ESRS · UK SRS · a gap analysis from the EU side
ESRS vs UK SRS: starting from an ESRS statement
ESRS vs UK SRS looks different depending on which report you already have.
This page starts from an ESRS sustainability statement — the one an EU-parented group, an EU-listed issuer or a group with an in-scope EU subsidiary already prepares — and asks what UK SRS still needs.
The short answer: most of the climate work carries, a handful of UK SRS requirements are extra, and a listed company adds the FCA’s comply-or-explain statement.
Which way round
Two comparisons, two different jobs
The same two regimes can be compared from either end, and the answer is not symmetrical.
Starting from UK SRS and moving to the ESRS, the work is large: the impact lens, ten topical standards and both Scope 2 methods have to be added — that analysis is on UK SRS vs ESRS, from the UK side.
Starting from the ESRS and moving to UK SRS, the work is smaller but specific.
The joint ESRS–ISSB interoperability guidance says “almost all the disclosures in ISSB Standards related to climate are included in ESRS” — which is the direction that helps an ESRS reporter.
It is not the converse, and it does not say an ESRS statement is a UK SRS report.
Who starts from the ESRS?
An EU-parented group with a UK listing; a UK group whose EU subsidiary has reported as a wave-one company since 2024; and an issuer listed in both the EU and the UK.
Whether the CSRD reaches a UK group at all is a scoping question, answered on CSRD vs UK SRS.
The vocabulary
CSRD and ESRS: the duty and the content
The CSRD and the ESRS are often run together, and the difference matters when comparing them with the UK.
The CSRD is the duty: the directive that requires an in-scope company to publish a sustainability statement in its management report, with limited assurance.
The ESRS are the content: the standards that say what the statement contains.
The UK has the same split.
UK SRS S1 and S2 are the content, published by the Department for Business and Trade as voluntary standards.
The duty, for listed companies only, is the FCA’s listing rules, which since PS26/19 ask them to report against UK SRS or explain.
So the fair comparisons are ESRS with UK SRS, and the CSRD with the FCA’s rules — which is how this page is organised.
The Commission’s CSRD page and our ESRS guide cover the EU side in full.
| CSRD | ESRS | |
|---|---|---|
| What it is | A directive | Delegated regulations |
| Instrument | Directive (EU) 2022/2464, read in Directive 2013/34/EU | DR (EU) 2023/2772, replaced from FY2027 by DR (EU) 2026/1563 |
| What it decides | Who reports, where, and with what assurance | What the sustainability statement contains |
| Needs transposition? | Yes, into each Member State’s law | No, directly applicable |
| UK counterpart | The FCA’s listing rules (for listed companies) | UK SRS S1 and S2 |
The disclosure map
What an ESRS statement already gives you
Area by area, starting from the revised ESRS and asking what UK SRS adds.
The last column is the work.
| Area | ESRS (revised) | UK SRS | For UK SRS |
|---|---|---|---|
| Materiality | Impact or financial, or both (ESRS 1) | Financial only: could reasonably be expected to influence primary users (S1 ¶18) | Carries: take the financially material subset |
| General disclosures | ESRS 2: BP, GOV-1 to GOV-4, SBM-1 to SBM-3, IRO-1, IRO-2 | Four content areas: governance, strategy, risk management, metrics and targets (S1 ¶25) | Carries: re-cut into the four areas |
| Scenario analysis | E1: disclosed if used | Required for the resilience assessment (S2 ¶22), commensurate with circumstances | Add, if you have not used it |
| Resilience assessment | Not required annually | Annual (S2 ¶B18) | Add an annual assessment |
| Scope 1 | Gross Scope 1 | Scope 1 | Carries |
| Scope 2 | Location-based and market-based | Location-based required; market-based permitted (S2 ¶29(a)(v), ¶B30) | Carries |
| Scope 3 | Each significant category, where material | Required, by category; one-year relief under the FCA rules | Carries |
| Targets | Gross; no removals, credits or avoided emissions | Targets as set; a net target needs its gross target too | Carries |
| Internal carbon price, pay | Check what your E1 and GOV disclosures hold | Named cross-industry metrics (S2 ¶29(f)–(g)) | Check, and add if absent |
| Financed emissions | No E1 equivalent (EFRAG’s 2023 mapping) | Required for asset management, banking and insurance (S2 ¶¶B59–B61); UK-only ¶B59A | Add, if a financial institution |
| Industry-based guidance | No sector ESRS | An entity “may refer to” the industry-based guidance when identifying risks (S2 ¶12) | Lighter than IFRS S2 |
| Location and timing | A section of the EU management report | General purpose financial reports, same time and period as the accounts (S1 ¶¶60, 64) | Move into the UK annual report |
| Assurance | Limited assurance required | Not required; if obtained, provider, scope and standard named | Add a sentence |
| Regulatory statement | Which ESRS version applied (FY2026 only) | Comply or explain against S2 and S1; reliefs; transition-plan statement (UKLR 6, 16, 22) | Add the FCA statement |
Read down the last column: the emissions rows carry, and the additions cluster around how UK SRS treats climate resilience, financial institutions and the annual report.
