How to Hire a Chief Sustainability Officer / Chief ESG Officer

The Chief Sustainability Officer — also called Chief ESG Officer, Chief Climate Officer or Head of Sustainability, depending on the firm — has moved from the edge of the UK C-suite to the middle of it. A decade ago this was largely a reputational and communications role. Today, at listed companies and large private businesses, it is a strategic and regulatory leadership role: it carries accountability for disclosures with legal weight, it shapes capital allocation decisions that affect the cost of funding, and it reaches into a supply chain that touches every part of the operating model.

This guide explains what a CSO (in the sustainability sense) does in a UK context, the regulatory framework that has made the role essential at listed firms and increasingly relevant elsewhere, what the right candidate looks like, and how to run a search that produces a leader rather than a report writer. It is written from the practical side of UK executive search, drawing on the work Exec Capital does on Chief Sustainability Officer recruitment for listed companies, large private businesses and private equity-backed firms.

What Is a Chief Sustainability Officer?

A Chief Sustainability Officer is the senior executive accountable for a company’s environmental, social and governance strategy, the data that sits behind it and the disclosures that report on it. In most organisations the role combines three jobs: setting a sustainability strategy that fits the commercial model, building the data and controls needed to report credibly, and persuading the rest of the business to change how it operates.

The abbreviation CSO is shared with the Chief Strategy Officer, which we cover in a separate guide. Throughout this page, CSO means the Chief Sustainability Officer unless stated otherwise. Where a firm uses the Chief ESG Officer title the role is functionally the same, although ESG framing is more common in financial services and investment management, where the role often sits close to product governance and regulatory disclosure.

Not every business needs a full C-suite CSO. Many mid-sized companies are better served by a Head of Sustainability or a Sustainability Director reporting into the CFO or COO, with board oversight provided by a non-executive with relevant experience. The decision depends on what the business is actually required to report, what it has publicly committed to, and how central sustainability is to its customers, lenders and investors. For a fuller view of how the role is scoped and where it reports, see our Chief Sustainability Officer job description.

The UK Regulatory Framework Driving CSO Appointments

The shift from reputational function to regulatory necessity has been driven by overlapping frameworks. Several of them changed during the past year, so any CSO brief written before then is likely to be out of date. The summary below reflects the position as of November 2026; it is a hiring guide rather than legal advice, and firms should confirm their own position with their advisers.

TCFD-aligned climate disclosure under the Companies Act. The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 require climate-related financial disclosures, built on the four TCFD pillars of governance, strategy, risk management, and metrics and targets, in the strategic reports of in-scope companies. Broadly, that means traded companies, banking and insurance companies with more than 500 employees, and other large companies and LLPs above the employee and turnover thresholds set in the regulations, for financial years beginning on or after 6 April 2022. These rules remain in force, and for large private companies they are still the main mandatory climate disclosure requirement.

Listed companies: from TCFD to UK SRS. Listed companies have had to make TCFD-aligned disclosures on a comply-or-explain basis under FCA rules since 2021. That regime is now being replaced. In February 2026 the government published the final UK Sustainability Reporting Standards, UK SRS S1 (general sustainability-related disclosures) and UK SRS S2 (climate-related disclosures), based on the ISSB’s IFRS S1 and S2 and endorsed for voluntary use. In September 2026 the FCA published its policy statement (PS26/19) setting final Listing Rules that move listed issuers onto UK SRS-based disclosure. As reported, the final rules operate on a comply-or-explain basis, apply to accounting periods beginning on or after 1 January 2027 (so the first reports appear in 2028), and include transitional relief for Scope 3 emissions. Listed issuers must also state whether they have obtained third-party assurance over their disclosures, although assurance itself is not required.

Transition plans. Under the FCA’s final rules, commercial company issuers must say whether they have published a climate transition plan and where it can be found, or explain why not. There is no requirement to produce one. Separately, the government consulted in 2025 on whether to require transition plans more widely; when we last checked, no final decision on mandating them had been published. Any CSO brief should treat mandatory transition plans as a possibility to prepare for, not a confirmed obligation.

