UK SRS Amendments to IFRS S1 and S2 — Definitive Reference
UK SRS is the UK endorsement of the International Sustainability Standards Board's IFRS S1 and IFRS S2.
The two standards have been adapted to the UK regulatory context with six UK-specific amendments, as set out in the exposure draft consultation document published by the Department for Business and Trade in June 2025.
The substance and structure of the global baseline are preserved; the amendments address UK regulatory context, proportionality, and UK-specific transitional mechanics.
The architecture of the amendments
The six amendments came from two committees that supported the UK government's endorsement process:
The UK Sustainability Disclosure Technical Advisory Committee (TAC)
An independent committee of technical experts hosted by the Financial Reporting Council. The TAC delivered its final technical assessment and endorsement recommendations to the Secretary of State for Business and Trade on 18 December 2024.
The Policy and Implementation Committee (PIC)
A cross-government and regulator committee coordinating UK SRS implementation. The PIC's input produced two further amendments at exposure draft stage.
This is the count consistently referenced by Linklaters, Slaughter and May, the Investment Association, KPMG, and the Department for Business and Trade itself.
The four TAC amendments
Removal of the first-year delayed reporting relief in IFRS S1
IFRS S1 paragraph E4 originally allowed reporting entities, in their first year of applying the standards, to publish their sustainability-related financial information at a different time from their main financial statements.
The TAC recommended removing this relief on the basis that UK users of sustainability information consistently emphasised the importance of integrated reporting — sustainability information and financial information being available concurrently.
Result: The exposure draft and final UK SRS S1 remove this transition relief. The Investment Association supported the removal "on the basis that users value integrated reporting."
Extension of the "climate first" relief in IFRS S1 to two years
IFRS S1 paragraph E5 allows a reporting entity, in the first year of applying the standards, to report only on climate-related risks and opportunities (deferring wider sustainability topics by one year). The TAC recommended extending this relief by an additional year, making it a two-year "climate first" relief.
Rationale: UK SRS S1 covers a broad set of sustainability topics, and phased implementation is helpful for preparers building data systems and governance for the first time. The relief is optional — entities can choose to report on the full scope from year one.
Treatment of the GICS classification requirement in IFRS S2
IFRS S2 originally required entities to use the Global Industry Classification Standard (GICS) for certain industry-based disclosure requirements. The TAC's initial recommendation was to remove the GICS requirement, on the grounds that GICS is a third-party proprietary classification not universally familiar to UK preparers.
The ISSB subsequently issued its own amendment to this requirement in December 2024 (the Amendments to Greenhouse Gas Emissions Disclosures package). When the TAC reviewed these in January 2026, it revised its position and concluded that no further UK amendment beyond the ISSB's own amendment was needed.
Result: The final UK SRS S2 incorporates the ISSB's amendment.
Removal of the fixed effective date in both standards
Both IFRS S1 and IFRS S2 originally specified a fixed effective date of 1 January 2024 in the standards text. The TAC recommended removing this fixed date from UK SRS, on the basis that the effective date for UK entities will be determined by UK law and FCA rules at the point of mandate, rather than embedded in the standards themselves.
Result: This is the technical mechanism that allows UK SRS to be available for voluntary use immediately on publication (25 February 2026), while the mandatory effective date is determined separately by the FCA (currently proposed for 1 January 2027) and by the Companies Act framework for private companies (timing TBC via the Modernising Corporate Reporting programme).
The two PIC amendments
Treatment of SASB materials
Both IFRS S1 and IFRS S2 require entities to "refer to and consider the applicability of" SASB Standards materials for industry-specific disclosures. The PIC considered the appropriate UK treatment of these materials, particularly given that SASB Standards were originally developed for the US market and are being internationalised under ISSB ownership.
The exposure draft proposed amendments to clarify the application of SASB materials in the UK context. The Investment Association response notes the importance of allowing flexibility where SASB materials are not relevant to a UK preparer's specific circumstances.
Treatment of transition reliefs
Both IFRS S1 and IFRS S2 contain transitional reliefs of different durations and purposes. The PIC discussed whether these reliefs should run from the point of voluntary adoption or from the point of mandatory application.
The PIC concluded — and the government accepted — that the reliefs should be explicitly linked to the introduction of mandatory reporting requirements, not to voluntary use. This affects paragraphs E3, E4, and E5 in UK SRS S1 and paragraphs C3 and C4 in UK SRS S2.
Practical effect: Voluntary early adopters can use the reliefs (or not) at their discretion, but the reliefs do not "burn" against them by starting their clock before mandatory adoption begins. A company that voluntarily adopts UK SRS in 2026 will not have used up its Scope 3 relief by the time mandatory reporting begins in 2027.
What the final standards added beyond the six amendments
The government made three further adjustments at finalisation in February 2026, in response to consultation feedback:
Modifications to the reliefs themselves
Concerning non-climate reporting and Scope 3 GHG emissions, to ensure the reliefs work cleanly under the FCA's proposed CP26/5 implementation timetable.
Statement of compliance amendment
In UK SRS S1, clarifying how entities should describe their compliance with the standards (particularly in early voluntary use).
ISSB December 2024 amendments
Incorporation of the ISSB's December 2024 Amendments to Greenhouse Gas Emissions Disclosures, with the exception of the ISSB's new content on the effective date and transitional provisions (which UK SRS handles differently via Amendment 4 above).
These finalisation adjustments are detailed in the government response to the consultation, Chapter 2.
What this means in practice
UK SRS preserves the core IFRS S1 and S2 framework — the four-pillar TCFD-aligned structure (governance, strategy, risk management, metrics and targets), the financial-materiality focus, the value-chain scope.
A company that reports under UK SRS is reporting under the global ISSB baseline, with minor UK adaptations.
For preparers already on TCFD-aligned reporting, UK SRS S2 is, in the words of Taylor Wessing's analysis cited by Nexio Projects, "not a reinvention; it is a structured upgrade."
For preparers new to sustainability reporting, the six amendments shape a UK-specific implementation path: the climate-first relief, the linkage of reliefs to mandatory adoption, and the removal of fixed effective dates collectively allow a phased, proportionate rollout that works for both voluntary and mandatory reporters.