while the industrial estates at Speke, Aintree and Knowsley house the large manufacturing and logistics operators that the SECR thresholds catch.
The point for a Head of Sustainability or Finance Director reading this is not that these particular names need our help — it is that Liverpool’s business base is full of companies that either already report or are one growth year away from having to. If your company is quoted, or if you meet two of the three “large” thresholds, the energy and carbon disclosure goes in your directors’ report and is filed with your accounts at Companies House. It has a hard deadline, and a vague sustainability page does not satisfy it. We tell you precisely where you sit before we quote a thing.
Decarbonisation, the grid and honest levers in the Liverpool City Region
Reporting is only half the job. The other half is the decarbonisation roadmap — the costed, sequenced plan that actually makes next year’s numbers better than this year’s — and here the local context is the electricity network your sites sit on. The Distribution Network Operator for Merseyside is SP Energy Networks, whose SP Manweb licence covers Merseyside, Cheshire and North Wales. That matters the moment a roadmap recommends on-site generation.
We treat renewables honestly, as a lever rather than the product. On-site solar or a well-structured power purchase agreement (PPA) can reduce your market-based Scope 2 emissions — the figure that reflects the electricity you have specifically contracted for under the GHG Protocol’s dual Scope 2 method. There are two honest caveats a Liverpool company needs to hear up front. First, it only touches Scope 2: it does nothing for your Scope 1 fuel use or your Scope 3 value chain, which for a Merseyside logistics or retail business — where inbound and outbound transport and purchased goods dominate — is very often the larger part of the footprint. Second, the credibility of the claim depends on quality and additionality: a genuine on-site array on a large Speke or Knowsley warehouse roof, or a proper PPA, is far more defensible than unbundled certificates bought to flatter the number. Where a roadmap does recommend on-site generation, the grid-connection notification to SP Energy Networks (a G98 notification for small installs, G99 for larger) applies to that measure, downstream of the reporting itself, never as part of the disclosure.
That distinction — reporting first, decarbonisation as the delivery half, renewables as one honest lever inside it — is the whole discipline. It is what keeps a Liverpool City Region company’s net-zero claims clear of a greenwashing challenge under the CMA’s Green Claims Code, and it is why we never dress a solar install up as an ESG strategy.
ESG in Liverpool’s tenders: the anchor institutions raising the bar
For many Liverpool businesses, the trigger to act on ESG is not a filing deadline at all — it is a lost bid. The region’s large public and anchor institutions have moved carbon requirements firmly into their procurement, so a supplier without a credible carbon footprint and reduction plan is increasingly shut out of work it would otherwise win.
The Liverpool City Region Combined Authority and Liverpool City Council both apply social-value and carbon criteria to their own contracts, and the combined authority has tied much of its regional strategy to the net-zero pathway. Across higher education, the University of Liverpool and Liverpool John Moores University, two of the city’s largest institutions, operate sustainable-procurement and supplier-engagement programmes that push Scope 3 expectations onto anyone wanting to trade with them. And across the health economy, Liverpool University Hospitals NHS Foundation Trust and the wider Cheshire and Merseyside NHS bodies sit within the national NHS Net Zero Supplier Roadmap, under which suppliers must complete the Evergreen Sustainable Supplier Assessment and, from 6 April 2026, hold a PPN 006-compliant Carbon Reduction Plan at Level 1 to tender through NHS Supply Chain.
That national procurement rule, PPN 006 (which updated the former PPN 06/21 to reflect the Procurement Act 2023), requires suppliers bidding for major central-government contracts worth more than £5 million a year including VAT to have and publish a Carbon Reduction Plan confirming a commitment to net zero by 2050. Beyond that central-government threshold, the selection questionnaires used by Liverpool’s council, universities and NHS bodies increasingly ask for your footprint, your reduction targets and your environmental-management arrangements as a matter of course. The practical reality for a Liverpool supplier is simple: a missing Carbon Reduction Plan can disqualify an otherwise winning bid, and getting one in place is a commercial move, not a green gesture.
Our ESG services, applied across the Liverpool City Region
We deliver the whole programme rather than a directory of frameworks or a free online checker. For a Liverpool company, that runs across five connected services, each of which we apply to your actual sites and data across Merseyside and the wider city region.
- ESG strategy and materiality — a materiality (or double-materiality) assessment and the governance layer that a TCFD-aligned disclosure and the emerging UK SRS both expect you to describe. This is the foundation everything else is built on.
- Carbon footprint and baseline — a Scope 1 and 2 greenhouse gas inventory built to the GHG Protocol Corporate Standard, using the UK government’s conversion factors, with both location-based and market-based Scope 2 figures. This is the starting line for a Liverpool site, whether it is an Old Hall Street office floor or an Estuary Commerce Park distribution unit.
- SECR reporting — the disclosure that goes into your directors’ report and is filed with your accounts, prepared to stand up to scrutiny and, where you want it, to independent assurance. This is the money page for a company searching for ESG reporting help.
- Net-zero roadmap — a costed, sequenced plan with SBTi-aligned targets, energy efficiency first and on-site generation or a PPA treated as an honest Scope 2 lever, aligned to both the statutory 2050 target and a PPN 006 Carbon Reduction Plan.
