UK SRS amendments · Annex A of the government response
UK SRS amendments: where the UK text departs from IFRS
UK SRS S1 and S2 are the ISSB’s IFRS S1 and S2, endorsed for the UK with a small set of amendments.
The authoritative list is Annex A of the government response: a paragraph map that states “where requirements in the standards are not included in the table, there are no differences between the two”.
It gives no total, so neither do we — the “six amendments” often quoted were the proposals of June 2025, not what was published.
The authority
Annex A is the map, and it has no total
The government endorsed the International Sustainability Standards Board’s first two standards for UK use and published them as UK SRS S1 and UK SRS S2 on 25 February 2026.
The government response explains every change, and its Annex A sets them out paragraph by paragraph against IFRS S1 and IFRS S2.
The scoping rule makes Annex A exhaustive: anything not in it is identical to the IFRS text.
A count of “UK amendments” depends on how you group rows, which is why no official one exists and why any number you see is someone’s own tally — usually the June 2025 proposal count.
The rest of the text is the ISSB baseline; global sustainability standards sets it among the other frameworks, and the IFRS navigator holds the originals.
“Where requirements in the standards are not included in the table, there are no differences between the two.”
“Additional paragraphs in UK SRS follow the structure used by the ISSB in its amendments to IFRS S2 as issued in December 2025, to avoid discrepancies in overall paragraph numbering.”
UK SRS S1
UK SRS S1 against IFRS S1, row by row
| IFRS S1 | UK SRS S1 | The difference |
|---|---|---|
| ¶¶55(a), 58(a) | ¶¶55(a), 58(a) | Entities “may” rather than “shall” refer to and consider the applicability of the SASB Standards. |
| — | ¶¶73A, 73B (new) | 73A: using the climate-only relief (E3) means no statement of compliance with UK SRS S1, and the relief must be disclosed; using E3 or the S2 reliefs does not prevent a statement of compliance with UK SRS S2, if disclosed. 73B: application is subject to regulation or legislation by the Companies Act, the FCA or another UK authority able to set reporting requirements. |
| ¶¶E1, E2 | ¶E2 | Effective date removed; entities apply the standard when they choose, unless required by law or regulation. S1 and S2 are still applied at the same time. |
| ¶E3 | ¶E1 | Date-of-initial-application reference removed; the no-comparatives-in-year-one relief kept. |
| ¶E4 | Not applicable | The first-year permission to publish sustainability information after the financial statements is removed. |
| ¶E5 | ¶¶E3, E5, 73A | Climate-first relief kept, with “the first annual reporting period” removed; its availability is set by legislation or regulation (new E5); the duty to disclose its use moves to 73A. |
| ¶E6 | ¶E4 | Comparative information is needed only in the second period in which the entity no longer applies the E3 relief. |
The body of the standard — the conceptual foundations, the four content areas, materiality at ¶3 — is unchanged; the differences sit in the SASB wording, the compliance-statement paragraphs and the closing appendix, now called “Application and transition”.
UK SRS S1 reads the standard itself.
UK SRS S2
UK SRS S2 against IFRS S2, row by row
| IFRS S2 | UK SRS S2 | The difference |
|---|---|---|
| ¶¶12, 23, 32 | ¶¶12, 23, 32 | Entities “may” rather than “shall” refer to and consider the ISSB’s Industry-based Guidance. Paragraphs 37 and B65(d) keep “shall”, because they refer to industry-based metrics generally. |
| — | ¶B59A (new) | Where financed emissions cannot reliably be estimated for the same period as the financial statements, explain why. |
| ¶¶C1, C2 | ¶C2 | Effective date removed. The ISSB’s transitional paragraphs C1A, C1B and C6 are not needed, because UK SRS S2 already includes the December 2025 amendments. |
| ¶C3 | ¶C1 | Date-of-initial-application reference removed; the no-comparatives relief kept. |
| ¶C4 | ¶¶C3, C4, C6 | The GHG Protocol methodology relief becomes C3 and keeps its first-year limit. The Scope 3 relief becomes C4 and loses it. New C6 makes both subject to UK law or regulation. |
| ¶C5 | ¶C5 | Same substance, adding that use of these reliefs is disclosed alongside the statement of compliance, under UK SRS S1 ¶73A. |
The asymmetry in the C4 row is deliberate: the government limited the methodology relief to the first period and removed the limit from the Scope 3 relief.
