UK SRS: the UK Sustainability Reporting Standards
Published 25 February 2026. Required of nobody, yet.
Check whether UK SRS applies to youTwo standards. Start with what each one covers.
The two core UK SRS standards
UK SRS is two standards, not one: UK SRS S1 covers sustainability-related financial information in general, and UK SRS S2 covers climate.
Both were issued by the Secretary of State for Business and Trade and published on GOV.UK on 25 February 2026, and the Department for Business and Trade’s guidance page is the government’s own landing page for them.
S1 is the frame. S2 is the one subject the frame is already filled in for.
They are meant to be applied together, and UK SRS S1 paragraph E2 keeps that requirement from IFRS S1.
| UK SRS S1 | UK SRS S2 | |
|---|---|---|
| Full title | General Requirements for Disclosure of Sustainability-related Financial Information | Climate-related Disclosures |
| Subject | All sustainability-related risks and opportunities | Climate-related risks and opportunities only |
| Based on | IFRS S1 | IFRS S2, including the ISSB’s December 2025 amendments |
| Disclosure test | Effects on cash flows, access to finance or cost of capital, over the short, medium or long term (paragraph 3) | The same test, applied to climate |
| Emissions | Not specified | Scope 1, Scope 2 and Scope 3 greenhouse gases |
| Effective date | None — removed before publication | None — removed before publication |
| Climate-only route | Paragraph E3 permits climate-only disclosure | Applies in full where used |
If you only ever read one paragraph, read UK SRS S1 paragraph 3 — every other requirement hangs off it.
Our guide to UK SRS S1 takes the general standard paragraph by paragraph, and UK SRS S2 does the same for climate.
If you need them treated as one regime rather than two documents, UK SRS S1 and S2 covers the pair together.
Neither was written in Whitehall.
Where UK SRS comes from
UK SRS is the UK’s endorsed version of the global baseline written by the International Sustainability Standards Board, not a domestic invention.
The ISSB was formed on 3 November 2021 and issued IFRS S1 and IFRS S2 in June 2023.
The UK did not write a standard. It assessed one, and endorsed it with changes.
The FRC-hosted Technical Advisory Committee agreed its endorsement recommendations at a public meeting on 5 December 2024 and published them on 18 December 2024.
DBT then consulted on exposure drafts from 25 June to 17 September 2025 and received 209 responses, 199 of them from organisations.
Between the ISSB issuing its standards and the UK publishing its own, the chain runs through a committee, a consultation and a letter, and each link is dated and public.
The UK did not have to endorse anything. It chose to, and it chose what to change.
The framework for that decision is set out in the government’s own endorsement framework.
The last link in the chain has not happened: the FCA’s rules are proposed and unmade.
The UK is one jurisdiction among many.
UK SRS and the global baseline
The ISSB Standards are a global baseline that jurisdictions adopt on their own terms, and the UK is one of them.
The IFRS Foundation’s registry counted 19 jurisdictions with requirements in effect at 24 February 2026.
Over 40 jurisdictions have decided to use the ISSB Standards or are taking steps towards them.
Those jurisdictions account for more than 40% of global market capitalisation, so a UK company with overseas listings should expect the same four pillars in more than one place.
Everything above is settled. What follows is not.
Is UK SRS law yet, or still a proposal?
No entity is required to report against UK SRS S1 or UK SRS S2 today, and the standards themselves say so by construction.
The Department for Business and Trade’s guidance puts it plainly — the standards are “available for voluntary use, by any entity that chooses to do so” — and the government will “consider whether to introduce requirements” afterwards.
The standards contain the machinery to be mandated, and no mandate.
UK SRS S1 paragraph E5 and UK SRS S2 paragraph C6 are drafted in the conditional: they bite “where an entity is required to apply this Standard under UK law or regulations”.
That requirement has to come from the Companies Act, from the FCA, or from another UK regulator, and none of the three has made one.
| Instrument | Status | What that means for you |
|---|---|---|
| UK SRS S1 and S2 | Published | They exist and may be used voluntarily. They apply to nobody by force of law. |
| An effective date in the standards | Does not exist | The effective-date provisions were removed before publication. Any “effective from” date in a UK SRS table is invented. |
| FCA CP26/5 | Proposed | A consultation, not a rule. The FCA aims to publish a policy statement in autumn 2026. |
| The FCA policy statement | Not published | Until it exists, everything in CP26/5 is a proposal and may change. |
| Companies Act route | Not consulted on | UK SRS S2 is named as a national framework for section 414CB(6), but no duty has been made under it. |
| SECR | In force | A separate, live obligation that UK SRS does not replace. |
The distinction between exists and applies is the one that trips people up.
If you need the legislative detail rather than the summary, UK SRS legislation traces each route, and the consultation covers CP26/5 in full.
The regulator’s own role is set out on UK SRS and the FCA, and the wider programme this sits inside is covered on Modernisation of Corporate Reporting.
So the question becomes: would it apply to you?
Who would have to report under UK SRS
The FCA’s proposal in CP26/5 would reach around 600 listed companies, split into two very different groups.
Its cost benefit analysis at paragraph 43 puts 515 companies in the group that would have to comply, and 89 in a lighter-touch group that would only have to state which regime they follow.
Quoting 515 on its own gets the scope wrong three separate ways.
The 515 are three listing categories. The 89 are the two that only have to say which regime they follow.
Answer the four questions beside this and the instrument will tell you which branch you are on.
The question in full is on who is in scope, and UK SRS compliance covers what falling in scope would oblige you to do.
And none of it is a rule yet.
The FCA had published no policy statement responding to CP26/5 as at 8 September 2026, so every figure on this page describes a proposal.
Next, the dates that actually exist.
When UK Sustainability Reporting Standards would apply
There are only two kinds of date here: ones that have happened, and one that is proposed.
The standards were published on 25 February 2026, and the FCA’s CP26/5 paragraph 1.11 proposes rules coming into force from 1 January 2027.
1 January 2027 is a proposed commencement, not a reporting deadline.
Between those two sits a letter: DBT wrote to the FCA on 5 January 2026 to say the relief time limits were coming out.
That letter is why several widely-repeated relief periods no longer describe the published text.
Two of these dates are commonly reported wrongly, and both are on the rail.
The Technical Advisory Committee agreed its recommendations on 5 December 2024 and published them on 18 December 2024, and the two are routinely merged into a single event.
And 1 January 2027 is a proposed commencement for rules that do not yet exist, not a reporting deadline for anybody.
A dated view of the whole sequence is on the UK SRS timeline, and the deadline question takes the proposed 2027 date on its own.
Your first UK SRS reporting period
The FCA proposes rules in force from 1 January 2027, applying to accounting periods beginning on or after that date.
That is year-end arithmetic rather than a single deadline, and it is set out in CP26/5.
A December year-end and a March year-end are more than a year apart in practice.
Choose your year-end beside this and the instrument computes the first period that would be caught.
It computes from the proposal as drafted, and the proposal is not final.
And what would you actually have to produce?
UK SRS timelines and requirements
A UK SRS report is a set of disclosures inside the annual report, covering the risks that could affect the entity’s cash flows, its access to finance or its cost of capital.
That test is UK SRS S1 paragraph 3, and it is the whole scope of the exercise.
Materiality is a judgement here, not a threshold you can look up.
The standard “does not specify any thresholds for materiality or predetermine what would be material”.
On timing the standards impose none — the effective-date provisions were removed before publication.
Timing comes instead from whichever instrument mandates them, and the only one proposed is the FCA’s.
The diagram shows where the disclosures actually sit, and what a first report has to contain.
What a report contains in practice is on UK SRS reporting, and the readiness assessment is the gap-analysis version of the same question.
Assurance is a separate decision, covered on sustainability assurance, and the data underneath it is usually the real constraint — ESG data management and carbon reporting software both deal with that rather than with the standard.
Four headings carry all of it.
The four UK SRS pillars
Every UK SRS disclosure sits under one of four pillars: governance, strategy, risk management, and metrics and targets.
The structure is inherited: the Task Force on Climate-related Financial Disclosures set out four pillars and eleven recommended disclosures in June 2017, and the ISSB built on that frame.
If your TCFD report is already organised this way, the shape is not the work.
UK SRS S1 paragraph 25 sets the four pillars for sustainability generally, and UK SRS S2 applies the same four to climate.
The diagram shows what that nesting actually is: S1 is the frame, and climate is the one subject already written out inside it.
Four pillars, eleven recommended disclosures, and one of them now written out in full.
The TCFD’s final report of June 2017 set the frame at its Figure 4, and every standard since has inherited it.
What UK SRS S2 adds is specificity: where TCFD recommended, it requires.
One metric is misreported more than any other.
Scope 2, and the dual-reporting myth
UK SRS S2 requires location-based Scope 2 emissions and permits market-based — it does not require dual reporting.
Paragraph B30 settles it: “for the avoidance of doubt, an entity is required to disclose its Scope 2 greenhouse gas emissions using a location-based approach”.
You can comply with UK SRS S2 and publish a single location-based figure.
The confusion comes from the GHG Protocol Scope 2 Guidance — a different document, with a different status.
Switch the control to see what each document actually asks of you.
The three emission scopes are set out on Scope 1, 2 and 3 emissions, and UK SRS Scope 3 reporting takes the hardest of them on its own.
Which risks count, and to whom.
Financial focus
UK SRS applies single, financial materiality: what could reasonably be expected to affect the entity’s cash flows, its access to finance or its cost of capital.
That wording is UK SRS S1 paragraph 3, and it is the operative test on both the UK and the ISSB side.
It is a narrower question than the one the European Union asks.
The CSRD adds a second limb: the entity’s own impacts on people and the environment.
A company may have a material impact under the EU regime and nothing to disclose about it here.
The reverse is also true, which is why the two are not a superset and a subset.
If you report in both jurisdictions, CSRD vs UK SRS sets the two side by side, and double materiality covers the EU test on its own terms.
At the level of the standards, UK SRS vs ESRS compares the texts, and global sustainability standards places both against the wider field.
For the UK reporting picture as a whole, see ESG reporting requirements in the UK.
Endorsed, then changed. Here is what changed.
Key UK adjustments vs the global baseline
The differences between UK SRS and the IFRS Standards it endorses are set out in Annex A of the government response, and that annex is exhaustive by its own terms.
Annex A states the rule that makes it exhaustive: “where requirements in the standards are not included in the table, there are no differences between the two”, which is published with the standards on GOV.UK.
Annex A carries no count, and no authoritative count of the final differences exists.
