UK SRS consultation: where it stands
Two consultations, asking two different questions. The Department for Business and Trade consulted on the standards themselves; the FCA consulted on who must apply them. Both have closed [1] [2].
DBT finished its half: UK SRS S1 and S2 were published on 25 February 2026 for voluntary use. The FCA has not finished its half. No policy statement responding to FCA CP26/5 had been published as at 14 August 2026.
The UK SRS consultation is two consultations, and they asked different things
Almost every page on this subject blurs them together. Keeping them apart is the whole of the story.
When people say “the UK SRS consultation” they are usually talking about one of two documents, published seven months apart by two different bodies, asking two questions that do not overlap at all.
The distinction matters because the two halves are in completely different states. DBT has finished. The standards exist, they are final, and anyone who wants to use them may. The FCA has not. Its proposals are proposals. Nothing in the UK Listing Rules has changed, and no company is required to report under UK SRS as a result of either consultation.
That is why a page which tells you “UK SRS becomes mandatory on 1 January 2027” is wrong twice over. The date is the FCA’s proposed commencement, and the FCA has not made the rule that would commence.
The standards are written and voluntary. The rules that would make them compulsory for listed companies are drafted and unmade. Everything else on this page is detail hanging off those two facts.
Photo: Unsplash / Noah Buscher
The UK SRS exposure draft consultation, and what it actually asked
Twelve weeks in the summer of 2025, eleven questions, and a decision the government had already partly made.
The UK SRS exposure draft consultation ran from 1pm on 25 June 2025 to 11:59pm on 17 September 2025 [1]. It sat inside the Mansion House package of November 2024, in which the government set out how it intended to build “a world-leading sustainable finance framework”, and it was published alongside two sibling consultations — one on the transition-plan manifesto commitment, one on oversight of sustainability assurance providers.
The document put three things to consultees, and it is worth being precise about which was which, because only the middle one was genuinely open.
Who answered, and what they already report
The government received 209 responses: 170 through an online survey and 39 by email directly to DBT. 199 were organisations and 10 were individuals [3]. That figure is DBT’s, and it belongs to this consultation only — the FCA has never published a response count for CP26/5, and a page that attributes 209 responses to the FCA has confused the two consultations this page exists to separate.
Demographic detail is available for the 170 survey respondents. The largest single sector was financial and insurance services at 25% (42 of 170), followed by professional, scientific and technical activities at 11% (18 of 170). The rest came from manufacturing, utilities, retail and elsewhere in the real economy.
The most useful table in the whole response document is the one showing what those organisations already report against. It explains why the consultation produced so little argument about principle and so much about mechanics: most respondents were not being asked to start reporting. They were being asked to change the standard they report to.
Respondents also split almost evenly on whether they were preparers or users of reports: 29% preparers only, 16% users only, 31% both, and 24% neither. A consultation answered largely by people who both write and read these reports is a different beast from one answered by lobbyists on one side of the table, and it shows in how technical the responses were.
If you want the underlying regime rather than the consultation about it, the UK SRS S1 and S2 overview covers what the two standards require; the legislation page covers the statutory machinery this consultation was feeding into.
Photo: Unsplash / Nicholas Doherty
What the UK SRS consultation actually changed, one amendment at a time
Six were proposed. One was withdrawn, one was changed into something quite different, and several more were added after the consultation closed.
Here is the thing almost every summary of this consultation gets wrong, and it is worth being blunt about it.
You will read, in a great many places, that UK SRS contains “six UK-specific amendments” to the ISSB baseline. The number is real and it is DBT’s own: the consultation document says, in terms, that “the government proposes 6 minor amendments to the standards for application in a UK context” [1]. Four came from the Technical Advisory Committee and two from the Policy and Implementation Committee.
But six is the number that was proposed, in June 2025. It is not the number that exists. By the time the standards were published in February 2026, one of the six had been withdrawn, one had been replaced by something broader, and at least three further changes had been made that nobody consulted on at all — because they arose from the consultation responses themselves, from the ISSB’s own December 2025 amendments, and from questions raised in PIC meetings after the consultation closed [3].
