United Kingdom · Sustainability · Lead (8-12 years)

Lead, ESG Reporting

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.

See how AI is changing this job, and get the full read by email.

As a Lead, ESG Reporting, a good place to start on AI-Powered Data Validation & Anomaly Detection 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 bandLead (8-12 years)
  • Direct reports3-5 reports
  • Reports toSenior Manager, ESG Disclosure & Strategy
  • UK framework levelUsually a manager, or the deepest specialist in a team

Also advertised as ESG Disclosure Manager · Staff ESG Analyst · Sustainability Reporting Lead · Senior ESG Program Manager

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

ABBE Level 4 Diploma in Non Domestic Green Deal Advice Awarding Body for the Built Environment · Level 4 · covers 2 of 2 standards
ABBE Level 3 Diploma in Domestic Green Deal Advice Awarding Body for the Built Environment · Level 3 · covers 2 of 2 standards

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

The units you would start with

Prepare and issue non-domestic Green Deal Advice Reports ABBE Level 4 Diploma in Non Domestic Green Deal Advice
Prepare and issue domestic Green Deal Advice Reports ABBE Level 3 Diploma in Domestic Green Deal Advice

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
Automation Fluency building AI into how work runs
Sustainability Fluency building care for people and planet into the work
Your Plan Illustration

Built for Lead, ESG Reporting

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

  1. Prepare and issue non-domestic Green Deal Advice Reports Awarding Body for the Built Environment · covers 2 of 2 standards Level 4
  2. Prepare and issue domestic Green Deal Advice Reports Awarding Body for the Built Environment · covers 2 of 2 standards Level 3
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 Lead, ESG Reporting?

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

The new skills this role is being asked for

  • AI-Powered Data Validation & Anomaly Detection
  • Advanced Prompt Engineering for Regulatory Analysis
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 Lead, ESG Reporting 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

Lead, ESG Reporting designs and manages the systems behind public sustainability disclosures, making sure the data is accurate and auditable.

4What you'd actually use

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

Workiva Wdesk (or similar ESG Reporting Platform) Advanced

You'll configure data collection templates, build new reports and dashboards, manage user permissions, and troubleshoot integration errors. You're the platform's power user and architect.

You'll build complex data models using Power Query, automate data collection where possible, and design data governance protocols. You're expected to be able to handle any data challenge Excel throws at you.

Microsoft SharePoint Lists Expert

You'll design and manage data collection from SharePoint, ensuring version control and data integrity. You'll also automate data flows from SharePoint into other reporting tools.

You'll connect various data sources, build new interactive dashboards to track key ESG performance indicators (e.g., GHG emissions by site, DEI metrics), and present these insights to leadership.

MS Teams, Asana, Jira Advanced

You'll manage complex project plans for multiple reporting cycles (e.g., GRI, CSRD), set up automated workflows, and assign tasks to data owners across the business. You're a project management pro.

Diligent Boards (or Nasdaq Boardvantage) Basic

You'll prepare and upload final, approved PDF reports and presentations into the platform for board meetings, ensuring everything is correctly formatted and accessible.

ServiceNow GRC (or Archer) Intermediate

You'll work with the GRC team to map ESG risks and controls within the system, ensuring alignment between financial and non-financial risk management and pulling relevant compliance data for disclosures.

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 Reporting Framework Selection Follows chosen framework guidance. Proposes minor adjustments to framework application. Recommends and justifies adoption of new frameworks (e.g., ISSB, ESRS) to leadership, considering business impact and resource implications.
Data Collection Methodology Executes data collection using established templates and processes. Identifies inefficiencies in current data collection and proposes improvements. Designs and implements new data collection methodologies and systems, including automation, ensuring data quality and auditability.
ESG Reporting Platform Configuration Enters data and runs pre-built reports. Configures existing templates and dashboards within the platform. Leads the configuration, customisation, and optimisation of the ESG reporting platform, including integration points and user access management.
External Auditor Engagement Assists in gathering requested documentation. Responds to specific auditor queries with guidance from senior staff. Manages the entire external assurance process, acting as the primary point of contact and presenting data and processes to auditors.
Team Resource Allocation Manages own task list. Prioritises own tasks within project scope. Allocates tasks and manages workload for a team of 3-5 direct reports, ensuring project deadlines are met and resources are optimised.