The government consulted on six proposed amendments in June 2025, but the set changed before publication — one proposal was withdrawn because the ISSB made the change itself in December 2025, another was replaced, and four new provisions were added.
So “six UK amendments” describes a June 2025 consultation, not the standards published in February 2026.
| What changed | Where | Effect |
|---|---|---|
| SASB became optional | S1 ¶¶55(a), 58(a); S2 ¶¶12, 23, 32 | “Shall” became “may”, so entities may refer to and consider the SASB Standards and the industry-based guidance. |
| Effective dates removed | S1 E1/E2 → E2; S2 C1/C2 → C2 | Entities apply the standards when they choose, unless UK law or regulation requires otherwise. S1 and S2 are still applied at the same time. |
| A UK-law override added | S1 ¶¶73B, E5; S2 ¶C6 | Application is subject to anything set by the Companies Act, the FCA, or another UK body with power to make reporting requirements. |
| Compliance statement rule added | S1 ¶73A | Use the climate-only relief and you may not assert compliance with UK SRS S1, and must disclose the relief. You may still assert compliance with UK SRS S2. |
| Deferred first-year reporting removed | IFRS S1 ¶E4 | Not carried into UK SRS S1. The concession to publish sustainability disclosures after the financial statements in year one is gone. |
| A financed-emissions duty added | S2 ¶B59A | Where estimating financed emissions for the same period is impracticable, the entity must explain why. |
| Relief time limits changed | S1 ¶E3; S2 ¶¶C3, C4 | The Scope 3 and climate-only reliefs lost their first-period limits; the GHG-Protocol methodology relief kept its own. |
Two of those rows are the ones most often reported wrongly, and the next two chapters take each in turn.
Each difference is taken individually on UK SRS amendments, where the proposal-versus-final distinction is worked through row by row.
First, the one that became optional.
SASB Standards
Under UK SRS, the SASB Standards are optional: the UK changed “shall” to “may”, so an entity may refer to and consider them rather than being required to.
That change is recorded in Annex A of the government response, published alongside the standards on GOV.UK, and it touches UK SRS S1 paragraphs 55(a) and 58(a).
The equivalent change in UK SRS S2 covers paragraphs 12, 23 and 32, and applies to the ISSB’s Industry-based Guidance on Implementing IFRS S2.
The detail that gets lost is that the change is not universal within S2.
Paragraph 37 and paragraph B65(d) keep “shall”, so the industry-based guidance is still mandatory in those two places.
The exposure draft had proposed putting “may” into paragraph 37 as well, and that proposal was reverted before publication.
SASB itself is the Sustainability Accounting Standards Board, whose standards the IFRS Foundation took stewardship of when the ISSB was formed.
They are industry-specific metric sets, so their practical role is to tell a bank and a mining company to disclose different numbers under the same heading.
Making them optional lowers the floor for a first UK SRS report and widens the gap between two companies in the same industry.
An entity that wants its disclosures compared with international peers will usually apply them anyway.
Where you do use them, say so, because a reader cannot otherwise tell an omitted metric from an inapplicable one.
Then the reliefs, which moved late.
UK SRS transitional reliefs
UK SRS carries three transitional reliefs, and the published versions of two of them no longer carry a time limit.
The reason is on the record: DBT wrote to the FCA on 5 January 2026 to say it would remove the specific time references and specify instead that timing “will be set out in government regulations or FCA rules”.
Two of the three now run open-ended. One kept its end.
Climate-only reporting sits at paragraph E3, and its reference to the first reporting period was removed.
The Scope 3 relief at paragraph C4 lost the same reference.
The GHG Protocol methodology relief at paragraph C3 kept its limit to the first annual reporting period, and that asymmetry is deliberate.
Using a relief has a consequence under paragraph 73A: you must disclose the use, and you may not assert compliance with UK SRS S1 if you took the climate-only route.
Anything attaching “one year” or “two years” to the Scope 3 or climate-only reliefs is describing a draft, not the standards as published.
UK SRS does not arrive on an empty desk.
How UK SRS sits with SECR, ESOS and TCFD
UK SRS would sit on top of obligations that already exist, and it replaces none of them.
SECR is live under SI 2018/1155, and ESOS runs its own four-year cycle.
Four regimes, four triggers, one set of underlying energy and emissions data.
The statutory route is section 414CB, and UK SRS S2 is named a national framework for subsection (6).
Only one of the four stack layers is unlit, and it is the one this page is about.
Pick a regime to see what actually switches it on for a company.
Three of the four are in force. The one this page is about is not.
That is the whole practical point of the stack: a company worrying about UK SRS usually has live obligations it is closer to breaching.
SECR and the climate-related financial disclosure duty both apply now, and both draw on the same activity data a UK SRS report would use.
Start with the numbers themselves.
The three emission scopes
UK SRS S2 requires Scope 1, Scope 2 and Scope 3 greenhouse gas emissions, measured on the GHG Protocol Corporate Standard unless a regulator or exchange requires another.
Scope 1 is direct: the emissions from sources the entity owns or controls, which is usually fuel burned on site and in its own vehicles.
Scope 2 is the one most often reported wrongly, and it is the smallest of the three.
Scope 2 is indirect and comes from purchased energy, and UK SRS S2 requires the location-based figure.
Scope 3 is everything else in the value chain, in fifteen categories under the Corporate Value Chain Standard.
For most companies Scope 3 is the great majority of the total, and almost all of the work.
It is also the scope with a transitional relief attached, at UK SRS S2 paragraph C4.
The factors you multiply your activity data by are published annually as the government conversion factors for company reporting.
A full treatment of the fifteen categories is on UK SRS Scope 3 reporting.
Then the futures you have to test them against.
Climate scenario analysis
UK SRS S2 requires an entity to assess its climate resilience using climate-related scenario analysis, where the TCFD only recommended it.
That change of verb is one of the four places a company already reporting to TCFD usually finds genuinely new work.
A scenario is not a forecast. It is a coherent future you test the business against.
The standard does not name a scenario set, so the choice and its justification are themselves disclosures.
The NGFS scenarios portal is the central-bank set, and it is the one financial institutions are most often asked to use.
The IEA’s Net Zero Emissions by 2050 scenario in World Energy Outlook 2025 is the energy-sector reference, published on 12 November 2025.
Say which scenarios you used, which vintage, and why they fit your business.
The underlying physical science sits in the IPCC’s Sixth Assessment Report, and the mitigation pathways in its Working Group III volume.
Vintages move, so a scenario cited without its year is a scenario nobody can check.
A plan is a disclosure too.
Transition plans, and what they contain
Where an entity has a climate transition plan, UK SRS S2 expects it to be disclosed alongside the targets and the actions behind it.
The reference framework is the Transition Plan Taskforce’s Disclosure Framework of October 2023, now hosted by the IFRS Foundation.
Three guiding principles — Ambition, Action and Accountability — organised across five elements.
Those principles are set out at section 2.2 of the Framework, and the five elements at section 2.1.
The IFRS Foundation published its own guidance on transition plan disclosures in June 2025.
Whether a transition plan becomes a duty in its own right is a separate, open question.
The government has consulted on climate-related transition plan requirements and on the routes by which they could be imposed.
Until one of those routes is taken, a transition plan is disclosed because the entity has one, not because a rule demands it exist.
Somebody has to sign it.
Who signs a UK SRS report off
The governance pillar asks two questions: what the board does about these risks, and what management does.
Those are the TCFD’s two recommended disclosures under governance, carried into IFRS S2 and then UK SRS S2 — describe the board’s oversight, and describe management’s role.
The answer has to name bodies and people, not intentions.
In practice that means identifying the committee that holds the item, how often it sees it, and what it is competent to decide.
Because the disclosures sit in the strategic report, the directors’ existing responsibilities under the FRC’s Guidance on the Strategic Report apply to them.
A sustainability disclosure inside the strategic report is a directors’ statement.
That is also why connectivity matters: the same people are signing the accounts and the disclosures that sit beside them.
Where a relief has been used, UK SRS S1 paragraph 73A governs what the statement of compliance may say.
And somebody may have to check it.
Assurance, and who can give it
UK SRS says nothing about assurance, and that silence is deliberate — assurance is being decided on its own track.
The government consulted on assurance of sustainability reporting and has published its response on an oversight regime.
Nothing obliges you to have UK SRS disclosures assured today, because nothing obliges you to make them.
The standard a provider would work to is the FRC’s ISSA (UK) 5000, and the wider set is on the FRC’s assurance standards page.
| Limited assurance | Reasonable assurance | |
|---|---|---|
| The conclusion | Negative form — nothing has come to our attention | Positive form — the information is fairly stated |
| Work performed | Enquiry and analytical procedures, primarily | Testing of controls and substantive testing |
| Evidence you must hold | A traceable source for each figure | A controlled process that produces the figure repeatably |
| Typical first-year fit | Where most first reports land | Where the accounts already are |
| Standard | ISSA (UK) 5000 | ISSA (UK) 5000 |
| Required by UK SRS? | No | No |
The practical consequence is that the level of assurance you can obtain is set by the state of your data, not by your ambition.
Our page on sustainability assurance takes the oversight regime and the provider market in full.
The data decides what you can claim.
The data a UK SRS report needs
Almost every difficulty in a first sustainability report is a data problem wearing a disclosure problem’s clothes.
The activity data is mostly already in the business — meter readings, fuel cards, travel bookings, purchase ledgers — and the work is making it repeatable rather than finding it.
The question an assurance provider asks is not what the number is. It is how you would produce it again.
Emission factors come from the annually updated government conversion factors, and DEFRA’s environmental reporting guidelines govern the SECR disclosure sitting beside it.
| Pillar | The data | Where it usually lives | The usual gap |
|---|---|---|---|
| Governance | Minutes, terms of reference, delegations | Company secretary | Nothing records when the board actually saw it |
| Strategy | Scenario outputs, financial effects | Finance and risk | The scenario work exists but is never quantified |
| Risk management | The risk register and its process | Risk function | Climate risk is on it, unlabelled |
| Metrics & targets | Activity data, factors, targets, progress | Operations, procurement, energy | Scope 3 categories with no owner |
Scope 3 is where the ownership question bites, because the data belongs to somebody else.
Choosing tooling before you know which categories are material is the most common way to buy the wrong thing.
Our pages on ESG data management and carbon reporting software deal with that decision rather than with the standard.
So what does a first year actually look like?
A first report, in order
The order matters more than the pace, because each step decides what the next one is even able to say.
Nothing below is a legal deadline — no entity is required to report against UK SRS — so this is the order of work for a company that has decided to start.