The government publishes no count of the final differences. What it publishes instead is Annex A — a paragraph-by-paragraph mapping between IFRS S1/S2 and UK SRS S1/S2, with an explicit scope note: “Where requirements in the standards are not included in the table, there are no differences between the two.” That table, not a headline number, is the authoritative answer to “what is different about UK SRS”. It is reproduced in full further down this page.
What follows is each of the six proposals, what it asked, how consultees answered, and what became of it — then the changes that were made without being proposed.
Reporting at the same time as the accounts
IFRS S1 paragraph E4 — deleted, with no UK SRS equivalent
IFRS S1 lets a first-year reporter publish its sustainability information later than its financial statements. The TAC recommended removing that, and the government did.
A minority of respondents objected, wanting the flexibility. The majority agreed, on two grounds recorded in the response: that users value integrated reporting, and that UK entities already have years of practice at reporting climate information under the Companies Act and the Listing Rules. Connectivity between sustainability and financial reporting was one of the most commonly cited benefits of UK SRS across the whole consultation.
The practical effect is that a UK SRS reporter has no grace period. The sustainability report and the accounts land together, from the very first year.
How long you may report on climate alone
IFRS S1 paragraph E5 → UK SRS S1 paragraphs E3 and E5
IFRS S1 lets a first-year reporter disclose on climate only, deferring everything else. The exposure draft proposed extending that from one year to two. Most respondents agreed; those who objected said two years was an unnecessary delay, or that entities should be reporting on whatever is most financially material rather than assuming that is climate.
Then the proposal was overtaken. In PIC discussions after the consultation closed, a question arose about how UK SRS reliefs would interact with the equivalent provisions in the FCA’s Listing Rules. The government’s answer was not to pick a better number of years but to delete the time period altogether: the final standards, in its own words, “no longer specify how long the reliefs for non-climate reporting and Scope 3 reporting may be applied”.
For a voluntary reporter that means the relief has no expiry at all. For a future mandatory reporter it means the expiry is whatever the law or rule that mandates them says it is. The consultation asked “one year or two?” and the answer came back “that is the wrong question”.
The GICS requirement — consulted on, then dropped
Global Industry Classification Standard, IFRS S2
This is the most interesting item in the consultation and the one you will find nowhere else, because summaries written from the exposure draft never went back to check.
The exposure draft proposed removing IFRS S2’s requirement to use the Global Industry Classification Standard — a proprietary classification system — when disclosing certain information. Very few respondents disagreed. Of those who agreed, several made a pointed observation: the ISSB was itself consulting on the same problem, and the UK should align with whatever it decided rather than diverging on its own.
That is exactly what happened. The ISSB finalised its own amendment in December 2025, and its approach was “broadly consistent with the intention behind the UK’s proposed amendment”. So the government incorporated the ISSB’s change and “no longer recommends any further amendments to IFRS S2 regarding GICS beyond” it. Amendment 3 does not appear in Annex A, because there is no longer any difference to record.
It is worth sitting with that for a second. A UK-specific amendment was consulted on, supported, and then abandoned because the international standard-setter fixed the problem globally first. It is the clearest evidence available for the government’s stated priority of international alignment — and it means the count of UK divergences went down, not up, between consultation and publication.
The effective date, deleted on purpose
IFRS S1 paragraph E1 and IFRS S2 paragraph C1
IFRS S1 and IFRS S2 each carry an effective date of 1 January 2024. UK SRS carries none. The clauses were removed, in the government’s words, “to avoid any confusion with the introduction of any reporting requirements”. Almost no respondents disagreed.
This is the single most consequential thing about UK SRS and the reason this page exists. A standard with no effective date cannot commence. It can only be picked up voluntarily, or switched on by something else — a Companies Act requirement, an FCA rule, or another authority with the power to impose reporting duties.
So when the FCA proposes rules “coming into force from 1 January 2027”, that date is not in UK SRS and never was. It is a date in a draft FCA rule. The standards themselves are, as the government put it, available to voluntary reporters immediately — and to everyone else, never, until somebody legislates.
