FCA sustainability disclosure requirements: the rule that binds you today
If your shares are admitted to the Official List, the sustainability disclosure requirement you are actually subject to is a listing rule — UKLR 6.6.6R(8) in the FCA Handbook — and it is in force, unamended, this morning.
The regime the FCA itself calls Sustainability Disclosure Requirements is a different thing entirely: it governs how investment products are labelled and marketed, and it has nothing to say about your annual report.
Find your listing category, and what it means One question · four verdicts · nothing leaves your browserTwo FCA regimes share one name — and only one of them is about you
The FCA's SDR regime page and its sustainability reporting requirements page sit one click apart, and neither says which reader it is for.
If you run a fund and you are here about labels, naming or the anti-greenwashing rule, the page you want is FCA SDR and the anti-greenwashing rule. Nothing below this line applies to you.
Below here, everything is either a rule or a proposal — and the difference is the whole page.
UKLR 6.6.6R(8) — the requirement you are subject to right now
The UK Listing Rules replaced the old Listing Rules sourcebook on 29 July 2024, and with it the premium and standard segments disappeared [1].
What survived the move is the climate disclosure duty, renumbered.
If you have equity shares listed as a commercial company, UKLR 6.6.6R(8) requires your annual financial report to carry a statement saying whether your climate-related financial disclosures are consistent with the TCFD Recommendations and Recommended Disclosures — and, where they are not, where they are, why not, and when you expect to be able to make them [1].
16.3.23R · 22.2.24R
Three things follow, and each contradicts something you will read elsewhere this week.
“The FCA's SDR applies to listed companies”
“TCFD reporting has been replaced”
“Premium-listed companies must…”
The FCA's power to make this rule comes from section 73A of the Financial Services and Markets Act 2000, and how it supervises and enforces against it is a separate subject — the FCA's UK SRS authority and enforcement covers the statutory machinery and the National Storage Mechanism.
The eleven recommended disclosures your statement is measured against
UKLR 6.6.6R(8) does not itself list what to disclose.
It points at the TCFD's four pillars and their eleven recommended disclosures, and asks whether your report is consistent with them [1][2].
This is the list — and it matters twice, because UK SRS S2 inherits the same four pillars and the same eleven items intact [3].
Note what the eleventh item says, and what it does not: under TCFD, Scope 3 is disclosed “if appropriate”.
Under UK SRS S2 that judgement disappears, which is the single largest change hiding inside a proposal that is usually described as a like-for-like swap [4].
The eleven disclosures in full, with the TCFD's own supplemental guidance, are on the TCFD recommended disclosures; the framework's history and status sit on TCFD reporting in the UK.
Which listing category are you in, and what does it actually mean?
The FCA's proposal is scoped by UK Listing Rules category, not by company size, turnover or index membership [5].
Five categories are named in it, and they do not carry the same obligation as each other — two of the five would have no UK SRS duty at all [6].
Five more are carved out by name, which is a different answer from simply not being on the list [7].
This is the question every other page on this subject answers with a table. Pick your category and read the consequence.
The five UKLR categories in scope, and what each one actually means
These are the FCA Handbook's own chapter titles, verified against the Handbook on 8 August 2026 — because getting them wrong is the commonest error on this subject, and it was live in our own tooling until this page was built [8].
The distinction between the full route and the statement route is not a technicality: it is the difference between building a UK SRS S2 reporting capability and writing one paragraph about your home venue.
How many companies sit in each category, and the edge cases — dual listings, newly admitted issuers, companies changing category mid-period — belong to UK SRS who is in scope, and the population question to UK SRS thresholds.
Five things are carved out by name, which is not the same as being unmentioned
Being outside a rule because nobody thought of you is a weak position; being outside it because the regulator listed you is a strong one.
CP26/5 names five exclusions [7]:
If you are in one of those five, the proposal does not reach you — and neither does the rule it would replace.
You may still choose to report against UK SRS S1 and S2, which the Department for Business and Trade published on 25 February 2026 for voluntary use [9].
