CP26/5 Consultation Tracker — Status, Responses, and What Happens Next
Last updated: 17 May 2026
The FCA's Consultation Paper CP26/5: Aligning listed issuers' sustainability disclosures with international standards is the proposed mechanism by which UK SRS S2 climate disclosures become mandatory for listed companies from 1 January 2027.
This page tracks where the consultation stands today, what major stakeholders said in response, and what to expect before the Policy Statement is published in autumn 2026.
Current status
The FCA confirmed on its CP26/5 landing page that it aims to publish a Policy Statement in autumn 2026, subject to the final UK SRS, with the rules coming into force from 1 January 2027.
What CP26/5 proposes
Mandatory UK SRS S2
Climate disclosures for listed companies in UKLR categories 6, 16, and 22 (and certain category 14 and 15 entities with variations), for accounting periods beginning on or after 1 January 2027.
Scope 3 "Comply or Explain"
One-year transitional relief for Scope 3 emissions — effectively mandatory from accounting periods beginning on or after 1 January 2028. Analysis from KPMG.
S1 Two-Year Relief
UK SRS S1 (non-climate) disclosures on a "comply or explain" basis with two-year transitional relief — effectively from accounting periods beginning on or after 1 January 2029.
Voluntary Assurance
No mandatory assurance, but companies must disclose whether they obtained voluntary third-party assurance, the provider, level, standard used, and where the report can be found. Eversheds Sutherland analysis.
Transition Plans Optional
No mandatory transition plan disclosures, but "comply or explain" requirement to state whether published and where, or why not. The FCA notes mandating transition plans is a Government matter. Latham & Watkins analysis.
Major stakeholder responses
The consultation attracted formal responses from institutional investors, industry bodies, professional bodies, and the Big Four.
Selected positions on the most consequential questions:
Investment Association (asset managers)
Represents UK asset managers responsible for £9.1 trillion in assets, 49% overseas client money
In its final response to CP26/5:
- Supported mandatory UK SRS S2 climate disclosure on the proposed timetable
- Backed retention of Scope 3 "comply or explain" with one-year relief
- Encouraged the FCA to set a clear mandatory date for UK SRS S1 rather than leaving it as open-ended
- Asked for a roadmap for applying UK SRS to FCA-regulated asset managers and asset owners
Norges Bank Investment Management
Norway's sovereign wealth fund manager
Responded directly with a more assertive position:
"UK SRS S1 should also have a clear mandatory reporting timeline. Non-climate sustainability information is equally capable of being financially material... An open-ended 'comply or explain' regime provides insufficient certainty for preparers or investors."
Institute and Faculty of Actuaries
The IFoA response agreed with mandatory UK SRS S2 and supported Scope 3 "comply or explain." Also supported consequential amendments allowing asset managers, life insurers, and FCA-regulated pension providers to cross-refer to UK SRS S2 disclosures in their TCFD entity reports.
ICAEW
Supported the four TAC-recommended amendments, with one important request: temporary relief from the requirement to restate comparative information for Scope 3 emissions, on the grounds that annual restatement presents "significant practical challenges."
What to expect before autumn 2026
FCA may publish a Primary Market Bulletin signalling its approach to monitoring and enforcement, as flagged by Latham & Watkins.
FRC launches the interim sustainability assurance practitioner register, which will materially affect how listed companies disclose assurance arrangements under the new rules. See our sustainability assurance page for the detail.
FCA was expected to consult separately on streamlining TCFD product-level reporting rules for FCA-regulated asset managers and asset owners. The IA's response references this work as ongoing.
Government consultation on the Modernising Corporate Reporting programme, including consideration of UK SRS reporting for large private companies. See our MCR primer.
Policy Statement and final rules published.
What in-scope companies should be doing now
The implementation guidance from KPMG, PwC, Slaughter and May, and Eversheds Sutherland converges on broadly the same readiness actions. We've consolidated these into a 12–18 month implementation roadmap as part of our UK sustainability reporting landscape guidance.
The single most important strategic point: do not wait for the Policy Statement. CP26/5 is detailed enough that gap analysis, governance setup, data infrastructure, and scenario analysis can all begin now.
Companies that start in summer 2026 will have a comfortable margin to FY2027 reporting. Companies that wait until autumn 2026 will not.