For a voluntary user, the FRC puts it plainly: the reliefs can be used “without time limits, indefinitely”.
For a listed company, the FCA has since set the lengths — see UK SRS Scope 3 reporting.
Every difference, filterable
Filter the differences by standard and by kind
The two tables above, joined and tagged: filter to one standard, to the differences added after the consultation, or to the changes often mistaken for UK amendments.
Filter the differences
Showing 13 of 13
| Standard | Paragraphs | The difference | Origin |
|---|---|---|---|
| S1 | IFRS S1 ¶¶55(a), 58(a) → same | “May” rather than “shall” consider the SASB Standards | Proposed (PIC), made |
| S1 | New ¶73A | Climate-first relief costs the S1 compliance statement; S1 E3 and S2 C3–C4 do not prevent an S2 statement if disclosed | Added after consultation |
| S1 | New ¶73B | Application subject to rules set by the Companies Act, the FCA or another UK authority | Added after consultation |
| S1 | IFRS S1 ¶¶E1–E2 → ¶E2 | Effective date removed | Proposed (TAC), made |
| S1 | IFRS S1 ¶E4 → none | First-year later publication permission removed | Proposed (TAC), made |
| S1 | IFRS S1 ¶E5 → ¶¶E3, E5 | Climate-first relief kept with no time limit; length set by law or regulation | Proposed as two years (TAC); replaced |
| S1 | IFRS S1 ¶E6 → ¶E4 | Non-climate comparatives only from the second period without the E3 relief | Consequential |
| S2 | IFRS S2 ¶¶12, 23, 32 → same | “May” rather than “shall” consider the Industry-based Guidance; ¶¶37 and B65(d) keep “shall” | Proposed (PIC), made, narrowed |
| S2 | New ¶B59A | Explain where financed emissions cannot be estimated for the accounting period | Added after consultation |
| S2 | IFRS S2 ¶¶C1–C2 → ¶C2 | Effective date removed | Proposed (TAC), made |
| S2 | IFRS S2 ¶C4 → ¶¶C3, C4, C6 | Method relief keeps its first-year limit; Scope 3 relief loses it; both subject to UK law or regulation | Changed after consultation (time limit removed; C6 from the PIC proposal) |
| S2 | ¶¶29A–29C | Financed-emissions limitation — the ISSB’s own December 2025 amendment | Not a UK amendment |
| S2 | GICS requirement | Removed by the ISSB itself in December 2025 | Proposed (TAC), withdrawn |
Sources: DBT government response and Annex A (25 February 2026); ISSB amendments to IFRS S2 (December 2025).
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The one stricter place
Paragraph B59A: the UK asks for more on financed emissions
Every other UK difference loosens something: “shall” becomes “may”, effective dates go, reliefs lose their clocks.
B59A runs the other way, and it is the only paragraph that does.
Where IFRS S2 leaves an entity that cannot estimate financed emissions on time with no further duty, UK SRS S2 makes it explain why.
The FRC restates it: an entity unable to disclose financed emissions in line with the requirements “is required to explain why, which includes explaining the measurement approach taken”.
So “UK SRS is IFRS with the hard parts taken out” is wrong in exactly one place, and it is the place banks and asset managers care about most.
Annex A, the B59A row
B59A was “added to require entities to explain why they have not been able to disclose in line with the financed emissions requirements as set out in paragraph B59, if they have determined that it is impracticable to reliably estimate financed emissions for the same reporting period as the related financial statements.”
