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The UK SRS reference · checked against FCA PS26/19

UK SRS: sustainability reporting

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.

UK SRS diagram: framework → rules → reporting
Reading sequence · not an eligibility assessment

A finder

Find your route in one click

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.

Your reporting routeSelect your entity

Module 01 / 08

UKLR 6

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 rules

The road to first reports

From the standards to 2028, date by date

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.

5
listing categories in scope
6
categories excluded
1 year
Scope 3 relief
2 years
S1 relief beyond climate
  1. 25 Feb 2026
    UK SRS S1 and S2 published
    For voluntary use.
    DBT publication page
  2. 30 Jan – 20 Mar 2026
    CP26/5 consultation
    Proposed mandatory S2; not adopted.
    FCA CP26/5
  3. 24 Sep 2026
    Instrument made
    In force 1 January 2027.
    PS26/19, Appendix 1
  4. 30 Sep 2026
    PS26/19 published
    Comply or explain across UK SRS.
    FCA policy statement
  5. 28 Oct 2026
    Guidance comments close
    Draft Technical Note 803.1.
    Primary Market Bulletin 66
  6. 30 Nov 2026
    Modernising Corporate Reporting closes
    GOV.UK consultation
  7. 1 Jan 2027
    The rules apply
    To periods beginning on or after this date.
    PS26/19 ¶3.12
  8. 2028
    First reports
    With the Scope 3 and S1 reliefs available.
    PS26/19 ¶3.14

Where UK SRS stands

What is final, what is voluntary, what is only a consultation.

Read the statusExplore

Module 01 / 04

Published

DBT published S1 and S2 on 25 February 2026 for voluntary use. Publication of the standards does not by itself decide who must report.

Status ledger

Where UK SRS stands, at a glance

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.

Read all eleven status checks and their sources
  • UK SRS S1 and S2 exist and any entity may use themFinal · voluntaryDBT, 25 February 2026
  • Listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRSFinal rule · comply or explainPS26/19 ¶3.6
  • The rules apply to periods beginning on or after 1 January 2027Final · first reports in 2028PS26/19 ¶3.12
  • UK SRS S2 is mandatory for listed companiesNot adopted · CP26/5 proposed itPS26/19 ¶1.2, ¶1.7
  • Scope 3 emissionsComply or explain · one-year reliefPS26/19 ¶3.14
  • UK SRS S1 beyond climateComply or explain · two-year reliefPS26/19 ¶3.14
  • Third-party assuranceNot required · state whether obtainedUKLR 6.6.6R(8)(d)
  • A climate transition planNot required · UKLR 6, 16 and 22 state whether publishedUKLR 6.6.6R(8)(e)
  • FCA guidance on how to explainDraft · comments by 28 October 2026TN 803.1, PMB 66
  • A UK SRS duty for private or unlisted companiesNot proposed · consultation open to 30 November 2026UK SRS MCR
  • An effective date inside the standardsNone · removed before publicationDBT consultation response
Three kinds of statusExplore

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Final standards

S1 and S2 were published on 25 February 2026 for voluntary use.

Legal status

Is UK SRS law, a regulation, or voluntary?

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.

From standard to ruleExplore

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Published standards

DBT publishes S1 and S2 for voluntary use. Publication alone does not impose a reporting duty.

The standards

The two core UK SRS standards, and how they fit

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.

S1 with S2Explore

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S1 foundations

Reporting entity, materiality, connected information and the compliance statement sit in S1.

Where it comes from

From a global baseline to a UK standard

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.

  1. 3 Nov 2021
    ISSB announced
    At COP26.
    IFRS Foundation
  2. Jun 2023
    IFRS S1 and S2 issued
    IFRS S1
  3. May 2024
    TAC commissioned
    FRC as secretariat.
    FRC TAC
  4. 18 Dec 2024
    Recommendations published
    Agreed 5 December.
    FRC
  5. 25 Jun – 17 Sep 2025
    Exposure drafts
    209 responses.
    DBT consultation
  6. 5 Jan 2026
    DBT writes to the FCA
    Relief time limits come out.
    DBT letter
  7. 25 Feb 2026
    UK SRS S1 and S2 published
    For voluntary use.
    DBT

The international picture

IFRS sustainability standards in the United Kingdom

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.

40+
jurisdictions using or introducing
19
with requirements in effect
40%+
of global market capitalisation

The FCA’s final rules

PS26/19, the explanation, and the draft guidance.

The FCA obligationExplore

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Listing category

The rules cover five listing categories: UKLR 6, 14, 15, 16 and 22. Start with the issuer’s actual category.

FCA PS26/19

The final rules: comply or explain, from 2027

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.

Still open

Draft Technical Note 803.1, in Primary Market Bulletin 66, takes comments until 28 October 2026.

UKLR 6.6.6RFrom 1 Jan 2027
Select a node
Tap or focus any regime to stop the orbit and read what it asks of the company at the centre.

Explaining

What an explanation has to say

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 an S2 explanation from your disclosure gaps

Draft your UK SRS S2 statement · UKLR 6.6.6R(7A)

Reliefs
¶6(a) Oversight body or individual

Identify the body or individual that oversees climate risks and opportunities: terms of reference, skills, how and how often informed, trade-offs, oversight of targets and remuneration links.

¶6(b) Management’s role

Whether the role is delegated to a management position or committee, and the controls and procedures that support oversight.

¶¶10–12 Risks, opportunities and time horizons

Each climate risk and opportunity, whether each risk is physical or transition, its time horizon, and how short, medium and long term are defined.

¶13 Business model and value chain

Current and anticipated effects on the business model and value chain, and where they are concentrated.

¶14 Strategy, decision-making and any transition plan

How the entity has responded and plans to respond, any transition plan it has, how it plans to meet its targets, how this is resourced, and progress on earlier plans.

¶¶15–16(a)–(b) Current financial effects

Effects on financial position, performance and cash flows for the period, and the risks with a significant chance of a material adjustment next year.

¶¶15–16(c)–(d), 17–21 Anticipated financial effects

How financial position, performance and cash flows are expected to change over the short, medium and long term, given the strategy.

¶22 Climate resilience and scenario analysis

The resilience assessment at the reporting date, and how and when the scenario analysis was carried out: scenarios, inputs, assumptions, horizons and scope.

¶¶25–26 Risk management processes

How climate risks and opportunities are identified, assessed, prioritised and monitored, and how far this is integrated into overall risk management.

¶29(a)(i)–(v) Scope 1 and Scope 2 emissions

Gross Scope 1 and location-based Scope 2 in tonnes CO₂e, measured under the GHG Protocol, split between the consolidated group and other investees, with the method.

¶29(a)(vi), 29A–29C Scope 3 emissions

Gross Scope 3 emissions, the categories included, and financed emissions for asset managers, banks and insurers.

¶29(b)–(e) Exposure and capital metrics

Amount and percentage of assets or activities vulnerable to transition and physical risk and aligned with opportunities, and capital deployed.