Scenario analysis is the sharpest difference.
Revised ESRS E1 asks for disclosure about climate scenario analysis only if the company uses it, and does not require a resilience analysis every year.
UK SRS S2 requires scenario analysis for the resilience assessment, with an approach commensurate with the company’s circumstances, and requires the resilience assessment itself annually even where the scenario analysis follows the strategic planning cycle.
The interoperability guidance makes the same point for IFRS S2: an entity starting with ESRS must state the scenario disclosures in IFRS S2 paragraph 22(b)(i) explicitly.
Industry-based metrics run the other way for a UK reporter: IFRS S2 requires an entity to refer to and consider the industry-based guidance, but UK SRS S2 paragraph 12 makes it “may”.
Financed emissions are an addition for banks, asset managers and insurers, and the UK added a duty the ISSB does not have: where financed emissions cannot be estimated for the same period as the accounts, explain why and give a plan with a timeline (paragraph B59A).
Plan the additions
From your ESRS work to a UK SRS report
Answer six questions about the UK entity and the ESRS statement you already have.
The planner lists what UK SRS adds, and the parts of the statement a listed company makes in its annual financial report.
Under the FCA’s final rules that statement says, for UK SRS S2 and then S1, whether the company complies and, for anything it does not, why not and the steps it plans.
The S2 limb asks for steps but no timeframe.
A company using a relief — one year without Scope 3, two years without S1 matters beyond climate — says so, and needs give no further explanation during the relief.
A company in UKLR 6, 16 or 22 also says whether it has published a climate transition plan and where; if it has not, why not.
That statement does not apply to UKLR 14 and 15.
Where assurance was obtained, the company names the provider, the disclosures assured and the standard used (PS26/19 ¶2.45).
The rules apply to accounting periods beginning on or after 1 January 2027, with first reports in 2028; they finalise CP26/5, which had proposed a mandatory S2.
What “comply or explain” requires in practice is on UK SRS compliance.
From an ESRS statement to UK SRS
What UK SRS adds to your ESRS work
- Run climate-related scenario analysis for the resilience assessment (UK SRS S2 ¶22), commensurate with your circumstances (¶¶B1–B17). The ESRS let you omit it if you have not used it; UK SRS does not.
- Assess climate resilience every year (UK SRS S2 ¶B18), even if the scenario analysis itself follows the strategic planning cycle.
- Check the two cross-industry metrics UK SRS S2 names outright: whether and how an internal carbon price is used, and the share of executive pay linked to climate (¶29(f)–(g)).
- Move the disclosures into the general purpose financial reports — for a UK company, typically the strategic report — published at the same time and for the same period as the financial statements (UK SRS S1 ¶¶60, 64).
- Keep the location-based Scope 2 figure you already report under ESRS E1: it is the one UK SRS S2 requires (¶29(a)(v), ¶B30).
What the annual financial report must state
- A statement against UK SRS S2: complies, or explains for each part not met why not and the steps planned (UKLR 6.6.6R(7A), or the matching rule for your category).
- A statement against UK SRS S1 on the same comply-or-explain basis (UKLR 6.6.6R(7B), or its equivalent).
- Any relief used — one year without Scope 3, two years without S1 matters beyond climate — named as used; no further explanation needed during the relief (PS26/19 ¶¶3.14, 3.20).
- That no transition plan is published, and why not (UKLR 6.6.6R(8)(e)).
- Who gave the assurance, which disclosures it covered and the standard used (PS26/19 ¶2.45).
Rules: UK SRS S1 ¶¶60, 64; UK SRS S2 ¶¶22, 29, B18, B30, B59–B61, B59A; FCA PS26/19 and UKLR 6.6.6R(7A), (7B), (8), for accounting periods beginning on or after 1 January 2027.
A planning aid; materiality stays your judgement.
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Materiality
Take the financial subset, leave the impacts
An ESRS double materiality assessment is a superset of what UK SRS needs.
The joint guidance says the financial-materiality definition in the ESRS is aligned with the definition of materiality in IFRS S1, which UK SRS S1 carries.
What is not aligned is the regime: under the ESRS a matter is material if it is material from the impact perspective or the financial perspective, or both.
So the financially material conclusions transfer; the impact-only conclusions have no UK SRS home.
An impact enters UK SRS only through the risk or opportunity it creates for the company — a regulatory fine, a lost customer, a cost of capital.
