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FCA consultation · closed record

CP26/5: what the FCA proposed, and what PS26/19 did with it

FCA CP26/5 proposed moving listed companies from TCFD-aligned disclosures to UK SRS, with UK SRS S2 on a mandatory basis.

It closed on 20 March 2026, and on 30 September 2026 the FCA answered it in PS26/19, which made the rules comply or explain across the board.

This page is the record of the consultation, proposal by proposal, beside what the final rules kept, changed or dropped.

Status

The consultation is closed, and answered

CP26/5 is a closed consultation, and nothing in it is a rule.

Its proposals now survive only where PS26/19 and its made instrument adopted them.

The consultation page itself was not updated when the policy statement appeared, and as read on 30 September 2026 it still says the FCA will “aim to publish a Policy Statement in autumn 2026”.

That sentence is history: read the final rules, provision by provision, for the law.

CP26/5 also described the UK SRS reliefs in their exposure-draft form, because the government told the FCA on 5 January 2026 that the final standards would not be ready when the consultation went live.

When UK SRS S1 and S2 were published on 25 February 2026, the relief periods had gone from the standards, leaving the FCA to set them — which PS26/19 did.

Still open

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

It is guidance on how to explain, not a reopening of the rules.

  1. 5 Jan 2026
    DBT writes to the FCA

    The final standards will carry no relief periods; timing will be set by FCA rules or regulations.

  2. 30 Jan 2026
    CP26/5 published

    Written against the exposure drafts of UK SRS.

  3. 25 Feb 2026
    UK SRS S1 and S2 published

    By DBT, for voluntary use.

  4. 20 Mar 2026
    CP26/5 closes
  5. 24 Sep 2026
    Instrument made

    By the FCA Board.

  6. 30 Sep 2026
    PS26/19 published

    With PMB 66 and draft TN 803.1.

  7. 28 Oct 2026
    TN 803.1 comments close

    The only open consultation left.

  8. 1 Jan 2027
    Rules in force

The ledger

Every proposal, and what became of it

Sixteen proposals from CP26/5, each with the paragraph that made it and the provision that answered it.

Sources: CP26/5 · PS26/19 and Appendix 1 · draft TN 803.1. “Kept” means kept in substance; paragraph numbers are the documents’ own.
CP26/5 proposedWherePS26/19Outcome
Replace the TCFD-aligned listing rules with UK SRSCP26/5 ¶4.4Done — the new rules replace the TCFD-aligned disclosures (PS26/19 ¶1.10)Kept
UK SRS S2 climate disclosures on a mandatory basis, excluding Scope 3CP26/5 ¶¶1.5, 4.4Comply or explain across all categories of disclosure (PS26/19 ¶¶1.2, 1.7)Changed
Scope 3 on comply or explainCP26/5 ¶¶1.5, 4.8Comply or explain, with a one-year relief (PS26/19 ¶3.14)Kept
UK SRS S1 beyond climate on comply or explainCP26/5 ¶1.6Comply or explain, with a two-year climate-first relief (PS26/19 ¶3.14)Kept
S1 explanation framed by risk or opportunity, not requirement by requirementCP26/5 ¶¶5.8–5.9Made as UKLR 6.6.6R(7B)(b)Kept
Explanations to include the timeframe for future disclosureCP26/5 ¶¶4.8, 5.8Made rule asks for steps; draft TN 803.1 says no timeframe is requiredChanged
UKLR 14 and 15: a statement signposting home-jurisdiction standards, no UK SRSCP26/5 ¶¶9.4–9.6Comply-or-explain UK SRS reporting, relying on home reporting where it meets UK SRS (PS26/19 ¶1.7)Changed
Six categories left out: UKLR 11, 12, 13, 17, 18, 19CP26/5 ¶3.5The same six (PS26/19 ¶3.7); the debt exclusion loses its “at this time”Kept
A rule, draft UKLR 6.6.6AR, listing the UK SRS S1 paragraphs a company “must apply”CP26/5 Appendix 1Made as guidance, UKLR 6.6.6A G: the company “is reminded”Changed
Early adopters lose the transitional reliefsCP26/5 ¶8.11Early adopters keep them (PS26/19 ¶3.19)Changed
Initial application window: periods beginning in 2027CP26/5 ¶8.8The same window (PS26/19 ¶3.18)Kept
State a relief is used; no explanation during the relief periodCP26/5 ¶8.12Kept (PS26/19 ¶3.20)Kept
Transition plans: say whether and where one is published, or why notCP26/5 ¶6.9Made as UKLR 6.6.6R(8)(e); no duty to have a planKept
Assurance: a statement of whether it was obtained, with provider, scope, level and standardsCP26/5 ¶¶7.5–7.7Made as UKLR 6.6.6R(8)(d); mandatory assurance kept under reviewKept
Disclosures in the annual financial report, with cross-referencing allowedCP26/5 Question 5Kept; cross-reference only as UK SRS S1 ¶¶B45–B47 permitKept
No digital tagging requirementCP26/5 Questions 18–19None proposed; the FCA continues to engage with the governmentKept