¶29(f) Internal carbon prices

Whether and how a carbon price is used in decision-making, and the price per tonne.

¶29(g) Remuneration

Whether and how climate is factored into executive remuneration, and the percentage linked to it.

¶32 Industry-based metrics

Metrics associated with the business model or industry; the SASB-derived guidance may be considered.

¶¶33–37 Climate targets

Each target’s metric, objective, scope, period, base period, milestones, how it was set and reviewed, performance against it, and for GHG targets the gases, scopes, gross or net and planned carbon-credit use.

Statement of compliance with UK SRS S2

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.

Explain the gapExplore

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Requirements

Identify the S2 requirements that have not been met. A generic readiness statement is insufficient.

How the FCA decided

Why the rules ended up comply or explain

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.

Proposed scope
94 of 110
Replace TCFD rules
over 90%
Comply or explain, S2
over two thirds
Comply or explain, S1
78 of 113
Assurance statement
over 90%

Respondent support, with “over” answers drawn at the stated floor; source FCA PS26/19, chapter 2, which gives counts per question and no single total.

CP26/5 to PS26/19

From the proposal to the final rules

The FCA changed the core approach: S2 moved from proposed mandatory disclosure to comply or explain. Follow the decision, then its application date.

  1. 30 January 202601

    CP26/5 proposes mandatory S2

    The proposal treats S2 core disclosures as mandatory, with a different route for Scope 3.

    FCA CP26/5

  2. 20 March 202602

    Consultation closes

    The FCA considers responses on scope, feasibility and proportionality.

    FCA consultation

  3. 30 September 202603

    PS26/19 changes the approach

    The final rules adopt comply or explain across UK SRS disclosures, including S2.

    PS26/19 ¶¶1.2, 1.7

  4. Periods from 1 January 202704

    The final rules apply

    A one-year Scope 3 relief and two-year wider S1 relief accompany the new regime.

    PS26/19 ¶¶3.12, 3.14

Read the CP26/5 tracker and the FCA and UK SRS guide.

UKLR 6.6.6R(7B)

The S1 limb works risk by risk

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 an S1 explanation for an identified reporting gap

Draft your UK SRS S1 statement · UKLR 6.6.6R(7B)

Beyond climate, we have…
Risk or opportunity 1
Risk or opportunity 2
Explanation under UKLR 6.6.6R(7B)(b)

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.

Risk by riskExplore

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Identify

S1 ¶3 defines the sustainability-related risks and opportunities the reporting process considers.

Official guidance

UK SRS reporting guidance: who publishes what

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.

Entity and periodExplore

Module 01 / 04

Entity

Record the listed issuer, its reporting entity and the applicable UKLR category. A group label alone does not answer the scope question.

Scope

Who the rules reach, and who they do not

The FCA’s rules follow the listing category, not company size.

The UK SRS thresholds page covers the size tests that do exist.

Read the five listing categories and transition-plan statements
Sources: FCA PS26/19 ¶¶3.6–3.7 · AIM Rules for Companies. The Policy Statement gives no total number of companies.
Listing categoryUnder PS26/19Plan statement
UKLR 6 · commercial companiesIn · comply or explainYes
UKLR 14 · international commercial companiesIn · comply or explainNo
UKLR 15 · depositary receiptsIn · comply or explainNo
UKLR 16 · non-equity and non-voting sharesIn · comply or explainYes
UKLR 22 · equity shares (transition)In · comply or explainYes
UKLR 11, 12, 13, 17, 18 and 19Out—
AIM, or not listed at allNot 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.

Start with the categoryExplore

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In scope

UKLR 6, 14, 15, 16 and 22 are covered by the final rules.

Check your position

Which rules reach your company

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.

Check your listing category and separate reporting duties

Choose your actual listing category to see which reporting route to investigate. Size figures are relevant to separate company-law duties.

Step 1 · What is listed?

Choose the category your securities are admitted to on the Official List.

A company with securities in two categories can run this twice.

Step 2 · The size-based regimes beside UK SRS (optional)

Is it a UK quoted company, or a UK company or LLP that exceeds at least two of these limits?

Turnover £36 million · balance sheet total £18 million · 250 employees (SI 2008/410 Sch 7 ¶20B; SI 2008/1911 for LLPs).

Does it have more than 500 employees and is it traded, a bank, an insurer, on AIM, or has turnover over £500 million?

Companies Act 2006 s 414CA, with the 500-employee floor in s 414CA(4); small and medium-sized companies are out.

Does it (or its UK group) have 250 or more employees, or turnover over £44 million and a balance sheet over £38 million?

SI 2014/1643 Sch 1, tested on the Phase 4 qualification date, 31 December 2026.

Nothing you choose here is stored or sent anywhere.

Start with the categoryExplore

Module 01 / 04

In scope

UKLR 6, 14, 15, 16 and 22 are covered by the final rules.

Thresholds

No UK SRS size threshold, but four tests that get mistaken for one

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.

Listing
category

UK SRS starts here

No FCA company-size threshold. Follow the issuer’s actual listing category.

  1. 1

    SECR

    Annual energy and carbon disclosures

  2. 2

    ESOS

    Energy assessments and their own qualification test

  3. 3

    Company law

    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

Your first UK SRS reporting 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

  1. 1 January 2027

    Your first eligible period starts

    The trigger is the period start, rather than the year printed on the report.
  2. 31 December 2027

    Close the reporting year

    UK SRS disclosures cover the same period as the financial statements.
  3. By 30 April 2028

    Publish the annual report

    The four-month DTR deadline includes the sustainability disclosures.

Other year ends shift the dates. This is a calendar-year example, not every issuer’s deadline.
PS26/19 ¶¶3.12, 3.18

DTR 4.1.3R · four-month publication deadline

Transitional reliefs

The reliefs: what the standards allow, and for how long

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

First periodSecond periodThird onwards
Scope 3
First period only
Wider S1
First two periods
Prior GHG method
First period only

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

Every UK SRS date, with its status

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.

S1 with S2Explore

Module 01 / 04

Governance

Explain oversight and management responsibility for relevant risks and opportunities. Reporting starts with the decisions and accountability behind the disclosures.

Contents

What a UK SRS report has to contain

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

Four content areasExplore

Module 01 / 04

Governance

Who oversees relevant risks and opportunities, and how management supports that oversight.

Materiality

Financial materiality: the test everything hangs on

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.

Financial effectsExplore

Module 01 / 04

Cash flows

Could the risk or opportunity reasonably be expected to affect cash flows?

The paragraph map

UK SRS S1 and S2, paragraph by paragraph

Find the provision behind a claim. Start with the foundations, then the disclosure and its application guidance.