Most first reports fail on evidence, not on effort.
The one hard sequencing rule in the standards is UK SRS S1 paragraph E2: S1 and S2 are applied at the same time.
| Step | What you do | What it decides |
|---|---|---|
| Scope | Establish whether any proposal would reach you, and on which branch | Whether this is preparation or a live obligation |
| Period | Fix the reporting period against your year end | Every date downstream of it |
| Materiality | Identify the sustainability risks that could affect cash flows, finance or cost of capital | What is in the report at all |
| Governance | Put the item on a named committee with a standing agenda slot | Whether pillar one has evidence behind it |
| Inventory | Build Scope 1 and 2 on the GHG Protocol, then screen Scope 3 by category | Which Scope 3 categories are worth measuring properly |
| Scenarios | Choose a scenario set, state the vintage, run the resilience assessment | What the strategy pillar can claim |
| Reliefs | Decide which transitional reliefs you rely on | What your statement of compliance may say, under ¶73A |
| Connectivity | Put the disclosures in the same package and period as the accounts | Whether finance owns the timetable |
| Assurance | Decide the level, if any, and evidence accordingly | How much of the above has to be repeatable |
Choose the reliefs before you write, not after — they change what the compliance statement may say.
A readiness assessment against this order is on the readiness assessment page, and UK SRS reporting covers the output itself.
And here is where they usually come apart.
How a first disclosure usually fails
The recurring failures are not about ambition, and they are all visible from outside the company.
The commonest is a compliance statement that does not survive the reliefs behind it, which UK SRS S1 paragraph 73A governs precisely.
Take the climate-only route and you may not claim compliance with UK SRS S1 at all.
The second is a Scope 2 figure presented as dual reporting when the standard asked only for the location-based number.
The third is scenario analysis with no named set and no vintage, which nobody can check and nobody can repeat.
A governance claim with no minute behind it is the one an assurance provider finds first.
And the fourth is a date: any table showing a UK SRS “effective from” is inventing it, because those provisions were removed before publication.
Test your own draft against the six questions beside this.
It is not the only rule you are under.
The wider UK sustainability rules
A UK company’s sustainability obligations are a stack of separate regimes with separate triggers, and only one of them is the subject of this page.
Each was made under its own instrument, on its own timetable, and none of them was designed against the others.
Nothing consolidates them. That is the actual state of UK sustainability regulation.
The programme that could change that is Modernisation of Corporate Reporting, set out in a written ministerial statement of 21 October 2025.
| Regime | Instrument | Status | What it asks for |
|---|---|---|---|
| UK SRS | Issued by the Secretary of State, 25 Feb 2026 | Voluntary | Sustainability and climate disclosures under four pillars |
| SECR | SI 2018/1155 | In force | Energy use and carbon in the directors’ report |
| Climate-related financial disclosure | SI 2022/31, CA 2006 s.414CB | In force | TCFD-aligned disclosure by large companies and LLPs |
| ESOS | Energy Savings Opportunity Scheme | In force | Energy audits on a four-year cycle |
| FCA listing rules | UKLR, and CP26/5 as proposed | Partly proposed | Issuer disclosure aligned to UK SRS, if made |
| Assurance oversight | Government response, consultation closed | Not yet made | A regime for who may assure these disclosures |
| Transition plans | Consultation on implementation routes | Not yet made | Whether a plan becomes a duty in its own right |
Three of the seven are proposals. Reading them as rules is the commonest mistake on this subject.
The 2026 post-implementation review of SECR is the best signal on whether the oldest of them survives in its present form.
Our page on UK SRS legislation traces the routes by which the voluntary standard could become a duty.
And the international standards behind it.
IFRS sustainability standards in the United Kingdom
The UK does not apply IFRS S1 and IFRS S2 directly; it applies its own endorsed versions of them, and the difference is not merely formal.
The IFRS Sustainability Standards Navigator is the index of what the ISSB has issued and amended.
Complying with UK SRS is not automatically complying with the ISSB Standards.
The Foundation’s own UK jurisdiction snapshot is the master record of where the UK sits, and it is the source to cite rather than any commentary.
| IFRS S1 / S2 (ISSB) | UK SRS S1 / S2 | |
|---|---|---|
| Issued by | The International Sustainability Standards Board | The Secretary of State for Business and Trade |
| Issued | June 2023 | 25 February 2026 |
| Effective date | IFRS S2 from 1 January 2024 | None — removed before publication |
| SASB Standards | “Shall” refer to and consider | “May”, except at S2 ¶¶37 and B65(d) |
| Deferred first-year reporting | Permitted by IFRS S1 ¶E4 | Removed |
| Financed emissions | ¶B59 | ¶B59 plus an added explanation duty at ¶B59A |
| Override for national law | None | S1 ¶¶73B and E5, S2 ¶C6 |
| Where the differences are listed | — | Annex A of the government response, exhaustively |
The ISSB was formed on 3 November 2021 and announced at COP26.
More than 40 jurisdictions have decided to use the ISSB Standards or are taking steps towards them, and 19 had requirements in effect as at 24 February 2026.
Those jurisdictions account for more than 40% of global market capitalisation, on the Foundation’s own figures.
Open the standard itself.
What the general standard contains, by paragraph
UK SRS S1 is a short standard, and knowing where each requirement lives makes it far easier to argue with.
The map below is taken from the standard’s own contents page, and every appendix carries the line “this appendix is an integral part of UK SRS S1 and has the same authority as the other parts of the Standard”.
There is a trap in the front matter: it says the standard is “set out in paragraphs 1–86”, and it is not.
Paragraphs 73A and 73B are UK-specific additions, and that sentence was inherited from IFRS S1 unamended — so do not cite “1 to 86” as the paragraph count.
| Section | Paragraphs | What it settles |
|---|---|---|
| Objective | 1–4 | What the standard is for |
| Scope | 5–9 | What it applies to |
| Fair presentation | 11–16 | What a faithful report looks like |
| Materiality | 17–19 | The test, and that there is no threshold |
| Reporting entity | 20 | Same entity as the financial statements |
| Connected information | 21–24 | Consistency with the accounts, and the currency |
| Core content | 25 | The four pillars |
| — Governance | 26–27 | Board oversight and management’s role |
| — Strategy | 28–42 | Risks, business model, effects, resilience |
| — Risk management | 43–44 | How risks are identified and monitored |
| — Metrics and targets | 45–53 | What is measured, and against what |
| Location of disclosures | 60–63 | Where in the report they sit |
| Timing | 64–69 | When they are published |
| Comparative information | 70–71 | Prior-period figures |
| Statement of compliance | 72–73, 73A, 73B | What you may claim, and the UK-law override |
| Judgements and uncertainty | 74–82 | Estimates, and how to disclose them |
| Errors | 83–86 | Restatement |
| Appendices A–E | — | Defined terms, application guidance, transition |
Strategy is the longest section by a wide margin, and it is where most first reports are thinnest.
It decomposes at paragraph 29 into five limbs: the risks themselves, the business model and value chain, strategy and decision-making, the effects on financial position and cash flows, and resilience.
Our page on UK SRS S1 works through the general standard in full.
The accounts and the disclosures are one package.
Connectivity to the financial statements
UK SRS S1 paragraph 20 requires the disclosures to be “for the same reporting entity as the related financial statements”, and paragraphs 21 to 24 do the rest of the work.
Paragraph 21 asks for the connections within and across reports to be explained, and paragraph 22 asks you to identify the financial statements the disclosures relate to.
Paragraph 23 is the one that changes how a company is organised: consistent data and assumptions.
If the sustainability report assumes one growth rate and the impairment model assumes another, that is now a visible inconsistency rather than two teams’ private business.
Paragraph 24 adds that the presentation currency must match, which sounds trivial and is the first thing a reader checks.
This is where the sustainability team stops owning the timetable.
Because the disclosures ship with the accounts, they inherit the accounts’ close, their controls and their sign-off.
The FRC’s Guidance on the Strategic Report governs the document they land in.
The first year has its own rules.
Comparatives, and what year one may leave out
A first sustainability report is allowed to be a first report, and the transition appendices are where that permission lives.
UK SRS S1 paragraphs 70 and 71 carry the comparative-information requirement, and Appendix E carries the exceptions to it in the year of initial application.
Annex A records that the no-comparatives-in-year-one limb was retained as paragraph E1 of UK SRS S1.
What was not retained is IFRS S1 paragraph E4, which had let an entity publish its sustainability disclosures after its financial statements in the first year.
Annex A is explicit: “this has been removed from UK SRS S1”, so the connectivity requirement bites from the very first report.
| Question | Year one | Where it says so |
|---|---|---|
| Prior-year comparatives | Not required | UK SRS S1 ¶E1 |
| Publish after the accounts | Not permitted — removed | IFRS S1 ¶E4, not carried across |
| Climate only, deferring the rest | Permitted, with consequences | UK SRS S1 ¶E3, and ¶73A |
| Comparatives on non-climate matters | Not required until the second period after ceasing the relief | UK SRS S1 ¶E4(b) |
| Scope 3 | Relief available; its timing set elsewhere | UK SRS S2 ¶C4 |
| A change of GHG methodology | Relief limited to the first period | UK SRS S2 ¶C3 |
| S1 and S2 together | Required — same time | UK SRS S1 ¶E2 |
Take the climate-only route and you may not assert compliance with UK SRS S1 at all.
You may still assert compliance with UK SRS S2, provided the use of the relief is disclosed, and that distinction is the one most often got wrong.
Errors and restatement are dealt with separately, at UK SRS S1 paragraphs 83 to 86.
Two kinds of climate risk, and they behave differently.
Physical risk and transition risk
Climate risk splits in two, and the split matters because the two halves move in opposite directions.
Physical risk is the effect of the climate itself — acute events like flood and storm, and chronic shifts like heat and water stress.
Transition risk is the effect of the response to climate change, not of the climate.
It covers policy and legal change, technology substitution, market shifts and reputation.
A scenario that is good for one is usually bad for the other, which is why the NGFS scenario set runs both an orderly and a disorderly transition.
A disclosure that reports only one half has not done the assessment.
The physical basis for the first sits in IPCC AR6 Working Group I, and the pathways for the second in Working Group III.
UK SRS S2 requires both to be assessed through the resilience limb of the strategy pillar.
The draft and the final standards differ.
What changed between the draft and the final standards
A great deal of what is written about UK SRS describes the June 2025 exposure drafts rather than the standards published on 25 February 2026.
The consultation ran from 25 June to 17 September 2025 and drew 209 responses, 199 of them from organisations.