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.

Third-Party Assurance Findings
Number of major non-conformance findings from our external ESG auditors.
Target · Zero major non-conformance findings annually.

After the 2024 assurance, we had one minor finding related to a data lineage document, which was immediately addressed, but no major issues. That's a win.

ESG Reporting Cycle Time
The total time from the 'data lock' date to the final publication of our annual ESG report.
Target · Reduce cycle time by 10% year-over-year, aiming for publication within 6 weeks of data lock.

In 2023, it took us 8 weeks. In 2024, you'd aim to get that down to 7.2 weeks, ideally less, by streamlining processes.

Data Gap Closure Rate
Percentage of identified 'data gaps' (metrics we need but don't currently track well) that have a clear, documented collection process in place.
Target · 80% of identified data gaps closed within 12 months.

If we identify 10 critical data gaps for CSRD, you'd need to have robust collection processes for 8 of them within a year. Think 'water usage by site' or 'employee training hours on human rights'.

Reporting Platform Optimisation
Percentage of key ESG reporting platform features (e.g., automation, custom dashboards, integration points) that are actively configured and used.
Target · Achieve 75% utilisation of core platform capabilities within 18 months of onboarding.

If Workiva has 20 core features for data collection and reporting, we'd expect you to have 15 of them actively set up and working, not just sitting there unused.

Cross-Functional Data Owner Engagement
How well you build relationships and get buy-in from data owners across the business.
  • Data owners (e.g., plant managers, HR leads) respond promptly to requests, proactively offer data, and see you as a helpful partner, not just someone asking for more work. They'll invite you to their team meetings to discuss data challenges, which is a great sign.
Regulatory Preparedness & Foresight
Your ability to anticipate and prepare for new ESG reporting regulations.
  • You're presenting clear action plans for upcoming regulations (like new ISSB guidance) well in advance of deadlines. You've already identified potential data impacts and started conversations with relevant teams before it becomes an 'urgent' problem. Your team isn't caught off guard by regulatory changes.
Team Development & Mentorship
The growth and capability of your direct reports and junior team members.
  • Your team members are taking on more complex tasks, showing increased autonomy, and successfully managing their own reporting workstreams. They're asking fewer basic questions and more strategic ones. You'll see them leading small internal projects confidently.
Process Documentation Quality
The clarity, completeness, and accessibility of our ESG data collection and reporting process documentation.
  • A new joiner or an external auditor can pick up your process documents and understand exactly how a metric is calculated, where the data comes from, and who is responsible, without needing constant clarification from you. It's all there, in plain English.

7Would you like it

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

What people enjoy
Building Robust Systems

You'll spend a good chunk of your time designing new data collection templates, refining workflows in Workiva, and documenting procedures. You get a real kick out of seeing a process you built run smoothly and efficiently.

Successfully implementing a new automated data collection workflow in Workiva that reduces manual effort by 30% and improves data quality, meaning fewer headaches for everyone.

Ensuring Accuracy & Credibility

You're driven by the desire to ensure every piece of information we publish is beyond reproach. This means meticulous review, cross-referencing, and a constant focus on audit readiness. You're the guardian of our ESG reputation.

Catching a significant error in a Scope 3 emissions calculation before it goes to the board, preventing a potential public restatement and saving us a huge reputational headache.

Navigating Complexity

You thrive on dissecting dense regulatory texts (like CSRD or ISSB) and translating them into clear, actionable data requirements and project plans for your team and the wider business. You enjoy the intellectual challenge of figuring out how to comply.

Successfully mapping the new ESRS requirements to our existing data points and identifying the key gaps, then presenting a clear, phased plan to close those gaps to senior leadership.

