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The UK SRS reference · checked against FCA PS26/19
UK SRS is the UK’s version of the international sustainability standards: S1 for sustainability-related financial information, S2 for climate.
The Department for Business and Trade published both on 25 February 2026, for voluntary use.
The FCA’s final rules, PS26/19, put them to work: listed companies report against UK SRS, comply or explain, from 1 January 2027.
A finder
Choose your type of organisation around the ring to see its reporting route.
Each route gives the legal status, its source and the guide to read next.
For size, use the scope check below or the scope checker.
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In scope · comply or explain
The FCA’s final rules (PS26/19) require UK SRS reporting on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reports in 2028.
A company may use the one-year Scope 3 relief and the two-year relief for S1 matters beyond climate by saying that it is doing so, and one without a published transition plan says why not.
The FCA rules, limb by limb · Complying, or explaining · UK SRS S2
PS26/19 ¶3.6, ¶3.12, ¶3.14, ¶3.20 · UKLR 6.6.6R(7A), (7B), (8)
FCA final rulesModule 02 / 08
In scope · comply or explain
The final rules bring these categories in on the same comply-or-explain basis; the consultation draft had proposed only a signposting statement for them.
The transition-plan statement in UKLR 6.6.6R(8)(e) does not apply to UKLR 14 and 15.
The rules apply from 1 January 2027.
PS26/19 ¶1.7, ¶3.6, ¶4.35
FCA final rulesModule 03 / 08
In scope · comply or explain
Both categories are within the scope of the final rules, and the transition-plan statement covers UKLR 6, 16 and 22.
See the policy statement for the rule text and reliefs.
PS26/19 ¶3.6 · UKLR 6.6.6R(8)(e)
FCA final rulesModule 04 / 08
Outside the FCA rules
The final rules exclude closed-ended investment funds, open-ended investment companies, shell companies, debt and debt-like securities, securitised derivatives, and warrants, options and other miscellaneous securities.
UK SRS remains available for voluntary use by any entity.
PS26/19 ¶3.7
FCA final rulesModule 05 / 08
Not reached by the listing rules
AIM securities are not admitted to the Official List, so the listing-rule categories do not reach them; UK SRS is voluntary.
For SECR purposes an AIM company is unquoted, so the size test applies.
See the AIM Rules for Companies.
AIM Rules for Companies · CA 2006 s.385
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No UK SRS duty
No UK entity outside the listed categories is required to use UK SRS, and no private-company threshold is proposed anywhere.
The standards are available for voluntary use.
The Modernising Corporate Reporting consultation is open until 30 November 2026.
SECR and ESOS may still apply on their own tests.
Modernising Corporate Reporting · ESOS and SECR checker · Scope checker
DBT guidance · PS26/19 ¶3.6
FCA final rulesModule 07 / 08
UK SRS and the EU regime are separate
A group may fall under the Corporate Sustainability Reporting Directive as well.
The two regimes rest on different materiality tests, and the Commission adopted revised ESRS on 3 July 2026.
Climate data can usually be shared between reports; the materiality assessments cannot.
UK SRS S1 ¶3 · Directive (EU) 2022/2464
FCA final rulesModule 08 / 08
Voluntary use
The Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026 for voluntary use by any entity.
A voluntary preparer chooses its own statement of compliance and should say plainly that the use is voluntary.
DBT publication, 25 February 2026
FCA final rulesThe road to first reports
The road lights up as you scroll, and every step is dated to its instrument.
A calendar-year company starts on 1 January 2027 and reports in 2028; the first-period section works out yours.
The full register is the dated register of UK SRS events.
Choose a path
Also: the UK SRS legislation behind the rules, and every date on the dated timeline.
Where UK SRS stands
What is final, what is voluntary, what is only a consultation.
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Status ledger
Published standards, final rules and draft guidance have different legal weight.
Start with the instrument that reaches your entity. This reference is checked to 9 October 2026.
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Legal status
UK SRS is available for voluntary use. The FCA’s listing rules create the duty for the five covered categories.
Company-law recognition of S2 as a framework does not create a separate UK SRS reporting duty.
Sources: DBT guidance · section 73A · UK Listing Rules · section 414CB(6).
Read the UK SRS legislation guide.
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The standards
UK SRS S1 sets the foundations. UK SRS S2 adds climate disclosures. Apply them together.
DBT published both on 25 February 2026, endorsing the ISSB baseline with UK changes.
DBT removed their effective-date provisions; rules and legislation set the timing.
Read S1 and S2 together · the TCFD foundations.
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Where it comes from
UK SRS is the UK’s endorsed version of the ISSB’s global baseline, not a domestic invention.
The UK assessed the baseline under the government’s framework for UK Sustainability Reporting Standards, and chose what to change.
The last link in the chain, the FCA’s rules, arrived with PS26/19 on 30 September 2026.
The UK SRS consultation page has each step and what respondents argued.
The international picture
The UK applies its own endorsed versions, so complying with UK SRS is not automatically complying with the ISSB Standards.
The Foundation lists the UK in its register of use by jurisdiction, and its United Kingdom snapshot is the source to cite.
New or amended ISSB standards go through UK endorsement first; the IFRS Navigator indexes the current texts.
Our global sustainability standards page sets the UK beside the rest of the field.
The FCA’s final rules
PS26/19, the explanation, and the draft guidance.
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FCA PS26/19
The FCA published PS26/19 on 30 September 2026.
It finalises CP26/5, but changed course: the final rules adopt comply or explain across all categories of disclosure, S2 included.
The rules sit in UKLR 6.6.6R, apply to accounting periods beginning on or after 1 January 2027, and replace the TCFD-aligned disclosures.
The FCA and UK SRS page sets out each limb; the UK SRS deadline page handles non-calendar year ends.
Draft Technical Note 803.1, in Primary Market Bulletin 66, takes comments until 28 October 2026.
Explaining
For UK SRS S2 an explanation has three parts: the requirements not met, the reasons, and the steps taken or planned.
The FCA’s draft Technical Note 803.1 proposes that it can be short and proportionate, but not omit material information.
Using a relief is not an explanation: the company states the relief and says no more while it runs (PS26/19 ¶3.20).
UK SRS compliance explains the rule in detail.
Draft your UK SRS S2 statement · UKLR 6.6.6R(7A)
An entity that complies in full makes an explicit and unreserved statement of compliance (UK SRS S1 ¶72).
A drafting aid built from UKLR 6.6.6R(7A) and its equivalents, UK SRS S1 ¶¶72–73A and the FCA’s draft TN 803.1, which is open for comment until 28 October 2026. It is not advice and nothing you enter leaves this page.
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How the FCA decided
PS26/19 records that the market did not speak with one voice.
The FCA concluded that full UK SRS disclosure is not yet feasible for some smaller issuers, and declined a size threshold, because climate risk follows business model rather than size.
The consultation’s own record is on the CP26/5 tracker.
CP26/5 to PS26/19
The FCA changed the core approach: S2 moved from proposed mandatory disclosure to comply or explain. Follow the decision, then its application date.
Read the CP26/5 tracker and the FCA and UK SRS guide.
UKLR 6.6.6R(7B)
For S2 a company summarises the requirements it has not met; for S1 it names the risks it identified under S1 ¶3 but did not disclose, and says why.
A company that has identified none says so in a brief statement.
For the first two periods it may instead report climate first and state the relief (PS26/19 ¶3.14).
The price sits in the standard: S1 ¶73A says a company using ¶E3 may not assert compliance with UK SRS S1.
The general standard is taken paragraph by paragraph on UK SRS S1.
Draft your UK SRS S1 statement · UKLR 6.6.6R(7B)
Explaining against part of UK SRS S1 rules out a statement of compliance with S1, under the FCA’s draft guidance.
A drafting aid built from UKLR 6.6.6R(7B) and its equivalents, UK SRS S1 ¶¶3, 72–73A and E3, and the FCA’s draft TN 803.1 (comments to 28 October 2026).
The suggested names are illustrations: UK SRS S1 has no topic list.
Nothing you enter leaves this page.
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Official guidance
There is no single UK SRS guidance document; each body publishes guidance on the part it owns.
Guidance explains a rule; where it and the standard disagree, the standard and the listing rules govern.
The nine preparation steps in Primary Market Bulletin 66 are encouragement, not rules.
Our guides take each question in turn: UK SRS reporting, UK SRS compliance and the readiness assessment.
Scope and dates
Who the rules reach, your first period, and the reliefs.
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Scope
The FCA’s rules follow the listing category, not company size.