- Scope 3 and supply-chain emissions — value-chain emissions across the fifteen GHG Protocol categories, spend-based screening to find the hotspots first, then supplier-specific data where it moves the number. This is the service a Merseyside logistics or retail supply chain now probes hardest.
Every engagement is scoped on the shape of your business — how many sites and meters are in the inventory, how mature your data is, and above all whether Scope 3 is in scope — not priced off a menu, because a headline figure would mislead you. Our guide to what an ESG programme costs sets out what drives the fee.
Nearby cities, our services and getting started
We deliver ESG reporting and decarbonisation programmes for companies across Liverpool and the wider city region, including Birkenhead, Bootle, Wallasey, St Helens, Crosby and Knowsley, and out across the North West. For businesses in neighbouring city regions, see our ESG compliance in Manchester, Leeds and Sheffield pages, each anchored to its own combined-authority net-zero context. For the detail of what we do, start with our SECR reporting and net-zero roadmap service hubs, or the wider services overview, and see how a programme is scoped on our cost guide and answered in full in our FAQs. If you want to check where your company sits before anything else, our UK ESG compliance specialists will tell you honestly which duties bind you.
The first step is a short readiness conversation, not a hard sell. We will tell you whether SECR or TCFD-aligned disclosure applies to your Liverpool business, what a Liverpool City Region tender is likely to ask for, and — if none of it bites yet — we will say so, and show you what your customers’ contracts will soon require. Use the enquiry form below to book that conversation; we respond within one working day.
Government sources, verified 2 July 2026: the UK government environmental reporting guidelines including SECR (gov.uk), UK Sustainability Reporting Standards guidance (gov.uk), PPN 006 on Carbon Reduction Plans (gov.uk), and the Liverpool City Region Pathway to Net Zero / net-zero-by-2040 target (LCRCA).
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Other areas we cover
ESG compliance in Liverpool: local questions
Does the Liverpool City Region's 2040 net-zero target place a legal reporting duty on my company?
No, not directly. The Liverpool City Region Combined Authority was the first combined authority in the country to declare a climate emergency, in 2019, and has committed the region to being net zero carbon by 2040 — ten years ahead of the UK's statutory 2050 target — through its Pathway to Net Zero and Five-Year Climate Action Plan. That is a regional policy commitment, not a company-level regulation, and the same is true of Liverpool City Council's own climate declaration. Your legal reporting duties come from national law: SECR if you are quoted or a large company or LLP, and TCFD-aligned disclosure if you are one of the very largest firms. What the 2040 target does change is the commercial context, because it drives the combined authority, the councils, the city's universities and its NHS trusts to demand carbon plans from their suppliers — so the practical pressure to hold credible numbers is real even where the legal duty is not.
We are inside the Liverpool Freeport — does that change our ESG or carbon-reporting obligations?
Not the reporting obligations themselves, but it changes the economics of decarbonisation. Freeport status, which covers sites across the Liverpool City Region including the Port of Liverpool and land around it, offers tax reliefs such as Enhanced Capital Allowances and business-rates relief within the designated tax sites — reliefs that can improve the payback on the physical decarbonisation measures a net-zero roadmap recommends, such as on-site solar or building-fabric upgrades on qualifying sites. It does not alter whether SECR or TCFD-aligned disclosure applies to you; those are national tests based on your size and structure. We treat the Freeport reliefs as a funding lever for the roadmap where a site genuinely qualifies, and we are clear that they sit downstream of the reporting, never as part of the disclosure.
Which Liverpool public bodies will ask us for a Carbon Reduction Plan in a tender?
Any major central-government contract above £5 million a year triggers the formal PPN 006 requirement for a published Carbon Reduction Plan. Below that, in day-to-day Liverpool City Region procurement, the Liverpool City Region Combined Authority, Liverpool City Council, the University of Liverpool, Liverpool John Moores University and NHS bodies such as Liverpool University Hospitals all now build carbon and sustainability questions into their selection questionnaires. NHS suppliers face a firmer test: the Evergreen Sustainable Supplier Assessment, which from 6 April 2026 requires a PPN 006-compliant Carbon Reduction Plan at Level 1 to tender through NHS Supply Chain. If you sell to Liverpool's large anchor institutions, expect to be asked for a footprint and a reduction plan.
Talk to an ESG specialist in Liverpool
Whether SECR is due with your accounts, a tender needs a Carbon Reduction Plan, or you are preparing for TCFD-aligned disclosure, we will give you an honest read scoped to your business — no obligation, no phone required.
Get an ESG quoteResponds within one working day
- 1. Readiness call — an honest read on which duties (SECR, TCFD-aligned disclosure, PPN 006) actually apply, no obligation.
- 2. Scoped proposal — a programme priced on your size, sites and reporting scope, set out in writing.
- 3. Delivered & assurance-ready — baseline, report and net-zero roadmap built to the GHG Protocol.
- GHG Protocol
- ISO 14064-1
- SBTi
- TCFD-aligned