Not UK amendments
Three things often called UK amendments that are not
The ISSB’s December 2025 changes. UK SRS S2 includes the ISSB’s amendments to the greenhouse gas requirements — paragraphs 29(a)(ii), 29(a)(vi)(2), B21–B22, B24, B28, B37, B59, B62(a) and B63(a) amended, and 29A–29C, B62A and B63A added.
They are there because UK SRS S2 was issued after them; the government records them as fully consistent with the ISSB’s versions, so the category 15 limitation and the measurement reliefs in them belong to the ISSB, not the UK.
Comply or explain. The standards contain no comply-or-explain mechanism; that is the basis of the FCA’s listing rules in PS26/19, and UK SRS compliance explains it.
The one-year and two-year reliefs. The standards set no length; the FCA set one year for Scope 3 and two years for S1 beyond climate for listed companies (¶3.14), under the power paragraphs E5 and C6 leave to regulators.
The effective dates, for their part, were removed rather than replaced: no date appears in either UK standard, and the dates that matter come from the FCA’s rules, set out on the UK SRS timeline.
The FCA’s separate product rules — SDR and anti-greenwashing — are a different regime again, untouched by any of this.
Citation trap
The appendices were renumbered, so name the standard
The body paragraphs of both standards keep the IFRS numbering; the closing appendices do not.
That makes a bare appendix reference ambiguous: “C4” in IFRS S2 is a combined relief limited to the first year, while in UK SRS S2 it is the Scope 3 relief with no time limit.
A sentence saying “the C4 relief expires after year one” is true of one standard and false of the other.
Always write “UK SRS S2 ¶C4” or “IFRS S2 ¶C4”, and re-check any appendix reference carried over from an IFRS-based source.
| IFRS | UK SRS |
|---|---|
| S1 ¶E3 | S1 ¶E1 |
| S1 ¶E5 | S1 ¶E3 |
| S1 ¶E6 | S1 ¶E4 |
| S1 ¶¶E1–E2 | S1 ¶E2 |
| S1 ¶E4 | removed |
| S2 ¶C3 | S2 ¶C1 |
| S2 ¶C4, methodology limb | S2 ¶C3 |
| S2 ¶C4, Scope 3 limb | S2 ¶C4 |
| S2 ¶¶C1–C2 | S2 ¶C2 |
History
The six proposals of June 2025, and what became of them
The exposure-draft consultation said the government “proposes 6 minor amendments”: four from the Technical Advisory Committee and two from the Policy and Implementation Committee.
| # | Proposal | From | Outcome at publication |
|---|---|---|---|
| 1 | Remove the first-year later-publication relief | TAC | Made (IFRS S1 ¶E4 not applicable) |
| 2 | Extend the climate-first relief from one year to two | TAC | Replaced: the time limit removed altogether |
| 3 | Remove the GICS requirement for disaggregating financed emissions | TAC | Withdrawn: the ISSB changed IFRS S2 in December 2025 |
| 4 | Remove the effective date | TAC | Made in both standards |
| 5 | SASB material: “shall” to “may” | PIC | Made in S1 ¶¶55(a), 58(a) and S2 ¶¶12, 23, 32; S2 ¶37 reverted to “shall” |
| 6 | Link reliefs to when reporting becomes required | PIC | Made and extended: S1 ¶¶73A, 73B, E5; S2 ¶C6 |
The two-year and GICS proposals both began in the TAC’s recommendations, agreed on 5 December 2024 and published on 18 December 2024; neither survived to the final standards.
Proposal 6 drew the strongest support — 83%, 138 of 166 respondents — and proposal 5 drew 70%, 122 of 175, as the UK SRS consultation page sets out.
Paragraphs 73A, 73B, B59A and E5 were added after the consultation closed, which is why the proposal count cannot describe the final standards.
The committee behind four of the proposals is the UK Sustainability Disclosure Technical Advisory Committee, for which the FRC acts as secretariat; the government’s department page is DBT, and the listing-rule regulator is the FCA.
Compliance statements
What you may still call compliance, once you take a relief
Paragraph 73A is asymmetric, which is why it is often misstated.
