Voluntary IFRS reporter
Applies IFRS S1 and S2 as issued and states compliance with them.
IFRS S1 ¶72ISSB · IFRS S1 and S2 · UK
ISSB reporting requirements in the UK: IFRS S1, S2 and UK SRS
The ISSB reporting requirements are IFRS S1 and IFRS S2, the global baseline for sustainability and climate disclosure, effective internationally from 1 January 2024.
In the UK they apply through UK SRS S1 and S2, the endorsed versions published on 25 February 2026, which are voluntary, and which the FCA applies to listed companies on comply or explain from 2027.
This page covers what IFRS S1 and S2 require, how the UK versions differ, and when a UK company or group still reports against the ISSB text directly.
In brief
ISSB reporting requirements and the UK, in brief
The International Sustainability Standards Board was announced on 3 November 2021 at COP26 and issued IFRS S1 and IFRS S2 in June 2023.
An ISSB standard has no force in a jurisdiction until that jurisdiction adopts or otherwise uses it, and the UK did so by endorsement, creating UK SRS.
The UK SRS publication page says the standards were created by assessing and endorsing the global baseline of IFRS Sustainability Disclosure Standards.
So the question “what are the ISSB reporting requirements in the UK” has two answers: the IFRS text, which anyone may choose to apply, and UK SRS, which is what UK rules refer to.
The ISSB itself is described on the ISSB framework page, and the standards are read in depth on the IFRS S1 and IFRS S2 pages.
In one table
ISSB and UK SRS requirements side by side
| Question | IFRS S1 and S2 (ISSB) | UK SRS S1 and S2 |
|---|---|---|
| Who issues it | ISSB, IFRS Foundation | Secretary of State for Business and Trade, after endorsement |
| Legal status in the UK | None of its own; voluntary use | Voluntary; comply or explain for five listing categories under FCA rules |
| Effective date | Periods beginning on or after 1 January 2024 | None in the standards; FCA rules from periods beginning on or after 1 January 2027 |
| Four disclosure areas | Governance, strategy, risk management, metrics and targets | Same |
| Materiality | Information that could influence primary users’ decisions | Same |
| SASB and industry guidance | Entity “shall” refer to and consider | Entity “may” refer to and consider |
| Later publication in year one | Permitted (IFRS S1 ¶E4) | Removed: always with the financial statements |
| Climate-first relief | First annual reporting period (IFRS S1 ¶E5) | No time limit in the standard (UK SRS S1 ¶E3); FCA limit for listed companies |
| Scope 3 relief | First annual reporting period (IFRS S2 ¶C4(b)) | No time limit in the standard (UK SRS S2 ¶C4); FCA limit for listed companies |
| Financed emissions not estimable for the period | No equivalent explanation duty | Explain why, the approach and a plan (UK SRS S2 ¶B59A) |
The UK duties are set out in full on the UK SRS S1 reporting requirements and UK SRS S2 reporting requirements pages.
IFRS S1
What IFRS S1 requires
IFRS S1 requires disclosure of information about all sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s cash flows, its access to finance or cost of capital over the short, medium or long term.
The disclosures cover governance, strategy, risk management, and metrics and targets, and only material information is required.
They form part of the general purpose financial reports and are published at the same time and for the same period as the financial statements, under ¶¶60 and 64.
To identify risks and opportunities beyond climate, ¶55(a) says the entity shall refer to and consider the SASB Standards’ disclosure topics.
An explicit and unreserved statement of compliance is allowed only if every requirement is met, under ¶72.
In the first year IFRS S1 lets an entity report climate only (¶E5) and publish after its financial statements (¶E4), and both reliefs end after that first year.
IFRS S2
What IFRS S2 requires
IFRS S2 applies the same four areas to climate-related risks, physical and transition, and climate-related opportunities.
It requires climate-related scenario analysis to assess resilience, using an approach commensurate with the entity’s circumstances.
Its metrics include absolute gross Scope 1, 2 and 3 emissions measured under the GHG Protocol, with location-based Scope 2, plus transition and physical risk exposure, opportunities, capital deployment, internal carbon prices and remuneration.
It requires industry-based metrics, with the entity referring to the ISSB’s Industry-based Guidance, and disclosures about climate targets.
