United Kingdom · Sustainability · Director/VP (16-20 years)

Director, ESG & Sustainability

Here is the whole job, in plain words. What it is, what you decide, how you're judged, how people get here and where they go next. Then the part no course gives you: twelve AI tutors who learn your work.

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As a Director, ESG & Sustainability, a good place to start on AI-Driven Strategic Foresight is Planning Automation Across a Department, a free Future Fluency module at Level 5. You'd practise working out what in your department's work could be automated, what should not be, and what to recommend.

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  • Experience bandDirector/VP (16-20 years)
  • Direct reports25-100+ reports
  • Reports toChief Sustainability Officer (CSO) or CEO
  • UK framework levelUsually a director, accountable for a division and its numbers

Also advertised as VP of Sustainability · Head of ESG Strategy · Director of Corporate Responsibility

Built on 43,079 real UK job descriptions we analysed · grounded in what real qualifications cover

1From this job to a course

The qualifications matched to this job

GQA Level 7 NVQ Diploma in Construction Senior Management GQA Qualifications Limited · Level 7 · covers 1 of 5 standards
Highfield Level 7 NVQ in Construction Senior Management (RQF) Highfield Qualifications · Level 7 · covers 1 of 5 standards
ProQual Awarding Body Level 7 Vocationally-Related Qualification in Construction Management ProQual Awarding Body · Level 7 · covers 1 of 5 standards
ABBE Level 6 NVQ Diploma in Conservation Awarding Body for the Built Environment · Level 6 · covers 1 of 5 standards

Matched from the standards this job is measured against: a suggestion, not an official ruling.

The units you would start with

Assess and evaluate the sustainability and environmental impact of developments in construction management GQA Level 7 NVQ Diploma in Construction Senior Management
Sustainability and environmental impact of developments in construction management Highfield Level 7 NVQ in Construction Senior Management (RQF)
Corporate Social Responsibility as a Key Strategic Issue NOCN Level 7 Extended Diploma in Strategic Leadership of Performance and Productivity
Prepare project briefs and plans in planning and conservation ABBE Level 6 NVQ Diploma in Conservation

The future skills this job leans on

AI Fluency working with AI as a thinking partner
Data Fluency turning numbers into a decision
AI Governance Fluency using AI responsibly
Sustainability Fluency building care for people and planet into the work
Foresight Fluency seeing round the corner
Your Plan Illustration

Built for Director, ESG & Sustainability

4 units that map to this job, from the qualifications that cover it.

  1. Assess and evaluate the sustainability and environmental impact of developments in construction management GQA Qualifications Limited · covers 1 of 5 standards Level 7
  2. Sustainability and environmental impact of developments in construction management Highfield Qualifications · covers 1 of 5 standards Level 7
  3. Corporate Social Responsibility as a Key Strategic Issue NOCN · covers 1 of 5 standards Level 7
  4. Prepare project briefs and plans in planning and conservation Awarding Body for the Built Environment · covers 1 of 5 standards Level 6
These are the real units behind this job, in the order they rank for it. Nothing here is marked done, because this plan has not been started by anyone yet. Yours would fill in as you go.

2AI and this work

Will AI change your work as a Director, ESG & Sustainability?

Nobody can say exactly how. Here is what this job is being asked for next, and where to start.

The new skill this role is being asked for

  • AI-Driven Strategic Foresight
Why each one is rising

The future skills this job leans on

We'll only ever tell you what we can actually back up. No hype, no scare tactics.

What happens when you start

Next, a free account. We build your Director, ESG & Sustainability plan as you set up, starting with the free Automation Fluency module. No card.

Your first Future Fluency module is free. After that, your AI tutor is £70 a month.

Keep this read. One email with what AI is changing in this job, the new skills it asks for and where to start free. Nothing else follows unless you confirm your address.

3What this role really is

This job sets the direction for a business unit's approach to environmental, social and governance issues. It involves building a sustainability strategy that meets compliance needs and drives value. It means thinking about long-term impact and getting people across the business on board.

4What you'd actually use

The tools this job runs on, and how well you'd need to know each one.

ESG Data Platforms (MSCI ESG Manager, Sustainalytics Platform, S&P Global CSA Portal) Strategic

Evaluating and selecting new platforms, managing vendor relationships, ensuring data integration into broader BI systems, and using platform insights for strategic decision-making.