Search the complete S1 and S2 paragraph register

Find a paragraph

33 of 33 entries

StandardParagraphsSectionWhat it settles
UK SRS S11–4ObjectiveDisclose 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 S15–9ScopeWhat the standard applies to and how it relates to the entity’s financial statements.
UK SRS S110Conceptual foundationsIntroduces the foundations that follow; UKLR 6.6.6A G points climate reporters to ¶¶10–24.
UK SRS S111–16Fair presentationA complete, neutral and accurate depiction, with additional information where needed.
UK SRS S117–19Materiality¶18 defines material by influence on primary users’ decisions; ¶B19 says no threshold is specified.
UK SRS S120Reporting entityThe same reporting entity as the related financial statements.
UK SRS S121–24Connected informationConnections within and across reports (¶21), the financial statements identified (¶22), consistent data and assumptions (¶23), the same presentation currency (¶24).
UK SRS S125Core contentThe four content areas: governance, strategy, risk management, and metrics and targets.
UK SRS S126–27GovernanceThe 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 S128–42Strategy¶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 S143–44Risk managementHow risks are identified, assessed, prioritised and monitored, and how that sits in overall risk management.
UK SRS S145–53Metrics and targetsMetrics required by a standard and the entity’s own; targets, their basis and progress; ¶52 keeps metrics consistent over time.
UK SRS S154–59Sources of guidanceWhere to look beyond the standards — ¶55(a) and ¶58(a) say an entity “may” consider the SASB Standards.
UK SRS S160–63Location of disclosuresPart of general purpose financial reports (¶60); may sit beside regulatory information if clearly identifiable (¶62); cross-reference allowed (¶63, ¶¶B45–B47).
UK SRS S164–69Timing of reportingAt the same time as, and for the same period as, the related financial statements (¶64).
UK SRS S170–71Comparative informationComparatives for the preceding period for all amounts (¶70).
UK SRS S172–73, 73A, 73BStatement of complianceWhen compliance may be asserted; ¶73A limits it after the climate-only relief; ¶73B subjects the standard to UK law.
UK SRS S174–76JudgementsThe judgements with the most significant effect on the disclosures.
UK SRS S177–82Measurement uncertaintyThe amounts subject to high uncertainty, the sources of it, and the assumptions made.
UK SRS S183–86ErrorsCorrecting material prior-period errors.
UK SRS S1Appendices A–EDefined terms to application and transitionEach 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 S21–2ObjectiveClimate-related risks and opportunities useful to primary users.
UK SRS S23–4ScopePhysical and transition risks, and climate-related opportunities.
UK SRS S25–7GovernanceThe climate twin of S1 ¶27; ¶7 allows integrated governance disclosures to avoid duplication.
UK SRS S28–23StrategyEach 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 S222Climate resilienceResilience assessed using climate-related scenario analysis, by an approach commensurate with the entity’s circumstances.
UK SRS S224–26Risk managementProcesses to identify, assess and monitor climate risks, including whether scenario analysis informs them (¶25(a)(ii)).
UK SRS S227–32MetricsScope 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 S233–37TargetsObjective, 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 S2B1–B18Scenario analysis guidanceAn approach commensurate with circumstances (¶B2); quantitative for a highly exposed, resourced entity (¶B17); resilience assessed annually (¶B18).
UK SRS S2B29–B57Greenhouse gas measurementNo emission factors prescribed (¶B29); location-based Scope 2 (¶B30); Scope 3 measurement framework, primary data preferred all else equal (¶¶B38–B57).
UK SRS S2B59–B63AFinanced emissionsFinanced 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 S2C1–C6Application and transitionNo 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.

S1 says it is set out in “paragraphs 1–86”, but ¶¶73A and 73B are UK additions, so do not cite that as a count.

S1 and S2 both have a ¶22 and a ¶29, so always name the standard; UK SRS S1 and UK SRS S2 work through each in full.

Find the provisionExplore

Module 01 / 04

Foundations

Start with S1: materiality, reporting entity and connections to financial statements.

The climate standard

What UK SRS S2 actually asks for

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.

  1. ¶¶5–7
    Governance
    Board oversight and management’s role.
  2. ¶¶8–21
    Strategy
    Risks, concentrations, responses, effects.
  3. ¶22
    Resilience
    Scenario analysis, ¶¶B1–B18.
  4. ¶¶24–26
    Risk management
  5. ¶29
    Scope 1, 2 and 3
    Gross; Scope 2 location-based.
  6. ¶¶33–36
    Targets
    Validation, progress, gross or net.
  7. ¶¶C1–C6
    Application and transition
    Reliefs and the UK-law override.

UK vs IFRS

Key UK adjustments to the global baseline

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

IFRS S1 → UK SRS S1

International baselineGeneral requirements
UK changes includeSASB choice; UK-law provisions

Effective-date and late-publication provisions change. Climate-first relief affects the compliance statement.

IFRS S2 → UK SRS S2

International baselineClimate disclosures
UK changes includeIndustry guidance; financed emissions

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

SASB Standards: optional almost everywhere

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.

77
industries covered
2
S2 places keep “shall”

Draft to final

What changed between the drafts and the standards

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.

6
amendments proposed, June 2025
68%
agreed with the four TAC ones
1
withdrawn, one replaced

Climate in detail

Scopes, scenarios, transition plans and judgement.

Climate evidenceExplore

Module 01 / 04

Inventory

S2 includes gross Scope 1, 2 and 3 emissions disclosures, subject to the applicable requirements and reliefs. Set the organisational and value-chain boundaries first.

Emissions

The three emission scopes, and how they are measured

UK SRS S2 requires all three, measured on the GHG Protocol Corporate Standard unless a regulator or exchange requires another method.

  1. Step 1 of 3

    Direct emissions

    Sources the entity owns or controls: fuel burned on site and in its own vehicles.

  2. Step 2 of 3

    Purchased energy

    S2 requires the location-based figure (¶B30).

  3. Step 3 of 3

    The value chain

    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

Scope 2, and the dual-reporting myth

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

Purchased
electricity

Location-based

Grid-average emissions for the electricity consumed.

Required by UK SRS S2 ¶29(a)(v).

Market-based

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

Climate scenario analysis, and how much is enough

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

Different pathways

Compare physical and transition risks.

Proportionate method

Match analysis to exposure, skills and resources.

Business response

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 and transition 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

Transition plans: disclosed if you have one

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.

  1. UK SRS S2 ¶14(a)(iv)
    Describe any plan you have
    Key assumptions and dependencies.
    UK SRS S2
  2. UKLR 6.6.6R(8)(e)
    Say whether one is published
    UKLR 6, 16 and 22 only.
    PS26/19
  3. DESNZ consultation
    Whether a plan becomes a duty
    Closed 17 September 2025; no response.
    DESNZ

Judgement

Judgements, estimates and uncertainty

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.

  1. 1

    Evidence

    Activity records, source data and the reporting boundary.

  2. 2

    Estimate

    The method, assumptions and significant judgements used.

  3. 3

    Disclosure

    Explain measurement uncertainty and information needed to understand the estimate.

UK SRS S1 ¶¶74–82

UK SRS S2 ¶¶19–21 · financial-effects provisions

Metrics and targets

Metrics and targets, and how a target is judged

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.