Deletion and replacement, not amendment
CP26/5 does not propose to update the TCFD listing rules.
It proposes to delete them and put mandatory UK SRS S2 in their place [10].
That distinction is easy to lose and it changes what you should be building.
That last row is the one most commentary gets backwards.
The four-pillar architecture is not being dissolved; the listing rule is [3][10].
Where the consultation itself has got to — who responded, what they argued, and when a Policy Statement might land — is tracked on the CP26/5 consultation tracker. The rest of this page is about what the rules would require, not about the process.
The full route and the statement route are different obligations entirely
Every summary of CP26/5 you will read describes “five categories in scope”.
Two of those five would not report under UK SRS at all [6].
The logic is that a secondary listing should not force a second, parallel reporting regime onto a company already reporting somewhere else.
The practical consequence is that if you are UKLR 14 or 15, the correct response to CP26/5 is to read your home-venue requirements and draft one paragraph — not to procure a carbon accounting platform [6].
Two transitional reliefs, and they run from different starting points
The proposal is climate-first, and it phases in over three reporting cycles [6][11].
One thing the reliefs do not defer: the conceptual foundation of UK SRS S1.
Even during the climate-first years, S1's requirements about materiality, the reporting entity, connected information and fair presentation apply to the climate disclosures you are making [11].
A company that reads “S1 is deferred for two years” as “S1 is irrelevant for two years” has misread it.
What S1 and S2 actually require, standard by standard, is on UK SRS S1 and UK SRS S2, and how they interlock on UK SRS S1 and S2.
Where the proposal has actually got to
This is the chapter that dates fastest, so it is built from a single verified status block rather than scattered through the page.
The FCA's own words on its consultation page, quoted in full, are the most useful sentence on this subject and almost nobody reproduces them [12]:
This consultation has now closed. We will review the feedback and aim to publish a Policy Statement in autumn 2026, subject to the final UK SRS, with the rules coming into force from 1 January 2027.
Read the conditionals. The FCA aims to publish; the timing is subject to the final UK SRS; and 1 January 2027 is what the rules would come into force from if both of those hold.
Every professional summary of CP26/5 in the first page of search results was written in February 2026 and none has been revised since.
They describe a January 2027 start as though it were fixed, because when they were written there was no reason to think otherwise.
If you need the process view — stakeholder positions, what a Policy Statement usually contains, what to watch for — the CP26/5 consultation tracker is the page that follows it, and the UK SRS consultation covers the earlier exposure drafts.
Every date that matters, from the first climate listing rule to the first mandatory report
Six of these dates have happened. Four have not, and are marked as proposals.
The single-date question — is 1 January 2027 real, what happens if it moves — is the UK SRS deadline's subject, and the wider regulatory calendar is on the UK sustainability regulation timeline.
Which of your accounting periods would carry which duty
The proposal attaches to accounting periods beginning on or after 1 January 2027, so the answer depends on your year end and nothing else [12].
A December year end and a March year end are a full year apart in when the first mandatory report lands, and roughly fifteen months apart in when the data collection has to start.
Enter your period start and category, and the component lays out your next four periods — what is mandatory, what is comply-or-explain, what is voluntary, and which calendar year each report's underlying data comes from.
Every row it produces is conditional on a Policy Statement that does not exist yet, and it says so on every row.
Your first mandatory report is built from data you are generating now
This is the part almost nobody writes down, and it is the only part with a deadline that has already passed you.
Take the cleanest case: a company with a 31 December year end, in UKLR 6.
The 2026 period is the last one in which a measurement decision can be made quietly.
After it, changing your emissions boundary or your Scope 2 method is a restatement, disclosed as one.
That is the argument for doing the boring work — boundary, method, controls — in a year with no duty at all, and it holds whether or not the Policy Statement ever appears, because UK SRS S1 and S2 are already available for voluntary use [9].
Where the emissions numbers themselves come from is Scope 1, 2 and 3 emissions's subject, and the Scope 3 question specifically is on UK SRS Scope 3 reporting.