What frustrates people
  • Spending 60% of your time chasing down data from 50 different people across the globe who see your request as a low-priority administrative burden.
  • Being held accountable for the accuracy of your final report, even when you're forced to use incomplete, estimated, or poorly documented data from other departments.
  • A major framework (like ISSB or ESRS) releasing a critical update or 'final' guidance three months before your reporting deadline, forcing a major scramble to adapt.
  • Constantly having to explain complex ESG concepts (like market-based vs. location-based emissions) to senior executives who just want a simple 'good' or 'bad' number.
  • The period from January to April feeling like a relentless, high-pressure assembly line of data validation, narrative writing, and review cycles with zero room for strategic work.
  • Navigating the tension between the optimistic stories the Communications team wants to tell and the often less-flattering reality of the quantitative data you've collected.
What this role does not give you
  • A quiet, predictable 9-to-5 job with no surprises.
  • Direct control over all the data sources you rely on.
  • A role where every single piece of your work makes it to production or is immediately adopted.
  • A purely strategic role without significant hands-on data management and process work.

8Who you work with

This role is absolutely central to our company's public image and regulatory compliance in the sustainability space. You're essentially building the trust engine for our ESG narrative. Get it right, and we attract ethical investment, avoid regulatory headaches, and boost our brand. Get it wrong, and we face reputational damage, potential legal issues, and a significant hit to our market value. You'll directly influence how the market perceives our commitment to sustainability and our ability to deliver on those promises. You're also shaping how internal teams collect and manage data, driving better practices across the business.

Inside the business
  • Head of Investor Relations
  • Group Finance Director
  • Legal & Company Secretary
  • Heads of Operations & Supply Chain
  • HR Director
  • Internal Audit
Outside the business
  • External ESG Auditors (e.g., PwC, EY)
  • ESG Rating Agencies (e.g., MSCI, Sustainalytics)
  • Investors & Fund Managers
  • Regulators (e.g., FCA, EFRAG)
  • Industry Bodies (e.g., GRI, SASB)

9What you need before you start

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

  • Proven experience (roughly 5+ years) managing end-to-end ESG reporting cycles for a large, complex organisation, not just collecting data points.
  • Demonstrable expertise in at least two major ESG reporting frameworks (e.g., GRI and SASB), including successful report publication.
  • Experience leading small project teams or mentoring junior colleagues, showing you can guide others.
  • A strong track record of designing and improving data collection processes, ideally with experience in an ESG reporting platform.
  • The ability to translate complex technical or regulatory information into clear, actionable plans for business teams.

10What to practise next

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

ESG Reporting Platform API Integration & Customisation

To truly automate and streamline our ESG data flows, we can't rely solely on manual inputs or basic connectors. The ability to use APIs to pull data directly from source systems (ERP, HRIS) into our reporting platform, or to build custom modules, will become essential for efficiency and data integrity.

RESTful API principles and authentication methods · JSON/XML data structures · Scripting languages for API calls (e.g., Python, J · Data mapping and transformation for integration · Error handling and logging for automated data pipe

  • This month: Research the API capabilities of our current ESG reporting platform (e.g., Workiva) and identify potential integration points.
  • Next quarter: Take an online course on API fundamentals and basic scripting (e.g., Python for data integration).
  • Within 6 months: Work with our IT team to scope out a pilot API integration project for a critical ESG data stream (e.g., HR data for DEI metrics).
  • Within 12 months: Successfully implement and maintain at least one API-driven data integration for ESG reporting, reducing manual effort and improving data freshness.

Quick win: Explore Zapier or similar low-code/no-code tools to create simple automated workflows between our ESG platform and other internal tools, even without direct API coding.

Advanced Data Visualisation & Storytelling

As ESG data becomes more complex and audiences more diverse (investors, employees, customers), simply presenting tables of numbers won't cut it. You'll need to tell compelling stories with data, making complex information accessible and actionable through advanced visualisation techniques. This isn't just about pretty charts; it's about clarity and impact.

Principles of effective data storytelling (narrati · Advanced Power BI/Tableau features (e.g., custom v · Interactive dashboard design for different stakeho · Infographic design principles for ESG reports · Techniques for visualising complex concepts like d

  • This month: Review leading ESG reports for examples of excellent data visualisation and storytelling. What works? What doesn't?
  • Next quarter: Take an advanced Power BI or Tableau course focusing on dashboard design and interactive visualisations.
  • Within 6 months: Redesign one of our existing internal ESG dashboards to be more interactive, insightful, and user-friendly, gathering feedback from key stakeholders.
  • Within 12 months: Lead the development of a new, visually compelling section of our annual ESG report, using advanced data visualisation to tell a key sustainability story.