  1. 1

    Basis

    Objective, base period and milestones.

  2. 2

    Boundary

    Gases and scopes; gross or net. A net target also needs the gross target.

  3. 3

    Validation

    Whether a third party validated it; distinguish validation from achieved performance.

  4. 4

    Progress

    Performance against the target, and the trend.

UK SRS S2 ¶¶33–36

Reporting in practice

Sign-off, assurance, data, a first report, and how reports fail.

Build the reportExplore

Module 01 / 04

Owners

Allocate accountability for each disclosure, with finance, risk, operations and the governing body involved where relevant. This is a suggested preparation practice.

Governance

Who signs a UK SRS report off, and what they must say

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

  1. 1

    Management and data owners

    Prepare evidence, operate controls and explain methods.

  2. 2

    Responsible body or individual

    Oversee risks, opportunities and targets. Describe actual responsibilities and how information reaches them.

  3. 3

    Annual financial report

    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

DTR 4.1.12R · responsibility statements

Connectivity

One package: the disclosures and the accounts

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

  1. 1 January–31 December 2027

    One reporting period

    Use the same reporting entity and consistent data and assumptions.
  2. By 30 April 2028

    One publication date

    Publish the UK SRS disclosures with the financial statements.
    Financial statementsUK SRS disclosures

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

DTR 4.1.3R · annual financial report deadline

Assurance

Assurance: a statement, not a requirement

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.

State
whether

Was assurance obtained?

The FCA asks for transparency. It does not require obtaining assurance.

Provider

Who carried out the engagement.

Coverage

Which disclosures, and the assurance level.

Standard

Which assurance standards were used.

Report

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

The data a UK SRS report needs, and where it lives

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.

Your UK SRS dataOur reading, not a rule
Select a node
Tap or focus any regime to stop the orbit and read what it asks of the company at the centre.

Sequence

A first UK SRS report, in order

The order matters more than the pace; this is an order of work, not a legal timetable.

  1. Step 1 of 10

    Do the FCA’s rules reach you?

    PS26/19 ¶3.6
  2. Step 2 of 10

    Fix the first period against your year end

    PS26/19 ¶¶3.12, 3.18
  3. Step 3 of 10

    Identify the risks that could affect cash flows, finance or cost of capital

    UK SRS S1 ¶3
  4. Step 4 of 10

    Put the subject on a named committee

    UK SRS S1 ¶27
  5. Step 5 of 10

    Scopes 1 and 2, then screen Scope 3

    UK SRS S2 ¶29(a)
  6. Step 6 of 10

    Name the set and its vintage

    UK SRS S2 ¶22
  7. Step 7 of 10

    Decide which reliefs you rely on

    S1 ¶73A; UKLR TP 16
  8. Step 8 of 10

    Draft what will not be met

    UKLR 6.6.6R(7A)–(7B)
  9. Step 9 of 10

    Same report, same period as the accounts

    UK SRS S1 ¶64
  10. Step 10 of 10

    Decide whether to obtain it, and at what level

    UKLR 6.6.6R(8)(d)

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.

1

Evidence ready

Can the disclosure be traced to records and an owner?

2

Gaps visible

Which requirements, assumptions or inputs need work?

3

Next steps

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

How a first UK SRS disclosure usually fails

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.

  • UK SRS S1 ¶73AA compliance claim that outlives its reliefClimate-only means no S1 claim.
  • UK SRS S2 ¶B30Scope 2 shown as dual reportingOnly location-based is required.
  • UK SRS S2 ¶22, ¶B2Scenarios with no named setName the set and its vintage.
  • UK SRS S1 ¶27Governance with no minute behind itName the body, with dates.
  • UKLR TP 16A relief with no provision namedState the transitional provision.
  • UK SRS S1 Appendix EAn invented “effective from” dateThose provisions were removed.
  • UK SRS S1 ¶23Assumptions that differ from the accountsKeep data and assumptions consistent.
1 / 7

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

Reporting voluntarily now, and what it buys you

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

If you already report under TCFD

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.

TCFD-aligned rules

Four pillars and eleven recommended disclosures, on comply or explain.

UK SRS S2 under PS26/19

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.

Separate regimesExplore

Module 01 / 04

SECR

Energy and carbon reporting has its own statutory population and required disclosures. It is not replaced merely because an entity uses UK SRS.

Other regimes

How UK SRS sits beside SECR, ESOS and TCFD

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

UK SRSS1 and S2
Select a node
Tap or focus any regime to stop the orbit and read what it asks of the company at the centre.

The landscape

Which sustainability reporting rules apply to UK companies from 2027

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

If you also report under CSRD

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.

UK SRS

One question: what could affect the entity (S1 ¶3).

CSRD and ESRS

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.

Follow the sourceExplore

Module 01 / 04

Instrument

For a duty, open the made rule or legislation. Guidance and a consultation explain different things and should be labelled accordingly.

Test yourself

Fourteen statements about UK SRS: true or false?

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.

  1. UK SRS S2 is mandatory for listed companies from 2027.
    Show the answer

    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).

  2. 515 listed companies must comply with UK SRS.
    Show the answer

    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.

  3. Secondary-listed companies only have to signpost their home reporting.
    Show the answer

    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.

  4. A listed company using the Scope 3 relief has to explain why.
    Show the answer

    It states that it is using the relief; PS26/19 ¶3.20 says no further explanation is needed during the relief period.

  5. The standards themselves limit the Scope 3 relief to one year.
    Show the answer

    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).

  6. UK SRS S2 requires Scope 2 to be reported on both a location-based and a market-based basis.
    Show the answer

    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.

  7. Listed companies must have their UK SRS disclosures assured.
    Show the answer

    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.

  8. Listed companies must publish a climate transition plan.
    Show the answer

    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)).

  9. UK SRS replaces SECR.
    Show the answer

    SECR continues under SI 2018/1155. The Modernising Corporate Reporting consultation proposes moving where SECR sits in the annual report, not removing it.

  10. There are six UK amendments to the ISSB Standards.
    Show the answer

    Six was the count of proposals in the June 2025 consultation. The final differences are mapped in Annex A, which gives no count.

  11. Using the climate-only relief means you cannot claim compliance with UK SRS S1.
    Show the answer

    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.

  12. In one place UK SRS asks for more than IFRS S2 does.
    Show the answer

    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.

  13. A company whose shares trade only on AIM is caught by the FCA’s UK SRS rules.
    Show the answer

    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.

  14. The UK SRS standards have an effective date of 1 January 2027.
    Show the answer

    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

UK SRS terms, defined against the source

Every term in use on this page, defined against the provision it comes from.