Where UK SRS S2 goes deeper than a TCFD statement ever asked
The unhelpful version of this question is “which of the eleven TCFD disclosures carry across into S2?”
The answer is all eleven, every time, because S2 inherits the four pillars and the eleven recommended disclosures intact [3].
The useful question is about depth: for each pillar, how far does your current disclosure go, and what does S2 ask for beyond that?
Rate each pillar as you actually report it today, and the component works out the gap and names the requirement that creates it.
The measurement basis is named, and TCFD never named one
A TCFD statement can report emissions on whatever basis the company thinks reasonable.
UK SRS S2 requires the GHG Protocol Corporate Standard, which settles the boundary question, the consolidation approach and the gases in scope before you start [16].
For UK companies the conversion factors come from the Department for Energy Security and Net Zero's annual set [16].
It also requires Scope 3 disaggregated across the fifteen categories, which is where most of the work sits and which the one-year relief exists to acknowledge.
Category 15 is the one that catches listed companies with treasury or pension exposure by surprise, and category 11 is the one that dominates for most manufacturers.
The protocol itself is covered on the GHG Protocol, and the fifteen categories in detail on Scope 3 emissions.
Scenario analysis stops being a narrative and starts having numbers in it
TCFD asked for the resilience of the strategy under different climate scenarios, including a 2°C or lower scenario.
In practice most annual reports answered that qualitatively, and the FCA's own supervisory reviews have said so.
UK SRS S2 asks for climate resilience assessed through scenario analysis, and for the anticipated financial effects of climate-related risks and opportunities — quantitatively, unless the company determines it cannot [4].
This is the requirement that most reliably turns a two-page climate section into a workstream, and it is the one item on this page that no relief defers.
Same reporting period, same date, same set of judgements
A TCFD statement could sit in the strategic report and take its own view of the world.
UK SRS S1's conceptual foundation requires sustainability disclosures to be reported for the same reporting period as the related financial statements, and published at the same time [11].
It also requires the information to be connected: the assumptions in your climate scenario analysis and the assumptions behind your impairment testing cannot contradict each other without someone noticing.
For a finance team this is the sleeper requirement.
It moves sustainability reporting from a spring project into the year-end close, and it does so during the climate-first years, because the conceptual foundation is not what the two-year relief defers [11].
How S1 and S2 interlock, and the six UK-specific amendments made on endorsement, are on the UK SRS amendments.
Assurance is not mandatory — the statement about it is
This is the most commonly misreported part of CP26/5, and it was wrong on this site until 8 August 2026.
The FCA does not propose mandatory assurance over sustainability disclosures, in any year of the phase-in [17].
What it proposes is a statement covering four things, where assurance has been obtained [17]:
And the detail that gets lost: no explanation is expected for a decision not to obtain assurance [17].
A company choosing not to assure its climate disclosures says so and moves on; it does not have to justify the choice.
What limited and reasonable assurance actually involve, and where the UK assurance market has got to, is on sustainability assurance.
A transition plan is disclosed if you have one — not required
CP26/5 proposes that in-scope companies disclose whether and where they have published a transition plan, or explain why they have not [18].
That is a disclosure requirement about a plan, not a requirement to have a plan.
Mandating transition plans is a matter for Government rather than the FCA, and the Department for Energy Security and Net Zero consulted on implementation routes without settling one [19].
Anyone telling you transition plans are mandatory in the UK is describing a decision that has not been taken.
The policy position, the TPT materials now held by the IFRS Foundation, and what a disclosable plan contains are on UK SRS transition plans.
Where you are incorporated changes the rule number, not the duty
An overseas company with equity shares in the commercial-company category is caught by UKLR 6.6.17R, which applies the same climate statement duty as 6.6.6R(8) [1].
A company whose primary listing is overseas and which is secondary-listed here sits in UKLR 14, and under the proposal takes the statement route instead [6].
Depositary receipt programmes sit in UKLR 15 and do the same.
The line is not incorporation, it is which listing category the securities were admitted under — which is why the resolver above asks that question and not where your head office is.