Quick win: Start experimenting with different chart types in Power BI for existing data. Can you tell a clearer story about our emissions trends with a different visual? Probably.

11Staying current once you are in

What people here do to keep up
  • Regularly attending webinars and conferences on new ESG regulations (e.g., CSRD updates, ISSB developments) and best practices in reporting.
  • Participating in industry working groups or forums focused on sustainability reporting challenges and solutions.
  • Subscribing to key regulatory alerts and sustainability news outlets to stay informed on emerging trends.
  • Taking advanced courses in data analytics, particularly around data governance, quality, and visualisation, to strengthen your technical toolkit.
  • Mentoring junior professionals in the sustainability field, which helps solidify your own knowledge and leadership skills.

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-Powered Data Validation & Anomaly Detection

Manual data validation is incredibly time-consuming and prone to human error, especially with the sheer volume of ESG data. AI tools are getting incredibly good at spotting inconsistencies and outliers much faster and more reliably. Competitors are already using this to streamline their processes.

  • Machine learning models for outlier detection (e.g
  • Natural Language Processing (NLP) for cross-refere
  • Automated data quality checks and rule-based valid
  • Explainable AI (XAI) for understanding why an anom
  • Integration of AI tools with existing ESG reportin

Advanced Prompt Engineering for Regulatory Analysis

New regulations like CSRD are incredibly dense and complex. Analysts who can effectively 'talk' to Large Language Models (LLMs) will be able to summarise, compare, and extract key requirements from these documents in minutes, not days. This is a massive productivity boost.

  • Structured prompting techniques (e.g., Chain-of-Th
  • Context window management and token limits for lar
  • Using LLMs for comparative analysis of different r
  • Extracting specific data points and deadlines from
  • Validating LLM outputs for accuracy and 'hallucina

13What you’ll use

What you’ll use

Skills this role draws on

Technical

  • ESG Reporting Frameworks (GRI, SASB, TCFD, ISSB, CSRD/ESRS)
  • Double Materiality Assessment
  • GHG Accounting & Climate Data (GHG Protocol)
  • Data Governance & Assurance Readiness (ISAE 3000, AA1000AS)
  • Regulatory Analysis & Implementation
  • Supply Chain Due Diligence Data

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

    Senior ESG Disclosure Analyst (L3)

    3-5 years

    Skills to master

    • You'd need to have successfully managed multiple full reporting cycles, including data collection, validation, and narrative drafting. Proving you can mentor junior staff and independently handle non-routine situations is key.

    You're ready to move on when

    • Consistently delivering accurate and timely reports with minimal supervision.
    • Successfully leading a significant reporting project (e.g., a full GRI report) from start to finish.
    • Demonstrating strong problem-solving skills for data inconsistencies or reporting challenges.
    • Receiving positive feedback on your ability to guide and support junior team members.
  2. 2

    Financial Reporting Manager with ESG Focus

    4-6 years

    Skills to master

    • You'd need to have a solid background in financial reporting and audit, but with a growing specialisation in non-financial disclosures. This means understanding data assurance, internal controls, and how to work with auditors, then applying that rigour to ESG data.

    You're ready to move on when

    • Experience with external audit processes and managing audit requests.
    • Strong understanding of internal controls and data governance principles.
    • Demonstrated ability to adapt financial reporting skills to new, complex non-financial data sets.
    • A clear interest and some experience in sustainability reporting or data.
  3. 3

    Sustainability Consultant (Senior Level)

    3-5 years

    Skills to master

    • You'd bring a broad understanding of different industries and reporting challenges from client work. The key here is translating that consulting experience into building and owning internal processes, and demonstrating leadership within a corporate setting.

    You're ready to move on when

    • Experience advising multiple clients on ESG reporting strategy and implementation.
    • Strong project management skills, managing complex deliverables and client expectations.
    • Ability to quickly understand a company's internal data landscape and identify gaps.
    • A desire to move from advising to directly owning and implementing reporting programmes.

15Where this role leads

The long view: This role can lead to director-level sustainability reporting, a chief sustainability officer position, or a specialist role in ESG assurance within internal audit.

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 Lead, ESG Reporting 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 Prepare and issue non-domestic Green Deal Advice Reports, worked against Lead, ESG Reporting.