88 shown

UK SRS Standards
The UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2, issued by the Secretary of State for Business and Trade and published on 25 February 2026 for voluntary use by any entity.
UK SRS S1 Standards
General Requirements for Disclosure of Sustainability-related Financial Information: the materiality test, the four content areas and the general requirements every disclosure follows.
UK SRS S2 Standards
Climate-related Disclosures: the climate standard, covering Scope 1, 2 and 3 greenhouse gas emissions, scenario analysis, targets and any transition plan the entity has. Sometimes written UK SRS2 or SRS S2.
IFRS S1 and IFRS S2 Standards
The International Sustainability Standards Board’s global baseline standards, issued in June 2023. UK SRS S1 and S2 are the UK’s endorsed versions, with the differences set out in Annex A.
ISSB Standards
The International Sustainability Standards Board, whose formation the IFRS Foundation’s trustees announced on 3 November 2021 at COP26.
Annex A Process
The annex to the government’s consultation response that maps every difference between UK SRS and IFRS S1 and S2. Where a requirement is not in its table there is no difference; it carries no count.
Endorsement Process
The process by which the UK assesses an international standard and adopts it, with or without changes, under the government’s framework for developing UK Sustainability Reporting Standards.
TAC Process
The UK Sustainability Disclosure Technical Advisory Committee, with the FRC as its secretariat. It agreed its endorsement recommendations on 5 December 2024 and published them on 18 December 2024.
DBT and BIST Process
The Department for Business and Trade consulted on and published UK SRS. GOV.UK has carried an organisation page for the Department for Business, Innovation, Science and Trade (BIST) since 20 July 2026; acts before that date keep the DBT name.
Exposure draft Process
A draft standard published for consultation. The UK SRS exposure drafts were consulted on from 25 June to 17 September 2025 and drew 209 responses.
Government response Process
DBT’s response to the exposure-draft consultation, published with the standards on 25 February 2026. ¶1.21 says that for voluntary reporters UK SRS is available to use immediately; Annex A maps the differences from IFRS.
CP26/5 FCA rules
The FCA’s January 2026 consultation on aligning listed issuers’ sustainability disclosures with UK SRS. It proposed mandatory UK SRS S2; the final rules did not adopt that. Its cost-benefit analysis estimated around 600 listed companies affected.
PS26/19 FCA rules
The FCA’s Policy Statement of 30 September 2026 finalising CP26/5: listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
The 2026 instrument FCA rules
The UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, made by the FCA Board on 24 September 2026 and in force on 1 January 2027. The Policy Statement gives it no instrument number.
Comply or explain FCA rules
The basis of the FCA’s rules: make the UK SRS disclosures, or state what has not been disclosed, why, and what the company is doing about it. It is a feature of the listing rules, not of the standards.
UKLR 6.6.6R(7A) FCA rules
The UK SRS S2 limb for commercial companies: climate disclosures in accordance with UK SRS S2, or a statement summarising the requirements not met, the reasons and the steps planned.
UKLR 6.6.6R(7B) FCA rules
The UK SRS S1 limb: disclosures beyond climate, or a statement of the risks and opportunities identified under S1 ¶3 but not disclosed, and why — risk by risk, not requirement by requirement.
UKLR 6.6.6R(8) FCA rules
The statements that sit beside the limbs: where the disclosures are (c), whether third-party assurance was obtained (d), and whether a climate transition plan has been published (e).
UKLR 6.6.6A G FCA rules
Guidance, not rule, reminding a company making climate disclosures to apply the relevant parts of UK SRS S1, including ¶¶10–24 and ¶¶60–71.
UKLR TP 16 FCA rules
The transitional provisions that time the reliefs: the Scope 3 relief for the first period, the climate-first relief for the first two, and early adoption for periods beginning before 1 January 2027.
Relief statement FCA rules
The statement a company makes when it relies on a transitional relief. Under PS26/19 ¶3.20 it needs no further explanation during the relief period.
Early adopter FCA rules
A listed company that applies the new UK SRS limbs to a period beginning before 1 January 2027. PS26/19 ¶3.19 lets it keep the same transitional reliefs.
TN 803.1 FCA rules
A draft FCA Technical Note on UK SRS comply or explain, published for consultation in Primary Market Bulletin 66 with comments due by 28 October 2026. Proposed guidance, not final.
UKLR FCA rules
The FCA’s UK Listing Rules. Their categories, not company size, decide who the UK SRS rules reach.
UKLR 6 FCA rules
The equity shares (commercial companies) category, the largest of the five categories in scope of PS26/19.
Secondary listing FCA rules
UKLR 14, equity shares of international commercial companies. In scope of PS26/19 on comply or explain; home-jurisdiction reporting may be relied on where it meets UK SRS outcomes; no transition-plan statement.
Depositary receipts FCA rules
UKLR 15, certificates representing certain securities. Treated like UKLR 14 under PS26/19.
AIM FCA rules
The London Stock Exchange’s growth market. AIM securities are not admitted to the Official List, so the UK Listing Rules categories PS26/19 amends do not cover them.
DTR 4.1.3R FCA rules
The Disclosure and Transparency Rule that makes an issuer publish its annual financial report within four months of its financial year end — the practical deadline for UK SRS disclosures in that report.
Financial materiality Standards
The UK SRS test: information about risks and opportunities that could reasonably be expected to affect the entity’s cash flows, access to finance or cost of capital (UK SRS S1 ¶3).
Material Standards
Information is material if omitting, misstating or obscuring it could reasonably be expected to influence primary users’ decisions (UK SRS S1 ¶18). No threshold is set (¶B19).
Double materiality Other regimes
The EU test under the CSRD and ESRS, which adds the entity’s impacts on people and the environment to the financial test.
Primary users Standards
Existing and potential investors, lenders and other creditors — the readers whose decisions the materiality test is about.
General purpose financial reports Standards
The reporting package UK SRS disclosures form part of (UK SRS S1 ¶60), such as the annual report containing the strategic report.
The four content areas Standards
Governance, strategy, risk management, and metrics and targets, set at UK SRS S1 ¶25 and inherited from the TCFD’s 2017 structure.
Connected information Standards
UK SRS S1 ¶¶21–24: explain connections within and across reports, identify the related financial statements, use consistent data and assumptions, and the same presentation currency.
Reporting entity Standards
The entity the disclosures are for, which UK SRS S1 ¶20 makes the same as for the related financial statements.
Fair presentation Standards
The requirement in UK SRS S1 ¶¶11–16 that disclosures faithfully represent the risks and opportunities they describe.
Statement of compliance Standards
An entity’s assertion that it has complied with a UK SRS standard (S1 ¶¶72–73). ¶73A limits it where the climate-only relief is used.
Paragraph 73A Standards
A UK addition: an entity using the climate-only relief may not assert compliance with UK SRS S1 and must disclose the relief; it may still assert compliance with UK SRS S2.
Paragraph 73B Standards
A UK addition subjecting UK SRS S1 to the Companies Act, the FCA or any other UK body able to set reporting requirements.
Paragraph E2 Standards
The provision requiring UK SRS S1 and S2 to be applied at the same time. It survived the removal of the effective dates.