Private companies and UK SRS. The government has not yet decided whether private companies will have to report against UK SRS. It has said it will consider this as part of its Modernising Corporate Reporting programme, with further consultation expected. Until then, UK SRS is voluntary for private companies, but lenders, private equity owners and large customers may ask for it anyway.

UK Streamlined Energy and Carbon Reporting (SECR). Large UK companies and LLPs must report energy use and greenhouse gas emissions in their annual reports under SECR. The CSO typically owns the data collection, the methodology and the narrative on progress, and SECR data is often the starting point for wider emissions reporting.

FCA Sustainability Disclosure Requirements (SDR) and the anti-greenwashing rule. The FCA’s SDR regime introduced investment labels, naming and marketing rules and disclosure requirements for asset managers. Its anti-greenwashing rule, in force since 31 May 2024, applies to every FCA-authorised firm that makes sustainability-related claims about its products and services: claims must be fair, clear and not misleading, and consistent with the sustainability profile of the product or service. For financial services firms, this turns ESG knowledge from a useful credential into a compliance requirement.

UK Carbon Border Adjustment Mechanism (CBAM). The UK CBAM comes into effect on 1 January 2027, with primary legislation in the Finance Act 2026. It applies to imports of specified goods from the aluminium, cement, fertiliser, hydrogen, and iron and steel sectors, and importers will need to keep records of embedded emissions and, where liable, register and pay. For manufacturers, construction businesses and distributors that import these goods, CBAM makes emissions data a direct cost and procurement issue, which often brings the CSO and procurement leadership into the same conversation.

EU CSRD and CSDDD after the Omnibus. UK groups with EU operations need to track EU rules as well. The EU’s Omnibus I simplification package, proposed in 2025 and published in the Official Journal in February 2026, cut the scope of both directives sharply. As amended, the Corporate Sustainability Reporting Directive (CSRD) applies to EU companies with more than 1,000 employees and net turnover above €450 million, and to non-EU parent groups with more than €450 million of EU turnover and an EU subsidiary or branch above €200 million. The Corporate Sustainability Due Diligence Directive (CSDDD) now applies to companies with more than 5,000 employees and €1.5 billion of turnover (or €1.5 billion of EU turnover for non-EU companies), with compliance from July 2029. Many UK groups that were preparing for CSRD are now out of scope; the largest are not. A CSO who can work out which side of the line the group sits on, and stop unnecessary work where it is no longer required, adds immediate value.

Net zero commitments and science-based targets. Many UK listed firms have made public net zero commitments, often validated by the Science Based Targets initiative (SBTi). These commitments create their own accountability: annual reporting against interim targets, third-party validation and investor scrutiny. Delivering them requires a CSO who can design and manage a decarbonisation programme across the whole value chain, including Scope 3.

What a Chief Sustainability Officer Actually Does

The CSO mandate at a UK listed or large private firm covers several distinct areas, each requiring technical knowledge and commercial leadership.

Sustainability strategy development. The CSO develops and owns the sustainability strategy: identifying the material ESG topics for the firm’s sector, setting targets (emissions, supply chain standards, water, waste, workforce), designing the programmes to meet them, and making sure sustainability is part of the business strategy rather than sitting next to it. Good CSOs are selective. They focus effort on the handful of topics that matter commercially and to stakeholders, rather than spreading thinly across every possible metric.

Regulatory reporting and compliance. Companies Act climate disclosures, UK SRS-based Listing Rule disclosures, SECR, SDR and, for some groups, CSRD: the CSO is accountable for the firm’s compliance with whichever obligations apply. That requires knowledge of the frameworks and the ability to build the data infrastructure and governance that produce reportable, auditable metrics. With assurance status now a disclosure item for listed companies, the CSO also needs to be able to work with auditors and assurance providers.

Investor and stakeholder relations. ESG is a primary lens for many institutional investors, and the CSO is often the lead contact with them on sustainability performance. ESG rating agencies, proxy advisers and asset managers with stewardship commitments all scrutinise the CSO’s work directly.

Supply chain sustainability. Scope 3 emissions, generated in the value chain rather than by the firm itself, are usually the largest part of a company’s footprint. Managing them means engaging with large numbers of suppliers, which is a significant supply chain programme in its own right. The CSO owns the Scope 3 strategy and works with procurement and operations leaders on delivery. Our guide to hiring a Procurement Director or Chief Procurement Officer covers the other side of that partnership.