Two proposals were abandoned and four provisions appeared that had not been consulted on.
That is why no count of “UK amendments” taken from the consultation survives contact with the published text.
| Proposed | What happened | Why |
|---|---|---|
| SASB “shall” → “may” | Adopted | Carried into S1 ¶¶55(a), 58(a) and S2 ¶¶12, 23, 32 |
| Remove the GICS requirement | Withdrawn | The ISSB made the change itself in December 2025 |
| Extend the climate-first relief to two years | Replaced | The time limit was removed altogether instead |
| One-year Scope 3 relief | Replaced | ¶C4 has no time limit in the final text |
| — | Added: ¶73A | How the statement of compliance works with a relief |
| — | Added: ¶73B | Application subject to UK law and regulators |
| — | Added: ¶B59A | Explain why financed emissions are impracticable |
| — | Added: ¶E5 / ¶C6 | The UK-law override clauses |
| “May” into S2 ¶37 | Reverted | ¶37 and ¶B65(d) keep “shall” |
The reason the relief timings moved is on the record, in a letter.
DBT wrote to the FCA on 5 January 2026 to say it would remove the specific time references and set timing in regulations or FCA rules instead — seven weeks before publication, and while CP26/5 was already drafted against the old position.
Each difference is taken individually on UK SRS amendments.
And if you report in Europe as well.
If you also report under CSRD
A group with UK and EU obligations is running two regimes that ask overlapping questions from different premises, and neither is a subset of the other.
The Corporate Sustainability Reporting Directive is the EU instrument, and the European Commission adopted a revised set of ESRS in July 2026.
The difference is not strictness. It is the question being asked.
| UK SRS | CSRD / ESRS | |
|---|---|---|
| Materiality | Single — financial only | Double — financial and impact |
| Primary users | Investors, lenders, creditors | A wider stakeholder set |
| Legal status | Voluntary; no entity required to apply it | A directive, transposed into member-state law |
| Topic coverage | Climate written out; other topics general | Topical standards across environment, social, governance |
| Assurance | Not addressed; consulted on separately | Assurance built into the directive |
| Where it sits | The strategic report | The management report |
| Emissions | Scope 1, 2 and 3; location-based Scope 2 | Scope 1, 2 and 3 under ESRS E1 |
A material EU impact can be nothing at all to disclose under UK SRS.
The practical consequence is that the two reports share an inventory and a governance story, and diverge on what counts as material.
Our page on CSRD vs UK SRS sets them side by side, and UK SRS vs ESRS compares the standards themselves.
Now the climate standard itself.
What the climate standard asks for
UK SRS S2 applies the same four pillars to a single subject, and almost all of its length is in the fourth.
The differences from IFRS S2 are set out in Annex A of the government response, published with the standards on GOV.UK.
Where a requirement is not in Annex A’s table, there is no difference from IFRS S2.
| Pillar | What UK SRS S2 requires | Notes |
|---|---|---|
| Governance | Board oversight and management’s role for climate | Same two disclosures as the TCFD |
| Strategy | Climate risks and opportunities, and their effects | Split across risk, business model, finances, resilience |
| Strategy — resilience | Assessed using climate-related scenario analysis | Required, where TCFD recommended |
| Strategy — transition | The transition plan, where the entity has one | Whether a plan must exist is a separate consultation |
| Risk management | How climate risks are identified, assessed, monitored | And how that sits in overall risk management |
| Metrics — Scope 1 | Direct emissions | GHG Protocol Corporate Standard |
| Metrics — Scope 2 | Location-based, plus contractual instruments if they exist | ¶B30; market-based permitted by ¶B31 |
| Metrics — Scope 3 | Value-chain emissions | Relief at ¶C4, its timing set elsewhere |
| Metrics — financed | Financed emissions where applicable | ¶B59, plus an explanation duty at ¶B59A |
| Targets | Climate targets and progress against them | Including how they were set |
| Industry guidance | May refer to and consider it | “Shall” kept at ¶37 and ¶B65(d) |
| Transition | ¶¶C1–C6 | Effective date removed; C6 is UK-specific |
Scope 2 and scenario analysis are the two that most often ship wrong.
Our page on UK SRS S2 takes the climate standard in full detail.
Which category are you in?
The listing categories, and which branch you fall into
The FCA’s proposal does not treat all listed companies alike, and the category your shares sit in decides which of two very different obligations would apply.
The figures come from CP26/5’s cost benefit analysis at paragraph 43, and the categories themselves from the UK Listing Rules.
Around 600 companies are affected. Only 515 of them would have to comply.
| Category | Branch | What you would do |
|---|---|---|
| Commercial companies | In the 515 | Apply UK SRS S2, with comply-or-explain on Scope 3 and S1 non-climate |
| Non-equity and non-voting equity shares | In the 515 | The same |
| Transition category | In the 515 | The same |
| Secondary listing only | In the 89 | State which climate or sustainability requirements apply in your primary listing location |
| Depositary receipts only | In the 89 | The same statement |
| Not listed | Out of scope | Nothing — CP26/5 reaches listed issuers only |
Quoting 515 on its own gets the scope wrong three separate ways.
It misstates the total, erases the lighter-touch branch, and implies 515 spans five categories when it spans three.
And none of it is a rule yet: the FCA had published no policy statement as at 8 September 2026.
Who is in scope is worked through in full on who is in scope.
You are probably already collecting most of it.
SECR and the same data, reported twice
A company already doing SECR has built much of the inventory a UK SRS S2 disclosure needs, under a different instrument and to a different audience.
SECR is live under SI 2018/1155, and DEFRA’s environmental reporting guidelines govern it.
The activity data is shared. The boundary, the audience and the purpose are not.
| SECR | UK SRS S2 | |
|---|---|---|
| Status | In force | Voluntary |
| Where it appears | Directors’ report | Strategic report, with the accounts |
| Scope 1 and 2 | Required | Required |
| Scope 3 | Limited — business travel for some | Required, with a relief |
| Energy use | Required in kWh | Not specified as such |
| Intensity ratio | At least one required | Targets and metrics, not a prescribed ratio |
| Scenario analysis | No | Required |
| Governance narrative | No | Required |
| Audience | General readers of the report | Investors, lenders and creditors |
UK SRS does not replace SECR, and nothing currently proposes that it should.
The 2026 post-implementation review of the SECR Regulations is the government’s own assessment of whether the older regime worked.
Our SECR reporting guide covers the live obligation in full.
Where and when it all gets published.
Where and when the disclosures are published
Two short sections of UK SRS S1 settle questions that cause a surprising amount of argument inside companies.
Paragraphs 60 to 63 deal with the location of disclosures, and paragraphs 64 to 69 with their timing.
The disclosures are part of general purpose financial reporting, not a separate document.
That is why they sit in the strategic report rather than in a standalone sustainability report, and why the connectivity requirements bite.
| Question | What UK SRS S1 says | Paragraphs |
|---|---|---|
| Where do they go? | In general purpose financial reports, cross-referenced where permitted | 60–63 |
| When are they published? | At the same time as the related financial statements | 64–69 |
| For what period? | The same reporting period as the financial statements | 64–69 |
| For which entity? | The same reporting entity | 20 |
| In what currency? | The same presentation currency | 24 |
| Can they come later? | Not in the UK — IFRS S1 ¶E4 was removed | Annex A |
A separate sustainability report published in June is not a UK SRS disclosure.
It may be a perfectly good document, but the standard is about what appears in the annual reporting package.
And where judgement enters.
Judgements, estimates and uncertainty
Much of a sustainability disclosure is estimated, and the standard treats that as normal rather than as a failure.
UK SRS S1 paragraphs 74 to 76 cover judgements, and paragraphs 77 to 82 cover measurement uncertainty.
The requirement is not to be certain. It is to be explicit about where you are not.
That is the same discipline the financial statements already apply to provisions and impairments.
| Area | What the standard asks | Paragraphs |
|---|---|---|
| Judgements | The judgements made in preparing the disclosures | 74–76 |
| Uncertainty | The sources of measurement uncertainty | 77–82 |
| Effect | The effect of that uncertainty on the amounts disclosed | 77–82 |
| Estimates | That an amount is an estimate, and the basis for it | 77–82 |
| Errors | Correction of prior-period errors | 83–86 |
| Scope 3 in practice | Estimation is expected; the relief at S2 ¶C4 exists for the timing, not the difficulty | S2 ¶C4 |
An unlabelled estimate is the defect. An labelled one is the standard working.
Scope 3 is where this matters most, because almost none of it is measured directly.
The board sees numbers and targets.
Metrics and targets, and how a target is judged
The fourth pillar is where the disclosure stops being narrative, and it is the one an outside reader checks first.
UK SRS S1 paragraphs 45 to 53 set the general requirement, and UK SRS S2 fills it in for climate.
A target without its basis, its scope and its progress is not a disclosure.
The standard asks not only what the target is but how it was set, what it covers, and where the entity has got to.
| Element | What is asked | Where |
|---|---|---|
| Cross-industry metrics | Required of every entity applying S2 | S2, metrics |
| Industry-based metrics | May refer to and consider | S2 ¶¶12, 23, 32 |
| Scope 1 and 2 | Required, Scope 2 location-based | S2 ¶¶29, B30 |
| Scope 3 | Required, with a relief | S2 ¶C4 |
| Financed emissions | Where applicable, plus an explanation duty | S2 ¶¶B59, B59A |
| Targets | The target, its scope, and how it was set | S1 ¶¶45–53 |
| Progress | Performance against the target | S1 ¶¶45–53 |
| Basis | Whether the target is required by law or voluntary | S1 ¶¶45–53 |
A target set against a baseline you no longer report is the commonest gap.
Because the disclosures ship with the accounts, the target and its progress are now audited-adjacent even where they are not assured.
Some companies are starting anyway.
Reporting voluntarily now, and what it buys you
The consultation response is explicit 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.
That is an unusual position for a reporting standard, and it creates a genuine choice rather than a compliance date.
Nobody has to do this. Some will anyway, and their reasons are not compliance reasons.
The commonest is that investors, lenders or a parent company are already asking the questions the standard answers.
The second is that a first report takes longer than a deadline usually allows, and doing it early converts a scramble into a project.
| What it gets you | What it does not | |
|---|---|---|
| Compliance | A statement of compliance, if the reliefs allow it | Any legal protection — there is no obligation to comply with |
| Data | A tested inventory and a repeatable process | A shortcut past Scope 3 screening |
| Governance | An evidenced oversight trail from year one | A committee that did not previously exist |
| Assurance | A dry run before assurance is ever required | An assurance opinion anyone is obliged to give |
| Comparatives | A prior year in hand when a duty arrives | Relief from ¶E1 — you would not need it anyway |
| Position | Time to argue with the standard before it binds | Certainty that the final rules will match the drafts |
The risk is doing it against CP26/5 as drafted rather than against the standards as published.