Paragraph E3 Standards
The climate-only (climate-first) relief in UK SRS S1. The standard sets no time limit; for listed companies PS26/19 sets two years from initial application.
Paragraph C3 Emissions
The GHG measurement-method relief in UK SRS S2, limited to the first annual reporting period.
Paragraph C4 Emissions
The Scope 3 relief in UK SRS S2. The standard sets no time limit; for listed companies PS26/19 sets one year from initial application.
Paragraph B59A Emissions
The one UK change that is stricter than IFRS: explain why financed emissions cannot be estimated for the same period as the accounts, how any figure was measured, and the plan to catch up.
Transitional relief Standards
A provision easing a requirement for a period. UK SRS carries three — ¶E3, ¶C3 and ¶C4 — and the FCA’s rules set how long listed companies may use them.
Effective date Standards
A date from which a standard applies. UK SRS has none: the provisions were removed so that legislation or the FCA could set timing.
UK-law override Standards
UK SRS S1 ¶¶73B and E5 and UK SRS S2 ¶C6, which make application of the standards subject to UK law and regulators.
SASB Standards Standards
Industry-based disclosure standards the ISSB took responsibility for in August 2022. UK SRS changed “shall” to “may” for them, except at UK SRS S2 ¶37 and ¶B65(d).
Industry-based guidance Standards
The ISSB’s Industry-based Guidance on Implementing IFRS S2, which UK SRS S2 ¶¶12, 23 and 32 say an entity may consider.
Cross-industry metrics Emissions
The climate metrics UK SRS S2 asks of every entity, as opposed to the industry-based metrics it makes optional in most places.
Scope 1 Emissions
Direct greenhouse gas emissions from sources an entity owns or controls.
Scope 2 Emissions
Indirect emissions from purchased energy. UK SRS S2 requires the location-based figure (¶29(a)(v), ¶B30).
Scope 3 Emissions
All other indirect emissions across the value chain, in fifteen categories under the GHG Protocol. Required by UK SRS S2, with the ¶C4 relief.
Location-based Emissions
A Scope 2 method using the average emissions intensity of the grids where energy is consumed. The figure UK SRS S2 requires.
Market-based Emissions
A Scope 2 method reflecting contractual instruments such as renewable electricity certificates. UK SRS S2 permits it and asks for information about contractual instruments that exist.
Dual reporting Emissions
Publishing location-based and market-based Scope 2 figures together. The GHG Protocol Scope 2 Guidance asks for it in markets with contractual data; UK SRS S2 does not.
GHG Protocol Emissions
The Greenhouse Gas Protocol Corporate Standard, the measurement basis UK SRS S2 uses unless a jurisdictional authority or exchange requires another method.
Emission factors Emissions
Multipliers that turn activity data into emissions. UK SRS S2 prescribes none (¶B29); UK companies commonly use the government’s annual conversion factors.
Activity data Emissions
The operational quantities — litres of fuel, kilowatt-hours, distance travelled, spend — that emissions are calculated from.
Primary data Emissions
Data from specific activities in the value chain, such as supplier-specific emission factors. UK SRS S2 ¶B47 prioritises it, all else being equal.
Secondary data Emissions
Industry-average data from published databases, government statistics, literature and trade bodies (UK SRS S2 ¶B49).
Financed emissions Emissions
Emissions attributed to an entity’s loans and investments, disclosed by asset managers, banks and insurers under UK SRS S2 ¶B59 and the UK addition ¶B59A.
Value chain Standards
The full range of interactions, resources and relationships related to an entity’s business model, upstream and downstream — the boundary Scope 3 is measured across.
Intensity ratio Other regimes
Emissions per unit of activity or revenue. SECR asks for at least one; UK SRS S2 does not prescribe one.
Scenario analysis Standards
Testing the business against possible climate futures. UK SRS S2 ¶22 requires resilience to be assessed with it, commensurate with the entity’s circumstances.
Climate resilience Standards
The capacity of an entity to adjust to climate-related change. The assessment is updated at every reporting date (UK SRS S2 ¶B18).
Physical risk Standards
Risk from the climate itself: acute events such as floods and storms, and chronic shifts such as heat and water stress.
Transition risk Standards
Risk from the response to climate change: policy and legal change, technology, markets and reputation.
NGFS scenarios Standards
The Network for Greening the Financial System’s reference scenarios; the current set is version 5.0 of November 2024. A reference set, not a requirement.
IEA NZE Standards
The International Energy Agency’s Net Zero Emissions by 2050 Scenario; the current vintage is in World Energy Outlook 2025, published 12 November 2025.
Transition plan Standards
An aspect of an entity’s overall strategy that lays out its targets, actions or resources for its transition towards a lower-carbon economy (UK SRS S2, Appendix A).
TPT Disclosure Framework Other regimes
The Transition Plan Taskforce’s October 2023 framework: three principles — Ambition, Action, Accountability — across five elements. Archived guidance hosted by the IFRS Foundation, not law.
Gross and net targets Emissions
UK SRS S2 ¶36(c): a company disclosing a net greenhouse gas target must also disclose the associated gross target, and ¶36(e) its planned use of carbon credits.
TCFD Other regimes
The Task Force on Climate-related Financial Disclosures, whose June 2017 report set four recommendations and eleven recommended disclosures. It disbanded in October 2023.
Section 414CB Other regimes
The Companies Act 2006 provision carrying the climate-related financial disclosure duty for large companies; UK SRS S2 is a national reporting framework for subsection (6).
Section 463 Other regimes
The Companies Act 2006 safe harbour for directors’ liability. The government confirmed it covers UK SRS disclosures placed in the strategic report.
Strategic report Other regimes
The narrative part of a UK annual report required by the Companies Act, governed in practice by the FRC’s Guidance on the Strategic Report.
SECR Other regimes
Streamlined Energy and Carbon Reporting, under SI 2018/1155: energy use and emissions in the directors’ report of quoted and large companies. UK SRS does not replace it.
ESOS Other regimes
The Energy Savings Opportunity Scheme, under SI 2014/1643, administered by the Environment Agency. Phase 4 notification is due by 5 December 2027.
CSRD and ESRS Other regimes
The EU Corporate Sustainability Reporting Directive and its European Sustainability Reporting Standards; the Commission adopted a revised ESRS set on 3 July 2026.
Modernising Corporate Reporting Other regimes
The government programme announced in written statement HCWS973 (21 October 2025, which calls it Modernisation of Corporate Reporting) and consulted on from 7 September to 30 November 2026.
Assurance Process
An independent practitioner’s conclusion on reported information. Neither UK SRS nor the FCA’s rules require it; the FCA asks whether it was obtained.
Limited and reasonable assurance Process
Limited assurance gives a negative-form conclusion; reasonable assurance a positive opinion that needs controlled, repeatable evidence.
ISSA (UK) 5000 Process
The FRC’s sustainability assurance standard, issued 12 November 2025 for voluntary use and effective for periods beginning on or after 15 December 2026.
Measurement uncertainty Standards
Where amounts rest on estimates. UK SRS S1 ¶¶77–82 ask for the amounts affected, the sources and the assumptions.
Comparative information Standards
Prior-period figures (UK SRS S1 ¶70). Not needed in the first year (¶E1); the FCA’s transitional guidance says the same for the first period under its rules.