Internal culture and governance. A strategy the CSO owns but the business ignores produces reports, not results. The CSO builds the internal governance — sustainability committees, KPI frameworks, business unit accountability — that turns commitments into decisions on the ground.

Climate risk management. Working with the CFO and Chief Risk Officer, the CSO assesses and discloses the firm’s exposure to physical climate risks (extreme weather, supply disruption, asset impairment) and transition risks (policy, technology, changing customer preferences). This is a risk management discipline that needs both climate literacy and financial modelling capability, and under UK SRS S2 it sits at the heart of the disclosure.

When Is the Right Time to Hire a CSO?

Four situations consistently create the right moment for a CSO appointment at UK firms.

Regulatory obligation. Companies Act climate disclosures, the move to UK SRS for listed issuers and the FCA’s SDR regime all create a compliance trigger. Once a firm is in scope, the work involved — data collection, controls, assurance readiness, investor engagement and regulatory liaison — usually justifies a dedicated senior leader rather than spreading the accountability across existing functions. For listed companies, the first UK SRS-based reports for accounting periods beginning in 2027 mean the data needs to be in place during 2027, so the hiring decision has a deadline attached.

Net zero commitment. A firm that has made a public net zero commitment, particularly one validated by SBTi, needs someone to own delivery. A public commitment without a credible internal programme is a reputational risk and, as the FCA and the Competition and Markets Authority (CMA) take a closer interest in green claims, a regulatory one too.

Investor and lender pressure. Institutional investors and sustainability-linked lenders increasingly ask for ESG data as a condition of investment or lending. Firms that want access to green or sustainability-linked finance need a CSO who can engage credibly with those requirements and manage the reporting that comes with the capital.

Supply chain and trade exposure. Firms with complex supply chains face the reporting duty under section 54 of the Modern Slavery Act 2015, customer due diligence requests passed down from EU groups, and, from 2027, UK CBAM for importers of in-scope goods. A CSO with supply chain expertise can manage both the compliance obligations and the reputational risk that supply chain failures create.

Permanent, interim or fractional?

Not every trigger needs a permanent C-suite hire on day one. An interim CSO can be the right answer when a firm needs to get its first UK SRS-based report or CSRD scoping exercise done while it works out the long-term shape of the function, or when a CSO leaves mid-cycle. A fractional CSO suits smaller listed companies, PE-backed businesses and private companies that need senior judgement a few days a month — to set strategy, oversee a Sustainability Manager and face the board and lenders — without a full-time salary. Many businesses start fractional, build the data and the team, and then recruit a permanent CSO once the scale of the job is clear.

The CSO Candidate Profile

The CSO candidate pool is changing fast because the role has changed fast. Candidates who suited a CSO appointment five years ago, often from corporate communications and corporate responsibility, are frequently not the right fit for the technical, regulation-heavy mandate the role now carries.

Technical ESG and reporting knowledge is now the baseline. A CSO who cannot work through the UK SRS S2 requirements unaided, explain how they differ from the TCFD-aligned disclosures they replace, or discuss Scope 3 category calculation methods is not an adequate appointment for a listed company with mandatory reporting. The candidate need not be a climate scientist, but should have worked in the sustainability reporting environment long enough to understand the technical requirements and their limits.

Commercial orientation is the differentiator. The most effective CSOs connect sustainability to the commercial model: cost savings from energy efficiency, customer preference for credible sustainability credentials, better access to sustainability-linked finance, and supply chain resilience. A CSO who talks only in terms of purpose and values, without linking the agenda to financial performance, will struggle to keep the board and the leadership team on side.

Science and engineering backgrounds are increasingly represented. As climate risk and decarbonisation have become central, candidates with environmental science, engineering or climate modelling backgrounds who have since developed commercial and communication skills are often the strongest technical appointments. They may need support on investor relations and board communication, but their technical foundation tends to last.