Sustainability Management Software (Workiva, OneTrust ESG, SAP Sustainability Control Tower) Architect

Leading the implementation and integration of these platforms with core ERP/HRIS systems, designing the enterprise-wide data governance framework, and overseeing data integrity and reporting automation.

Data Analysis & Visualization (Power BI/Tableau) Strategic

Defining the key metrics and visualisation strategy for executive and board-level reporting, overseeing the data pipeline, and ensuring insights are actionable and communicated effectively.

Board Reporting Platforms (Diligent, Nasdaq Boardvantage) Advanced

Managing the ESG/Sustainability committee workspace, curating content, and ensuring board members have timely, accurate, and relevant information for strategic oversight.

Collaboration & Project Management (MS Teams/Slack, Asana/Jira, SharePoint/Confluence) Strategic

Implementing collaboration best practices across cross-functional teams, using these tools to report on programme status to leadership, and ensuring efficient workflow for large-scale initiatives.

5What you get to decide, and how that grows

Power in a job isn't your title. It's what you're allowed to decide. Here's how it grows as you move up.

The choiceComing in Where you are nowThe step above
ESG Strategy & Vision No independent decision. Executes tasks aligned with defined strategy. Proposes minor adjustments to existing strategy for specific projects. Designs and recommends strategic initiatives within existing frameworks.
Budget Allocation (ESG Programmes) No budget authority. Submits requests for approval. Manages small project budgets up to £5K, with manager approval. Approves project-level spend up to £25K. Recommends larger investments.
External Communications & Disclosures Drafts sections of reports, all content reviewed by senior staff. Prepares full drafts for specific rating agency submissions, reviewed by manager. Leads the drafting of major report sections, makes recommendations on disclosure content.

6How you'll be judged

The scoreboard, and what is not on it. The hard targets, how often each is actually looked at, and the quiet signals that never reach a dashboard.

ESG Peer Percentile Ranking
Our company's standing against competitors in key ESG ratings.
Target · Achieve top quartile ESG rating within our GICS industry for at least two major rating agencies (e.g., MSCI, Sustainalytics).

Moving from the 60th percentile to the 75th percentile in the MSCI ESG rating over 18 months, demonstrating sustained improvement against our peers.

Sustainability-Linked Financing Secured
The volume and favourable terms of financing (loans, bonds) directly tied to our ESG performance.
Target · Secure at least £50M in new sustainability-linked financing with measurable interest rate benefits, or refinance existing debt with ESG KPIs.

Successfully structuring a £100M revolving credit facility where the interest rate is tied to achieving specific Scope 1 & 2 emissions reduction targets.

Board/Executive ESG KPI Achievement
The percentage of Board-approved ESG key performance indicators (KPIs) that the business unit successfully meets or exceeds.
Target · Achieve 90% or more of the annual ESG KPIs set by the Board and Executive Committee.

Ensuring that targets for renewable energy procurement, employee diversity, and supply chain audit completion are all met or exceeded by year-end.

ESG Risk Mitigation & Opportunity Realisation
The measurable reduction of identified high-priority ESG risks and the successful capture of new ESG-related business opportunities.
Target · Reduce exposure to at least 3 high-priority ESG risks (e.g., water scarcity, human rights in supply chain) by 20% year-on-year, and launch 1 new ESG-aligned product/service.

Implementing a new water recycling programme that reduces operational water withdrawal by 25% in high-stress regions, simultaneously launching a 'green' product line that captures 5% market share.

Board & Investor Confidence
The level of trust and proactive engagement from the Board and institutional investors regarding our ESG strategy and performance.
  • Regular invitations to present at Board meetings beyond formal reporting
  • unsolicited positive feedback from investors on ESG disclosures
  • active participation in investor roadshows
  • direct engagement from board members seeking your counsel on ESG matters
  • no significant shareholder resolutions challenging ESG strategy.
Internal ESG Integration
How deeply ESG considerations are embedded into core business processes and decision-making across the business unit.
  • ESG criteria formally included in M&A due diligence processes
  • ESG impacts considered in new product development gates
  • sustainability goals integrated into business unit annual operating plans
  • budget allocations reflecting ESG priorities
  • internal teams proactively seeking ESG guidance for their projects.
Regulatory Preparedness & Influence
Our ability to anticipate, adapt to, and even influence emerging ESG regulations, avoiding penalties and gaining competitive advantage.
  • Zero regulatory fines or penalties related to ESG
  • early adoption of new regulatory requirements ahead of deadlines
  • active participation in industry working groups shaping future regulations
  • positive feedback from legal/compliance teams on proactive guidance
  • recognised as a thought leader in relevant policy discussions.