EFRAG’s non-authoritative IG 1 put it from the EU side: an ESRS reporter “is expected to be able to comply” with the identification of risks and opportunities under the ISSB standards.
The comparer beside this text applies each regime’s test to one matter you describe.
The method for running the assessment is on the double materiality assessment, and the concept on double materiality.
One matter, four tests
Answer both to see how each regime treats the matter.
Tests: Directive 2013/34/EU Art 19a(1) and CSRD recital 29 (either perspective); revised ESRS 1 ¶24 (immaterial information not disclosed); UK SRS S1 ¶¶3, 18; GRI 1 §2.2; EFRAG’s ESRS-40a exposure draft.
You make the two judgements; this applies each regime’s test to them.
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The architecture
Twelve ESRS against two UK standards
The revision kept all twelve ESRS.
Only E1 has a UK SRS counterpart; the rest reach UK SRS only through S1’s general test.
| ESRS | Topic | Where it lands in UK SRS |
|---|---|---|
| ESRS 1 · ESRS 2 | General requirements and disclosures | UK SRS S1: conceptual foundations, the four content areas |
| E1 | Climate Change | UK SRS S2, almost line for line on emissions |
| E2 | Pollution | S1, only if a risk or opportunity could affect prospects |
| E3 | Water | S1, only if a risk or opportunity could affect prospects |
| E4 | Biodiversity and Ecosystems | S1, only if a risk or opportunity could affect prospects |
| E5 | Resource Use and Circular Economy | S1, only if a risk or opportunity could affect prospects |
| S1 to S4 | Own workforce, value-chain workers, communities, consumers | S1, only if a risk or opportunity could affect prospects |
| G1 | Business Conduct | S1, only if a risk or opportunity could affect prospects |
An ESRS reporter’s non-climate disclosures are not wasted for UK SRS.
IFRS S1 names the ESRS as a source of guidance an entity may use for topics beyond climate, so ESRS material can be the basis of S1 disclosures — provided the S1 requirements themselves are met.
Applying the guidance without the standard’s requirements does not support a statement of compliance (IFRS S1 Appendix C, C3).
Under the FCA’s rules, a company can take two years’ relief from S1 matters beyond climate, so for the first two UK reports the non-climate ESRS material is optional for UK purposes.
The UK departures from IFRS S1 and S2 are mapped in the government’s response to the UK SRS exposure drafts, which gives no headline count; none of them adds an impact lens.
The UK general standard is set out on UK SRS S1, and the ISSB climate standard behind S2 on IFRS S2; the ISSB’s own pages carry the originals.
Assurance and location
Two differences that are not about content
Assurance runs opposite ways.
An ESRS statement under the CSRD carries a limited assurance opinion, covering compliance with the ESRS, the materiality process and the Taxonomy disclosures.
A UK SRS report under the FCA’s rules needs no assurance; if the company obtains some, it says who, over what and to which standard.
So an ESRS reporter that reuses assured data in its UK report can say so, and name the scope — but the UK statement must not imply that the UK report itself was assured where it was not.
The UK position on assurance standards, including ISSA (UK) 5000 for voluntary use, is on sustainability assurance, and the FRC’s sustainability pages carry the regulator’s own material.
Location runs differently too.
An ESRS statement is a section of the EU management report of the entity in scope.
UK SRS disclosures sit in the UK company’s general purpose financial reports, at the same time and for the same period as its financial statements, with comparatives — though not in the first year (UK SRS S2 ¶C1).
An EU subsidiary’s statement does not become the UK parent’s UK SRS report by being linked from it.
Build the GHG inventory once with both Scope 2 methods; run the double materiality assessment once and tag its financially material subset; keep scenario analysis on a cycle that supports an annual UK resilience assessment.
Then cut two reports, each in its own place.
Which applies to you
Who reports under which
UK group, no EU entity in scope
UK SRS only.
If listed in UKLR 6, 14, 15, 16 or 22, report against it or explain from 2027; otherwise voluntary.
UK group with an in-scope EU subsidiary
The subsidiary reports under the ESRS; the listed UK parent reports against UK SRS.
Start the UK report from the subsidiary’s climate work, not its whole statement.
EU-parented group with a UK listing
The group reports under the ESRS.
The UK-listed entity makes the FCA statement against UK SRS — this page’s main case.
Issuer listed in the EU and the UK
The ESRS statement for the EU listing; the UK SRS statement for the UK listing.
The planner above lists the additions.
The CSRD reaches an EU entity only above both €450 million net turnover and 1,000 employees, from financial year 2027, under Article 19a of the consolidated Accounting Directive.
Our sister reference on sustainability reporting standards covers the standards editorially; for the frameworks investors use alongside both, see ESG reporting.