SASB: “shall refer to and consider” becomes “may”
UK SRS S1 paras 55(a) and 58(a); UK SRS S2 paras 12, 23 and 32
IFRS S1 tells an entity it shall refer to and consider the applicability of the SASB Standards. UK SRS S1 says may. The same change was made in UK SRS S2 for the Industry-based Guidance on Implementing IFRS S2.
70% of respondents (122 of 175) agreed. Those in favour largely argued that using SASB material should be a business decision. Those against worried about comparability, and many on both sides asked for the change to be revisited once the ISSB completes its own work on the industry guidance.
One detail in Annex A is easy to miss and matters if you are drafting. Paragraphs 37 and B65(d) of UK SRS S2 still say “shall” — because they refer to industry-based metrics in general, not to the SASB guidance document specifically. You are still required to consider industry-based metrics. You are merely no longer required to consider that publication when deciding what they are.
Tying the reliefs to whenever reporting actually starts
UK SRS S1 paras 73A, 73B and E5; UK SRS S2 para C6
The transitional reliefs in IFRS S1 and S2 are keyed to “the first annual reporting period in which the entity applies the Standard”. If a standard has no effective date, that phrase has nothing to bite on. The proposal was to link the reliefs to the date any reporting requirement comes into force instead.
It was the most strongly supported proposal in the entire consultation — 83%, or 138 of 166 respondents. But respondents also said the drafting was not clear enough about whether and how a regulator could control the reliefs, and about what an entity could claim while using them.
So the government went further than it had consulted on. It added paragraph E5 to UK SRS S1 and paragraph C6 to UK SRS S2, each stating that the availability of the reliefs is subject to the Companies Act, the FCA, “or any other UK regulatory or government entity with the means to enact reporting requirements” — and then added paragraphs 73A and 73B to deal with the consequences for compliance statements. Those are the next banner.
Three changes nobody consulted on
The remaining differences in Annex A were not in the exposure drafts. They were made afterwards, in response to what consultees said, to the ISSB’s December 2025 amendments, and to questions raised in PIC meetings after the consultation had closed. The government flags this itself: “the government encourages stakeholders to take note of the final amendments that the government has made”.
Financed emissions: an explain mechanism that did not exist before
UK SRS S2 paragraph B59A — new, no IFRS S2 counterpart
Question 2 asked whether a financial institution should be able to use financed-emissions data from a different reporting period to the related financial statements. It was the most evenly divided question in the consultation: 50%, 73 of 146 respondents, agreed. Question 3 drew 82 responses, many of them arguing that the requirement was simply not practicable on the timetable it assumed.
Rather than grant a blanket exemption, the government asked the TAC for fresh advice, got it on 26 January 2026, and added a new paragraph. Paragraph B59A requires an entity that cannot reliably estimate financed emissions for the same period as its financial statements to explain why — a duty to account for the gap rather than permission to leave one.
It is the only wholly new substantive requirement UK SRS adds to the ISSB baseline. Every other difference in Annex A removes something, softens something, or renumbers something.
What you may call compliance, once you have taken a relief
UK SRS S1 paragraphs 73A and 73B — new
Paragraph 73A does two things, and they are not symmetrical — which is why so many summaries state it wrongly.
First: an entity using the climate-only relief at UK SRS S1 paragraph E3 may not assert compliance with UK SRS S1, and must disclose that it has used the relief. Second: an entity using any one or more of the three reliefs — S1 paragraph E3, S2 paragraph C3 on GHG Protocol alternatives, S2 paragraph C4 on Scope 3 — is not prevented from asserting compliance with UK SRS S2, provided it discloses which reliefs it used.
So the climate-only relief costs you an S1 compliance statement and nothing else. The Scope 3 and GHG Protocol reliefs cost you nothing at all, so long as you say you are using them. Paragraph 73B then puts the whole question under whichever authority ends up requiring the reporting. There is a working calculator for this below, because the combinations are genuinely hard to hold in your head.
There is one further category, which Annex A handles in a single row: the ISSB’s own targeted amendments of December 2025. Because UK SRS S2 was issued after they were made, it simply contains them — amended paragraphs 29(a)(ii), 29(a)(vi)(2), B21–B22, B24, B28, B37, B59, B62(a) and B63(a), and added paragraphs 29A–29C, B62A and B63A. The government records them as “fully consistent” with the ISSB’s versions.