The central change

From mandatory S2 to comply or explain

CP26/5 asked three linked questions: whether to replace the TCFD rules, whether UK SRS S2 should be mandatory, and whether Scope 3 should be comply or explain.

Over 90% of respondents to the first question supported replacing the TCFD-aligned rules with UK SRS.

On mandatory S2, many buy-side and professional-services respondents were in favour, while listed companies were more mixed and asked for proportionality for smaller issuers.

Some respondents suggested a size threshold; the FCA rejected it, saying thresholds would add complexity and that climate exposure depends on business model rather than size.

On Scope 3, over two thirds of those who answered supported comply or explain, and most of the rest wanted to go further.

The FCA’s answer was to put the whole of UK SRS, S2 included, on comply or explain, and to publish draft guidance on what a good explanation contains.

On UK SRS S1, 78 of 113 respondents agreed with comply or explain, and more than a quarter of those asked for a clear path to mandatory S1; the FCA proceeded with comply or explain, saying it gives listed companies time to adjust.

For what an explanation now has to say, see UK SRS compliance; for how UK SRS S1 and UK SRS S1 and S2 fit together, the standards pages.

The FCA’s reasons, in its words

Disclosing fully in line with UK SRS “is not yet feasible for certain smaller issuers”, and a mandatory approach “may be disproportionately burdensome for small companies”.

A “well-reasoned explanation can give investors decision-useful information”.

Source: PS26/19, response to Questions 2–4

The other three changes

International issuers, early adopters and a rule that became guidance

International issuers. CP26/5 would have asked the secondary-listing and depositary-receipt categories only to state which home-jurisdiction standards they follow and where the disclosures sit.

PS26/19 received 66 responses on that question; two thirds supported it and a third wanted more.

Some respondents warned it could encourage companies to downgrade to a secondary listing to avoid disclosure, and the FCA moved these issuers onto comply-or-explain UK SRS reporting, with home reporting counting where it meets UK SRS.

Early adopters. CP26/5 ¶8.11 would have denied the transitional reliefs to a company that adopted the new rules early.

Respondents said that would penalise early adoption, and PS26/19 ¶3.19 removed the bar, so an early adopter keeps the reliefs.

The S1 paragraph list. CP26/5 drafted a rule telling companies which UK SRS S1 paragraphs they “must apply” to their climate disclosures.

The made text, UKLR 6.6.6A G, is guidance that “reminds” companies to apply UK SRS S1 so far as it relates to climate.

The numbers

What CP26/5 counted, and what PS26/19 does not

CP26/5’s cost-benefit analysis estimated that around 600 listed companies would be affected, and split them between the route that would report against UK SRS and the route that would only signpost.

PS26/19 abolished the split, so “515 must comply” no longer describes anything.

The policy statement gives no total of its own, and the only defensible number is the consultation’s estimate of around 600, labelled as such.

Who falls in each category is the subject of UK SRS thresholds and scope.