The UK SRS thresholds page covers the size tests that do exist.
| Listing category | Under PS26/19 | Plan statement |
|---|---|---|
| UKLR 6 · commercial companies | In · comply or explain | Yes |
| UKLR 14 · international commercial companies | In · comply or explain | No |
| UKLR 15 · depositary receipts | In · comply or explain | No |
| UKLR 16 · non-equity and non-voting shares | In · comply or explain | Yes |
| UKLR 22 · equity shares (transition) | In · comply or explain | Yes |
| UKLR 11, 12, 13, 17, 18 and 19 | Out | — |
| AIM, or not listed at all | Not reached by the listing rules | — |
The who is in scope guide and the scope checker take you through the five categories.
Everyone else has no UK SRS duty, and none is proposed for private companies.
The UK SRS mcr consultation, open until 30 November 2026, asks how UK SRS should sit in the Companies Act.
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Check your position
The test is the listing category, and nothing else.
A small commercial company on the Main Market is in; a large private group is not.
AIM securities are not admitted to the Official List, though an AIM company with more than 500 employees is in the Companies Act regime for climate-related financial disclosures.
No government document proposes a UK SRS threshold or date for private companies.
Choose your actual listing category to see which reporting route to investigate. Size figures are relevant to separate company-law duties.
Nothing you choose here is stored or sent anywhere.
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Thresholds
UK SRS has no size threshold, and the FCA declined to add one.
Four statutory tests from neighbouring regimes get mistaken for one: SECR, ESOS, the Companies Act climate duty and its size limits.
UK SRS thresholds sets out the separate tests and their provisions. Use the full guide when assessing your entity.
No FCA company-size threshold. Follow the issuer’s actual listing category.
Annual energy and carbon disclosures
Energy assessments and their own qualification test
Climate disclosures and company-size classification
These are different routes, not four versions of a UK SRS threshold.
FCA PS26/19 · scope and proportionality
Your first period
The rules apply to periods beginning on or after 1 January 2027, so your year end sets your first period (PS26/19 ¶¶3.12, 3.18).
A calendar-year company reports on 2027 in an annual report due by 30 April 2028, four months after year end under DTR 4.1.3R.
For other year ends, use the UK SRS deadline guide. The dated register of UK SRS events gives the wider timetable.
Calendar-year listed issuer · illustration
Other year ends shift the dates. This is a calendar-year example, not every issuer’s deadline.
PS26/19 ¶¶3.12, 3.18
Transitional reliefs
The standards leave climate-only reporting (¶E3) and the Scope 3 relief (¶C4) untimed, as Annex A records.
For a listed company the FCA set the clock: two years beyond climate, one year for Scope 3 (¶3.14).
When a relief expires nothing becomes mandatory; the disclosure joins the rest on comply or explain (¶¶3.23, 3.24).
Using one has a price: S1 ¶73A bars a claim of compliance with UK SRS S1.
Read the FCA and UK SRS guide for conditions and statements.
Relief window · annual reporting periods
Once relief ends, the relevant disclosure is on comply or explain.
For in-scope listed issuers. Wider S1 relief concerns sustainability matters beyond climate.
PS26/19 ¶¶3.14, 3.16, 3.23–3.24
The record
Each date carries its instrument and a status: final, voluntary or consultation.
What the standards contain
The content areas, the materiality test and the UK changes.
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Contents
Every UK SRS disclosure answers to four content areas, and UK SRS reporting goes through them disclosure by disclosure.
The frame is the TCFD’s 2017 Final Report; the verb changes from recommend to require.
S2 adds gross Scope 1, 2 and 3 emissions on the GHG Protocol Corporate Standard, scenario analysis, and any transition plan.
S1 reaches past climate to every sustainability-related risk that meets its test.
See also: Scope 1, 2 and 3 · Scope 3 Standard · UK SRS Scope 3 reporting · climate transition plans · UK SRS transition plans · carbon accounting UK SRS · ESG data management · ESG governance · ESG pillars
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Materiality
The test is financial: could the risk or opportunity affect cash flows, access to finance or cost of capital?
S1 sets no numerical materiality threshold. The judgement concerns information useful to investors, lenders and creditors.
Compare CSRD vs UK SRS · double materiality · ESG reporting requirements in the UK.
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The paragraph map
Find the provision behind a claim. Start with the foundations, then the disclosure and its application guidance.
Find a paragraph
33 of 33 entries
| Standard | Paragraphs | Section | What it settles |
|---|---|---|---|
| UK SRS S1 | 1–4 | Objective | Disclose sustainability-related risks and opportunities useful to primary users; ¶3 sets the test — effects on cash flows, access to finance or cost of capital over the short, medium or long term. |
| UK SRS S1 | 5–9 | Scope | What the standard applies to and how it relates to the entity’s financial statements. |
| UK SRS S1 | 10 | Conceptual foundations | Introduces the foundations that follow; UKLR 6.6.6A G points climate reporters to ¶¶10–24. |
| UK SRS S1 | 11–16 | Fair presentation | A complete, neutral and accurate depiction, with additional information where needed. |
| UK SRS S1 | 17–19 | Materiality | ¶18 defines material by influence on primary users’ decisions; ¶B19 says no threshold is specified. |
| UK SRS S1 | 20 | Reporting entity | The same reporting entity as the related financial statements. |
| UK SRS S1 | 21–24 | Connected information | Connections within and across reports (¶21), the financial statements identified (¶22), consistent data and assumptions (¶23), the same presentation currency (¶24). |
| UK SRS S1 | 25 | Core content | The four content areas: governance, strategy, risk management, and metrics and targets. |
| UK SRS S1 | 26–27 | Governance | The body or individual responsible, terms of reference, skills, how and how often informed, trade-offs, oversight of targets, remuneration links, and management’s role. |
| UK SRS S1 | 28–42 | Strategy | ¶29 divides it into risks and opportunities (¶¶30–31), business model and value chain (¶32), strategy and decisions (¶33), financial effects (¶¶34–40) and resilience (¶¶41–42). |
| UK SRS S1 | 43–44 | Risk management | How risks are identified, assessed, prioritised and monitored, and how that sits in overall risk management. |
| UK SRS S1 | 45–53 | Metrics and targets | Metrics required by a standard and the entity’s own; targets, their basis and progress; ¶52 keeps metrics consistent over time. |
| UK SRS S1 | 54–59 | Sources of guidance | Where to look beyond the standards — ¶55(a) and ¶58(a) say an entity “may” consider the SASB Standards. |
| UK SRS S1 | 60–63 | Location of disclosures | Part of general purpose financial reports (¶60); may sit beside regulatory information if clearly identifiable (¶62); cross-reference allowed (¶63, ¶¶B45–B47). |
| UK SRS S1 | 64–69 | Timing of reporting | At the same time as, and for the same period as, the related financial statements (¶64). |
| UK SRS S1 | 70–71 | Comparative information | Comparatives for the preceding period for all amounts (¶70). |
| UK SRS S1 | 72–73, 73A, 73B | Statement of compliance | When compliance may be asserted; ¶73A limits it after the climate-only relief; ¶73B subjects the standard to UK law. |
| UK SRS S1 | 74–76 | Judgements | The judgements with the most significant effect on the disclosures. |
| UK SRS S1 | 77–82 | Measurement uncertainty | The amounts subject to high uncertainty, the sources of it, and the assumptions made. |
| UK SRS S1 | 83–86 | Errors | Correcting material prior-period errors. |
| UK SRS S1 | Appendices A–E | Defined terms to application and transition | Each appendix has the same authority as the body; Appendix E runs ¶¶E1–E5 — no comparatives in year one (¶E1), S1 and S2 together (¶E2), climate-only relief (¶E3). |
| UK SRS S2 | 1–2 | Objective | Climate-related risks and opportunities useful to primary users. |
| UK SRS S2 | 3–4 | Scope | Physical and transition risks, and climate-related opportunities. |
| UK SRS S2 | 5–7 | Governance | The climate twin of S1 ¶27; ¶7 allows integrated governance disclosures to avoid duplication. |
| UK SRS S2 | 8–23 | Strategy | Each climate risk and opportunity and its time horizon; where they are concentrated in the business model and value chain (¶13(b)); responses and any transition plan the entity has (¶14(a)(iv)); financial effects as a single amount or a range (¶17), with the cases where numbers may be omitted (¶¶19–21); ¶12 and ¶23 say an entity “may” consider the industry-based guidance. |
| UK SRS S2 | 22 | Climate resilience | Resilience assessed using climate-related scenario analysis, by an approach commensurate with the entity’s circumstances. |
| UK SRS S2 | 24–26 | Risk management | Processes to identify, assess and monitor climate risks, including whether scenario analysis informs them (¶25(a)(ii)). |
| UK SRS S2 | 27–32 | Metrics | Scope 1, 2 and 3 emissions (¶29(a)); location-based Scope 2 (¶29(a)(v)); cross-industry metrics; industry metrics “may” be considered (¶32). |
| UK SRS S2 | 33–37 | Targets | Objective, third-party validation, progress; for GHG targets the gases, scopes, gross or net, and planned use of carbon credits (¶36); ¶37 keeps “shall”. |
| UK SRS S2 | B1–B18 | Scenario analysis guidance | An approach commensurate with circumstances (¶B2); quantitative for a highly exposed, resourced entity (¶B17); resilience assessed annually (¶B18). |
| UK SRS S2 | B29–B57 | Greenhouse gas measurement | No emission factors prescribed (¶B29); location-based Scope 2 (¶B30); Scope 3 measurement framework, primary data preferred all else equal (¶¶B38–B57). |
| UK SRS S2 | B59–B63A | Financed emissions | Financed emissions for asset managers, banks and insurers; ¶B59A, a UK addition, requires an explanation if they cannot be estimated for the same period. |
| UK SRS S2 | C1–C6 | Application and transition | No comparatives in year one (¶C1); method relief for the first period (¶C3); Scope 3 relief (¶C4); UK-law override (¶C6). |
Sources: the contents pages and text of UK SRS S1 and UK SRS S2 (DBT, 25 February 2026).