The consultation paper was written before the final text existed and describes relief periods the published standards do not contain, which DBT anticipated in its letter of 5 January 2026.
A readiness assessment is on the readiness assessment page.
How it was argued over, and by whom.
How the standards were consulted on
The endorsement ran over roughly fourteen months, and the record of it is public at every stage.
The FRC-hosted Technical Advisory Committee agreed its recommendations at a public meeting on 5 December 2024 and published them on 18 December 2024 — two dates that are frequently merged into one.
209 responses, 199 of them from organisations.
The exposure-draft consultation ran from 25 June to 17 September 2025, and the government response records 170 online submissions and 39 by email.
The Investment Association’s response to CP26/5 alone represented 250 members managing around £10 trillion.
Then a letter, seven weeks before publication, changed the reliefs.
DBT wrote to the FCA on 5 January 2026 because, in its own words, “the final standards will not be published by the time your consultation goes live”.
Our page on the consultation covers the responses in detail.
The standard defines its own vocabulary.
The words the standard defines for itself
Appendix A of UK SRS S1 is a defined-terms appendix, and it carries the same authority as the body of the standard.
That matters because several of these words mean something narrower inside the standard than they do in ordinary use.
A term the standard defines is not a term you may use loosely in a disclosure that claims compliance.
| Term | The narrower sense the standard uses |
|---|---|
| Material | Judged by influence on primary users’ decisions, not by size or public concern |
| Primary users | Existing and potential investors, lenders and other creditors — not the public |
| Value chain | The activities, resources and relationships the entity uses and depends on |
| Reporting entity | The same entity as the related financial statements |
| Climate resilience | Capacity to adjust, assessed through scenario analysis |
| Transition plan | An aspect of overall strategy, with targets and actions |
| Connected information | Consistency of data, assumptions and currency with the accounts |
| General purpose financial reports | The reporting package the disclosures belong to |
“Material” is the one that causes the most trouble.
A topic can be significant to the public, to employees and to regulators, and still not be material under UK SRS, because the test is influence on the decisions of investors, lenders and creditors.
That is the whole of the single-versus-double materiality argument, in one defined term.
And the standard behind the standard moved too.
The ISSB’s December 2025 amendments
UK SRS S2 was issued after the ISSB amended IFRS S2, and that timing removed the need for several provisions the UK would otherwise have had to add.
Annex A records it directly: because UK SRS S2 was issued after those amendments, the additional provisions at IFRS S2 paragraphs C1A, C1B and C6 “are not needed”.
The amendments are already inside UK SRS S2 rather than sitting on top of it.
Annex A lists them for clarity: amended paragraphs 29(a)(ii), 29(a)(vi)(2), B21 to B22, B24, B28, B37, B59, B62(a) and B63(a), and added paragraphs 29A to 29C, B62A and B63A.
It also notes that additional paragraphs in UK SRS follow the numbering structure the ISSB used, so that paragraph numbers do not drift apart between the two texts.
One proposed UK amendment was withdrawn because of this.
The UK proposed removing the GICS requirement; the ISSB made that change itself, so the UK amendment was dropped.
This is the clearest example of why a count of UK amendments taken from the June 2025 consultation cannot describe the published standards.
The current text of the international standards is indexed in the IFRS Sustainability Standards Navigator.
Five things you will read that are not true.
Common statements about the standards that are wrong
Each of the claims below appears widely, including in professional commentary, and each is contradicted by the published text.
They share a cause: they describe the June 2025 exposure drafts, or the FCA’s consultation, rather than the standards issued on 25 February 2026.
A consultation is not a rule, and a draft is not a standard.
| The claim | Why it is wrong |
|---|---|
| “UK SRS is mandatory from 2027” | It is mandatory for nobody. The FCA has proposed rules from 1 January 2027 and had published no policy statement as at 8 September 2026. |
| “There are six UK amendments” | Six was the count of proposals in June 2025. One was withdrawn, one replaced, and further provisions added. Annex A is the authoritative map and carries no count. |
| “The Scope 3 relief lasts one year” | Paragraph C4’s reference to the first annual reporting period was removed before publication. |
| “The climate-first relief was extended to two years” | That was the exposure draft. The final standard removed the time limit altogether. |
| “UK SRS S2 requires dual reporting of Scope 2” | Paragraph B30 requires location-based; paragraph B31 makes market-based permissive. Dual reporting is the GHG Protocol’s requirement. |
| “UK SRS has an effective date” | The effective-date provisions were removed before publication, deliberately, so timings could be set later. |
| “515 companies are affected” | Around 600 are affected. 515 would have to comply; 89 would state which regime applies to them. |
| “UK SRS replaces SECR” | SECR remains in force under SI 2018/1155 and nothing proposes its withdrawal. |
| “Complying with UK SRS means complying with the ISSB Standards” | UK SRS is not word-for-word IFRS S1 and S2; the differences are in Annex A. |
The cheapest way to avoid all nine is to read the standard rather than a summary of it.
Both documents are free, published on GOV.UK, and shorter than most of the commentary written about them.
So read it yourself.
How to read the primary sources yourself
Everything on this page can be checked against four documents, and the order you open them in makes a considerable difference.
Start with the standards, because most disagreements dissolve on contact with the actual paragraph.
Then read Annex A, because it tells you exactly what the UK changed and what it did not.
| Read | For | Watch for |
|---|---|---|
| 1. The standards | The requirements themselves, and the transition appendices | The front matter says “paragraphs 1–86” and there are also ¶¶73A and 73B |
| 2. Annex A | Every difference from IFRS S1 and S2 | It is exhaustive by its own terms, and carries no count |
| 3. The government response | What the consultation said and what was decided | ¶1.21 is where the voluntary position is stated |
| 4. CP26/5 | The FCA’s proposal and its cost benefit analysis | Drafted before the final standards existed, so its relief periods are superseded |
If a commentary and a paragraph disagree, the paragraph wins.
Where a claim on this page rests on a document, that document is linked in the record below, with a line saying why you would open it.
Nothing here rests on a consultancy explainer: where one was the only available source, we went to what it cited instead.
Most readers here already report something.
If you already report under TCFD
A company already reporting to TCFD has the structure of a UK SRS S2 disclosure and not yet its depth.
The four pillars are the same, because the TCFD’s eleven recommended disclosures under four pillars were the frame the ISSB built IFRS S2 on.
The TCFD was disbanded in 2023 and the IFRS Foundation took over monitoring companies’ climate-related disclosures.
So this is a continuation rather than a change of direction.
The differences are in specificity, and there are four worth planning for.
UK SRS S2 requires Scope 3 greenhouse gas emissions, where TCFD recommended them only if appropriate.
It requires the GHG Protocol Corporate Standard as the measurement basis unless another is required by a regulator or exchange.
It requires climate resilience to be assessed using climate-related scenario analysis, rather than recommending it.
And it requires the disclosures to connect to the financial statements, in the same reporting package and for the same period.
That connectivity requirement is where most of the new work sits, because it forces sustainability data onto the finance team’s timetable and controls.
Our climate-related financial disclosures page covers the existing UK duty, and UK SRS S2 goes through the climate standard in detail.
The framework itself is on TCFD, the overlap on TCFD and UK SRS, and the move between them on TCFD to UK SRS migration.
Which leaves one sentence worth keeping.
UK SRS exists, applies to nobody yet, and the FCA proposes 2027.
What to take away
25 February 2026
UK SRS S1 and S2 were published for voluntary use by any entity.
Nobody, yet
No entity is required to report against them by force of law.
No effective date
The effective-date provisions were removed before publication, deliberately.
1 January 2027
The FCA proposes rules from this date. It is a proposal, not a rule.
515 and 89
515 listed companies would comply; 89 would state which regime they follow.
Location-based
UK SRS S2 requires location-based Scope 2 and permits market-based.
SASB is optional
“Shall” became “may” — except at S2 paragraphs 37 and B65(d).
Annex A is the map
It records every difference from IFRS, and carries no count.
Find out which UK regimes reach you, and from when.
See which regimes apply to your companyFrequently asked questions
No. UK SRS S1 and S2 were published on 25 February 2026 and are available for voluntary use by any entity. No UK law or regulation currently requires any entity to report against them. The FCA has consulted on making UK SRS S2 mandatory for certain listed companies, but it had not published a policy statement as at 8 September 2026.
The standards themselves have no effective date — the effective-date provisions were removed before publication so that timing could be set later by legislation or the FCA. The only date currently proposed is the FCA’s, for accounting periods beginning on or after 1 January 2027, and it is a proposal.
UK SRS S1 covers sustainability-related financial information in general and sets the four-pillar structure. UK SRS S2 covers climate specifically, including Scope 1, 2 and 3 greenhouse gas emissions, scenario analysis and transition plans. Paragraph E2 of UK SRS S1 requires them to be applied at the same time.
CP26/5’s cost benefit analysis at paragraph 43 estimates around 600 listed companies affected. Of those, 515 in the commercial companies, non-equity shares and transition categories would be required to comply, and 89 listed only in the secondary listing or depositary receipts categories would instead state which climate or sustainability requirements they follow.
No. UK SRS is the UK’s endorsed version of the ISSB Standards, with differences set out in Annex A of the government response. Annex A states that where a requirement is not in its table, there is no difference. Compliance with UK SRS is therefore not automatically compliance with the ISSB Standards.
No authoritative count exists. The government consulted on six proposed amendments in June 2025, but that set changed before publication: one proposal was withdrawn after the ISSB made the change itself in December 2025, another was replaced, and further provisions were added. Annex A of the government response is the authoritative mapping of the final differences and carries no count.
No. Paragraph B30 states that an entity is required to disclose Scope 2 greenhouse gas emissions using a location-based approach, and paragraph B31 makes market-based disclosure permissive. The GHG Protocol Scope 2 Guidance requires dual reporting; UK SRS S2 does not.
Largely no. The UK changed “shall” to “may” in UK SRS S1 paragraphs 55(a) and 58(a) and UK SRS S2 paragraphs 12, 23 and 32, so entities may refer to and consider them. Paragraph 37 and paragraph B65(d) of UK SRS S2 keep “shall”.