The IFRS Foundation says IFRS S2 integrates and builds on the TCFD recommendations, and the Foundation took over monitoring of companies’ climate disclosures when the TCFD was disbanded.
In its first year, IFRS S2 ¶C4 relieves an entity from Scope 3 and lets it keep a non-GHG Protocol method it used before.
December 2025
The December 2025 IFRS S2 amendments and the UK
On 11 December 2025 the ISSB issued targeted amendments to IFRS S2’s greenhouse gas requirements, responding to application challenges.
They are effective for reporting periods beginning on or after 1 January 2027, with early application permitted.
The ISSB also made consequential amendments to the financed emissions metrics in three SASB Standards.
DBT told the FCA in its letter of 5 January 2026 that it would review the amendments with a view to incorporating them into UK SRS S2.
It did: Annex A says the amendments have been included in UK SRS S2 and are fully consistent, so the IFRS S2 transition paragraphs for them are not needed in the UK text.
They are the ISSB’s changes, not UK amendments, which matters most for GICS: the UK had proposed removing it and withdrew the proposal once the ISSB acted.
- 1
Category 15
Scope 3 Category 15 may be limited to financed emissions. - 2
Classification
Systems beyond GICS may be used to disaggregate financed emissions. - 3
GHG Protocol relief
The jurisdictional relief applies where only part of an entity must use another method. - 4
Global warming potentials
A jurisdictional relief from using the latest IPCC values.
UK endorsement
How the UK endorsed the ISSB standards as UK SRS
The UK endorsement framework splits the work between a Technical Advisory Committee, which assesses the standards, and a Policy and Implementation Committee of government departments and regulators.
The TAC was commissioned in May 2024, agreed its recommendations on 5 December 2024, and the FRC as secretariat published them on 18 December 2024, recommending endorsement with minor amendments.
The government consulted on exposure drafts from 25 June to 17 September 2025 and received 209 responses.
It proposed six amendments then, but the final standards differ from IFRS as set out in Annex A, which carries no count, and the history is on the UK SRS amendments page.
UK SRS S1 and S2 were published on 25 February 2026, and the standards’ own notice says they have not been prepared or endorsed by the ISSB.
A future ISSB standard does not apply in the UK automatically: the FRC says it would first need to go through the UK’s formal endorsement process.
UK differences
Where UK SRS departs from IFRS S1 and S2
Annex A of the government response is exhaustive: where a requirement is not listed, there is no difference.
| Difference | Standard | Direction |
|---|---|---|
| Effective dates removed; application set by the Companies Act, FCA or another UK authority | S1 ¶¶E2, E5, 73B; S2 ¶¶C2, C6 | Different mechanism |
| SASB and Industry-based Guidance: “shall” becomes “may” | S1 ¶¶55(a), 58(a); S2 ¶¶12, 23, 32 | More permissive |
| First-year later publication removed | IFRS S1 ¶E4 not carried over | Stricter |
| Climate-first relief without a time limit | S1 ¶E3 | More permissive |
| Climate-only reporters cannot assert S1 compliance | S1 ¶73A | Clarifying |
| Scope 3 relief without a time limit; GHG-method relief still one year | S2 ¶¶C3, C4 | More permissive |
| Explain where financed emissions cannot be estimated for the period | S2 ¶B59A | Stricter |
The FRC’s FAQs say a voluntary UK SRS user can apply the untimed reliefs indefinitely, while an IFRS reporter cannot.
Direct use
Who in the UK reports against IFRS S1 and S2 directly
IFRS S1 and S2 are available to any entity, so a UK company can apply them as issued and say so, whatever its UK obligations.
A UK group with listings or subsidiaries in a jurisdiction that requires ISSB-based reporting reports there under that jurisdiction’s version, which may carry its own reliefs or modifications.
International companies with a UK secondary listing report against UK SRS on comply or explain, and the FCA said in PS26/19 they may rely on home-jurisdiction reporting where it aligns with UK SRS outcomes, explaining where requirements are not met.
A single report can carry both statements only if it meets both texts in full, under IFRS S1 ¶72 and UK SRS S1 ¶72.
On a reading of the two texts, that means meeting the ISSB’s first-year limits on the climate-first and Scope 3 reliefs and its SASB requirement, and the UK’s publication timing and ¶B59A.
One report, two statements
A UK SRS report using the Scope 3 relief in its second year can still assert compliance with UK SRS S2 under ¶73A.