S1’s front matter says it is set out in paragraphs 1–86, but it also carries ¶¶73A and 73B.
S2 is set out in ¶¶1–37 and Appendices A–C, all of equal authority.
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The climate standard
S2 applies the four content areas to climate, in paragraphs 1 to 37 and Appendices A to C, all with equal authority.
Most of its length is in the application guidance behind metrics and targets.
Annex A of the government response lists the differences from IFRS S2. Requirements absent from that map have no UK-versus-IFRS difference.
Our UK SRS S2 page takes the standard in full, and IFRS S2 is the original.
UK vs IFRS
Annex A lists the differences from the IFRS Standards, and by its own terms it is exhaustive.
Almost every UK change relaxes or removes something; the exception is S2 ¶B59A, a financed-emissions explanation duty.
S1 ¶¶73B and E5 and S2 ¶C6 let the FCA time the reliefs without editing the standards.
UK SRS amendments takes each difference row by row.
Selected differences · Annex A
Effective-date and late-publication provisions change. Climate-first relief affects the compliance statement.
Industry guidance becomes optional in specified paragraphs. B59A adds an explanation when financed emissions cannot use the accounts’ period.
A summary of selected changes, not a count or the complete paragraph map.
DBT response · Annex A
SASB
Under UK SRS the SASB Standards are optional: “shall” became “may”, except at S2 ¶37 and ¶B65(d).
The ISSB took responsibility for them in August 2022, and the industry classification decides which metrics apply.
An entity that wants peer comparison will usually apply them anyway, and should say so; SASB Standards has more.
Draft to final
A great deal written about UK SRS describes the June 2025 exposure drafts, not the standards published on 25 February 2026.
One proposal was withdrawn, one replaced by something wider, and provisions that had not been consulted on were added.
So “six UK amendments” describes a consultation, not the standards.
The ISSB’s December 2025 amendments to IFRS S2 are already inside UK SRS S2.
Climate in detail
Scopes, scenarios, transition plans and judgement.
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Emissions
UK SRS S2 requires all three, measured on the GHG Protocol Corporate Standard unless a regulator or exchange requires another method.
Sources the entity owns or controls: fuel burned on site and in its own vehicles.
S2 requires the location-based figure (¶B30).
Estimation is expected (¶B38), in fifteen categories under the Scope 3 calculation guidance.
15 Scope 3 categories
The standard prescribes no emission factors (¶B29); UK preparers usually use the government conversion factors, reissued each year.
The 2026 set and its methodology report are the current ones.
Scope 3 also carries the one-year FCA relief; UK SRS Scope 3 reporting covers the fifteen categories.
Scope 2
UK SRS S2 requires location-based Scope 2 emissions and does not require dual reporting.
The confusion comes from the GHG Protocol Scope 2 Guidance, a different document with a different status.
The three scopes are set out on Scope 1, 2 and 3 emissions.
One activity · different accounting lenses
Grid-average emissions for the electricity consumed.
Required by UK SRS S2 ¶29(a)(v).Emissions reflecting qualifying contractual instruments.
Additional market-based information is permitted; read ¶B31.UK SRS S2 ¶29(a)(v), ¶¶B30–B31
The GHG Protocol’s dual-reporting guidance is a separate requirement set.
GHG Protocol Scope 2 Guidance
Scenario analysis
UK SRS S2 requires climate resilience to be assessed with scenario analysis, where the TCFD only recommended it.
The standard names no scenario set, so the choice and its justification are themselves disclosures.
Common sets are the NGFS scenarios with their data, the IEA’s Net Zero Emissions by 2050 in World Energy Outlook 2025, and the IPCC’s WG I and WG III reports.
The NGFS has warned that the paper behind its Phase V physical-risk estimates has been retracted.
A scenario cited without its edition is a scenario nobody can check.
Explore futures · assess resilience
Compare physical and transition risks.
Match analysis to exposure, skills and resources.
Explain resilience, assumptions and implications.
Conceptual pathways, not forecasts, probabilities or measured risk scores. Name the scenario source and edition.
UK SRS S2 ¶22, ¶¶B2, B17–B18
Two kinds of risk
Physical risk is the effect of the climate itself; transition risk is the effect of the response to it.
A fast, orderly transition raises transition risk and lowers long-run physical risk; a late one does the reverse.
A disclosure that reports only one half has not done the assessment.
S2 asks for both through strategy, and for how scenario analysis informs risk identification (¶25(a)(ii)).
Transition plans
No UK entity is under a legal duty to have a climate transition plan, and neither UK SRS nor the FCA’s rules create one.
The FCA says it is not requiring listed companies to produce transition plans; it asks only whether one is published.
The reference framework is the TPT Disclosure Framework, now archived among the TPT resources.
The IFRS Foundation’s guidance of 23 June 2025 adds nothing to IFRS S2’s requirements.
The government consulted on requirements and routes and has published no response; UK SRS transition plans goes further.
Judgement
Much of a sustainability disclosure is estimated, and the standard treats that as normal rather than as failure.
Judgements and measurement uncertainty are covered by S1 ¶¶74 to 82; an unlabelled estimate is the defect.
Scope 3 often relies on estimates. Make the method and its uncertainty clear.
Activity records, source data and the reporting boundary.
The method, assumptions and significant judgements used.
Explain measurement uncertainty and information needed to understand the estimate.
Metrics and targets
The fourth content area is where the disclosure stops being narrative, and the one an outside reader checks first.
A target without its basis, scope and progress is not a disclosure, and a net target also needs its gross target.
S1 ¶¶45 to 53 set the general requirement and S2 ¶¶33 to 36 fill it in for climate.
Objective, base period and milestones.
Gases and scopes; gross or net. A net target also needs the gross target.
Whether a third party validated it; distinguish validation from achieved performance.
Performance against the target, and the trend.
Reporting in practice
Sign-off, assurance, data, a first report, and how reports fail.
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Governance
Governance asks two questions: what the board does about these risks, and what management does.
The answer has to name bodies and people, and a claim with no minute behind it is the one a reviewer finds first.
The FCA disclosures sit in the annual financial report, with cross-reference permitted under its rules. The named persons give the applicable responsibility statements.
For strategic-report disclosures: FRC guidance · section 463. Read UK SRS reporting for placement and statements.
ESG governance covers the board side more widely.
Evidence → review → responsibility
Prepare evidence, operate controls and explain methods.
Oversee risks, opportunities and targets. Describe actual responsibilities and how information reaches them.
Publish the disclosures and applicable responsibility statements, identifying the responsible persons and functions.
Illustrative relationships; UK SRS does not prescribe this organisation chart or a mandatory committee.
UK SRS S1 ¶¶26–27 · oversight and management
Connectivity
UK SRS S1 ¶¶20 to 24 put the disclosures in the same package as the accounts: same entity, consistent data and assumptions, same currency.
¶64 makes it the same day and the same period, and UKLR 6.6.6R(8)(c) asks the company to say where they are.
Year one is lighter: no comparatives (S1 ¶E1, S2 ¶C1), but IFRS S1’s late-publication relief (¶E4) was not carried across, so connectivity bites from the first report.
This is where the sustainability team stops owning the timetable.
Calendar-year illustration
A later standalone sustainability report does not replace the required same-time disclosures. Other year ends shift the dates.