Three. Climate-only reporting under UK SRS S1 paragraph E3, a Scope 3 relief under UK SRS S2 paragraph C4, and a GHG Protocol methodology relief under UK SRS S2 paragraph C3. The first two had their first-period time limits removed before publication; the third kept its limit. Using a relief must be disclosed under paragraph 73A.
No. Streamlined Energy and Carbon Reporting continues under SI 2018/1155 as a separate, live obligation. UK SRS does not replace SECR, ESOS, or the climate-related financial disclosure duty in section 414CB of the Companies Act 2006.
Single, financial materiality. UK SRS S1 paragraph 3 asks what could reasonably be expected to affect the entity’s cash flows, its access to finance or its cost of capital. This differs from the EU’s double materiality, which adds the entity’s impacts on people and the environment.
The standards are issued by the Secretary of State for Business and Trade. Their own copyright notice reads “UK Sustainability Reporting Standards are issued by the Secretary of State for Business and Trade”, and it adds that they “have not been prepared or endorsed by the International Sustainability Standards Board”. The publication page is on GOV.UK.
No. UK SRS is the UK’s endorsed version of IFRS S1 and IFRS S2, and Annex A of the government response maps every difference. Annex A also states that where a requirement is not in its table there is no difference, which is what makes it exhaustive. Compliance with UK SRS is therefore not automatically compliance with the ISSB Standards.
They were removed before publication. Annex A records that “the effective date has been removed from UK SRS S1, meaning that entities can apply the Standard when they choose to do so, unless required by UK law or regulations”. The requirement that S1 and S2 are applied at the same time was retained, at paragraph E2.
The Department for Business and Trade wrote to the FCA on 5 January 2026 saying it would remove the specific time references and specify instead that timing “will be set out in government regulations (Companies Act) or FCA rules (where relevant) or by any other relevant authority”. That letter is the primary source for the change, and it was written seven weeks before the standards appeared.
209. The government response records 199 from organisations and 10 from individuals, across 170 online submissions and 39 by email. The consultation on the exposure drafts ran from 25 June to 17 September 2025.
The FRC-hosted Technical Advisory Committee agreed its endorsement recommendations at a public meeting on 5 December 2024 and published them on 18 December 2024. Those two dates are frequently merged into one and they are different events.
No entity of any kind is currently required to apply UK SRS, private or listed. The FCA’s proposal in CP26/5 reaches listed issuers only. Any extension to private companies would have to come through the Companies Act, and no such consultation has been run.
It is a UK addition with no IFRS equivalent. An entity using the climate-only relief at paragraph 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 the use of the relief is disclosed.
Another UK addition. Where an entity determines it is impracticable to reliably estimate financed emissions for the same reporting period as the related financial statements, UK SRS S2 paragraph B59A requires it to explain why. It adds a disclosure duty rather than relaxing one.
CP26/5’s cost benefit analysis at paragraph 43 puts 515 companies in the commercial companies, non-equity shares and non-voting equity shares, and transition categories in the group required to comply. A further 89 listed only in the secondary listing or depositary receipts categories would instead disclose which requirements apply in their primary listing location.
No. As at 8 September 2026 the FCA had published no policy statement responding to CP26/5. The consultation page says the regulator aims to publish one in autumn 2026, subject to the final UK SRS, with rules coming into force from 1 January 2027. Until that policy statement exists, everything in CP26/5 is a proposal.
UK SRS S2 requires Scope 1, Scope 2 and Scope 3 greenhouse gas emissions. A transitional relief at paragraph C4 exists for Scope 3, and its reference to the first annual reporting period was removed before publication, so its availability would be set by whichever instrument mandates the standard.
The GHG Protocol Corporate Standard, unless another is required by a regulator or an exchange the entity is listed on. A transitional relief at UK SRS S2 paragraph C3 covers a change of methodology, and unlike the other two reliefs it kept its limit to the first annual reporting period.
Yes. UK SRS S2 requires an entity to assess its climate resilience using climate-related scenario analysis, where TCFD recommended it. This is one of the four places a TCFD reporter usually finds new work.
In practice it supersedes it. The TCFD was disbanded in 2023 and the IFRS Foundation took over monitoring companies’ climate-related disclosures. The four pillars and eleven recommended disclosures the TCFD set out in June 2017 are the frame IFRS S2, and therefore UK SRS S2, is built on.
UK SRS expects sustainability disclosures to be published in the same reporting package and for the same period as the financial statements. For most companies this is where the real work sits, because it puts sustainability data on the finance team’s timetable and under its controls.
Largely no. The UK changed “shall” to “may” in UK SRS S1 paragraphs 55(a) and 58(a) and UK SRS S2 paragraphs 12, 23 and 32, so an entity may refer to and consider them. Paragraph 37 and paragraph B65(d) of UK SRS S2 keep “shall”, so the industry-based guidance remains mandatory in those two places.
No authoritative count exists, and any number you are given should be treated with care. The government consulted on six proposed amendments in June 2025, but one was withdrawn after the ISSB made the change itself in December 2025, another was replaced, and further provisions were added. Annex A of the government response is the authoritative mapping of the final differences and it carries no count.
Inside the strategic report, which is where UK narrative and sustainability reporting sits under the Companies Act. UK SRS S1 paragraphs 60 to 63 deal with the location of disclosures, and the FRC’s Guidance on the Strategic Report governs the document itself.
Yes. UK SRS S1 paragraph 20 requires them to be for the same reporting entity as the related financial statements, and paragraph 22 requires you to identify which financial statements they relate to. Paragraph 24 adds that the presentation currency must match.
Paragraph 23 requires consistent data and assumptions across the two. In practice this is the requirement that changes how a company is organised, because an inconsistency between a scenario assumption and an impairment assumption becomes visible.
No. The no-comparatives-in-year-one provision from IFRS S1 was retained as paragraph E1 of UK SRS S1. Comparatives on non-climate matters are not required until the second annual reporting period after the entity stops using the climate-only relief, under paragraph E4(b).
No. IFRS S1 paragraph E4 permitted that in the first year and it was not carried into UK SRS S1. Annex A records that “this has been removed”, so the connectivity requirement applies from the first report.
Physical risk is the effect of the climate itself, acute like flood and storm or chronic like heat and water stress. Transition risk is the effect of the response to climate change — policy, technology, market and reputation. A scenario that lowers one usually raises the other.
No. It requires disclosure of the transition plan where the entity has one. Whether having a plan becomes a duty in its own right is the subject of a separate government consultation on climate-related transition plan requirements.
The Transition Plan Taskforce’s Disclosure Framework of October 2023, now hosted by the IFRS Foundation. It applies three guiding principles — Ambition, Action and Accountability — across five elements. The IFRS Foundation published its own guidance on transition plan disclosures in June 2025.
Its front matter says the standard is “set out in paragraphs 1–86”, but that sentence was inherited from IFRS S1 unamended: UK SRS S1 also contains paragraphs 73A and 73B, which are UK-specific additions. Do not cite 1 to 86 as the paragraph count.
Yes. Each appendix to UK SRS S1 carries the line “this appendix is an integral part of UK SRS S1 and has the same authority as the other parts of the Standard”. Appendix E is where the application and transition provisions live.
Strategy, by a wide margin: paragraphs 28 to 42. It decomposes at paragraph 29 into five limbs — the risks and opportunities, the business model and value chain, strategy and decision-making, effects on financial position and cash flows, and resilience.
Information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions primary users make on the basis of general purpose financial reports. That is paragraph 18. Paragraph B19 confirms the standard sets no threshold.
Existing and potential investors, lenders and other creditors. That definition is what makes UK SRS a financial-reporting standard rather than a sustainability one, and it is the reason the materiality test is financial.
UK SRS S1 covers sustainability-related risks and opportunities generally, so it is not limited to climate. Climate is simply the one topic written out in full, in UK SRS S2. There are no separate topical standards for other subjects.
UK SRS S1 paragraphs 73B and E5, and UK SRS S2 paragraph C6, subject the application of the standards to anything set out in the Companies Act, by the FCA, or by any other UK regulatory or government entity with the means to enact reporting requirements. They are UK-specific additions with no IFRS equivalent.
Over 40 have decided to use them or are taking steps towards them, on the IFRS Foundation’s own figures. Nineteen had requirements in effect as at 24 February 2026. Those jurisdictions account for more than 40% of global market capitalisation.
3 November 2021, announced at COP26 and hosted by the IFRS Foundation. It issued IFRS S1 and IFRS S2 in June 2023, and IFRS S2 took effect internationally from 1 January 2024.
No. SECR requires at least one intensity ratio. UK SRS S2 requires metrics and targets, including cross-industry metrics and the entity’s own targets, but does not prescribe a particular ratio in the way SECR does.
No. That is a SECR requirement under SI 2018/1155 and DEFRA’s environmental reporting guidelines. UK SRS S2 asks for greenhouse gas emissions rather than energy consumption as such, which is one reason the two reports are not interchangeable.
None is required, because no reporting obligation exists. The government has consulted on assurance of sustainability reporting and published a response on developing an oversight regime; the standard a provider would work to is the FRC’s ISSA (UK) 5000.
UK SRS S2 does not name one, so the choice and its justification are themselves disclosures. The NGFS portal is the central-bank set, the IEA’s Net Zero Emissions by 2050 scenario in World Energy Outlook 2025 is the energy-sector reference, and the IPCC’s Sixth Assessment Report is the underlying science.
In practice yes. Scenario vintages move — the IEA’s NZE scenario in WEO-2025 is not the same pathway as earlier editions — so a scenario cited without its year is one nobody can check or reproduce.
The wider UK programme within which UK SRS sits, set out in a written ministerial statement of 21 October 2025. It is the vehicle by which the current patchwork of reporting regimes could be consolidated, and it is separate from the standards themselves.
Nothing currently proposes that. The government published a 2026 post-implementation review of the SECR Regulations 2018, which is the best available signal on the regime’s future, but SECR remains in force and UK SRS does not replace it.
On GOV.UK. The publication page carries both standard documents and the government response, and the guidance page is DBT’s landing page for the regime. Reading the text is materially different from reading commentary about it, and it is free.
No. It is mandatory for nobody. The FCA has proposed rules coming into force from 1 January 2027 for certain listed companies, and as at 8 September 2026 it had published no policy statement making them.
They are the same thing under different labels. The standards themselves are titled UK Sustainability Reporting Standards, abbreviated UK SRS, and that is the name used on GOV.UK and in the standards’ own text.
The standards are issued for the United Kingdom and carry no territorial carve-out of their own. Any obligation to apply them would come from the instrument that mandates them, and its own extent would govern.