7Would you like it

Both sides. What people enjoy, and what grinds them down.

What people enjoy
Driving Large-Scale Transformation

You'll spend your days crafting multi-year strategies, pitching big ideas to the executive team, and seeing those ideas slowly but surely change how the company operates. It's about moving mountains, not just pebbles.

Leading the charge to integrate climate risk into our enterprise-wide financial planning, knowing it will fundamentally shift investment decisions for years to come.

Shaping Corporate Strategy

Your input will directly influence where the company invests, what products it develops, and how it positions itself in the market. You're not just executing; you're helping to define the future direction.

Advising the M&A team on the ESG risks and opportunities of a potential acquisition, which then dictates the deal's structure or even whether it proceeds.

External Impact & Reputation

You'll be the public face of our sustainability efforts, engaging with investors, regulators, and industry peers. Seeing our company recognised for its leadership in ESG will be a huge driver for you.

Representing the company at a major industry conference, sharing our best practices, and seeing our peer ranking improve as a direct result of your team's work.

What frustrates people
  • Internal resistance to change, especially when it impacts established processes or profit centres.
  • The constant tension between short-term financial pressures and long-term sustainability investments.
  • Navigating complex organisational politics to secure resources and buy-in.
  • The slow pace of large-scale transformation, often measured in years rather than quarters.
  • Dealing with 'greenwashing' concerns and ensuring every claim is robustly defensible.
What this role does not give you
  • A highly structured, predictable daily routine.
  • Direct, day-to-day hands-on data analysis (you'll oversee it, not do it).
  • Immediate, tangible results for every initiative you launch.
  • A role where you have direct authority over all the teams whose input you need.
  • A quiet, solitary work environment; you'll be constantly engaging with people.

8Who you work with

This role directly shapes the company's long-term strategy, market positioning, and brand value. It influences capital allocation, investor relations, and our ability to attract and retain top talent. Essentially, you're helping to future-proof the business and ensure its licence to operate in an increasingly scrutinised world.

Inside the business
  • C-Suite (CEO, CFO, COO, CHRO)
  • Board of Directors and relevant sub-committees (e.g., ESG, Audit)
  • Business Unit Heads and their leadership teams
  • Investor Relations and Corporate Communications
  • Legal and Compliance
  • Risk Management
Outside the business
  • Institutional Investors and Shareholders
  • ESG Rating Agencies (MSCI, Sustainalytics, S&P Global)
  • Industry Bodies and Trade Associations
  • Regulators (e.g., FCA, SEC, EU Commission)
  • Key Supply Chain Partners
  • NGOs and Advocacy Groups

9What you need before you start

Not a wish list. The things you would be expected to already have.

  • Proven track record of 16-20 years in sustainability, corporate social responsibility, or related strategic roles, with at least 5-7 years in a senior leadership position (e.g., Head of, Senior Manager).
  • Demonstrable experience in developing and executing enterprise-level ESG strategies that have driven measurable business value and improved external perception.
  • Extensive experience presenting complex strategic and performance data to C-suite executives and Board members, with a history of influencing high-level decisions.
  • A deep, practical understanding of major ESG reporting frameworks (GRI, SASB/ISSB, TCFD, CSRD) and how to apply them strategically.
  • Significant experience leading and managing large, diverse teams (25+ people, including managers), fostering talent, and building strong organisational capabilities.
  • Demonstrable experience managing substantial budgets (£2M+) and being accountable for financial performance within a sustainability context.
  • A strong network within the sustainability industry, including relationships with rating agencies, investors, and relevant NGOs.

10What to practise next

Where the job is going, and what to do about it starting this week.

Advanced ESG Data Architecture & Governance

With increasing regulatory scrutiny and the sheer volume of ESG data, robust data architecture and governance are paramount. Directors need to design and oversee systems that ensure data quality, auditability, and efficient reporting at scale.