UK SRS S1 ¶¶20–24, 64
Assurance
Neither UK SRS nor the FCA’s rules require a report to be assured; PS26/19 requires a transparency statement, and the FCA keeps the case for mandatory assurance under review.
The government’s consultation says it has no plans at this stage to require assurance over UK SRS reporting.
The FRC issued ISSA (UK) 5000 for voluntary use, for periods beginning on or after 15 December 2026.
The government’s voluntary oversight regime for providers is not yet operating; the earlier consultation proposed its design.
Our sustainability assurance guide explains what an engagement covers.
The FCA asks for transparency. It does not require obtaining assurance.
Who carried out the engagement.
Which disclosures, and the assurance level.
Which assurance standards were used.
Where readers can find the assurance report.
Disclose the applicable details when assurance has been obtained.
UKLR 6.6.6R(8)(d) · PS26/19
Data
Almost every difficulty in a first report is a data problem wearing a disclosure problem’s clothes.
The activity data is mostly in the business already; the work is making it repeatable, because an assurer asks how you would produce the number again.
Factors usually come from the annual conversion factors, and the environmental reporting guidelines govern the SECR figure beside it.
ESG data management and carbon reporting software deal with the tooling decision.
Sequence
The order matters more than the pace; this is an order of work, not a legal timetable.
Choose the reliefs before you write, because they change what the compliance statement may say.
Before drafting, check the evidence, the gaps and who will resolve them. The full assessment sits on its dedicated page.
Can the disclosure be traced to records and an owner?
Which requirements, assumptions or inputs need work?
Assign the work and distinguish a relief from an explanation.
Open the full UK SRS readiness assessment →
Preparation overview, not a compliance verdict or a statutory sequence.
The fuller version is the UK SRS readiness assessment.
Failure modes
The recurring failures are not about ambition, and all of them are visible from outside the company.
Under the FCA’s draft guidance, a company that explains against any requirement cannot make an unreserved statement of compliance with that standard.
The FRC reviews annual reports against its Guidance on the Strategic Report, which is where these defects will be read.
The differences behind most of the confusion are catalogued on UK SRS amendments.
Voluntary use
Because the standards carry no effective date, an entity may apply them to a period of its choosing, with the reliefs as the standards write them.
Nobody outside the five listing categories has to; those who do usually have investors, lenders or a parent already asking the questions.
A listed company can also report early: for a period beginning before 1 January 2027 it may keep the TCFD-aligned rules or adopt UK SRS, and keep the reliefs (PS26/19 ¶3.19).
What a first report involves is set out on UK SRS compliance.
DBT consultation response
For voluntary reporters, UK SRS is available to use immediately.
Source: consultation response ¶1.21 · UK SRS S1 ¶E1
Migration
A company already reporting to TCFD has the structure of an S2 disclosure, and not yet its depth.
The TCFD was disbanded in 2023, and PS26/19 ¶1.10 says the new rules replace the TCFD-aligned disclosures.
Four things deepen, and one gets easier: the new explain limb asks for the steps a company is taking, but not a timeframe.
The FCA’s review of TCFD-aligned disclosures still records where explanations fell short.
The framework is on TCFD, and the existing Companies Act duty on climate-related financial disclosures.
Four pillars and eleven recommended disclosures, on comply or explain.
The same four content areas, on comply or explain, with more depth.
Sources: TCFD Final Report (2017) · UK SRS S2 · PS26/19 ¶1.10
Other regimes
SECR, ESOS, TCFD and the EU beside UK SRS.
Module 01 / 04
Module 02 / 04
Module 03 / 04
Module 04 / 04
Other regimes
UK SRS adds to the UK’s reporting rules; it replaces none of the statutory ones.
SECR still applies under SI 2018/1155, and the 2026 review recommended retaining it; modernising corporate reporting would move where it sits, as a proposal, not law.
SECR and S2 draw on the same data under different boundaries: the environmental reporting guidelines govern the SECR figure, and SECR requirements takes the regime paragraph by paragraph.
energy savings opportunity scheme runs on its own clock, per the Environment Agency’s Phase 4 guidance.
The IFRS Foundation took over monitoring when the TCFD disbanded; the Companies Act duty in section 414CB continues.
See also: SECR reporting guide · ESOS compliance guidance · ESOS online reporting · TCFD and UK SRS · moving from TCFD · UK ESG reporting requirements
The landscape
A UK company’s reporting is a stack of separate regimes, each with its own trigger and timetable.
Three of the eight are proposals or consultations, and reading them as rules is the commonest mistake here.
A private company has SECR, ESOS and, above 500 employees and £500 million of turnover, the Companies Act climate duty, and no UK SRS duty.
The government’s climate-related financial disclosures guidance is the place to check that duty, which the FRC’s FAQ confirms UK SRS S2 can meet.
The UK sustainability regulation timeline dates every regime, and UK SRS mcr takes the consultation on its own.
Groups in the EU
A UK group with EU operations may fall under the CSRD as well as UK SRS.
The two rest on different tests: the ESRS add the entity’s impacts, which is double materiality.
The Commission adopted revised ESRS on 3 July 2026; our UK SRS and ESRS comparison and CSRD and UK SRS pages map where one report can serve both.
The climate data can usually be shared and the materiality assessment cannot, so document the two separately.
One question: what could affect the entity (S1 ¶3).
Two questions: effects on the entity, and its impacts on people and the environment.
Sources: UK SRS S1 · Directive (EU) 2022/2464 · European Commission · revised ESRS delegated act
The reference shelf
A true-or-false check, a glossary, the sources and the questions.
Module 01 / 04
Module 02 / 04
Module 03 / 04
Module 04 / 04
Test yourself
Most statements about UK SRS that are wrong were right about a proposal once.
Every answer names the provision it rests on, and the CP26/5 tracker sets out the distinctions claim by claim.
True or false?
14 statements.
Answer each to see the provision.
CP26/5 proposed that, and PS26/19 dropped it: the final rules adopt comply or explain across all of UK SRS, S2 included (PS26/19 ¶¶1.2, 1.7).
515 was a CP26/5 route population that no longer exists. PS26/19 gives no total; CP26/5 estimated around 600 companies would be affected, and that is the consultation’s estimate.
That was CP26/5. PS26/19 ¶1.7(2) puts UKLR 14 and 15 on the same comply-or-explain basis, though they may rely on home-jurisdiction reporting that meets UK SRS outcomes.
It states that it is using the relief; PS26/19 ¶3.20 says no further explanation is needed during the relief period.
UK SRS S2 ¶C4 has no time limit; Annex A records that it was removed. For listed companies the one-year limit comes from the FCA’s rules (PS26/19 ¶3.14).
UK SRS S2 ¶B30 requires location-based and asks about contractual instruments only where they exist. Dual reporting is a GHG Protocol Scope 2 Guidance requirement.
UKLR 6.6.6R(8)(d) asks whether third-party assurance was obtained and, if so, from whom, over what, at what level and to which standards. Obtaining it is not required.
The FCA says it is not requiring transition plans. UKLR 6, 16 and 22 companies state whether one is published and where, or why not (UKLR 6.6.6R(8)(e)).
SECR continues under SI 2018/1155. The Modernising Corporate Reporting consultation proposes moving where SECR sits in the annual report, not removing it.
Six was the count of proposals in the June 2025 consultation. The final differences are mapped in Annex A, which gives no count.
UK SRS S1 ¶73A: an entity using ¶E3 may not assert compliance with UK SRS S1 and must disclose the relief. It may still assert compliance with UK SRS S2.
UK SRS S2 ¶B59A adds an explanation duty where financed emissions cannot be estimated for the same period as the accounts. Every other UK change relaxes or removes something.
AIM securities are not admitted to the Official List, so the UK Listing Rules categories PS26/19 amends do not cover them. An AIM company with more than 500 employees is in the Companies Act climate-disclosure regime instead.
The standards have no effective date; the provisions were removed before publication. 1 January 2027 is when the FCA’s rules come into force for periods beginning on or after that date.
Glossary
Every term in use on this page, defined against the provision it comes from.
88 shown
Sources: UK SRS S1 · UK SRS S2 · DBT consultation response · FCA PS26/19 · GHG Protocol
Method
Everything on this page can be checked against five documents, and the order matters.
Most disagreements dissolve on contact with the actual paragraph.
Much of what circulates was written against CP26/5, which is why “mandatory S2”, “515 companies” and “signposting for secondary listings” keep appearing after the final rules dropped all three.
Where a claim here rests on a document, the document is linked beside it; where a consultancy explainer was the only source, we went to what it cited.
The library
These are the instruments behind this site: read them yourself before relying on anyone’s summary, ours included.