Nothing changes for anyone, because nothing currently requires UK SRS reporting. A slip would move the proposed commencement, and voluntary reporters would be unaffected.
Only if you actually apply the standards and your use of any relief permits it. UK SRS S1 paragraphs 72 to 73 govern the statement of compliance, and paragraph 73A restricts it where the climate-only relief has been used.
No. Assurance is not addressed by the standards at all; it is being consulted on separately, and the government has published a response on developing an oversight regime.
UK SRS S1 runs to 86 numbered paragraphs plus 73A and 73B, with five appendices. Both are shorter than most of the commentary written about them, and both are free on GOV.UK.
UK SRS S1 paragraphs 83 to 86 deal with errors and their correction. A change of GHG methodology in the first annual reporting period has its own relief at UK SRS S2 paragraph C3.
UK SRS S2 is confirmed as a national reporting framework for section 414CB(6) of the Companies Act 2006. That is a recognition, not an obligation: no duty to apply UK SRS has been made under the Act.
There is nothing to be exempt from, because no obligation exists. The FCA’s proposal reaches listed issuers only, and any extension beyond them would require its own consultation.
It is a feature of the FCA’s proposed rules, not of the standards. Under CP26/5 as drafted, Scope 3 and the non-climate parts of UK SRS S1 would be on a comply-or-explain basis for the 515.
The standards themselves, and Annex A of the government response for anything about how the UK differs from IFRS. Both are primary, both are free, and both are shorter than the summaries.
They require disclosure of targets and of a transition plan where one exists, rather than requiring any particular ambition. What target an entity sets is its own decision; what it must do is disclose the target, its basis and its progress.
No. UK SRS S1 covers sustainability generally and UK SRS S2 covers climate. There are no separate topical standards for water, biodiversity, workforce or governance in the way the ESRS provide them.
The FRC hosted the Technical Advisory Committee that made the endorsement recommendations, and it publishes assurance standards and guidance on the strategic report. It is not the body that issues UK SRS.
Nobody. Three independent primary sources agree: the GOV.UK guidance says the standards are available for voluntary use by any entity; the consultation response says UK SRS is available to use immediately for voluntary reporters; and neither standard contains an effective-date paragraph.
Reporting a proposal as a rule. The FCA’s CP26/5 is a consultation, its policy statement has not been published, and the standards themselves impose no obligation on anyone. Almost every wrong statement about UK SRS traces back to that.
Through a separate instrument: the Companies Act, FCA rules, or another UK regulator. UK SRS S1 paragraphs 73B and E5, and UK SRS S2 paragraph C6, are the machinery for that, and none of the three routes has yet been taken.
S2, by a wide margin, because it requires Scope 1, 2 and 3 emissions, climate scenario analysis and transition-plan disclosure. S1 sets the frame; S2 fills it in for one subject and that filling-in is where the effort goes.
UK SRS S1 paragraph E3 permits exactly that. The consequence is at paragraph 73A: you may not assert compliance with UK SRS S1, and you must disclose that you used the relief. You may still assert compliance with UK SRS S2.
Yes. Both are published on GOV.UK alongside the government response and Annex A, at no cost and without registration. That is worth knowing because much of the commentary about them is not free and is less accurate.
It is the annex to the government response that maps every difference between UK SRS and the IFRS Standards. It matters because 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.
No. This is an independent reference site. It states what the standards and the consultations say, with a link to each source, and it is not legal, accounting or investment advice on your own position.
When a primary source changes. The verified date at the foot of the page and the dateModified in its structured data are updated together, and only when there is a real edit behind them.
The FCA publishing its policy statement. That single document would convert the largest proposal on this page into a rule, fix the commencement date, and settle which reliefs are available and for how long.
Because the government removed the effective-date provisions deliberately, so that timing could be set later by legislation or by the FCA rather than being fixed inside the standards. The consultation response gives the reason: to avoid confusion with the introduction of any reporting requirements.
That is a judgement rather than a compliance question. Waiting costs nothing legally, because nothing is required; but a first inventory, a governance trail and a Scope 3 screen all take longer than a commencement date usually allows, and none of that work is wasted if the rules change shape.
Two standards, issued by the Secretary of State for Business and Trade on 25 February 2026, based on the ISSB’s IFRS S1 and S2 with differences set out in Annex A, available for voluntary use by any entity, required of nobody, and proposed by the FCA for around 600 listed companies from 1 January 2027.
Yes. The consultation response states 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.
UK SRS terms, defined
Eighty terms this page uses, each defined against the provision it comes from.
- UK SRS
- The UK Sustainability Reporting Standards. Two standards — UK SRS S1 and UK SRS S2 — issued by the Secretary of State for Business and Trade on 25 February 2026 for voluntary use by any entity.
- UK SRS S1
- General Requirements for Disclosure of Sustainability-related Financial Information. The general standard: it sets the four-pillar structure and the materiality test that UK SRS S2 then applies to climate.
- UK SRS S2
- Climate-related Disclosures. The climate standard, covering Scope 1, 2 and 3 greenhouse gas emissions, climate scenario analysis and transition plans.
- ISSB
- The International Sustainability Standards Board, formed on 3 November 2021 and hosted by the IFRS Foundation. It issued IFRS S1 and IFRS S2 in June 2023.
- IFRS S1 / IFRS S2
- The ISSB’s global baseline standards. UK SRS S1 and S2 are the UK’s endorsed versions of them, with the differences set out in Annex A of the government response.
- Annex A
- The annex to the government response that maps every difference between UK SRS and the IFRS Standards. It is exhaustive by its own terms — where a requirement is not in its table, there is no difference — and it carries no count.
- Endorsement
- The process by which the UK assesses an international standard and adopts it, with or without change. The FRC-hosted Technical Advisory Committee agreed its recommendations on 5 December 2024.
- TAC
- The UK Sustainability Disclosure Technical Advisory Committee, hosted by the FRC. It made the technical endorsement recommendations that led to UK SRS.
- DBT
- The Department for Business and Trade, which ran the exposure-draft consultation and published the standards. It was renamed the Department for Business, Innovation, Science and Trade on 21 July 2026, so contemporaneous documents carry the older name.
- CP26/5
- The FCA consultation paper proposing to align listed issuers’ sustainability disclosures with UK SRS. Its cost benefit analysis at paragraph 43 is the source of the 515 and 89 figures.
- Policy statement
- The document by which the FCA makes rules after a consultation. None responding to CP26/5 had been published as at 8 September 2026, which is why everything in it remains a proposal.
- Comply or explain
- A mechanism under which an entity either meets a requirement or explains why it has not. It is a feature of the FCA’s proposed rules, not of the standards themselves.
- Financial materiality
- The test UK SRS applies: information about 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.
- Double materiality
- The EU’s test under the CSRD, which adds a second limb: the entity’s own impacts on people and the environment, whether or not those impacts rebound on its finances.
- Primary users
- Existing and potential investors, lenders and other creditors. Materiality under UK SRS is judged by influence on their decisions, which is what makes it a financial-reporting standard.
- The four pillars
- Governance, strategy, risk management, and metrics and targets. Set out at UK SRS S1 paragraph 25, and inherited from the TCFD’s 2017 structure.
- TCFD
- The Task Force on Climate-related Financial Disclosures, which published four pillars and eleven recommended disclosures in June 2017. It was disbanded in 2023 and the IFRS Foundation took over monitoring.
- Scope 1
- Direct greenhouse gas emissions from sources an entity owns or controls.
- Scope 2
- Indirect emissions from purchased energy. UK SRS S2 paragraph B30 requires the location-based figure; paragraph B31 makes market-based permissive.
- Scope 3
- Indirect emissions across the value chain, in fifteen categories under the GHG Protocol. Required by UK SRS S2, with a transitional relief at paragraph C4.
- Location-based
- A Scope 2 method using average emissions intensity of the grid the entity draws from. This is the figure UK SRS S2 requires.
- Market-based
- A Scope 2 method reflecting contractual instruments such as renewable energy certificates. UK SRS S2 permits it; it does not require it.
- Dual reporting
- Publishing both location-based and market-based Scope 2 figures. Required by the GHG Protocol Scope 2 Guidance where supplier-specific data exists. Not required by UK SRS S2.
- GHG Protocol
- The Greenhouse Gas Protocol Corporate Standard, the measurement basis UK SRS S2 requires unless another is required by a regulator or exchange.
- Financed emissions
- Emissions associated with an entity’s lending and investment. UK SRS S2 paragraph B59A requires an explanation where estimating them for the same period is impracticable.
- Scenario analysis
- A method of assessing resilience against different possible futures. UK SRS S2 requires climate resilience to be assessed using it, where TCFD only recommended it.
- Transition plan
- An entity’s plan for its response to climate change, including targets and the actions behind them. A separate government consultation asks whether these should become a requirement in their own right.
- Connectivity
- The requirement that sustainability disclosures sit in the same reporting package, and cover the same period, as the financial statements.
- Transitional relief
- A provision easing a requirement for a period. UK SRS has three; two lost their time limits before publication and one, at UK SRS S2 paragraph C3, kept its.
- Climate-only relief
- UK SRS S1 paragraph E3, permitting an entity to disclose only climate-related information. Using it means you may not assert compliance with UK SRS S1, under paragraph 73A.
- Statement of compliance
- The assertion that a report has been prepared in accordance with a standard. Paragraph 73A governs how it works where a relief has been used.
- SASB Standards
- Industry-specific metric sets, stewarded by the IFRS Foundation. The UK changed “shall” to “may” for them, except at UK SRS S2 paragraphs 37 and B65(d).
- SECR
- Streamlined Energy and Carbon Reporting, in force under SI 2018/1155. A separate, live obligation that UK SRS does not replace.
- ESOS
- The Energy Savings Opportunity Scheme, a mandatory energy assessment running on a four-year cycle, administered by the Environment Agency.
- Section 414CB
- The Companies Act 2006 provision carrying the existing climate-related financial disclosure duty. UK SRS S2 is named as a national framework for subsection (6).
- Strategic report
- The part of a UK annual report where narrative and sustainability disclosures sit, governed by the Companies Act and the FRC’s guidance.
- CSRD
- The EU Corporate Sustainability Reporting Directive, which applies double materiality and is the regime UK SRS is most often compared against.
- ESRS
- The European Sustainability Reporting Standards made under the CSRD. The Commission adopted a revised set in July 2026.
- UKLR
- The FCA’s UK Listing Rules. The categories in them determine which branch of the CP26/5 proposal a listed company would fall into.
- Assurance
- Independent examination of reported information. A separate consultation covers who may assure sustainability disclosures and to what standard.