Finance and audit backgrounds. With UK SRS putting sustainability disclosure alongside the financial statements, and assurance status now disclosed, candidates who have come through audit, financial reporting or internal controls bring something the sector has often lacked: comfort with data governance, controls and auditors. Some of the most effective recent CSO appointments have been finance professionals who moved into sustainability reporting and then into broader leadership.

Financial services ESG specialists. For asset managers, insurers and banks, a Chief ESG Officer who has worked inside a financial services ESG function — portfolio ESG integration, SDR disclosure, sustainable product governance or stewardship — brings directly relevant experience. The anti-greenwashing rule, product labelling and engagement with proxy advisers and rating agencies are best handled by someone who has done it before.

What to avoid. Communications and PR professionals who have led sustainability reporting without responsibility for the underlying data and programme. CSR and philanthropy leaders whose experience is mainly in community investment rather than operational sustainability. External consultants who have advised on strategy without accountability for delivering it inside a complex organisation. All three can be strong contributors within a sustainability team, but they often lack the accountable leadership record a board-facing CSO role requires.

Running the CSO Search

CSO searches need a technical assessment element alongside the standard executive search process, because the hiring panel often lacks the ESG expertise to test candidates’ claims independently.

Board involvement. At listed firms the CSO will present to the board, often to the audit committee (for reporting and assurance), the risk committee (for climate risk) and the full board (for strategy). The chair and the relevant committee chairs should take part in final-stage assessment. Their view of the candidate’s credibility in a boardroom is a quality check the executive team cannot provide alone.

Technical assessment. A realistic scenario exercise is the most reliable way to test technical depth. Examples include a UK SRS S2 gap analysis against the firm’s last TCFD-aligned disclosure, a Scope 3 data gap problem, a CBAM exposure question for an importer, or a greenwashing review of draft marketing copy. Watching how the candidate reasons through it tells you more than questions about frameworks.

Investor relations connection. Where the CSO will carry significant investor engagement, involving the investor relations lead, or a trusted investor’s perspective, in the assessment is valuable. ESG-focused investors have clear views on what they expect, and checking the candidate against those expectations before appointment avoids a credibility problem later.

Timeline. A CSO search usually takes longer than a typical functional director search. The technical end of the market is narrow, board involvement adds stages, searches are often confidential, and senior candidates commonly have long notice periods. Build that into planning, particularly if the hire is needed before a first reporting cycle; an interim appointment can bridge the gap.

CSO Compensation Benchmarks

Pay for sustainability leaders varies widely with the size of the business, the sector, the breadth of the mandate and whether the role sits on the executive committee. We do not publish salary figures here because there is no reliable public benchmark for this role, and ranges quoted without a source tend to mislead. Instead, these are the structural points that drive the package.

Base salary. The biggest drivers are scope and reporting line. A CSO who reports to the CEO, sits on the executive committee and owns regulatory disclosure, climate risk and supply chain programmes is benchmarked against other C-suite roles. A Head of Sustainability reporting into the CFO or COO is benchmarked against functional directors. Financial services firms often pay more for ESG leaders with regulatory disclosure experience, reflecting how scarce that profile is.

Bonus. Annual bonuses for CSOs are generally set in line with other executives at the same level. Many listed companies now include sustainability-linked measures in executive incentive plans — emissions reduction, disclosure quality, supply chain audit outcomes — and the CSO’s bonus is often weighted towards them. Measures should be specific and verifiable; vague ESG targets in pay plans attract investor and proxy adviser criticism.

Long-term incentives. At listed companies, CSOs on the executive committee normally participate in the LTIP alongside other senior executives, and many LTIPs now include sustainability performance conditions next to financial ones. In PE-backed businesses, management incentive plans increasingly reflect ESG due diligence from acquirers and lenders. Our executive compensation guide covers how these structures are put together.

Onboarding Your Chief Sustainability Officer

A CSO who joins without structured onboarding will spend the first months auditing the firm’s sustainability position from scratch. That is necessary, but it can be shortened by a good pre-start briefing and early access. The briefing pack should include the current sustainability strategy and targets, every regulatory reporting obligation and its status, the last two years of sustainability and climate disclosures with any assurance opinions, the materiality assessment if one exists, supply chain data and audit status, CBAM exposure if the business imports in-scope goods, and the most recent investor feedback on ESG.