Data Lake/Warehouse Design for ESG · Blockchain for Supply Chain Traceability · API Integration for Real-time Data · Data Privacy & Security in ESG

  • This quarter: Review our current ESG data architecture with the IT team; identify key weaknesses and opportunities for improvement.
  • Next 6 months: Develop a roadmap for enhancing our ESG data governance framework, including clear roles, responsibilities, and data quality standards.
  • Next 12 months: Lead the selection and implementation of a new data management tool or system that supports our long-term ESG data needs.
  • Ongoing: Champion data literacy within your team and across the business unit, ensuring everyone understands the importance of data integrity.

Quick win: Implement a quarterly data quality audit for 2-3 critical ESG metrics, identifying and rectifying any inconsistencies or gaps with your team.

Nature-Related Financial Disclosures (TNFD)

Following TCFD, the Taskforce on Nature-related Financial Disclosures (TNFD) is becoming critical. Directors need to understand and prepare for how nature-related risks and opportunities will impact financial reporting and business strategy.

LEAP Approach (Locate, Evaluate, Assess, Prepare) · Nature-Related Dependencies & Impacts · Biodiversity Measurement & Metrics · Integration with Climate & Water Risk

  • This quarter: Review the latest TNFD recommendations and assess their relevance to our business unit's operations and supply chain.
  • Next 6 months: Conduct an initial 'LEAP' assessment for a high-priority operational site or product line, identifying key nature-related dependencies and impacts.
  • Next 12 months: Develop a preliminary roadmap for integrating TNFD into our existing TCFD and broader ESG reporting frameworks.
  • Ongoing: Engage with industry peers and experts to share best practices and learn from early adopters of TNFD.

Quick win: Add 'nature-related risks' as a standing agenda item for relevant internal risk management meetings to start the conversation and raise awareness.

11Staying current once you are in

What people here do to keep up
  • Active participation in relevant industry associations and working groups (e.g., World Business Council for Sustainable Development, UN Global Compact networks).
  • Regular attendance at executive-level sustainability conferences and forums (e.g., GreenBiz, Responsible Business Summit) to stay current on trends and network.
  • Enrolling in executive education programmes focused on climate change leadership, sustainable finance, or corporate governance.
  • Publishing thought leadership articles or speaking at industry events to establish yourself and the company as a leader in the field.
  • Mentoring junior professionals within the sustainability space, both internally and externally.

12The rising capability

The rising capability

Zavmo analysis

What's rising in its place

This is where the work is heading, and the higher pay with it. Get fluent here and the shift stops being a threat and starts being your edge.

AI-Driven Strategic Foresight

AI is rapidly changing how we analyse vast amounts of data, predict trends, and identify emerging risks and opportunities. Directors who can harness AI for strategic foresight will be able to make more informed, proactive decisions and gain a significant competitive edge.

  • Predictive Analytics for ESG Risks
  • Generative AI for Scenario Planning
  • AI-Powered Opportunity Identification
  • Ethical AI Governance

13What you’ll use

What you’ll use

Skills this role draws on

Technical

  • Enterprise-Level Materiality Assessment
  • Integrated Reporting & Value Creation
  • Climate Scenario Analysis & Risk Integration
  • Sustainable Finance Mechanisms
  • Regulatory Advocacy & Policy Influence

14The pathway

The pathway

How you actually get there, here

How you become one varies far more by country than what one does. This is the UK route. Most people take one of these ways in; the right one depends on where you're starting from.

  1. 1

    From ESG Ratings Manager (L5) within Zavmo

    3-5 years as an ESG Ratings Manager

    Skills to master

    • Deepen strategic thinking beyond ratings, develop strong executive presence, master cross-functional influence, and build a track record of leading large-scale initiatives.

    You're ready to move on when

    • Successfully led a major ESG programme that resulted in significant business impact (e.g., new sustainable product line, major emissions reduction).
    • Consistently received positive feedback from VPs and C-suite on strategic contributions and communication.
    • Demonstrated ability to manage and mentor a team of managers effectively, not just individual contributors.
    • Proactively engaged with external stakeholders (investors, regulators) beyond formal reporting requirements.
  2. 2

    From Lead ESG Strategist (L4) in a larger organisation

    4-6 years as a Lead Strategist, often in a larger, more complex company.

    Skills to master

    • Transition from designing strategy to driving its enterprise-wide execution, gain P&L management experience, and develop board-level communication skills.