Sources: CP26/5 Annex 2 ¶43 · PS26/19 ¶4.35
FigureWhat it describedStatus now
Around 600Listed companies CP26/5 expected to be affectedThe consultation’s estimate
515CP26/5’s commercial, non-equity and transition routeDescribes a route the final rules abolished
89Issuers listed only as secondary listings or depositary receiptsNow under the same requirements as domestic issuers

The reliefs

Why CP26/5’s relief periods stopped matching the standards

CP26/5 ¶8.6 described a two-year relief for UK SRS S1 beyond climate and a one-year relief for Scope 3, “as set out in the Government’s exposure drafts”.

The final UK SRS S1 ¶E3 and UK SRS S2 ¶C4 carry no time limit at all, because the government chose to leave timing to FCA rules or regulations.

From 25 February 2026 until PS26/19 appeared, the consultation paper described relief periods the standards themselves no longer contained.

PS26/19 closed the gap by writing the periods into UKLR TP 16: one year for Scope 3 and two years for the climate-first relief, both from initial application in a period beginning in 2027.

The Scope 3 detail is on UK SRS Scope 3 reporting, and where your first period falls is worked through on the FCA rules page.

Who responded

Positions on the record, in respondents’ own words

A response speaks for its author.

None of these is evidence of what the rules say; the ledger above is.

The Investment Association

The IA’s own summary backed UK SRS S1 and S2 and supported comply or explain for areas such as Scope 3, while describing the FCA’s proposal as mandatory S2 with comply or explain for S1.

It gives its membership as 250 firms managing £10.0 trillion; more on the IA’s site.

Norges Bank Investment Management

In its letter of 20 March 2026 NBIM wrote that “UK SRS S1 should also have a clear mandatory reporting timeline”, and asked for mandatory Scope 3 after the transition period.

The final rules went the other way on both.

Professional bodies

The Institute and Faculty of Actuaries publishes its policy responses on its sustainability hub, and ICAEW its technical work on sustainability and climate change.

Commentary written before PS26/19

Summaries by KPMG, Eversheds Sutherland and Latham & Watkins describe CP26/5 as proposed, including mandatory S2.

They are accurate records of the consultation and out of date on the rules.

Assurance and transition plans

Two proposals carried through unchanged

On assurance, CP26/5 proposed a statement of whether third-party assurance was obtained, not a duty to obtain it, and PS26/19 kept that shape.

The FCA will keep the case for mandatory assurance under review, and the government’s oversight regime for assurance providers is voluntary; see sustainability assurance.

On transition plans, the FCA proceeded “as consulted on”: a company says whether and where it has published a plan, or why not, and is not required to have one.

The policy position on plans themselves sits with the government; UK SRS and transition-plan disclosure covers it.

The UK amendments to the ISSB standards that UK SRS carries were recommended by the FRC’s technical advisory committee, not by the FCA.

What to do with this

If you were preparing against CP26/5

Work done against the consultation is not wasted: the architecture, the S1 and S2 content and the relief windows survived.

What changes is the default: a gap in S2 is now explained, not a breach, and the explanation has to meet the FCA’s expectations once TN 803.1 is final.

A UK SRS readiness assessment is the place to re-sort the work by what you will disclose and what you will explain.

The wider programme around UK SRS, including the government’s Modernising Corporate Reporting consultation, is mapped on UK sustainability reporting.

The rulebook itself is the UK Listing Rules on the FCA Handbook, and the FCA’s other autumn instrument, on asset managers’ TCFD product reports, answered a separate consultation, CP26/17.

Frequently asked

CP26/5, answered

What is FCA CP26/5?

CP26/5, Aligning listed issuers' sustainability disclosures with international standards, is the FCA consultation paper published on 30 January 2026 that proposed replacing the TCFD-aligned listing rules with requirements to report against UK SRS. It closed on 20 March 2026.

The FCA answered it in PS26/19 on 30 September 2026.

Is CP26/5 still open?

No. The consultation closed on 20 March 2026 and the FCA published its final rules in PS26/19 on 30 September 2026.

The only live FCA consultation in this area is on draft Technical Note 803.1, in Primary Market Bulletin 66, with comments due by 28 October 2026.

Did the FCA make UK SRS S2 mandatory?