If you are not listed, none of this reaches you — and other things do
CP26/5 is a listing-rule instrument. It has no application to a private company, an LLP or a company whose securities are admitted to a market that is not the Official List.
Three regimes may still apply on a size basis rather than a listing basis, and they are entirely separate tests:
There is also a live question about economically significant private companies, which the Government consulted on separately and has not resolved.
That consultation, and who it would reach, is on the UK SRS management and company reporting consultation.
What actually happens if the Policy Statement slips past autumn
Nobody outside the FCA knows whether it will, and this page will not pretend otherwise.
What can be said is what moves and what does not.
The one thing a delay would not do is give you the time back.
A company that treats a slipped Policy Statement as a reason to stop collecting data ends up in exactly the same position one year later, with one fewer comparative year in hand.
What to do in the period you are actually in
In the order the answers depend on each other, and stopping at the point where the proposal stops being certain.
Twenty-three chapters, and the rule that binds you is still the one from 2024.
Your sustainability disclosure requirement today is UKLR 6.6.6R(8), a comply-or-explain TCFD statement in the annual financial report, and every 2027 date you have read about is a proposal the FCA has not yet made law.
The rule you are subject to is settled. The one you are preparing for is not — so the only work worth doing now is the work that survives either outcome.
What UK SRS S2 actually requires Or check the scope edge cases — who is in, and who is out
UKSRS — independent reference on UK sustainability and energy reporting. Every figure on this page is cited to a named primary source.
The requirements, consolidated
Everything on this page in one reference block, split by what is in force and what is proposed. Nothing here is new; it is the page restated as fact.
The rule map — every provision this page relies on
Chapter titles verified individually against the FCA Handbook on 8 August 2026. Each links to the Handbook page it comes from.
A note on the old numbering: LR 9.8.6R(8) was the pre-2024 form of this duty and now carries Handbook status “Deleted”. Any citation of LR 9.8.6R as live is two years out of date [1].
Four FCA questions, four pages
This subject splits cleanly, and each of these pages owns one question. If your question is not the one at the top of this page, one of the other three has it.
Three further pages carry subjects this one deliberately hands off: scope edge cases go to UK SRS who is in scope, the single-date question to the UK SRS deadline, and the framework-level TCFD-to-S2 comparison to TCFD and UK SRS, TCFD UK requirements and TCFD reporting requirements.
Common questions answered
Direct answers on scope, timing, the two regimes that share a name, and what is actually in force.
The requirement in force is UKLR 6.6.6R(8) in the FCA Handbook: a listed commercial company must include a statement in its annual financial report saying whether its climate-related financial disclosures are consistent with the TCFD Recommendations and Recommended Disclosures, and where they are not, where those disclosures are made instead, why not, and when it expects to be able to make them. Parallel duties apply at UKLR 14.3.24R, 15.3.1R(3), 16.3.23R and 22.2.24R, and UKLR 6.6.17R extends the duty to overseas commercial companies. This is a different regime from the FCA's Sustainability Disclosure Requirements (SDR), which governs investment product labels and marketing.
No. The FCA uses "Sustainability Disclosure Requirements (SDR)" for its investment-product regime: four sustainability investment labels, naming and marketing rules, and the anti-greenwashing rule that applies to FCA-authorised firms. That regime is aimed at asset managers and says nothing about corporate annual reports. The listed-company obligation is a listing rule, UKLR 6.6.6R(8), and the FCA has never branded it SDR. The two are frequently conflated because the FCA publishes both under similar headings.
If your equity shares are listed as a commercial company, UKLR 6.6.6R(8) applies today and has done since the UK Listing Rules replaced the Listing Rules sourcebook on 29 July 2024. It is a comply-or-explain requirement, not a mandatory disclosure standard. UK SRS S1 and S2, published by the Department for Business and Trade on 25 February 2026, are available for voluntary use but are not mandatory for anyone. The FCA has proposed making UK SRS S2 mandatory for listed companies from accounting periods beginning on or after 1 January 2027, but has not published a Policy Statement, so that proposal is not law.