This matters for a specific reason. Those December 2025 amendments are where the extended jurisdictional relief on Global Warming Potential values and the clarified relief on using a methodology other than the GHG Protocol come from. You will see both described as UK amendments. They are not: they are ISSB changes that UK SRS inherited by being published later. Annex A does not list them as differences, because they are not differences.
Photo: Unsplash / Ricardo Gomez Angel
FCA CP26/5 — the consultation on who must apply the standards
Thirty January to twenty March 2026. Closed, unanswered, and the reason anyone searches for this subject at all.
FCA CP26/5, Aligning listed issuers’ sustainability disclosures with international standards, opened on 30 January 2026 and closed on 20 March 2026 [2]. It proposes changing the UK Listing Rules so that listed companies report against UK SRS S2 instead of the FCA’s existing TCFD-aligned rules.
The cleanest available summary of what it proposes is not in the consultation paper. It is in DBT’s response document, at paragraph 1.15, written by the other regulator in the room:
“The FCA’s consultation proposes that in-scope listed entities will disclose information about their climate-related risks and opportunities in accordance with UK SRS S2 and must apply the specific provisions in UK SRS S1 as relevant to those disclosures. UK SRS S2 (excluding Scope 3 greenhouse gas (GHG) emissions reporting) would be mandatory. Scope 3 GHG emissions and information about sustainability-related risks and opportunities beyond climate would be captured under a ‘comply or explain’ approach. The FCA proposes a phased implementation approach, taking effect from 1 January 2027.”
Government response to the consultation on UK Sustainability Reporting Standards, DBT, 25 February 2026, paragraph 1.15Four things are worth pulling out of that.
The framing the FCA chose, and why it is worth quoting
CP26/5 does not present itself as a climate measure. It presents itself as a competitiveness measure. The FCA says the proposals support “the Government’s Leeds Reforms as well as the UK’s position as a global financial centre, by boosting comparability across markets and reducing duplicative rules”.
That is a deliberate choice of ground, and it tells you something about how the FCA expects to defend the policy statement when it arrives. A rule justified on comparability and the removal of duplication is a rule whose case does not depend on the climate argument holding politically. It is also, for what it is worth, the single freshest sourced sentence available on this subject, and no other page ranking for these terms currently carries it.
The population, and the number everybody quotes wrongly
CP26/5’s Cost Benefit Analysis sets out the affected population at paragraph 43, and it is a three-part figure, not the one-part figure usually quoted:
UKLR 6, 16 and 22 515 “will be required to comply with our UK SRS proposals and therefore face most costs and generate most benefits of our intervention”
UKLR 14 and 15 89 “our proposals will require disclosure of the climate or sustainability reporting requirements that apply in the company’s primary listing location or place of incorporation, or which they voluntarily adopt”
So “515 companies are in scope of CP26/5” is wrong: the scope is around 600, and 515 is the subset that would have to comply. The other 89 get a signposting duty about which regime they actually follow — a real obligation, and a completely different one. If you run a depositary receipt programme or a secondary listing, every page that quotes the 515 has silently left you out.
The five categories are UKLR 6 (commercial companies), UKLR 14 (secondary listing), UKLR 15 (depositary receipts), UKLR 16 (non-equity shares and non-voting equity shares) and UKLR 22 (the transition category), and the FCA says the requirements would apply “with some variation depending on the category” [4]. One thing to watch if you are reading older material: the premium and standard listing segments no longer exist. They were replaced by the UK Listing Rules categories on 29 July 2024, so any page describing CP26/5’s scope as “premium listed companies” is working from a superseded structure.
Does FCA CP26/5 reach you, and on which branch?
Two questions, run against the category split in CP26/5’s own Cost Benefit Analysis — including the 89-company branch most summaries drop.
Nothing is sent anywhere. The whole check runs in your browser.
Answer for the securities that are actually admitted to the Official List. A company can sit in more than one category, in which case run it twice — the FCA says the requirements vary by category, so the answers are not interchangeable.