If you want outside help
Each guide below says what that kind of consultant delivers, which UK rule it serves, and what to check before you hire.
The A–Z of sustainability consulting firms lists firms from their own descriptions and ranks none.
Key facts
UK SRS is a voluntary standard that the FCA has made comply or explain for listed companies in five categories, from 1 January 2027.
Sources: DBT · FCA PS26/19 · CP26/5 Annex 2 ¶43 · Annex A · UK SRS S2
A reading and preparation sequence
Dates, with their status
Continue your research
Frequently asked
121 questions, each answered against the primary sources.
No. UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 for voluntary use.
The FCA's final rules (PS26/19, 30 September 2026) require listed companies in five listing categories to report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
Comply or explain is not mandatory reporting: a company may explain instead of disclosing.
Every other UK entity may use the standards voluntarily.
Two standards for disclosing sustainability-related financial information: UK SRS S1, the general requirements, and UK SRS S2, climate-related disclosures.
They are the UK-endorsed versions of the ISSB’s IFRS S1 and IFRS S2, issued by the Secretary of State for Business and Trade and published on 25 February 2026.
SRS stands for Sustainability Reporting Standards.
Sustainability Reporting Standards.
In the UK context it means UK SRS S1 and UK SRS S2.
The abbreviation is also used in other jurisdictions for their own versions of the ISSB Standards, which is why this site always writes UK SRS.
UK SRS itself is a pair of standards, not a regulation: UK SRS S1 and S2, published by the Department for Business and Trade on 25 February 2026 for voluntary use.
The binding text for listed companies is the FCA’s rule instrument, the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, made on 24 September 2026 and in force on 1 January 2027, which requires comply-or-explain reporting against UK SRS for listed companies in UKLR 6, 14, 15, 16 and 22.
Other UK entities have no UK SRS rule to follow.
The standards are published by the Department for Business and Trade for voluntary use, and the obligation for listed companies comes from the FCA’s listing rules under PS26/19, which are the legal instrument for them.
The Modernising Corporate Reporting consultation, which closes on 30 November 2026, considers how UK SRS should be reflected in the Companies Act; that is a consultation, not law.
Not in the sense usually meant.
From accounting periods beginning on or after 1 January 2027, listed companies in UKLR 6, 14, 15, 16 and 22 must report against UK SRS or explain what they have not disclosed and why.
CP26/5 had proposed making UK SRS S2 mandatory for them; the final rules did not.
That listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS S1 and S2 on a comply-or-explain basis, for accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
The rules replace the existing TCFD-aligned listing-rule disclosures.
They sit in the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, made on 24 September 2026 and in force on 1 January 2027.
Yes.
The FCA Board made the instrument on 24 September 2026 and published it in PS26/19 on 30 September 2026.
It comes into force on 1 January 2027 and applies to accounting periods beginning on or after that date.
Nobody yet.
The FCA rules are made but not in force until 1 January 2027, and they apply from the first accounting period beginning on or after that date.
Until then UK SRS is used only voluntarily, and outside the five listing categories it stays voluntary.
Some of it is.
SECR requires energy and carbon reporting from quoted companies and large unquoted companies and LLPs; the Companies Act requires climate-related financial disclosures from large companies under section 414CB; ESOS requires energy assessments from large undertakings.
UK SRS reporting is comply or explain for listed companies in five categories from 2027, and voluntary for everyone else.
For listed companies in UKLR 6, 14, 15, 16 and 22: UK SRS on a comply-or-explain basis for periods beginning on or after 1 January 2027, with statements on assurance and, for UKLR 6, 16 and 22, transition plans.
Alongside that, whatever applies already: SECR for quoted companies and large unquoted companies and LLPs, the Companies Act climate-related financial disclosure duty for the largest companies and LLPs, and ESOS for large undertakings.
For UK SRS reporting, UK SRS S1 and S2.
For SECR, the regulations themselves and the government’s environmental reporting guidelines, usually with the GHG Protocol and the government conversion factors.
The Companies Act climate duty sets its own eight disclosures, which UK SRS S2 can satisfy as a national reporting framework.
UK groups reporting in the EU may also meet the ESRS.
For some companies.
SECR requires quoted companies to report global Scope 1 and 2 emissions, and large unquoted companies and LLPs to report UK energy use and associated emissions, in their annual reports under SI 2018/1155.
UK SRS S2 asks for Scope 1, 2 and 3, but only listed companies in five categories are asked to report against it, on a comply-or-explain basis, from 2027.
A company either makes the UK SRS disclosures or states what it has not disclosed, why, and what it is doing about it.
For UK SRS S2 the statement summarises the requirements not met; for UK SRS S1 it names the risks and opportunities identified but not disclosed.
The FCA's draft Technical Note 803.1, out for comment until 28 October 2026, proposes that an explanation can be short and proportionate and need not give a timeframe.
PS26/19 records that full UK SRS disclosure is not yet feasible for some smaller issuers and that a mandatory approach could be disproportionately burdensome for them.
Views differed: many buy-side and professional-service respondents supported mandatory climate disclosure, while listed companies were more mixed.
The FCA also declined a size threshold, saying climate exposure depends on business model and sector, not size.
The standards are not law in themselves: they carry no effective date and bind nobody by their own terms.
The obligation to use them comes from the FCA's listing rules, made under its powers in the Financial Services and Markets Act 2000, and applies only to listed companies in five categories.
The government has said it will consider how UK SRS should be reflected in the Companies Act 2006, which is a statement of intent, not a proposal.
Through a separate instrument, never through the standards themselves.
UK SRS S1 ¶¶73B and E5 and UK SRS S2 ¶C6 make them subject to the Companies Act, FCA rules or another UK regulator.
The FCA has used that route: its listing rules, made on 24 September 2026, apply UK SRS to listed companies in five categories on a comply-or-explain basis from 1 January 2027.
The Companies Act route has not been used.
The rules themselves are made: the instrument was made on 24 September 2026 and comes into force on 1 January 2027.
What is still open is guidance — draft Technical Note 803.1, with comments due by 28 October 2026 — and the FCA’s supervisory approach, which it plans to update in the second half of 2027.
Neither changes the dates in the rules.
A government decision to apply UK SRS through the Companies Act.
The Modernising Corporate Reporting consultation, open until 30 November 2026, says only that the government will consider how UK SRS should be reflected in the Act; any duty for unlisted companies would need that route.
Until then, UK SRS is comply or explain for five listing categories and voluntary for everyone else.
The standards were published on 25 February 2026 and could be used voluntarily from that day.
The FCA’s rules applying them to listed companies come into force on 1 January 2027 and apply to accounting periods beginning on or after that date, so the first reports under the rules appear in 2028.
UK SRS S1, the general requirements for sustainability-related financial information, and UK SRS S2, climate-related disclosures, both published on 25 February 2026.
They are the UK-endorsed versions of the ISSB's IFRS S1 and IFRS S2.
In the same year the FCA finalised rules applying them to listed companies from 2027, on a comply-or-explain basis.
Two are open.
The FCA is consulting on draft Technical Note 803.1, on how to comply or explain, in Primary Market Bulletin 66, with comments due by 28 October 2026.
The government's Modernising Corporate Reporting consultation, open until 30 November 2026, says the government will consider how UK SRS should be reflected in the Companies Act.
The DBT consultation on the standards themselves closed on 17 September 2025.
They refer to the same endorsement project.
The published standards are titled UK Sustainability Reporting Standards, abbreviated UK SRS.
Older government material and the advisory committee's name use the word disclosure, which is where UK SDS comes from.
Stating a proposal as a rule.
Before 30 September 2026 that meant describing CP26/5 as settled; since then it means repeating what CP26/5 proposed — mandatory UK SRS S2, 515 companies, a statement-only route for secondary listings — after the final rules changed all three.
Under the FCA's rules, companies listed in five categories: UKLR 6 (commercial companies), UKLR 14 (international commercial companies with a secondary listing), UKLR 15 (depositary receipts), UKLR 16 (non-equity and non-voting equity shares) and UKLR 22 (the transition category).
Closed-ended and open-ended funds, shell companies, debt, securitised derivatives and warrants are excluded.
Anyone else may use UK SRS voluntarily.
The FCA's Policy Statement gives no total.
Its consultation, CP26/5, estimated that around 600 listed companies would be affected; that is the consultation's estimate, not a count in the final rules.
PS26/19 does say that the 89 issuers with a secondary listing or depositary receipts are now subject to the same requirements as domestic listed issuers.
UKLR 6, 14, 15, 16 and 22 (PS26/19 ¶3.6).