CP26/5 names five: UKLR 6 (equity shares, commercial companies), UKLR 14 (equity shares, international commercial companies secondary listing), UKLR 15 (certificates representing certain securities, i.e. depositary receipts), UKLR 16 (non-equity shares and non-voting equity shares) and UKLR 22 (equity shares, transition). They do not carry identical obligations: UKLR 6, 16 and 22 would report under UK SRS, while UKLR 14 and 15 would instead make a statement about the sustainability disclosures made in their primary overseas listing venue, or that none are made, and would have no UK SRS obligation.
Five categories are excluded by name: closed-ended investment funds (UKLR 11), shell companies, debt and debt-like securities, securitised derivatives, and warrants, options and other miscellaneous securities. Closed-ended investment funds are the exclusion most often got wrong, because UKLR 11 is regularly confused with UKLR 15 — UKLR 15 is depositary receipts, not funds. Being excluded by name is a stronger position than simply not appearing in the scope list.
No. The consultation opened on 30 January 2026 and closed on 20 March 2026. The FCA's own page says it will "review the feedback and aim to publish a Policy Statement in autumn 2026, subject to the final UK SRS, with the rules coming into force from 1 January 2027". That page has not been substantively updated since 5 June 2026, no Policy Statement has appeared, and the FCA has not published the number of responses it received. Until a Policy Statement is published, none of the proposed requirements are rules.
The proposal is that they apply to accounting periods beginning on or after 1 January 2027, which means the first mandatory reports would be published in 2028 for a December 2027 year end. Two things make that date uncertain. It depends on a Policy Statement the FCA has only said it aims to publish in autumn 2026, and that publication is expressly subject to the final UK SRS. Note also that the FCA frames commencement in accounting periods, not financial years, so a non-December year end shifts the first in-scope period accordingly.
Not today. Under the TCFD recommendations the current listing rule points at, Scope 3 is disclosed "if appropriate", which leaves the judgement with the company. Under the proposal, UK SRS S2 would require Scope 3 across the fifteen GHG Protocol categories on a comply-or-explain basis, with a one-year transitional relief allowing it to be omitted from the first in-scope period. That change — from an optional disclosure to a comply-or-explain obligation across fifteen categories — is the largest practical difference hidden inside a proposal usually described as a like-for-like replacement.
No. The FCA does not propose mandatory assurance over sustainability disclosures in any year of the phase-in. What it proposes is a statement: where assurance has been obtained, the company fdr-states who provided it, which disclosures or explanations were assured and to what level, which assurance standards were used, and where the assurance report can be found. ISSA (UK) 5000 is the standard built for this work. No explanation is expected for a decision not to obtain assurance at all.
CP26/5 proposes to delete the TCFD-aligned listing rules and replace them with mandatory UK SRS S2, rather than amending them. That is a change of instrument, not of architecture: UK SRS S2 inherits TCFD's four pillars — governance, strategy, risk management, and metrics and targets — and its eleven recommended disclosures intact. What changes is depth. S2 names the GHG Protocol Corporate Standard as the measurement basis, requires Scope 3 across fifteen categories, requires industry-based metrics, requires quantified anticipated financial effects, and requires the disclosures to be published at the same time and for the same period as the financial statements.
The rest of the subject
Every claim on this page, traced
Regulator and legislation first. Professional commentary is named individually and used only for interpretation, never for a fact a primary source could carry.
Also consulted, and cited by name in the text where used: the FCA's SDR regime page (the investment-product regime, cited only to draw the boundary), FSMA 2000 s.73A, the DBT letter to the FCA of 5 January 2026, the FRC's sustainability reporting developments FAQ, the GHG Protocol Corporate Standard, PwC's CP26/5 summary, and the Leeds Reforms announcement.
Scope and timing
UK SRS thresholds UK SRS who is in scope The UK SRS deadline The UK SRS scope checkerThis page is independent reference material about UK regulation. It is not legal, accounting or investment advice, and it is not a certification, assessment or professional opinion. The proposals described here are not law. Verify every date against the FCA's own publications before relying on it.