    You're ready to move on when

    • Successfully designed and implemented a significant, multi-year ESG roadmap for a business unit or major function.
    • Managed a team of 10+ professionals, including senior specialists and project leads.
    • Demonstrated ability to influence senior leadership and secure resources for strategic initiatives.
    • Experience with direct investor engagement or presenting to executive committees.
  3. 3

    From Head of Corporate Affairs/Sustainability in a smaller company

    5-8 years in a similar leadership role, seeking a larger scale and impact.

    Skills to master

    • Adapt to the complexities of a larger, more matrixed organisation, manage larger teams and budgets, and navigate more intense external scrutiny.

    You're ready to move on when

    • Successfully built and scaled a sustainability function from scratch or significantly transformed an existing one.
    • Direct experience reporting to a CEO or Board on sustainability performance and strategy.
    • Proven ability to manage external reputation and engage with diverse stakeholder groups.
    • Demonstrated capability to attract and retain top talent in the sustainability space.

15Where this role leads

The long view: This role can lead to running a company as chief executive, sitting on a board as a non-executive director, or advising organisations on sustainability as a consultant.

The ten Future Fluencies

Zavmo analysis

The credential is what you can do today. These are what keep you valuable.

A qualification proves you can do the job as it's defined today. These ten are what decide whether you're still the obvious person for it in five years. They're the capabilities employers are now writing into senior roles faster than people are learning them. Zavmo weaves them through whatever you study, so you come out with both: the credential and the fluency.

The highlighted ones are the Fluencies your role leans on hardest, from how Director, ESG & Sustainability is actually changing.

How you would learn this

One to one, on the work you already do

A tutor sets the task against your own job and marks the reasoning, at your pace. There is no cohort to fall behind.

A lesson from Assess and evaluate the sustainability and environmental impact of developments in construction management, worked against Director, ESG & Sustainability.

Assess and evaluate the sustainability and environmental impact of developments in construction management Level 7

Applied to your work in Director, ESG & Sustainability

This unit aims to equip learners with the ability to assess the environmental impact of construction development proposals and evaluate sustainable requirements. Learners will be able to analyse the environmental impact assessment process and effectively present findings related to sustainable construction.

How the thinking builds
  1. 1 Remember
  2. 2 Understand
  3. 3 Apply
  4. 4 Analyse
  5. 5 Evaluate
  6. 6 Create
An illustration of a Zavmo lesson, built from this role’s own route. The unit, its objective and every criterion above are the awarding body’s own words, not an example.

It is £70 a month, billed monthly. Your free first module is Future Fluency, and you can cancel any time.

See Your Progress Grow Illustration
Director, ESG & Sustainability
  • Enterprise-Level Materiality Assessment
  • Integrated Reporting & Value Creation
  • Climate Scenario Analysis & Risk Integration
  • Sustainable Finance Mechanisms
  • Regulatory Advocacy & Policy Influence
This is your Mind Palace on learn.zavmo.ai. Every skill above comes from this role's own record, not an example borrowed from another job. A node lights up when you evidence it, and what you build stays yours between jobs. That is the part a course cannot do.

16The detail, folded away

Everything else the record holds

The career branches in full, how AI is already showing up in the day-to-day, and the questions people ask about this job. Here when you want them, out of the way while you decide.

Where it leads next, rung by rung

Where it leads

The career path, and where it branches

Director, ESG & Sustainability is a start, not a ceiling. Each step below asks for new skills and hands back more autonomy.

  1. Chief Sustainability Officer (CSO) / Head of Enterprise Sustainability (L7)

    3-5 years in the Director role

    This is the ultimate step up, moving from business unit-level strategy to enterprise-wide transformation, reporting directly to the CEO or Board.

    • Advanced Scenario Modelling (Enterprise-wide) Overseeing complex, multi-year scenario planning for climate, nature, and social risks across the entire enterprise.
    • Sustainable Finance Innovation Driving the development of novel sustainable finance products and mechanisms that create new revenue streams or significantly reduce cost of capital.
    • Global Regulatory Compliance Navigating and ensuring compliance with a complex web of international sustainability regulations across all operating geographies.
  2. Head of Corporate Affairs / Investor Relations (with ESG focus)

    3-6 years in the Director role

    This is a lateral move into a different functional area, leveraging your deep ESG knowledge for external communication and stakeholder management, potentially at a similar or slightly higher level depending on the organisation.