The same report cannot assert compliance with IFRS S2, whose Scope 3 relief ended after the first year.
A UK report
and the ISSB
and the ISSB
Group reporting abroad
Meets ISSB-based rules where its listings or subsidiaries are.
Check the jurisdiction’s profileUK secondary listing
May rely on home-jurisdiction reporting aligned with UK SRS, explaining any gap.
FCA PS26/19, UKLR 14Around the world
The ISSB adoption picture for UK groups
The IFRS Foundation’s jurisdiction registry, last updated 24 September 2026, publishes a profile once a jurisdiction’s approach is finalised and a snapshot where it is still in progress.
Profiles include Australia, Brazil, Hong Kong SAR, Japan, Malaysia, Mexico, Nigeria, Singapore and Türkiye, and the snapshots include Canada, China, South Korea, Switzerland and the United Kingdom.
The Foundation’s UK snapshot is dated 18 June 2026 and still describes the FCA’s consultation, so it predates PS26/19.
Its September 2026 adoption deck lists the UK’s effective date as to be determined, marking it as a jurisdiction that permits use of ISSB Standards before regulatory action is complete.
The Foundation said on 24 February 2026 that requirements in 19 jurisdictions had already come into effect, and the September deck says over 45 jurisdictions are on a journey to adopt or otherwise use the standards.
Adopting a standard and requiring companies to use it are different steps, and jurisdictions vary in reliefs: the Malaysia profile reproduced in that deck, for example, extends the climate-first and Scope 3 reliefs beyond the first year for some groups.
The same deck describes ISSB passporting, an option a regulator can grant for foreign issuers or local subsidiaries to meet local rules using the standards as issued by the ISSB.
EU subsidiaries report under CSRD and the European standards, with double materiality, as the CSRD reporting requirements page explains.
UK rules
UK listing rules refer to UK SRS, not the ISSB text
The FCA’s PS26/19 replaces the TCFD-aligned listing rules with requirements to report against UK SRS, described by the FCA as the UK-endorsed version of the ISSB standards.
It applies on a comply-or-explain basis to companies listed in UKLR 6, 14, 15, 16 and 22, for accounting periods beginning on or after 1 January 2027, with first reports in 2028.
No Companies Act duty to report against UK SRS or IFRS S1 and S2 has been made, and the government is consulting on the wider corporate reporting framework.
The combined UK picture is on the UK SRS reporting requirements page and the sustainability reporting requirements hub.
What is changing
ISSB work in progress that may reach the UK
The ISSB agreed in April 2026 to propose nature-related requirements as an IFRS Sustainability Practice Statement, and its August 2026 newsletter says it aims to publish an exposure draft in October 2026.
That is a proposal, and anything finalised would need UK endorsement before it formed part of UK SRS; nature reporting today is covered on the TNFD reporting requirements page.
The ISSB is also amending the SASB Standards and the IFRS S2 Industry-based Guidance industry by industry, which affects UK SRS users only so far as they choose to refer to that guidance.
Statements still in circulation that are wrong
“The UK has adopted IFRS S1 and S2 from 1 January 2024” — the UK endorsed them as UK SRS in 2026, with no effective date.
“ISSB reporting is mandatory for UK listed companies” — the FCA rules are comply or explain, against UK SRS.
“UK SRS compliance equals IFRS compliance” — only if the report meets every IFRS requirement too.
Check yourself
Six statements about the ISSB standards in the UK
Each answer names the source it turns on.
The standards are free to read on the IFRS Foundation’s site, and the UK versions on GOV.UK.
The wider family of frameworks is compared on the global sustainability standards page.
True or false?
IFRS S1 and S2 have applied in the UK by law since 1 January 2024.
Removing the GICS requirement for financed emissions was a UK amendment.
A new ISSB standard on nature would not apply in the UK until endorsed.
The IFRS Foundation lists the UK as a jurisdictional profile.
UK SRS S2 ¶B59A asks financial institutions for more than IFRS S2 does.
Under IFRS S1 the climate-first relief is limited to the first annual reporting period.
0 of 6 answered.
Nothing you choose is stored or sent.
Frequently asked
ISSB reporting requirements in the UK, answered
What are the ISSB reporting requirements?
The ISSB has issued two standards.
