UK SRS amendments — changes to IFRS S1 and S2

Amendment Framework Overview

UK SRS represents the UK endorsement of 1 IFRS S1 and IFRS S2 with six UK-specific amendments addressing regulatory context, proportionality, and transitional mechanics.

2 The amendments were developed through two expert committees: the UK Sustainability Disclosure Technical Advisory Committee (TAC) hosted by the Financial Reporting Council, and the Policy and Implementation Committee (PIC) coordinating across government and regulators.

The substance and structure of the global IFRS baseline are preserved, ensuring international comparability while addressing UK-specific implementation requirements through systematic adaptation.

Committee Development Structure

The six amendments emerged from two specialist committees supporting 4 UK government endorsement process with distinct technical and policy responsibilities.

Technical Advisory Committee (TAC): 3 Independent committee of technical experts hosted by the Financial Reporting Council, delivering final technical assessment to Secretary of State on 18 December 2024.

Policy and Implementation Committee (PIC): Cross-government and regulator coordination body addressing implementation mechanics and UK regulatory context considerations through exposure draft development phase.

The Four TAC Amendments

3 TAC delivered four technical amendments addressing UK user needs, implementation proportionality, and regulatory coordination requirements identified through comprehensive market consultation.

Amendments preserve IFRS S1 and S2 framework integrity while addressing UK-specific regulatory context and user feedback on integrated reporting and implementation timing.

1. Removal of First-Year Delayed Reporting Relief

5 IFRS S1 paragraph E4 originally permitted delayed sustainability disclosure publication separate from financial statements in first reporting year.

TAC rationale: UK users consistently emphasized integrated reporting importance for decision-useful information, requiring concurrent availability of sustainability and financial data.

Result: UK SRS S1 removes transition relief mandating integrated reporting from first compliance year, aligning with UK implementation timeline expectations.

2. Extension of Climate-First Relief to Two Years

5 IFRS S1 paragraph E5 provided one-year relief allowing climate-only disclosure before broader sustainability topics.

TAC recommendation: Extend climate-first relief to two years recognizing UK SRS S1 broad scope and systematic capability building requirements for comprehensive sustainability assessment.

Implementation benefit: Optional phased approach supporting organizations developing comprehensive data systems and governance while maintaining flexibility for immediate full-scope reporting.

3. Treatment of GICS Classification Requirement

6 IFRS S2 originally required Global Industry Classification Standard (GICS) usage for industry-based disclosures, creating proprietary dependency concerns.

TAC evolution: Initial recommendation removed GICS requirement, but 7 ISSB December 2024 amendments addressed same concerns independently.

Final position: TAC revised recommendation incorporating ISSB amendments, maintaining international alignment while addressing UK proprietary classification concerns.

4. Removal of Fixed Effective Date

Both IFRS standards specified 1 January 2024 effective dates embedded within standards text, conflicting with UK regulatory framework timing requirements.

UK regulatory benefit: Enables immediate voluntary adoption from 8 publication date (25 February 2026) while preserving FCA authority for mandatory effective date determination.

Implementation flexibility: Supports phased implementation approach with separate voluntary and mandatory timeline management through appropriate regulatory channels.

The Two PIC Amendments

Policy and Implementation Committee developed two additional amendments addressing 9 SASB materials application and transitional relief mechanics for UK regulatory context.

PIC amendments focus on practical implementation considerations and coordination with broader UK sustainability regulation framework through systematic policy integration.

5. Treatment of SASB Materials

Both IFRS standards require entities to "refer to and consider applicability" of 9 SASB Standards for industry-specific disclosures developed originally for US market conditions.

PIC consideration: SASB materials internationalization under ISSB ownership requires UK-specific application guidance ensuring relevance to UK business contexts and regulatory requirements.

Implementation approach: UK SRS clarifies SASB application flexibility where materials lack relevance to UK preparers' specific circumstances, maintaining international consistency while ensuring practical applicability.

6. Transition Relief Linkage

IFRS standards contain various transitional reliefs with different durations potentially creating confusion between voluntary adoption timing and mandatory application commencement.

PIC resolution: Reliefs explicitly linked to mandatory reporting requirement introduction rather than voluntary adoption, preserving relief availability for all covered entities regardless of early voluntary use.

Practical effect: Voluntary early adopters retain full transitional relief entitlement when mandatory requirements commence, preventing relief "burn-out" through early adoption and encouraging market development.

Implementation Impact Analysis

The six amendments collectively create UK-specific implementation pathway preserving 1 IFRS S1 and S2 core architecture while addressing UK regulatory context and proportionality requirements.

Framework preservation: Four-pillar TCFD structure, financial materiality focus, and value chain scope remain unchanged ensuring international comparability and global baseline alignment.

UK adaptation benefits: Enhanced voluntary adoption flexibility, proportionate phased implementation, and coordination with UK regulatory timeline management supporting systematic market development.

Relief modificationsAdjustment 1

Non-climate reporting and Scope 3 GHG emissions relief adjustments to ensure compatibility with the FCA CP26/5 implementation timetable.

Compliance statement clarificationAdjustment 2

UK SRS S1 amendments addressing voluntary-use compliance descriptions and early-adoption statement requirements.

ISSB December 2024 integrationAdjustment 3

Incorporation of 7ISSB’s GHG Emissions Disclosure amendments with UK-specific effective date and transition-provision modifications.

Final Standards Adjustments

11 Government response to consultation introduced three additional adjustments at finalisation stage addressing stakeholder feedback and regulatory coordination:

Relief modifications: Non-climate reporting and Scope 3 GHG emissions relief adjustments ensuring compatibility with FCA CP26/5 implementation timetable.

Compliance statement clarification: UK SRS S1 amendments addressing voluntary use compliance description and early adoption statement requirements.

ISSB December 2024 integration: Incorporation of 7 ISSB's Greenhouse Gas Emissions Disclosure amendments with UK-specific effective date and transition provision modifications.

Authority Sources

1. IFRS S1 and S2 Sustainability Standards (IFRS Foundation, 2023)
2. UK SRS Exposure Draft Consultation (DBT, June 2025)
3. UK Sustainability Disclosure Technical Advisory Committee (FRC, 2024-2026)
4. UK SRS S1 and S2 — Final Standards (DBT, 25 February 2026)
5. SASB Standards (SASB, 2023)
6. UK Government Publishes Final Versions of UK SRS (Linklaters, February 2026)