For the UK reference view of where things stand, start at the uksrs.org.uk home page, or book a free 15-minute call to talk a specific group through it.
Frequently asked
Questions people ask
What is the difference between ESRS and UK SRS?
The ESRS are the EU’s twelve standards under the CSRD: double materiality across environmental, social and governance topics.
UK SRS S1 and S2 are the UK’s endorsement of the ISSB’s IFRS S1 and S2: financial materiality, a general standard and a climate standard.
On climate they overlap heavily; beyond climate and on impacts, the ESRS ask for more.
What is the difference between CSRD and ESRS?
The CSRD is the directive that creates the duty to publish a sustainability statement, now read in Articles 19a and 29a of the Accounting Directive.
The ESRS are the standards that say what goes in it, set by Commission delegated regulation and revised in 2026 as Delegated Regulation (EU) 2026/1563.
Does an ESRS statement satisfy UK SRS?
Not on its own.
It covers most of what UK SRS asks on climate, and the financial-materiality definition is aligned.
But UK SRS S2 requires climate scenario analysis and an annual resilience assessment, names an internal carbon price and climate-linked pay, and asks financial institutions for financed emissions.
The disclosures must also sit in the UK annual report, and a listed company adds the FCA’s comply-or-explain statement.
Can a UK company use ESRS instead of UK SRS for the FCA’s rules?
No. The FCA’s final rules ask listed companies to report against UK SRS or explain.
IFRS S1 names the ESRS as a source of guidance, but an entity applying guidance without the standard’s own requirements cannot state compliance.
A company can build its UK SRS disclosures from ESRS work, and should say which UK SRS requirements it meets.
How many ESRS standards are there?
Twelve: two cross-cutting standards, ESRS 1 General Requirements and ESRS 2 General Disclosures, and ten topical standards — E1 to E5 on the environment, S1 to S4 on social matters and G1 on business conduct.
The 2026 revision kept all twelve.
Is UK SRS mandatory?
No. UK SRS S1 and S2 are voluntary standards.
Under the FCA’s final rules, PS26/19 of 30 September 2026, listed companies in UKLR 6, 14, 15, 16 and 22 report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reports in 2028.
Which Scope 2 figure carries across?
The location-based one.
ESRS E1 asks for location-based and market-based Scope 2; UK SRS S2 requires location-based and permits market-based.
A group already reporting under the ESRS holds the figure UK SRS requires.
Do the two regimes treat assurance the same way?
No. A CSRD statement needs a limited assurance opinion.
The FCA’s rules do not require assurance of a UK SRS report; where assurance is obtained, the company names the provider, which disclosures were assured and the standard used.
Is materiality the same under ESRS and UK SRS?
The financial-materiality definition is aligned, according to the joint ESRS–ISSB interoperability guidance.
The regimes differ because the ESRS add impact materiality.
So the financially material part of an ESRS assessment is the natural starting point for UK SRS; the impact-only conclusions have no UK SRS counterpart.
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.
- EUR-LexDelegated Regulation (EU) 2026/1563 — the revised ESRS, Annex I
Twelve standards; applies to financial years beginning on or after 1 January 2027.
- EFRAGESRS Knowledge Hub — revised ESRS E1 (delegated-act text)
Scenario analysis “if used”; resilience analysis not required annually; Scope 2 location- and market-based.
- EUR-LexDirective 2013/34/EU, consolidated 18.03.2026 — Arts 19a, 29a, 34
The CSRD duty, its scope and limited assurance.
- IFRS Foundation / EFRAGESRS–ISSB Standards Interoperability Guidance, 2 May 2024
Financial-materiality definition aligned; what an entity starting with ESRS adds for ISSB. Maps the 2023 ESRS.
- Department for Business and TradeUK SRS S1 — ¶¶3, 18, 60, 64
Financial materiality; disclosures in the general purpose financial reports, same time and period.
- Department for Business and TradeUK SRS S2 — ¶¶12, 22, 29, B18, B30, B59–B61, B59A, C1
Scenario analysis, annual resilience, cross-industry metrics, location-based Scope 2, financed emissions.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026 for voluntary use.
- Department for Business and TradeExposure drafts of UK SRS: consultation and response
Where the UK departures from IFRS S1 and S2 are mapped.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards
Comply or explain against UK SRS for UKLR 6, 14, 15, 16 and 22, periods from 1 January 2027.
- Financial Conduct AuthorityPS26/19 (PDF) — ¶¶2.37, 2.45, 3.14, 3.20
The transition-plan and assurance statements, and the reliefs.
- IFRS FoundationIFRS S1 — ¶¶55, 60–64 and Appendix C
Sources of guidance (ESRS named); no compliance statement on guidance alone.
- European Commission (DG FISMA)Corporate sustainability reporting
The Commission’s CSRD page.