Sources: UK SRS S1 · UK SRS S2 · DBT consultation response · FCA PS26/19 · GHG Protocol

Method

How to read the primary sources yourself

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.

  1. 1
    The standards
    Watch: “paragraphs 1–86”, but ¶¶73A and 73B exist.
    DBT
  2. 2
    Annex A
    Every difference; no count.
    DBT response
  3. 3
    PS26/19, Appendix 1
    The made rule text is in the appendix.
    FCA
  4. 4
    Draft TN 803.1
    Draft until the FCA finalises it.
    FCA
  5. 5
    CP26/5
    History only: PS26/19 changed its central proposal.
    FCA

The library

The primary sources, by regime

These are the instruments behind this site: read them yourself before relying on anyone’s summary, ours included.

The standards and the UK endorsement
The FCA listing rules
Company law, SECR and ESOS
Assurance and transition plans
The international baseline
Emissions accounting and climate scenarios
If you also report in the EU
Europe and the wider field

Key facts

What to take away from all of this

UK SRS is a voluntary standard that the FCA has made comply or explain for listed companies in five categories, from 1 January 2027.

25 Feb 2026
UK SRS S1 and S2 published for voluntary use
DBT
Comply or explain
The basis for every UK SRS disclosure under the FCA’s rules
PS26/19 ¶1.7
1 Jan 2027
The rules apply to periods beginning on or after this date
PS26/19 ¶3.12
5 categories
UKLR 6, 14, 15, 16 and 22; six are excluded
PS26/19 ¶¶3.6–3.7

Sources: DBT · FCA PS26/19 · CP26/5 Annex 2 ¶43 · Annex A · UK SRS S2

A reading and preparation sequence

UK SRS: from the question to the evidence

A suggested sequence for using this guide. These steps are not an eligibility finding, a statutory timetable or a guarantee of compliance.
  1. 0101

    Identify the reporting entity

    Record the entity, listing category and accounting-period start before choosing a reporting route.
  2. 0202

    Read S1 and S2 together

    Use the general foundations and the climate-specific requirements with their relevant reliefs.
  3. 0303

    Build the evidence

    Bring together inventory boundaries, risks, financial connections and the judgements behind the disclosures.
  4. 0404

    Resolve statements and explanations

    Distinguish a compliance statement from a rule-based explanation and retain the approval trail.

Dates, with their status

The relevant dates, drawn in order

  1. 25 February 202601

    UK SRS published

    S1 and S2 are published for voluntary use. The standards themselves do not decide which companies must report.

    DBT: published standards

  2. 30 September 202602

    FCA final rules

    PS26/19 sets a comply-or-explain reporting obligation for the five in-scope listing categories. It replaces the consultation proposals.

    FCA: PS26/19

  3. 28 October 202603

    Draft guidance comments close

    Technical Note 803.1 is proposed guidance on the explanations and compliance statements. Keep its draft status clear.

    FCA: Primary Market Bulletin 66

  4. Periods from 1 January 202704

    New listed-company regime

    The first eligible accounting periods begin. Optional reliefs cover Scope 3 for one year and wider S1 sustainability information for two years.

    PS26/19: implementation and UKLR TP 16

  5. 2028 reporting season05

    First annual reports

    The FCA identifies 2028 as the first reporting year. An issuer’s actual publication deadline follows its annual financial report rules and year end.

    FCA: first reporting

  6. Periods from 1 January 202906

    Transitional reliefs end

    The Scope 3 and climate-first transitional reliefs have expired. The comply-or-explain reporting obligation continues.

    PS26/19: UKLR TP 16

Frequently asked

UK SRS, answered

121 questions, each answered against the primary sources.

Status: law, rule or voluntary

Is UK SRS mandatory?

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.

What are the UK Sustainability Reporting Standards (SRS)?

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.

What does SRS stand for?

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.

What are the UK SRS regulations?

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.

Is there UK SRS legislation?

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.

Is UK SRS mandatory from 2027?

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.

What did the FCA decide in PS26/19?

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.

Has the FCA made its rules yet?

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.

Who has to comply with UK SRS today?

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.

Is sustainability reporting mandatory in the UK?

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.

What sustainability reporting requirements apply to UK companies from 2027?

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.

Which reporting standards apply to sustainability disclosures in the UK?

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.

Is greenhouse gas reporting mandatory in the UK?

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.

What does comply or explain mean for UK SRS?

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.

Why did the FCA choose comply or explain instead of mandatory rules?

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.

Is UK SRS law?

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.

How do the standards become binding on a company?

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.

Could the FCA timetable still change?

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.

What would change the picture most now?

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.

When did UK SRS start?

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.

What are the new UK sustainability reporting standards for 2026?

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.

What are the current consultations on UK SRS?

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.

What is the difference between UK SRS and UK SDS?

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.

What is the single most common error about UK SRS?

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.

Who has to report

Who will UK SRS apply to?

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.

How many companies must report under UK SRS?

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.

Which listing categories are caught by the FCA rules?

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).

Does UK SRS apply to private companies?

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.

Is there a small company exemption from UK SRS?

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.

Does UK SRS apply to SMEs?

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.

Are AIM companies in scope of UK SRS?

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.

Does UK SRS apply in Scotland, Wales and Northern Ireland?

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.

Do secondary-listed companies have to report under UK SRS?

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.

Dates and reliefs

When does UK SRS come into force?

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.

When will UK SRS be implemented?

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.

When do the first UK SRS reports under the FCA rules appear?

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.

What is the UK SRS deadline?

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.

What transitional reliefs are available?

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).

Does using a relief have to be explained?

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.

What happens when the reliefs expire?

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).

Why do the standards have no effective date?

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.

Why were the relief time limits removed from the standards?

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.

Can we adopt UK SRS early under the FCA rules?

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.

Can I report under UK SRS voluntarily now?

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.

What the standards contain

What is the difference between UK SRS S1 and UK SRS S2?

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.

What materiality test does UK SRS use?

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.

Who are the primary users?

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.

Does every UK SRS paragraph have to be disclosed?

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).

Does UK SRS cover social and governance topics?

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.

How many paragraphs does UK SRS S1 have?

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.

How long are the standards?

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.

Which section of UK SRS S1 is longest?

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.

Are the appendices part of the standard?

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.

What is UK SRS S1 paragraph 73A?

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.

What is the UK-law override?

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.

Who publishes UK SRS?

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.

Can I say we comply with UK SRS?

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.

Is S1 or S2 more work?

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.

What if I only want to report on 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.

UK SRS and the ISSB Standards

Is UK SRS the same as IFRS S1 and IFRS S2?

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.

Does complying with UK SRS mean complying 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.

Is there a UK SRS framework?