- Secretary of State for Business and Trade
- The office that issues UK SRS. The standards’ own copyright notice names it, and adds that they “have not been prepared or endorsed by the International Sustainability Standards Board”.
- Government response
- The document published alongside the standards setting out what the consultation said and what the government decided. Annex A of it is the authoritative map of every difference from IFRS.
- Exposure draft
- A draft standard published for consultation. The UK SRS exposure drafts ran from 25 June to 17 September 2025 and drew 209 responses.
- Paragraph 73A
- A UK-specific addition governing the statement of compliance where a relief has been used. Take the climate-only route and you may not assert compliance with UK SRS S1.
- Paragraph 73B
- A UK-specific addition subjecting application of UK SRS S1 to the Companies Act, the FCA, or any other UK body able to enact reporting requirements.
- Paragraph E2
- The provision requiring UK SRS S1 and UK SRS S2 to be applied at the same time. It survived the removal of the effective dates.
- Paragraph E3
- The climate-only relief in UK SRS S1: an entity may disclose only climate-related information. Its time limit was removed before publication.
- Paragraph C3
- The GHG Protocol methodology relief in UK SRS S2. Unlike the other two reliefs, it kept its limit to the first annual reporting period.
- Paragraph C4
- The Scope 3 relief in UK SRS S2. Its reference to the first annual reporting period was removed, so its availability is set by whichever instrument mandates the standard.
- Paragraph B30
- The Scope 2 provision. “For the avoidance of doubt, an entity is required to disclose its Scope 2 greenhouse gas emissions using a location-based approach.”
- Paragraph B31
- The provision making market-based Scope 2 permissive — an entity “might” disclose it.
- Paragraph B59A
- A UK-specific addition requiring an entity to explain why it cannot reliably estimate financed emissions for the same period as the related financial statements.
- Cost benefit analysis
- Annex 2 of CP26/5. Paragraph 43 is the source of the ~600, 515 and 89 figures, and citing 515 without the other two misstates the proposal.
- UKLR 6
- The commercial companies category in the UK Listing Rules. It is one of the three categories that make up the 515 in the FCA’s proposal.
- Secondary listing
- A UK Listing Rules category. Companies listed only in this category, or in depositary receipts, form the 89 in CP26/5 and would state which regime applies elsewhere.
- Written ministerial statement
- A formal statement to Parliament. HCWS973 of 21 October 2025 set out the Modernisation of Corporate Reporting programme UK SRS sits within.
- Modernisation of Corporate Reporting
- The wider UK programme covering how companies report. The correct name is “Modernisation”, not “Modernising”.
- Acute physical risk
- Event-driven climate risk — flood, storm, wildfire. Distinct from chronic physical risk, which is the slow shift in conditions.
- Chronic physical risk
- Longer-term shifts in climate conditions such as heat, water stress and sea-level rise.
- Transition risk
- Risk arising from the response to climate change rather than from the climate: policy and legal change, technology, market shift and reputation.
- Climate resilience
- The capacity of an entity to adjust to climate-related changes. UK SRS S2 requires it to be assessed using climate-related scenario analysis.
- NGFS
- The Network for Greening the Financial System, whose scenario set is the one financial institutions are most often asked to use.
- IEA NZE
- The International Energy Agency’s Net Zero Emissions by 2050 scenario. The current vintage is World Energy Outlook 2025, published 12 November 2025.
- IPCC AR6
- The Intergovernmental Panel on Climate Change’s Sixth Assessment Report. Working Group I carries the physical science basis; Working Group III carries mitigation pathways.
- Conversion factors
- The UK government’s emission factors for company reporting, published annually. They are what activity data is multiplied by.
- Activity data
- The underlying operational figures — litres of fuel, kilowatt-hours, miles travelled — that emissions are calculated from.
- Intensity ratio
- Emissions expressed per unit of activity or revenue. SECR requires at least one; UK SRS S2 does not prescribe a particular ratio.
- Cross-industry metrics
- The metrics UK SRS S2 requires of every entity, as opposed to the industry-based guidance it merely permits.
- Industry-based guidance
- The ISSB’s guidance on implementing IFRS S2 by industry. The UK made referring to it permissive, except at UK SRS S2 paragraphs 37 and B65(d).
- Value chain
- The full range of activities, resources and relationships an entity uses and depends on, upstream and downstream. It is the boundary Scope 3 is measured across.
- Fifteen categories
- The Scope 3 categories in the GHG Protocol Corporate Value Chain Standard, covering upstream and downstream emissions.
- Limited assurance
- An engagement giving a negative-form conclusion — that nothing has come to the provider’s attention. Where most first reports land.
- Reasonable assurance
- An engagement giving a positive-form opinion that the information is fairly stated. It requires a controlled process, not just a traceable source.
- ISSA (UK) 5000
- The FRC’s assurance standard for sustainability assurance engagements.
- Restatement
- Correcting a previously reported figure. UK SRS S1 paragraphs 83 to 86 deal with errors and their correction.
- Measurement uncertainty
- Where a figure depends on estimation. UK SRS S1 paragraphs 77 to 82 require the sources and effects of that uncertainty to be disclosed.
- Fair presentation
- The requirement at UK SRS S1 paragraphs 11 to 16 that a report faithfully represents the risks and opportunities it describes.
- Connected information
- UK SRS S1 paragraphs 21 to 24: the connections within and across reports, the accounts identified, consistent assumptions, and a matching presentation currency.
- Reporting entity
- The entity the disclosures are made for. Paragraph 20 requires it to be the same as for the related financial statements.
- Comply or explain
- Meeting a requirement or explaining why not. It appears in the FCA’s proposed rules, not in the standards themselves.
Where every claim on this page comes from
Each entry says what the document is and why you would open it.
- GOV.UK — UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
- GOV.UK — UK Sustainability Reporting Standards guidance
- GOV.UK — UK SRS guidance and documents collection
- GOV.UK — Exposure drafts: UK Sustainability Reporting Standards
- DBT — Consultation response (PDF)
- DBT — Letter to the FCA, 5 January 2026 (PDF)
- GOV.UK — Framework for developing UK Sustainability Reporting Standards
- FCA — CP26/5, Aligning listed issuers’ sustainability disclosures
- FCA — CP26/5 (PDF)
- FCA — Climate change and sustainable finance
- FCA — Reporting requirements
- FCA Handbook — UKLR 6
- legislation.gov.uk — FSMA 2000, section 73A
- FRC — UK Sustainability Disclosure Technical Advisory Committee
- FRC — TAC projects
- FRC — Sustainability reporting developments FAQs
- FRC — Guidance on the Strategic Report
- FRC — ISSA (UK) 5000 assurance engagements
- FRC — Assurance standards
- IFRS Foundation — IFRS S1 General Requirements
- IFRS Foundation — IFRS S2 Climate-related Disclosures
- IFRS Foundation — Sustainability Standards Navigator
- IFRS Foundation — the ISSB
- IFRS Foundation — who we are
- IFRS Foundation — United Kingdom jurisdiction snapshot
- IFRS Foundation — TCFD
- TCFD
- IFRS Foundation — guidance on transition plan disclosures
- IFRS Foundation — Transition Plan Taskforce resources
- GHG Protocol — Corporate Standard
- GHG Protocol — Scope 2 Guidance
- GHG Protocol — Corporate Value Chain (Scope 3) Standard
- GOV.UK — Government conversion factors for company reporting
- GOV.UK — Environmental reporting guidelines
- IPCC — Sixth Assessment Report, Working Group I
- IPCC — Sixth Assessment Report, Working Group III
- IEA — World Energy Outlook 2025
- NGFS — Scenarios portal
- legislation.gov.uk — Companies Act 2006, section 414CB
- legislation.gov.uk — SI 2018/1155
- legislation.gov.uk — SI 2018/1155, as made
- legislation.gov.uk — SI 2022/31
- legislation.gov.uk — SI 2022/31, as made
- GOV.UK — Energy Savings Opportunity Scheme
- GOV.UK — Comply with ESOS Phase 4
- GOV.UK — How to comply with ESOS Phase 4
- GOV.UK — 2026 post-implementation review of the SECR Regulations 2018
- GOV.UK — SECR regulations evaluation
- GOV.UK — Assurance of sustainability reporting
- GOV.UK — Assurance oversight: government response
- GOV.UK — Climate-related transition plan requirements
- GOV.UK — Transition plan implementation routes
- UK Parliament — Written statement HCWS973
- EUR-Lex — Corporate Sustainability Reporting Directive
- European Commission — revised sustainability reporting standards
- European Commission — CSRD delegated act (PDF)
- Sustainability Reporting Standards — UK SRS timeline
- Sustainability Reporting Standards — ESG reporting requirements
- Sustainability Reporting Standards
- UK SRS S1 — General Requirements (PDF)
- GOV.UK — UK SRS S2, Climate-related Disclosures
- FRC — the Technical Advisory Committee
- GOV.UK — “What the UK is doing”
- IFRS Foundation — the ISSB
- TCFD — the Final Report, June 2017
- FCA Handbook — UK Listing Rules
- legislation.gov.uk — FSMA 2000 s.73A
- GHG Protocol — the fifteen Scope 3 categories
- IPCC — AR6 Working Group III
- IEA — the NZE scenario vintage
- European Commission — the July 2026 ESRS revision
- GOV.UK — the SECR evaluation
- GOV.UK — ESOS Phase 4
- FRC
Where to go next
If you came for one answer and now need the next one, these are the pages that carry it.
The government’s own index of every official UK SRS document is the GOV.UK guidance and documents collection, which is the quickest way to check you are reading a current version.
SECR is covered in full on the SECR reporting guide and on SECR, and ESOS on the ESOS scheme page.
If ESOS is your live obligation, ESOS compliance guidance and the ESOS online service are the practical next steps.
Thresholds are a different question, and UK SRS thresholds computes which regimes reach a company from its size and listing.
If your next step is the climate standard itself, UK SRS S2 goes through Scope 1 to 3, scenario analysis and transition plans in detail.
For the general standard, UK SRS S1 covers the four pillars and the materiality test paragraph by paragraph.
If you are tracking whether the FCA proposal becomes a rule, the CP26/5 tracker follows it, and the consultation page covers the responses.
Companies already reporting energy and carbon should read SECR and ESOS, both of which continue unchanged.
For the comparison readers ask for most, CSRD vs UK SRS sets the two regimes against each other.
And UK SRS legislation traces each of the routes by which the standards could become law.
This site is an independent reference and is not legal or accounting advice; our privacy policy and terms of service set out how it is run.