IFRS S1 sets general requirements for disclosing material information about sustainability-related risks and opportunities that could affect an entity’s cash flows, access to finance or cost of capital, across governance, strategy, risk management, and metrics and targets.
IFRS S2 applies that structure to climate, including Scope 1, 2 and 3 emissions and scenario analysis.
Both are effective internationally for periods beginning on or after 1 January 2024.
Do UK companies have to follow the ISSB standards?
No. IFRS S1 and S2 have no legal force in the UK on their own.
The UK endorsed them as UK SRS S1 and S2, published by the Department for Business and Trade on 25 February 2026 as voluntary standards.
The FCA’s PS26/19 then put companies listed in UKLR 6, 14, 15, 16 and 22 on a comply-or-explain basis against UK SRS for accounting periods beginning on or after 1 January 2027.
Has the UK adopted IFRS S1 and S2?
The UK endorsed them with amendments and issued them as UK SRS.
The IFRS Foundation lists the United Kingdom as a jurisdictional snapshot, the tier for jurisdictions whose regulatory approach is in progress, rather than a profile; its September 2026 adoption deck lists the UK’s effective date as to be determined.
What is the difference between ISSB standards and UK SRS?
UK SRS is IFRS S1 and S2 with the differences listed in Annex A of the government’s consultation response: no effective date; SASB and industry guidance references become “may”; the first-year relief for later publication is removed; the climate-first and Scope 3 reliefs lose their first-year limit; ¶73A restricts the compliance statement for climate-only reporters; and UK SRS S2 ¶B59A adds an explanation duty for financed emissions.
Everything not listed is the same.
Does complying with UK SRS mean complying with IFRS S1 and S2?
Not automatically.
A UK SRS report that relies on a relief beyond the first year, or omits SASB-based industry consideration that IFRS requires, would not meet every IFRS requirement, and IFRS S1 ¶72 allows a compliance statement only where all requirements are met.
A report built to meet both texts can make both statements.
What were the December 2025 amendments to IFRS S2?
On 11 December 2025 the ISSB amended the GHG requirements of IFRS S2 to permit Category 15 Scope 3 emissions to be limited to financed emissions, allow classification systems other than GICS for financed emissions, clarify the jurisdictional relief from the GHG Protocol where only part of an entity must use another method, and add a jurisdictional relief from using the latest IPCC global warming potentials.
They are effective from 1 January 2027 with early application permitted.
Are the December 2025 IFRS S2 amendments in UK SRS S2?
Yes.
UK SRS S2 was issued after the amendments, and Annex A of the government response says they have been included and are fully consistent, listing paragraphs 29(a)(ii), 29(a)(vi)(2), B21–B22, B24, B28, B37, B59, B62(a) and B63(a) as amended and 29A–29C, B62A and B63A as added.
They are the ISSB’s changes, not UK amendments.
Do new ISSB standards apply automatically in the UK?
No. The FRC says any new or amended standards issued by the ISSB, for example on nature or human capital, would first need to go through the UK’s formal endorsement process before being incorporated into UK SRS.
Who in the UK uses IFRS S1 and S2 directly?
Any company can apply IFRS S1 and S2 voluntarily and state compliance with them.
UK groups with listings or subsidiaries in jurisdictions that require ISSB-based reporting meet those local rules.
International companies with a UK secondary listing may rely on home-jurisdiction reporting under the FCA rules where it aligns with UK SRS outcomes, explaining any requirement not met.
Does the FCA require IFRS S1 and S2?
No. The FCA’s rules in PS26/19 refer to UK SRS, the UK-endorsed version of the ISSB standards, and apply on a comply-or-explain basis to the five in-scope listing categories for accounting periods beginning on or after 1 January 2027.
When were the ISSB standards issued?
The ISSB was announced on 3 November 2021 at COP26 in Glasgow.
It issued IFRS S1 and IFRS S2 in June 2023, effective for annual reporting periods beginning on or after 1 January 2024.
IFRS S2 was amended in December 2025.
How many jurisdictions use the ISSB standards?
The IFRS Foundation said on 24 February 2026 that requirements in 19 jurisdictions had already come into effect, and its September 2026 adoption deck says over 45 jurisdictions are on a journey to adopt or otherwise use the standards.
Taking steps towards the standards is not the same as requiring companies to report against them.