No. CP26/5 proposed mandatory UK SRS S2 climate disclosures, excluding Scope 3.

PS26/19 adopted a comply-or-explain approach across all categories of disclosure instead, S2 included.

What changed between CP26/5 and PS26/19?

Four things of substance.

UK SRS S2 moved from mandatory to comply or explain.

Secondary-listing and depositary-receipt issuers moved from a signposting statement to comply-or-explain UK SRS reporting.

Early adopters kept the transitional reliefs instead of losing them.

And the list of UK SRS S1 paragraphs to apply was made as guidance rather than as a rule.

Draft guidance also drops the timeframe CP26/5 wanted in an explanation.

How many companies did CP26/5 cover?

CP26/5 estimated that around 600 listed companies would be affected, 515 of them in the commercial, non-equity and transition categories and 89 listed only as secondary listings or depositary receipts. That split described the consultation’s two routes.

PS26/19 puts the 89 on the same requirements as domestic issuers and gives no total count of its own.

Why did CP26/5 describe the reliefs as one year and two years?

CP26/5 was written against the government’s exposure drafts, which carried those periods.

The final UK SRS, published on 25 February 2026, removed the time limits from the standards and left timing to FCA rules or regulations.

PS26/19 then set the periods itself: one year for Scope 3 and two years for UK SRS S1 beyond climate.

How many responses did CP26/5 receive?

PS26/19 reports responses by question rather than a single total in the text read for this page: for example 94 of 110 respondents supported the proposed scope, 78 of 113 agreed with comply or explain for UK SRS S1, and there were 66 responses on the secondary-listing proposal.

The full list of respondents is in PS26/19 Annex 1.

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 13 sources fromFinancial Conduct AuthorityDepartment for Business and TradeFinancial Reporting CouncilThe Investment AssociationNorges Bank Investment Management
  1. Financial Conduct Authority
    CP26/5: Aligning listed issuers' sustainability disclosures with international standards — consultation page

    Opened 30 January 2026, closed 20 March 2026. The page still carries its pre-publication “next steps” wording.

  2. Financial Conduct Authority
    CP26/5 (PDF) — ¶¶1.5–1.7, 3.4–3.9, 4.4, 4.8, 5.8–5.12, 6.9, 8.6–8.12, 9.4–9.6 and Annex 2 ¶43

    Every “as proposed” cell in the ledger.

  3. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    Published 30 September 2026; the policy statement that answers CP26/5.

  4. Financial Conduct Authority
    PS26/19 (PDF) — Chapter 2 feedback, ¶¶1.7, 1.10, 3.7, 3.14, 3.18–3.20, 4.35 and Appendix 1

    Every “as made” cell in the ledger, and the response counts quoted.

  5. Financial Conduct Authority
    Primary Market Bulletin 66

    The consultation on draft TN 803.1, open to 28 October 2026.

  6. Financial Conduct Authority
    Primary Market TN 803.1 (draft, September 2026)

    Says no expected timeframe is required in an explanation.

  7. Department for Business and Trade
    Letter from DBT to the FCA, 5 January 2026 (PDF)

    Why CP26/5 described reliefs the final standards did not keep.

  8. Department for Business and Trade
    UK SRS S1 General Requirements (PDF) — Appendix E

    The climate-first relief at ¶E3, with no time limit of its own.

  9. Department for Business and Trade
    UK SRS S2 Climate-related Disclosures (PDF) — Appendix C

    The Scope 3 relief at ¶C4, with no time limit of its own.

  10. Department for Business and Trade
    An oversight regime for sustainability assurance — government response

    The voluntary registration regime for assurance providers.

  11. Financial Reporting Council
    UK Sustainability Disclosure Technical Advisory Committee

    The body that recommended the UK amendments to the ISSB standards.

  12. The Investment Association
    IA response to FCA consultation on aligning listed issuers’ sustainability disclosures, 23 March 2026

    The IA’s own summary of its CP26/5 position.

  13. Norges Bank Investment Management
    Letter to the FCA on CP26/5, 20 March 2026

    NBIM’s own response, quoted for its position only.

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