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.

How many UK amendments are there to the ISSB Standards?

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.

Are the SASB Standards mandatory under UK SRS?

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".

What is paragraph B59A?

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.

What is Annex A and why does it matter?

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.

When did the UK decide to endorse the ISSB Standards?

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.

How many responses did the UK SRS consultation receive?

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.

When was the ISSB formed?

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.

How many jurisdictions use the ISSB Standards?

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.

Do new ISSB amendments apply automatically in the UK?

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.

Emissions, scenarios and targets

Does UK SRS require Scope 3 emissions?

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.

Does UK SRS S2 require dual reporting of Scope 2?

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.

Which greenhouse gas methodology must be used?

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.

Which emission factors does UK SRS require?

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.

Do I need to measure all of my suppliers' emissions?

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).

Is climate scenario analysis required?

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).

Which scenario set should I use?

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.

Do I need to state the scenario vintage?

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.

What is the difference between physical and transition risk?

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.

Must a climate target be validated by the SBTi?

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.

Do the standards require a net zero 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.

Is there an intensity ratio requirement like SECR?

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.

Does UK SRS require energy use in kWh?

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.

Where and how it is reported

Where does UK SRS reporting go?

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.

What is the connectivity requirement?

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.

Do the disclosures have to cover the same period as the accounts?

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.

Can I publish the sustainability disclosures after the accounts?

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.

What if my sustainability data uses different assumptions from the accounts?

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.

Are comparatives required in the first year?

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)).

Do UK SRS disclosures have to be digitally tagged?

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.

Are UK SRS disclosures covered by the directors' safe harbour?

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.

Do I need to restate prior years if I change methodology?

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.

Assurance and transition plans

Must a UK SRS report be assured?

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.

Does UK SRS require an independent audit?

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.

What level of assurance will be required?

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.

Is there a UK SRS certification?

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.

Do listed companies have to publish a transition plan?

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.

Does UK SRS S2 require a transition plan to exist?

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.

What framework do transition plan disclosures follow?

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.

SECR, ESOS, TCFD and the EU

Is UK SRS replacing SECR?

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.

Does UK SRS replace ESOS?

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.

Does UK SRS replace TCFD?

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.

What is the relationship between UK SRS and the Companies Act?

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.

What is Modernising Corporate Reporting?

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.

Will SECR be withdrawn when UK SRS applies?

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.

What is the difference between UK SRS and CSRD?

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.

Is there a UK equivalent of the ESRS topical standards?

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.

What is the FRC's role?

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.

Getting started, and this site

How can companies prepare for 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.

How can I make it easier to comply with UK SRS?

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.

Should we wait for the FCA guidance before doing anything?

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.

What does UK SRS reporting cost?

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.

Where can I read the standards themselves?

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.

Are the standards free to read?

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.

Where is the official UK SRS reporting guidance?

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.

How long does a first UK SRS report take to prepare?

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.

Which document should I quote in a board paper?

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.

What is the shortest accurate summary of UK SRS?

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.

Does this page constitute advice?

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.

How often does this page change?

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

How this site checks what it says

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

Primary sources

Every figure, date and status on this page traces to the instrument’s owner.

Secondary commentary is never the source for a number.

Checked against 21 sources fromFinancial Conduct AuthorityFCA HandbookDepartment for Business and Tradelegislation.gov.ukGOV.UK (Environment Agency)GOV.UK
  1. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    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.

  2. Financial Conduct Authority
    PS26/19 (PDF): ¶¶1.2, 1.7, 1.9, 1.10, 2.7–2.47, 3.6–3.7, 3.12–3.24, 4.4, 4.35 and Appendix 1

    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).

  3. Financial Conduct Authority
    Draft Technical Note 803.1 (September 2026, for consultation)

    What the FCA proposes a proportionate explanation should contain. Draft guidance; comments by 28 October 2026.

  4. Financial Conduct Authority
    Primary Market Bulletin 66

    The guidance consultation and the nine preparation steps the FCA encourages.

  5. Financial Conduct Authority
    CP26/5 (PDF): the consultation PS26/19 finalises — Annex 2 ¶43

    Published 30 January 2026, closed 20 March 2026. Proposed mandatory UK SRS S2; estimated around 600 listed companies affected.

  6. FCA Handbook
    UK Listing Rules, UKLR 6.6 (annual financial report)

    Where the new comply-or-explain limbs, UKLR 6.6.6R(7A), (7B) and (8), sit from 1 January 2027.

  7. FCA Handbook
    Disclosure and Transparency Rules, DTR 4.1

    The annual financial report within four months of year end (DTR 4.1.3R) — the practical deadline for the disclosures.

  8. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2

    Published 25 February 2026 for voluntary use.

  9. Department for Business and Trade
    UK SRS S1 General Requirements (PDF) — ¶¶3, 18, 20–27, 60–73B and Appendix E

    The materiality test, the content areas, connectivity, the statement of compliance and the reliefs.

  10. Department for Business and Trade
    UK SRS S2 Climate-related Disclosures (PDF) — ¶¶5–37, B1–B63A and Appendix C

    Emissions, scenario analysis, targets, transition plans and the Scope 3 relief.

  11. Department for Business and Trade
    Exposure drafts of UK SRS: consultation response (PDF), Annex A

    The paragraph map of the UK differences from IFRS S1 and S2. It carries no count, so neither does this page.

  12. Department for Business and Trade
    UK Sustainability Reporting Standards — guidance

    “Available for voluntary use, by any entity that chooses to do so.”

  13. legislation.gov.uk
    Companies Act 2006, section 414CB

    The climate-related financial disclosure duty, for which UK SRS S2 is a national reporting framework under s 414CB(6).

  14. legislation.gov.uk
    Companies Act 2006, section 463

    The directors’ liability provisions that cover UK SRS disclosure placed in the strategic report.

  15. legislation.gov.uk
    The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (SI 2018/1155)

    SECR, which UK SRS does not replace.

  16. GOV.UK (Environment Agency)
    Energy Savings Opportunity Scheme (ESOS)

    Phase 4: qualification date 31 December 2026, notification of compliance by 5 December 2027.

  17. GOV.UK
    Modernising Corporate Reporting — consultation

    Open 7 September to 30 November 2026; considers how UK SRS should be reflected in the Companies Act.

  18. Financial Reporting Council
    ISSA (UK) 5000, General Requirements for Sustainability Assurance Engagements (PDF)

    Issued 12 November 2025 for voluntary use; effective for periods beginning on or after 15 December 2026.

  19. IFRS Foundation
    Use of IFRS Sustainability Disclosure Standards by jurisdiction

    The international baseline UK SRS endorses, and who else is adopting it.

  20. London Stock Exchange
    AIM Rules for Companies (PDF)

    AIM securities are not admitted to the Official List, so the listing-rule categories do not reach them.

  21. UK Parliament
    Written statement HCWS973, 21 October 2025

    The government’s policy statement on modernising corporate reporting.

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