Do the ISSB standards replace TCFD?
The TCFD was disbanded in 2023 and the IFRS Foundation took over monitoring of companies’ climate disclosures.
IFRS S2 integrates the TCFD recommendations.
In the UK, the FCA’s PS26/19 replaces the TCFD-aligned listing rules with UK SRS from periods beginning on or after 1 January 2027.
Do the ISSB standards use double materiality?
No. IFRS S1 and S2 apply a financial materiality test focused on the information needs of investors, lenders and other creditors.
The European Sustainability Reporting Standards under CSRD apply double materiality, which is why a UK group with EU reporting obligations may need both.
Is the ISSB working on a nature standard?
The ISSB agreed in April 2026 to propose nature-related requirements in the form of an IFRS Sustainability Practice Statement and aims to publish an exposure draft in October 2026.
Any resulting requirement would need UK endorsement before it became part of UK SRS.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 24 sources fromIFRS FoundationDepartment for Business and TradeGOV.UK (DBT)Financial Reporting CouncilFinancial Conduct Authority
- IFRS FoundationInternational Sustainability Standards Board — group page
Formation on 3 November 2021 and the ISSB’s remit.
- IFRS FoundationIFRS S1 General Requirements — Navigator
Effective for periods beginning on or after 1 January 2024.
- IFRS FoundationIFRS S2 Climate-related Disclosures — Navigator
Standard history, including the December 2025 amendments.
- IFRS FoundationIFRS S1 full text (HTML)
¶¶72, E4 and E5: compliance statement and first-year reliefs.
- IFRS FoundationIFRS S2, December 2025 text (HTML)
¶¶29, C4: emissions and first-year reliefs.
- IFRS FoundationISSB issues targeted amendments to IFRS S2 (11 December 2025)
The four GHG amendments, effective from 1 January 2027.
- IFRS FoundationUse of IFRS Sustainability Disclosure Standards by jurisdiction
Profiles and snapshots; page stamped 24 September 2026.
- IFRS FoundationJurisdictional snapshot: United Kingdom (18 June 2026, PDF)
The Foundation’s overview of the UK; it predates PS26/19.
- IFRS FoundationJurisdictional Readiness Assessment Guide and tool (24 February 2026)
“Requirements in 19 jurisdictions have already come into effect.”
- IFRS FoundationAdoption of IFRS Sustainability Disclosure Standards — WSS plenary deck (September 2026, PDF)
Effective dates by jurisdiction, the UK as “to be determined”, and ISSB passporting.
- IFRS FoundationNational Standard-setters Newsletter — August 2026
Nature-related practice statement, exposure draft aimed at October 2026.
- IFRS FoundationIFRS Foundation and the TCFD
The ISSB took over monitoring of climate disclosure from the TCFD.
- Department for Business and TradeUK SRS S1 (PDF)
¶¶72–73B and Appendix E, the UK differences in application.
- Department for Business and TradeUK SRS S2 (PDF)
¶B59A and Appendix C.
- GOV.UK (DBT)UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
UK SRS created by assessing and endorsing the IFRS baseline; published 25 February 2026.
- GOV.UK (DBT)UK Sustainability Reporting Standards — guidance
The endorsement process, the TAC and PIC, and voluntary use.
- GOV.UK (DBT)Framework and Terms of Reference for the Development of UK SRS
The endorsement framework.
- GOV.UK (DBT)Exposure drafts: UK Sustainability Reporting Standards — consultation and outcome
25 June to 17 September 2025; 209 responses.
- Department for Business and TradeConsultation response (PDF), Annex A
Every difference between UK SRS and IFRS S1 and S2.
- Department for Business and TradeLetter from DBT to the FCA, 5 January 2026 (PDF)
The ISSB’s December 2025 amendments to be reviewed for UK SRS S2.
- Financial Reporting CouncilUK Sustainability TAC issues final recommendations (18 December 2024)
Recommendation to endorse IFRS S1 and S2 for UK use.
- Financial Reporting CouncilSustainability Reporting Developments: Frequently Asked Questions
Future ISSB standards need UK endorsement; UK SRS differences.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards
Listed companies report against UK SRS on comply or explain.
- Financial Conduct AuthorityPS26/19 (PDF), response on international companies
UKLR 14 issuers may rely on home-jurisdiction reporting and explain gaps.