UKLR 11 and 12 funds, UKLR 13 shell companies and UKLR 17, 18 and 19 debt, securitised derivatives and miscellaneous securities are outside (¶3.7).
Not as a requirement.
No government document proposes a UK SRS threshold or date for private or unlisted companies.
The Modernising Corporate Reporting consultation, open until 30 November 2026, says the government will consider how UK SRS should be reflected in the Companies Act 2006; it contains no proposal or date.
Large private companies may already have Companies Act climate-disclosure and SECR duties.
There is no size test at all.
The FCA's rules turn on the listing category, and the FCA declined respondents' calls for a size threshold.
A small listed company in UKLR 6 is in scope; a large unlisted one is not.
Proportionality comes through comply or explain and through the standards themselves, which let a company use an approach commensurate with its circumstances in places such as scenario analysis.
Only if they are listed in one of the five categories, and then on comply-or-explain.
PS26/19 records the FCA's view that a mandatory approach could be disproportionately burdensome for smaller issuers, which is part of why it chose comply or explain.
An unlisted SME has no UK SRS duty and none is proposed.
Not through the FCA's UK SRS rules.
AIM securities are not admitted to the Official List, so the UK Listing Rules categories PS26/19 amends do not cover them.
An AIM company with more than 500 employees is, however, in the Companies Act climate-related financial disclosure regime.
The standards carry no territorial provision of their own because they are not law.
The FCA's rules draw scope by listing category, not by where a company is based or incorporated, so a company listed in one of the five categories is caught wherever it sits in the UK.
A Jersey- or Guernsey-incorporated company with a UK listing in those categories is caught in the same way.
Yes, on comply or explain.
CP26/5 proposed only a signposting statement for UKLR 14 and 15; PS26/19 ¶1.7(2) reversed that.
Where home-jurisdiction reporting aligns with UK SRS outcomes the company may already broadly comply and may rely on it, explaining where UK SRS is not met in full.
The transition-plan statement does not apply to them.
The standards have no effective date: the provisions were removed before publication so that legislation or the FCA could set timing.
The FCA's rules come into force on 1 January 2027 and apply to accounting periods beginning on or after that date, so first reports appear in 2028.
For listed companies in scope, from the first accounting period beginning on or after 1 January 2027.
A calendar-year company reports on 2027 in its 2028 annual report; a company with a period beginning on 1 April 2027 reports on the year to 31 March 2028.
Voluntary users may apply the standards now.
In 2028.
The rules apply to accounting periods beginning on or after 1 January 2027, so a company with a calendar year end reports on its 2027 year in its 2028 annual report.
A company whose period began before 1 January 2027 may keep using the TCFD-aligned rules for that period, or adopt UK SRS early and keep the same transitional reliefs.
There is no single deadline.
The rules apply to periods beginning on or after 1 January 2027, and the disclosures sit in the annual financial report, which the Disclosure and Transparency Rules require within four months of the year end (DTR 4.1.3R).
For a calendar 2027 year that points to 30 April 2028.
The standards carry three: climate-only reporting under UK SRS S1 ¶E3, Scope 3 relief under UK SRS S2 ¶C4, and a GHG measurement-method relief under ¶C3.
The standards left the first two untimed.
For listed companies the FCA has set them: two years for the climate-first relief and one year for Scope 3, from initial application (PS26/19 ¶3.14), with the method relief for one year if that method was used immediately before (¶3.16).
No. A company relying on a transitional relief states that it is doing so, and PS26/19 ¶3.20 says no further explanation is needed during the relief period.
Under the standards themselves, UK SRS S1 ¶73A requires the use of a relief to be disclosed alongside the statement of compliance.
Nothing becomes mandatory.
For periods beginning in 2028 the Scope 3 relief has expired and Scope 3 is comply or explain like everything else (PS26/19 ¶3.23).
From periods beginning on or after 1 January 2029 both reliefs have expired and every UK SRS disclosure is comply or explain (¶3.24).
The government removed the effective-date provisions so that timing could be set by legislation or FCA rules, and to avoid confusion with the introduction of any reporting requirements (consultation response ¶1.21).
DBT told the FCA on 5 January 2026 that it would remove the specific time references about the reliefs for the same reason.
DBT's letter to the FCA of 5 January 2026 said the government would remove specific time references about when the reliefs apply and specify instead that timing would be set out in government regulations, FCA rules or by another relevant authority.
PS26/19 is that FCA rule for listed companies.
Yes.
A company whose accounting period begins before 1 January 2027 may keep to the TCFD-aligned rules for that period or voluntarily report under the new UK SRS limbs, and PS26/19 ¶3.19 lets an early adopter use the same transitional reliefs.
CP26/5 had proposed denying early adopters the reliefs.
Yes.
The consultation response says that for voluntary reporters UK SRS is available to use immediately, and because the standards carry no effective date an entity may apply them to a period of its choosing.
A voluntary user takes the reliefs as the standards write them, without the FCA's time limits.
UK SRS S1 sets the general requirements for sustainability-related financial information: the materiality test, the four content areas and how the disclosures connect to the financial statements.
UK SRS S2 applies that structure to climate: greenhouse gas emissions, climate scenario analysis, targets and any transition plan.
UK SRS S1 ¶E2 requires the two to be applied at the same time.
Financial materiality.
UK SRS S1 ¶3 asks for information about sustainability-related risks and opportunities that could reasonably be expected to affect the entity's cash flows, its access to finance or its cost of capital over the short, medium or long term. ¶18 defines material by influence on primary users' decisions, and ¶B19 sets no threshold.
Existing and potential investors, lenders and other creditors.
Materiality is judged by influence on their decisions, which is what makes UK SRS a financial-reporting standard rather than an impact-reporting one.
No. UK SRS S1 ¶B25 says an entity need not disclose information that is not material, even where a standard lists it as a specific or minimum requirement.
Materiality judgements are reassessed at each reporting date (¶B28).
UK SRS S1 covers every sustainability-related risk and opportunity that meets its test, so it is not limited to climate.
Climate is the one topic written out in full, in UK SRS S2.
There are no separate UK SRS topical standards for water, biodiversity or workforce in the way the ESRS provide them.
Its front matter says it is set out in paragraphs 1 to 86, but that sentence was carried over from IFRS S1 unamended: UK SRS S1 also contains ¶¶73A and 73B, which are UK additions.
It has five appendices, A to E, each with the same authority as the body.
UK SRS S1 runs to paragraphs 1 to 86 plus 73A and 73B, with Appendices A to E. UK SRS S2 is set out in paragraphs 1 to 37 and Appendices A to C, all of equal authority.
Both are free on GOV.UK.
Strategy, ¶¶28 to 42. ¶29 divides it into five limbs: the risks and opportunities, the business model and value chain, strategy and decision-making, the effects on financial position, performance and cash flows, and resilience.
Yes.
Each appendix to UK SRS S1 says it is an integral part of the standard with the same authority as the other parts, and UK SRS S2 says all its paragraphs have equal authority.
Appendix E of S1 and Appendix C of S2 hold the application and transition provisions.
A UK addition with no IFRS equivalent.
An entity using the climate-only relief at ¶E3 may not assert compliance with UK SRS S1 and must disclose its use of the relief.
It may still assert compliance with UK SRS S2, provided it discloses the reliefs it used.
UK SRS S1 ¶¶73B and E5 and UK SRS S2 ¶C6 make application of the standards subject to anything set by the Companies Act, the FCA or another UK body able to make reporting requirements.
It is the machinery the FCA used when PS26/19 set the relief periods for listed companies.
The standards are issued by the Secretary of State for Business and Trade and were published on GOV.UK by DBT on 25 February 2026.
Their copyright notice adds that they have not been prepared or endorsed by the ISSB.
The FRC hosted the advisory committee but does not issue the standards, and the FCA applies them through its listing rules.
Only if you have applied the standards and your use of reliefs allows it.
UK SRS S1 ¶¶72 to 73 govern the statement of compliance and ¶73A bars a compliance claim for S1 where the climate-only relief is used.
The FCA's draft TN 803.1 adds that an issuer explaining against a requirement cannot make an explicit and unreserved statement of compliance, and that the listing rules require no separate compliance statement.
For most preparers, S2, because it requires Scope 1, 2 and 3 emissions, scenario analysis and targets.
Under the FCA rules a listed company may also report climate-first for its first two periods, deferring S1 beyond climate.
UK SRS S1 ¶E3 permits climate-only disclosure.
The consequence is at ¶73A: you may not assert compliance with UK SRS S1 and must disclose the relief, though you may still assert compliance with UK SRS S2.
For listed companies the FCA limits this to the first two periods.
Almost.
