The Greenhouse Gas Emissions (Directors' Report) Regulations 2013 will require quoted companies to report their greenhouse gas emissions in the directors' report section of their annual report. Recent DEFRA guidance on the likely implementation of the regulations included:
- It is likely that the emissions reporting requirements will be implemented around 1 October 2013 and will apply to company reporting years ending on or after 1 October 2013. While the draft guidance says that ideally a reporting year should tie in with the company’s financial year, quoted companies will be free to report on a different basis provided that they explain that they have done so in the directors' report.
- While concern has been expressed about the timing, DEFRA does not consider that the regulations will cause problems for quoted companies on the basis that most quoted companies already do some form of greenhouse gas emissions reporting and the introduction of mandatory reporting is widely known to be imminent.
- A revised draft of the Greenhouse Gas Emissions (Directors' Report) Regulations 2013 (expected to be laid before Parliament around February/March this year) will contain "comply or explain" provisions, so that quoted companies who have been unable to comply fully with their obligations due to being unable to collect the necessary data could explain why they have been unable to do so. For example, companies whose financial years end on or shortly after 1 October 2013 who find that they do not have greenhouse gas emissions data for a full year may be able to satisfy their reporting requirements by explaining that they had not known about the need to collect such data in 2012 before the draft regulations came into force.