The first 30 days should focus on an audit of the sustainability estate: what the firm has committed to, what data supports those commitments, where the reporting gaps are, and where internal capability and external advisers are strong or weak. This is a factual baseline, not a strategy exercise.

Days 30–60 should produce a gap analysis and initial risk assessment: where the programme is credible and where it is exposed. For listed companies, the priority is readiness for UK SRS-based reporting, including Scope 3 data and whether to seek assurance. For groups with EU operations, it is confirming whether CSRD still applies after the Omnibus changes. The findings should go to the CEO, the audit committee and the board.

Days 60–90 should deliver a 12-month programme plan covering regulatory milestones, strategic initiatives, team requirements and budget. By this point the CSO should have working relationships with the CFO (on capital allocation, sustainability-linked finance and the link between sustainability and financial reporting) and the General Counsel (on regulatory compliance, green claims and supply chain due diligence).

The CSO should map stakeholders in the first 90 days: which institutional investors, proxy advisers and rating agencies matter most to the firm, how they currently assess it, and what changes would most improve that view. This is not about gaming ratings. It is about understanding what the firm’s main sustainability stakeholders value and using that to set priorities.

ESG Ratings and Investor Engagement

Investor engagement is a distinct and significant workload that job descriptions often underestimate. Large institutional investors, including UK pension schemes and global asset managers with UK holdings, have dedicated stewardship and ESG teams whose scrutiny of portfolio companies is systematic and detailed.

The main ESG rating providers use different methodologies, weight different factors and update on different timetables. A listed company CSO needs to understand each well enough to manage engagement, respond accurately to data requests and challenge assessments that are factually wrong. Weak ratings can affect index inclusion, the cost of sustainability-linked finance and appeal to investors with ESG mandates, so rating management is a financial activity, not only a reputational one.

Proxy advisers issue voting recommendations that influence how institutional investors vote at AGMs. Sustainability-linked pay, climate strategy, board oversight of sustainability and the quality of climate disclosure are all areas of growing scrutiny. The CSO works with investor relations and the company secretary to make sure disclosures meet the standards those recommendations are based on. The move to UK SRS will give investors more comparable data across listed companies, which makes weak disclosure easier to spot.

Greenwashing Risk and the CSO’s Compliance Mandate

Greenwashing — sustainability claims that are misleading, unsupported or materially incomplete — is now a real legal and regulatory risk for UK firms, and the CSO is usually the leader accountable for managing it.

For FCA-authorised firms, the anti-greenwashing rule requires sustainability claims to be fair, clear and not misleading, and consistent with the product or service’s actual sustainability characteristics. The FCA’s finalised guidance on the anti-greenwashing rule (FG24/3) sets out its expectations, including that claims should be capable of substantiation and that comparisons should be fair. For retail-facing firms, the Consumer Duty adds further obligations around customer understanding.

Outside financial services, the CMA’s Green Claims Code sets out how consumer protection law applies to environmental claims. Since April 2025, the Digital Markets, Competition and Consumers Act 2024 has given the CMA power to decide consumer law breaches and impose fines directly, without first going to court, which has raised the stakes on misleading environmental claims in marketing.

In practice, every public sustainability claim — in an annual report, on a product, in a campaign or in an investor presentation — must be supported by data and consistent with verified performance. A sustainability function built around communications rather than data creates greenwashing risk by design.

The CSO should work with the General Counsel and marketing leadership to set up a claims governance process: a review that checks every public sustainability claim against the underlying evidence before publication. This is not red tape. It is legal risk management that protects the firm’s reputation and its directors.

Common Hiring Mistakes

1. Appointing a CSO without regulatory technical depth. The most costly mistake at listed firms. A CSO who cannot manage the move from TCFD-aligned to UK SRS-based disclosure, or defend the firm’s methodology to auditors and assurance providers, creates regulatory exposure rather than managing it.

2. Placing the CSO in the communications function. A CSO reporting to the Chief Communications Officer rather than the CEO or CFO will lack the authority and budget to drive operational change. Sustainability is a business function, and the reporting line should reflect that.

3. Setting targets without someone to own them. Firms that publish net zero commitments or join SBTi before anyone owns delivery create a credibility problem. The commitment should follow the appointment, not come before it.