    • Crisis Communications Developing and executing communication strategies during high-profile corporate crises, often with an ESG dimension.
    • Shareholder Engagement Strategy Designing and leading comprehensive engagement plans with institutional and retail shareholders.
    • Integrated Reporting (External Focus) Owning the end-to-end production of annual reports, sustainability reports, and proxy statements.
    • Market Intelligence (Investor Focus) Deeply understanding investor sentiment, analyst expectations, and market trends to inform communication strategies.
Working with AI on the job

Working with AI

Where AI is starting to help

As a Director, your time is precious. You're constantly juggling strategic planning, investor relations, board presentations, and team leadership. The good news? AI isn't just for junior analysts anymore. It's a game-changer for senior leaders, helping you cut through the noise and focus on what truly matters: driving our sustainability vision forward.

Imagine having a highly intelligent assistant that can instantly summarise complex regulatory changes, draft compelling narratives for investors, and even help you spot strategic opportunities in vast datasets. That's the reality AI offers. We're building an internal AI productivity hub specifically for our Sustainability_Corporate_Social leaders, so you can spend less time on tedious tasks and more time on high-impact strategic work.

Strategic Insight Generation

Feed AI models with thousands of industry reports, competitor analyses, and market forecasts. Ask it to identify emerging ESG risks, pinpoint strategic opportunities, or benchmark our performance against specific peer groups. Get instant, data-driven insights that would take weeks of manual research.

Board Briefing Automation

Got a dense 50-page report on climate scenario analysis? Use AI to distill it into a concise, impactful 2-page summary for your board deck. It can even help you draft talking points, anticipate challenging questions, and ensure your message is crystal clear for executive audiences.

Regulatory Risk Forecaster

Point an AI assistant at new legislative proposals (like the EU's CSDDD or upcoming SEC rules). Ask it to predict the likely impact on our business unit, highlight key compliance requirements, and even suggest proactive measures we should take, giving you a head start on regulatory preparedness.

Investor Comms Drafts

When an institutional investor asks a nuanced question about our Scope 3 emissions or human rights due diligence, use AI to draft a comprehensive, evidence-based response. Provide your internal data and previous disclosures, and let the AI create a compelling, compliant narrative that saves you hours of writing.

Common questions

Common questions

How do you become a Director, ESG & Sustainability?

Common routes in include From ESG Ratings Manager within Zavmo (3-5 years as an ESG Ratings Manager), From Lead ESG Strategist in a larger organisation (4-6 years as a Lead Strategist, often in a larger, more complex company.) and From Head of Corporate Affairs/Sustainability in a smaller company (5-8 years in a similar leadership role, seeking a larger scale and impact.). Times vary with prior experience.

Where can a Director, ESG & Sustainability progress to?

This role can lead on to Chief Sustainability Officer (CSO) / Head of Enterprise Sustainability (3-5 years in the Director role) and Head of Corporate Affairs / Investor Relations (with ESG focus) (3-6 years in the Director role), depending on the skills you build.

What new skills matter most for a Director, ESG & Sustainability?

Increasingly, AI-Driven Strategic Foresight. These are the skills our record of this role lists as growing.

Free tools

Want a read on where you stand?

Three free tools, no account needed. Each one ends with a role, a level and a way in.

17Where to go from here

Other roles at Level 7

Same depth of qualification, different job. Useful if the work appeals but this particular role does not.

More jobs in sustainability

Stay in the field you know and move sideways rather than up.

If you leave this industry

The skills in this role transfer across almost all industries, especially those facing regulatory scrutiny or investor pressure. That includes finance, manufacturing, technology, consumer goods and energy, since every sector has its own sustainability challenges.

This role profile is © 2026 Growth Engineering Technologies Ltd. Built from UK occupational standards and regulated qualification data, and written for Zavmo.

You're not behind. You're right on time. The shift is only just beginning. Your role won't look the same in two years. Be the one who leads the change, not the one it happens to. Start my free Automation Fluency module What happens next: a free account, then we build your plan as you set up. No card. Build your plan, see your roadmap and meet the twelve tutors matched to you. All free. When you're ready to start learning, it's £70 a month, billed monthly. Cancel any time and billing stops.