Prepare and issue non-domestic Green Deal Advice Reports Level 4

Applied to your work in Lead, ESG Reporting

1. To enable the learner to describe the prescribed format and content of a Non-domestic Green Deal Advice Report. 2. To enable the learner to identify approved software options and select appropriate software for different types of non-domestic assessments.

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
Lead, ESG Reporting
  • ESG Reporting Frameworks (GRI, SASB, TCFD, ISSB, CSRD/ESRS)
  • Double Materiality Assessment
  • GHG Accounting & Climate Data (GHG Protocol)
  • Data Governance & Assurance Readiness (ISAE 3000, AA1000AS)
  • Regulatory Analysis & Implementation
  • Supply Chain Due Diligence Data
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

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

  1. Senior Manager, ESG Disclosure & Strategy (L5)

    3-5 years

    One level up, moving from leading programmes to directing a function.

    • Enterprise-wide Data Architecture Overseeing the data architecture for all ESG data across the organisation, not just reporting.
    • M&A Due Diligence (ESG) Understanding how ESG risks and opportunities are assessed during mergers and acquisitions.
    • Advanced Stakeholder Theory Deeper understanding of how different stakeholder groups (investors, employees, communities) influence and are influenced by ESG disclosures.
    • ESG Software Procurement & Vendor Management Leading the selection and management of major ESG software solutions.
Working with AI on the job

Working with AI

Where AI is starting to help

Let's be real, ESG reporting is a beast. It's complex, time-consuming, and often involves wrangling mountains of disparate data. But what if you could cut through the noise, automate the tedious bits, and free up your time for the truly strategic work? That's where AI comes in.

We're not talking about replacing human judgment; we're talking about giving you a serious superpower. Imagine AI handling the grunt work of data extraction, spotting anomalies, summarising regulations, and even drafting your first narrative sections. It means you can focus on validation, interpretation, and influencing the business, rather than getting bogged down in manual tasks. Here's a glimpse of how AI will change your day-to-day as a Lead, ESG Reporting.

Automated Data Extraction

Use AI-powered OCR tools to automatically scan and pull key data (like kWh from utility bills or waste volumes from invoices) from thousands of unstructured PDFs and images. It then populates your central database, saving you hours of soul-crushing manual entry and reducing human error. Honestly, it's a game-changer for Scope 1 & 2 data.

Anomaly Detection & Insight

Apply machine learning models to our historical ESG datasets (think water usage, safety incidents, or energy consumption). The AI will automatically flag significant deviations or anomalies that could point to a data error, a reporting misstep, or even a real-world operational issue that needs your urgent attention. It's like having a super-smart assistant constantly checking your numbers.

Regulatory & Peer Benchmarking

Feed newly released, dense regulatory documents (like an ESRS update or new ISSB guidance) into a large language model (LLM). It'll summarise the key data requirements and deadlines for you in minutes. You can also use it to analyse and benchmark our draft disclosures against the published reports of 5-10 key competitors, highlighting gaps and best practices. No more slogging through hundreds of pages of legalese.

First-Draft Narrative Generation

Got structured data tables (e.g., GHG emissions by scope, DEI statistics) and key themes? Feed them into a generative AI tool to create a first draft of the corresponding narrative sections for our annual sustainability report. This won't be perfect, but it'll give you a solid starting point, letting you focus on refining the story and ensuring it aligns with our strategy, rather than staring at a blank page.

Common questions

Common questions

How do you become a Lead, ESG Reporting?

Common routes in include Senior ESG Disclosure Analyst (3-5 years), Financial Reporting Manager with ESG Focus (4-6 years) and Sustainability Consultant (Senior Level) (3-5 years). Times vary with prior experience.

Where can a Lead, ESG Reporting progress to?

This role can lead on to Senior Manager, ESG Disclosure & Strategy (3-5 years), depending on the skills you build.

What new skills matter most for a Lead, ESG Reporting?

Increasingly, AI-Powered Data Validation & Anomaly Detection and Advanced Prompt Engineering for Regulatory Analysis. 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 5

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 work involves data governance, regulatory interpretation, stakeholder management and project leadership. These skills carry into ESG consulting, investor relations with an ESG focus, or data governance and compliance roles in other industries. Demand for ESG expertise continues to grow.

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.