4. Hiring an advocate rather than a leader. Passion for sustainability is common in the candidate pool. The ability to deliver a programme inside a complex commercial organisation while keeping the confidence of the CFO and operations team is rare. References should test evidence of commercial influence, not environmental conviction.

5. Briefing against yesterday’s rules. A brief that asks for “CSRD readiness” for a UK group the Omnibus has taken out of scope, or ignores UK SRS for a listed issuer, will attract the wrong candidates. Refresh the brief against the current rules before the search starts.

6. Inadequate budget and resource. A CSO without a meaningful budget, an adequate team and executive committee access cannot deliver. The appointment decision and the resource decision should be made together. A CSO title without backing is a risk for the firm and for the candidate.

How Exec Capital Approaches CSO Appointments

Exec Capital runs Chief Sustainability Officer and Chief ESG Officer searches as retained mandates, with board involvement designed in from the start. We work with the client to agree what the role is for — regulatory reporting, climate risk, decarbonisation, investor engagement or commercial differentiation — because a specific brief produces a better appointment than a generic one. We then build a technical assessment suited to the firm’s sector and reporting obligations alongside the standard search process.

We look across the full candidate market: sustainability leaders at listed and large private companies, financial services ESG specialists, finance and audit professionals who have moved into sustainability reporting, and experienced consultants ready to move in-house. Where the right answer is not a permanent hire, we can also place interim and fractional sustainability leaders, and we often help clients make the related appointments that make a CSO effective, from a CFO who will co-own sustainability reporting to board members with sustainability experience.

If you are weighing up the role, its scope or its timing, our team can help you test the brief before you commit. Find out more about our CSO search service, or tell us about the hire and we will come back to you.

Further Reading and Authoritative Sources

For the UK framework, start with the government’s response on the UK Sustainability Reporting Standards, which explains how UK SRS S1 and S2 were endorsed and what remains under consideration, including private company reporting. The FCA’s policy statement PS26/19 sets out the final Listing Rules for listed issuers, and its SDR pages cover labels, naming and marketing, and the anti-greenwashing rule. The Climate-related Financial Disclosure Regulations 2022 set the Companies Act requirements for large companies, and the government’s UK CBAM guidance covers importers.

Internationally, the ISSB’s IFRS S1 and S2 are the baseline on which UK SRS is built. For UK groups with EU operations, the European Commission and EFRAG publish the amended CSRD requirements and the European Sustainability Reporting Standards. The Science Based Targets initiative sets the framework most commonly used for corporate net zero targets.

For professional standing, the Institute of Environmental Management and Assessment (IEMA) is the main UK professional body for environment and sustainability professionals, and its membership grades can help when assessing candidates. The UN-supported Principles for Responsible Investment (PRI) publishes investor expectations that shape what institutional shareholders look for in a CSO.

Frequently asked questions

Is a Chief Sustainability Officer the same as a Chief ESG Officer?

In most organisations, yes. Chief ESG Officer is more common in financial services and investment management, where the role sits close to product governance and disclosure. Chief Sustainability Officer is more common in corporates. The underlying accountabilities are much the same.

Do UK companies have to report under UK SRS?

Not yet across the board. The government endorsed UK SRS S1 and S2 for voluntary use in February 2026. The FCA’s final rules move listed issuers onto UK SRS-based disclosure on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. Whether private companies will be required to report is still under consideration.

Does the EU CSRD still affect UK businesses?

For the largest groups, yes. After the Omnibus changes, non-EU parent groups are in scope only with more than €450 million of EU turnover and an EU subsidiary or branch above €200 million. Many UK groups previously preparing for CSRD are now outside it, but should confirm their position.

Who should a CSO report to?

Ideally the CEO, with regular access to the board and its audit and risk committees. Reporting to the CFO can work where the role is reporting-heavy. Reporting into communications rarely works, because the CSO lacks the authority to change how the business operates.

Can we start with a fractional CSO?

Often, yes. A fractional CSO can set strategy, oversee a sustainability manager and handle board and lender engagement a few days a month. Many businesses move to a permanent hire once the scope of the role and the reporting obligations are clear.