UK SRS S1 and S2 are the ISSB's IFRS S1 and S2 endorsed for the UK, with UK amendments.
UK SRS S2 is based on IFRS S2 as amended by the ISSB in December 2025.
Annex A of the government's consultation response maps each difference; where a requirement is not in it there is no difference, so compliance with UK SRS is not automatically compliance with the ISSB Standards.
Not automatically.
UK SRS is the UK’s endorsed version of IFRS S1 and S2, and Annex A of the government response maps every difference.
Most UK changes relax or remove something, so a UK SRS report can meet UK SRS without meeting IFRS S1 and S2 in full, for example where it relies on the untimed reliefs or does not consider the SASB Standards.
There is a Framework for developing UK Sustainability Reporting Standards, published by the government, which sets out how the UK assesses and endorses ISSB standards.
It is a process document, not a reporting framework; the reporting requirements are in UK SRS S1 and S2 themselves.
No authoritative count exists.
The government consulted on six proposed amendments in June 2025, but one was withdrawn after the ISSB made the change itself in December 2025, one was replaced by removing the relief time limits, and further provisions (¶¶73A, 73B, B59A and E5) were added.
Annex A maps the final differences and gives no count.
Largely no.
The UK changed "shall" to "may" in UK SRS S1 ¶¶55(a) and 58(a) and UK SRS S2 ¶¶12, 23 and 32, so an entity may refer to and consider them.
UK SRS S2 ¶37 and ¶B65(d) keep "shall".
A UK addition to UK SRS S2 and the one place UK SRS asks for more than IFRS S2.
Where an entity finds it impracticable to estimate financed emissions for the same period as its financial statements, it must say why, describe the measurement approach, inputs and assumptions of any figure it gives, and set out its plan and timeline to catch up.
It is the annex to the government's consultation response mapping every difference between UK SRS and IFRS S1 and S2.
It states that where a requirement is not in its table there is no difference, which makes it the only exhaustive account of what the UK changed.
The Technical Advisory Committee, with the FRC as secretariat, agreed its endorsement recommendations at a public meeting on 5 December 2024 and published them on 18 December 2024.
DBT consulted on exposure drafts from 25 June to 17 September 2025 and published the final standards on 25 February 2026.
209.
The government response records 199 from organisations and 10 from individuals, 170 through an online survey and 39 by email.
68% of those answering the relevant question (125 of 184) agreed with the four amendments the TAC recommended.
The IFRS Foundation's trustees announced it on 3 November 2021 at COP26.
It issued IFRS S1 and IFRS S2 in June 2023, effective internationally for periods beginning on or after 1 January 2024 — a date that never applied to UK SRS.
The IFRS Foundation said in June 2026 that over 40 jurisdictions have decided to use or are taking steps to introduce them.
In February 2026 it said requirements had already come into effect in 19 jurisdictions.
Its figures put the adopting jurisdictions at more than 40% of global market capitalisation.
The UK is listed as a snapshot, not a full profile.
No. A new or amended ISSB standard has to go through the UK endorsement process before it applies here.
The ISSB's December 2025 amendments to IFRS S2 were built into UK SRS S2 from the start because the UK text was issued after them.
UK SRS S2 requires Scope 3 greenhouse gas emissions.
Under the FCA's final rules that requirement, like every other, is comply or explain, and a listed company may use a one-year relief from disclosing Scope 3.
A company using a relief states that it is doing so and needs to give no further explanation during the relief period.
No. UK SRS S2 ¶B30 requires Scope 2 to be disclosed on a location-based approach and asks for information about contractual instruments only where they exist and matter.
The GHG Protocol Scope 2 Guidance asks for dual reporting; UK SRS S2 does not.
The GHG Protocol Corporate Standard, unless a jurisdictional authority or an exchange requires another method.
UK SRS S2 ¶C3 lets an entity keep another method it used immediately before for the first annual period, and the FCA allows the same for one year.
None in particular.
UK SRS S2 ¶B29 prescribes no factors and asks for those that best represent the entity's activity.
UK companies commonly use the government's annual conversion factors for company reporting.
No. UK SRS S2 expects Scope 3 to be measured largely by estimation. ¶¶B38 to B57 set a framework that prioritises direct measurement, value-chain-specific data, timely and relevant data and verified data, and ¶B47 prefers primary data only all else being equal.
Industry-average secondary data is acceptable (¶B49).
Yes.
UK SRS S2 ¶22 requires resilience to be assessed using scenario analysis, by an approach commensurate with the entity's circumstances.
A highly exposed entity with the skills and resources must use a more advanced quantitative approach (¶B17), and the resilience assessment is updated every reporting period even if the analysis follows the planning cycle (¶B18).
UK SRS S2 names none, so the choice and its justification are part of the disclosure.
The NGFS scenarios, currently version 5.0 of November 2024, are the central-bank reference set; the IEA Net Zero Emissions by 2050 Scenario in World Energy Outlook 2025 is the energy-sector reference; the IPCC Sixth Assessment Report is the underlying science.
In practice yes.
Scenario sets are reissued: the IEA's NZE in World Energy Outlook 2025 peaks at around 1.65 °C before returning below 1.5 °C by 2100, which earlier editions did not.
A scenario cited without its edition cannot be checked or repeated.
Physical risk is the effect of the climate itself — acute events such as floods and storms, and chronic shifts such as heat and water stress.
Transition risk is the effect of the response to climate change: policy, technology, markets and reputation.
A scenario that lowers one usually raises the other.
No. UK SRS S2 ¶34(a) asks whether a target and its methodology were validated by a third party, and ¶36 asks for each greenhouse gas target's gases, scopes, whether it is gross or net, and planned use of carbon credits.
A net target must be accompanied by its gross target.
No. UK SRS S2 requires disclosure of the climate-related targets an entity has set and any it is required by law or regulation to meet, with their basis, scope and progress, and information about any transition plan.
What target to set is the entity’s own decision; a company with a net target must also disclose the associated gross target.
No. SECR asks for at least one intensity ratio.
UK SRS S2 asks for cross-industry metrics and the entity's own targets but prescribes no particular ratio.
No. Energy use in kWh is a SECR requirement under SI 2018/1155.
UK SRS S2 asks for greenhouse gas emissions, which is one reason the two reports are not interchangeable even though they share data.
In the annual financial report.
UK SRS S1 ¶60 makes the disclosures part of general purpose financial reports, and the FCA kept the requirement for the disclosures or explanations to be in the annual report, allowing cross-reference where UK SRS S1 permits it (¶¶B45 to B47).
UKLR 6.6.6R(8)(c) requires the company to say where they are.
UK SRS S1 ¶¶20 to 24 and ¶64 require the disclosures to be for the same reporting entity and period as the financial statements, published at the same time, with consistent data and assumptions and the same presentation currency.
In practice it puts sustainability data on the finance team’s timetable and under its controls.
Yes.
UK SRS S1 ¶64 requires them at the same time as, and for the same period as, the related financial statements, and ¶20 for the same reporting entity. ¶24 requires the same presentation currency.
Not under UK SRS.
IFRS S1 ¶E4 allowed that in the first year and it was removed from UK SRS S1, so the disclosures travel with the financial statements from the first report.
UK SRS S1 ¶23 requires data and assumptions to be consistent with the financial statements, to the extent the accounting framework allows.
An inconsistency between a scenario assumption and an impairment assumption becomes visible, and has to be explained.
No. UK SRS S1 ¶E1 and UK SRS S2 ¶C1 relieve the first year, and the FCA's transitional guidance says the same for the first period under its rules.
Comparative non-climate information is needed only in the second period after the climate-only relief stops being used (¶E4(b)).
No. PS26/19 sets no requirement to tag sustainability disclosures digitally.
The existing tagging duty in DTR 4.1.18R applies to IFRS consolidated financial statements.
The government confirmed that UK SRS disclosures placed in the strategic report are covered by the protective provisions of section 463 of the Companies Act 2006.
The protection follows location: disclosures outside the strategic report are not covered unless section 463 is widened.
UK SRS S1 ¶¶83 to 86 deal with correcting prior-period errors, and ¶52 requires metrics to be defined consistently over time, with ¶B52 governing a redefinition.
A change of GHG method in the first year has its own relief at UK SRS S2 ¶C3.
No. The FCA's final rules require a listed company to state whether it obtained third-party assurance and, if it did, the provider, which disclosures were assured and to what level, and which standards were used.
The FCA says it will keep the case for mandatory assurance under review.
ISSA (UK) 5000, issued by the FRC on 12 November 2025, is for voluntary use.
No. The standards say nothing about assurance, and the FCA’s rules ask only whether third-party assurance was obtained and, if so, from whom, over what, at what level and to which standards.