The climate-only relief costs an entity its statement of compliance with UK SRS S1, because it is not reporting the other matters S1 requires.
The S2 reliefs — and E3 itself, as far as S2 is concerned — cost nothing, so long as the entity says which it used.
Paragraph 73B then places the application of UK SRS S1 under whichever UK authority requires the reporting.
Voluntary users asked for exactly this clarity: the government’s response records that respondents were unsure whether a voluntary adopter could claim compliance while using reliefs.
For listed companies the FCA’s rules add their own statement of relief use; the readiness self-check lists it among the statements a first report needs.
Linklaters’ note on the final standards is useful secondary reading; the SASB Standards are the industry material the “may” wording refers to, and GOV.UK’s UK SRS guidance the government’s summary.
Corrections this site has made to its own pages are listed on our amendments record.
| Relief used | Compliance with UK SRS S1? | Compliance with UK SRS S2? |
|---|---|---|
| None | Yes, if all requirements met | Yes, if all requirements met |
| S1 ¶E3, climate only | No; disclose the relief | Not prevented; disclose the relief |
| S2 ¶C3, methodology | Not affected | Not prevented; disclose the relief |
| S2 ¶C4, Scope 3 | Not affected | Not prevented; disclose the relief |
Since February 2026
What has changed around the text since it was published
Searches for “UK SRS update” usually want to know whether the standards have changed since 25 February 2026.
The changes that matter have come from around the text rather than inside it.
On 30 September 2026 the FCA’s final rules, PS26/19, set how listed companies apply the standards: comply or explain across both, one year’s Scope 3 relief and two years’ climate-first relief.
Alongside them the FCA is consulting on draft guidance about explanations, Technical Note 803.1, until 28 October 2026.
The government’s Modernising Corporate Reporting consultation, open until 30 November 2026, asks how UK SRS should be reflected in the Companies Act.
Any future ISSB amendment, or a new ISSB standard on another topic, would reach the UK only through the same endorsement process the originals went through.
The dated record of these events is on UK SRS in 2026, and the quiz beside this section checks the six claims about the differences most often got wrong.
UK SRS amendments: true or false?
UK SRS contains exactly six UK amendments to the ISSB standards.
Paragraph B59A of UK SRS S2 has no equivalent in IFRS S2.
Paragraphs 29A–29C of UK SRS S2 are UK amendments.
The UK removed the effective date from both standards.
The one-year Scope 3 relief for listed companies is written into UK SRS S2.
A new ISSB standard on nature would apply in the UK as soon as the ISSB issues it.
0 of 6 answered.
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Frequently asked
Questions people ask
How many UK amendments are there in UK SRS?
No authoritative count exists.
“Six” was the number of amendments the government proposed in June 2025.
By publication one had been withdrawn, one replaced by a broader change, and paragraphs 73A, 73B, B59A and E5 added.
Annex A of the government response maps every final difference and says that where a requirement is not in the table there is no difference; it gives no total, and neither does this page.
What are the main differences between UK SRS and IFRS S1 and S2?
The effective dates are removed.
IFRS S1’s first-year permission to publish sustainability information after the financial statements is removed.
The non-climate and Scope 3 reliefs carry no time limit, with their availability left to UK law or regulation.
Reference to the SASB-based industry material changes from “shall” to “may”.
Paragraphs 73A and 73B govern statements of compliance, and paragraph B59A requires an explanation where financed emissions cannot be estimated for the same period as the accounts.
Is UK SRS stricter than IFRS anywhere?
In one place: UK SRS S2 paragraph B59A.
Where an entity finds it impracticable to estimate financed emissions for the same reporting period as its financial statements, it must explain why.
Every other UK difference removes, softens or untimes something.
Did the UK remove the GICS requirement?
Not itself.
The UK proposed removing IFRS S2’s requirement to use the Global Industry Classification Standard when disaggregating financed emissions, but the ISSB changed IFRS S2 in December 2025 in a way the government found broadly consistent with the UK’s aim.
The UK amendment was withdrawn and UK SRS S2 includes the ISSB’s change instead.
Are the one-year Scope 3 and two-year S1 reliefs UK amendments?
No. The standards themselves carry no time limit on those reliefs; UK SRS S2 paragraph C6 and UK SRS S1 paragraph E5 leave their availability to law or regulation.
The one-year and two-year periods are the FCA’s rules for listed companies, in PS26/19 paragraph 3.14.
Comply or explain is likewise the FCA’s basis, not part of the standards.
Does using a relief affect a statement of compliance?
It depends which relief.
Under UK SRS S1 paragraph 73A, an entity using the climate-only relief in paragraph E3 may not assert compliance with UK SRS S1 and must disclose its use of the relief.
An entity using E3, or the S2 reliefs in C3 or C4, is not prevented from asserting compliance with UK SRS S2, so long as it discloses the reliefs used.
Do new ISSB amendments apply in the UK automatically?
No. New or amended ISSB standards have no UK status until the Secretary of State endorses them, after the Technical Advisory Committee’s assessment.
The ISSB’s December 2025 greenhouse gas amendments are in UK SRS S2 only because the UK standard was issued after them.
Why do paragraph references differ between UK SRS and IFRS?
Because the closing appendices were renumbered.
IFRS S1 paragraphs E3, E5 and E6 became UK SRS S1 paragraphs E1, E3 and E4; IFRS S2 paragraph C3 became UK SRS S2 C1, and C4 split into C3 and C4.
A bare “C4” means a time-limited relief in IFRS S2 and an untimed Scope 3 relief in UK SRS S2, so always name the standard.
What has happened to UK SRS since it was published?
The standards were published on 25 February 2026.
Since then the changes have come from outside their text: the FCA’s final rules, PS26/19 of 30 September 2026, set how listed companies apply them and how long the reliefs last for them; the FCA is consulting on draft guidance on explanations until 28 October 2026; and the government’s Modernising Corporate Reporting consultation, open until 30 November 2026, asks how UK SRS should be reflected in company law.
Where is the official list of UK SRS differences from IFRS?
Annex A of the government’s response to the UK SRS consultation, published on GOV.UK on 25 February 2026.
It maps every difference paragraph by paragraph and says that where a requirement is not listed there is no difference. It gives no total.
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.
- Department for Business and TradeGovernment response to the UK SRS consultation (PDF) — Annex A, pp. 29–34
The paragraph-by-paragraph map of every difference; it carries no count.
- Department for Business and TradeGovernment response — web version
The same response, with the support for each proposal.
- Department for Business and TradeUK SRS S1 General Requirements (PDF) — ¶¶55(a), 58(a), 73A, 73B, E1–E5
The S1 differences as they appear in the standard.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF) — ¶¶12, 23, 32, 37, B59A, C1–C6
The S2 differences as they appear in the standard.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
Published 25 February 2026.
- Department for Business and TradeExposure drafts: UK Sustainability Reporting Standards — consultation
“The government proposes 6 minor amendments to the standards for application in a UK context.”
- GOV.UKUK Sustainability Reporting Standards — guidance
The endorsement process and the consultation window.
- Financial Reporting CouncilThe TAC issues its final recommendations, 18 December 2024
Where the two-year and GICS proposals came from.
- Financial Reporting CouncilUK Sustainability Disclosure Technical Advisory Committee
The committee, with the FRC as secretariat.
- Financial Reporting CouncilSustainability reporting developments — FAQ
The reliefs usable “indefinitely” by voluntary users; B59A restated.
- IFRS FoundationAmendments to Greenhouse Gas Emissions Disclosures (Amendments to IFRS S2), December 2025 (PDF)
The ISSB’s own changes, which UK SRS S2 includes but which are not UK amendments.
- IFRS FoundationIFRS Sustainability Standards Navigator
The international texts UK SRS is compared against.
- Financial Conduct AuthorityPS26/19 (PDF), ¶3.14
The relief lengths for listed companies — an FCA rule, not a UK amendment to the standards.