The audit of the financial statements is a separate engagement and gives no assurance opinion on the sustainability disclosures.
The government has said it has no plans at this stage to require assurance over UK SRS reporting.
None is required.
If a company obtains assurance it says whether it was limited or reasonable.
Limited assurance gives a negative-form conclusion; reasonable assurance gives a positive opinion and needs controlled, repeatable evidence.
No. Neither the standards nor the FCA's rules create a certification scheme.
What exists is assurance: an independent practitioner's conclusion, which the FCA asks a listed company to disclose if it has one, and which a practitioner may perform under ISSA (UK) 5000.
No. The FCA says it is not requiring listed companies to produce transition plans.
A UKLR 6, 16 or 22 company states whether it has published a climate transition plan and where, or why not; UKLR 14 and 15 companies make no such statement.
No. UK SRS S2 ¶14(a)(iv) asks for information about any transition plan the entity has.
Whether having one becomes a duty is the subject of a separate DESNZ consultation, which closed on 17 September 2025 with no government response published.
None is required.
The Transition Plan Taskforce's Disclosure Framework of October 2023, now hosted by the IFRS Foundation, sets three principles — Ambition, Action and Accountability — across five elements.
The IFRS Foundation's guidance of 23 June 2025 explains how to disclose transition information under IFRS S2 and adds no requirements.
No. SECR continues under SI 2018/1155 and UK SRS does not replace it.
The Modernising Corporate Reporting consultation proposes removing the directors' report, which would move where SECR sits in the annual report, and DESNZ intends to consult on SECR and ESOS later in 2026; both are proposals, not law.
No. ESOS runs under SI 2014/1643 on its own four-year cycle; the Phase 4 qualification date is 31 December 2026 and notification of compliance is due by 5 December 2027.
UK SRS changes nothing about it.
For listed companies, yes: PS26/19 replaces the TCFD-aligned listing-rule disclosures with UK SRS.
The TCFD itself disbanded in October 2023.
Its four recommendations and eleven recommended disclosures of June 2017 are the frame IFRS S2, and therefore UK SRS S2, is built on.
UK SRS S2 is recognised as a national reporting framework for section 414CB(6), so a company already reporting against it can use it for the Companies Act climate-disclosure duty.
No duty to apply UK SRS has been made under the Act; the government has said only that it will consider how UK SRS should be reflected in it.
The government programme set out in written statement HCWS973 of 21 October 2025, which calls it Modernisation of Corporate Reporting, and consulted on from 7 September to 30 November 2026.
The consultation proposes removing the directors' report, reshaping the strategic report and consulting on a "very large company" category without giving thresholds.
It proposes nothing on UK SRS beyond considering how it should sit in the Companies Act.
Nothing proposes that.
The 2026 post-implementation review recommended keeping SECR with amendments, and the Modernising Corporate Reporting consultation would move where it sits rather than remove it.
UK SRS uses financial materiality; the EU's CSRD and ESRS use double materiality, adding the entity's impacts on people and the environment.
UK SRS reaches listed companies through comply-or-explain listing rules; the CSRD is a directive transposed into member-state law.
The Commission adopted a revised ESRS set on 3 July 2026.
No. UK SRS S1 covers sustainability generally and UK SRS S2 covers climate.
There are no UK SRS standards for water, biodiversity, workforce or governance.
The FRC was the secretariat to the Technical Advisory Committee that recommended endorsement, issues ISSA (UK) 5000 and the Guidance on the Strategic Report, and will monitor UK SRS disclosures by listed companies alongside the FCA. It does not issue UK SRS.
The FCA's Primary Market Bulletin 66 encourages listed companies to understand the requirements, identify financially material sustainability and climate risks and opportunities, review governance, integrate those risks into strategy, assess resilience, develop the data, metrics and targets, set internal controls, build capability, and engage investors. These are the FCA's encouragement, not rules.
Start from the data you already hold for SECR and TCFD reporting, decide early which reliefs you will rely on because they change what you may claim, and put the disclosures on the finance timetable, since they must be published with the accounts.
Where a requirement cannot be met, the rules allow an explanation instead.
The rules are final; only the guidance on explanations is still in draft, with comments due by 28 October 2026 and the FCA aiming to finalise it before 1 January 2027.
The inventory, governance trail and Scope 3 screening a first report needs do not depend on that guidance.
We do not publish prices.
The FCA's own cost-benefit analysis estimates the net present value of its final rules at £174.10m over ten years, and models average incremental costs per large issuer that complies in full at £127,900 one-off and £194,700 a year over TCFD-aligned reporting. Those are the FCA's modelled averages, not prices.
On GOV.UK.
The publication page carries UK SRS S1, UK SRS S2 and the government response with Annex A, free and without registration.
The FCA's PS26/19 page carries the Policy Statement and the made rules.
Yes.
UK SRS S1, UK SRS S2 and the government response with Annex A are published on GOV.UK at no cost and without registration, and the FCA publishes PS26/19 and the made rules free on its website.
There is no single document.
DBT’s guidance page covers the standards’ status; the FCA’s draft Technical Note 803.1, in Primary Market Bulletin 66, covers how to explain; the FRC publishes FAQs and its Guidance on the Strategic Report; and the IFRS Foundation publishes guidance on transition plan disclosures. Each covers the part its publisher owns.
No regulator publishes a timetable, and we do not give one.
The fixed point is the annual financial report, due within four months of the year end under DTR 4.1.3R, because the disclosures must be published with it.
The data for the reporting year has to exist by then, which is why the inventory and governance work usually starts well before the year it covers.
For what the standards require, the standards themselves and Annex A. For what a listed company must do, PS26/19 and the made rule text in its Appendix 1.
For how to explain, draft TN 803.1 — labelled as draft until the FCA finalises it.
Two standards, UK SRS S1 and S2, based on the ISSB's IFRS S1 and S2 with the differences in Annex A, published on 25 February 2026 for voluntary use, and applied by the FCA to listed companies in five categories on a comply-or-explain basis for periods beginning on or after 1 January 2027.
No. UKSRS.ORG.UK is an independent reference.
It states what the standards, the rules and the consultations say, with a link to each source, and it is not legal, accounting or investment advice on your own position.
When a primary source changes.
The last-verified date at the foot of the page and the dateModified in its structured data move together, and only when there is a real edit behind them.
How we work
UKSRS.ORG.UK is an independent reference: it is not a regulator, holds no regulatory status, and certifies or assures nothing.
Every figure, date and status traces to a numbered entry in the fact store this site maintains, and every correction is logged on the amendments trail.
Your data is covered by the privacy policy and the site by the terms of service.
To talk a question through, book a free 15-minute call, or read how the standards came to be in the UK SRS consultation page.
Sister references: sustainabilityreportingstandards.co.uk and its UK SRS timeline, and its guide to ESG reporting requirements in the UK.
Sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
First published 30 September 2026. The final rules: comply or explain across UK SRS for listed companies in UKLR 6, 14, 15, 16 and 22.
The paragraph-level source for the status ledger, scope, reliefs, cost-benefit figures and the made instrument (24 September 2026, in force 1 January 2027).
What the FCA proposes a proportionate explanation should contain. Draft guidance; comments by 28 October 2026.
The guidance consultation and the nine preparation steps the FCA encourages.
Published 30 January 2026, closed 20 March 2026. Proposed mandatory UK SRS S2; estimated around 600 listed companies affected.
Where the new comply-or-explain limbs, UKLR 6.6.6R(7A), (7B) and (8), sit from 1 January 2027.
The annual financial report within four months of year end (DTR 4.1.3R) — the practical deadline for the disclosures.
Published 25 February 2026 for voluntary use.
The materiality test, the content areas, connectivity, the statement of compliance and the reliefs.
Emissions, scenario analysis, targets, transition plans and the Scope 3 relief.
The paragraph map of the UK differences from IFRS S1 and S2. It carries no count, so neither does this page.
“Available for voluntary use, by any entity that chooses to do so.”
The climate-related financial disclosure duty, for which UK SRS S2 is a national reporting framework under s 414CB(6).
The directors’ liability provisions that cover UK SRS disclosure placed in the strategic report.
SECR, which UK SRS does not replace.
Phase 4: qualification date 31 December 2026, notification of compliance by 5 December 2027.
Open 7 September to 30 November 2026; considers how UK SRS should be reflected in the Companies Act.
Issued 12 November 2025 for voluntary use; effective for periods beginning on or after 15 December 2026.
The international baseline UK SRS endorses, and who else is adopting it.
AIM securities are not admitted to the Official List, so the listing-rule categories do not reach them.
The government’s policy statement on modernising corporate reporting.
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