And read the verdict as what it is: an account of a proposal. Nothing here is in the Listing Rules today.
Photo: Unsplash / Alexander AberoThe standards as published — voluntary, and with no effective date
The consultation produced a finished product. What it did not produce is any obligation to use it.
UK SRS S1 and UK SRS S2 were published on 25 February 2026. GOV.UK’s guidance page states the position in one sentence: “The standards are available for voluntary use, by any entity that chooses to do so” [5].
The government response is, if anything, broader: the standards “are available for any entity to use, in whole or in part, as they see fit”. Not just any entity — any part of them.
That is an unusual thing for a reporting standard to say, and it follows directly from Amendment 4. Delete the effective date and you delete the mechanism by which a standard imposes itself. What is left is a document anyone may adopt, on any timetable, to any extent.
What “no effective date” means in practice
Annex A states it for each standard in almost identical words. For S1: “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 to apply it from a specific reporting period.” For S2, the same. What survives in both is the requirement that S1 and S2 are applied at the same time — retained at S1 paragraph E2 and S2 paragraph C2.
Four consequences follow, and they are the practical content of the whole consultation.
If you want the standards themselves rather than the consultation about them, they sit on GOV.UK as published documents, and the UK SRS reporting page walks through what applying them involves.
Photo: Unsplash / Nick Fewings
What the policy statement must still settle
Five open questions, as at 14 August 2026, and none of them has a published answer.
This is the section that justifies the page. Everything above is a description of documents that exist. This is a description of a document that does not.
As at 14 August 2026, the FCA has published no policy statement responding to CP26/5. Its consultation page still carries the original sentence — “we will review the feedback and aim to publish a Policy Statement in autumn 2026, subject to the final UK SRS, with the rules coming into force from 1 January 2027” — and that page has not been substantively updated since 5 June 2026. Nothing has replaced it, superseded it, or brought the date forward.
Read the sentence carefully and it contains two conditions and a target, not a commitment. “Aim to publish” is not “will publish”. “Subject to the final UK SRS” is a condition that has since been satisfied — the standards were published five days before the consultation closed — but it was written when it had not been. And “autumn 2026” is a season, not a date.
Here is what that document, whenever it arrives, will have to decide. Each of these is genuinely open: the consultation asked about it, and no published answer exists.
There is a sixth question that nobody is obliged to answer, but which follows from the fifth: what happens to the 89 companies on the lighter-touch branch if the FCA changes its mind about the split. The Cost Benefit Analysis treats them as a distinct population with a distinct duty, but the consultation is explicit that requirements would apply “with some variation depending on the category”, and the variation itself is not fixed.
A page that tells you what has not happened is more useful here than one that speculates about what will. As at 14 August 2026: no FCA policy statement; no changes to the UK Listing Rules; no effective date in either standard; and no requirement on any UK entity to report under UK SRS. Every one of those sentences was true when this page was last verified, and each will stop being true on a date nobody has published.
Photo: Unsplash / Zbynek Burival
The UK SRS consultation timeline, with proposals kept separate from facts
Everything green has happened. Everything amber is somebody’s stated intention and may not.
Two consultations, two committees, an international standard-setter and a second regulator all act in this story, and they interleave. The rail below is in date order regardless of who did the acting, and it marks each entry as either something that happened or something that is proposed. The line between those two is the thing most coverage of this subject loses.
Notice what the rail shows once the two kinds of entry are separated: ten things have happened and three have not, and everything that has happened is DBT’s or the ISSB’s. Every outstanding item belongs to the FCA or to a programme that has not yet consulted. For a fuller view of how this sits against the other UK reporting regimes, see the UK SRS timeline.
Who the UK SRS consultation actually reaches, and when
Three populations, in three completely different positions. Most confusion about this subject comes from treating them as one.
Ask “does UK SRS apply to me” and the honest answer today is no, to everybody — there is no UK entity under any legal obligation to report against UK SRS S1 or S2. But that flat answer hides three quite different futures, and which one you are in depends on facts you already know about yourself.
It is worth noticing how small the mandatory population would be. Around 600 listed companies sit inside CP26/5 at all. By comparison, SECR reaches roughly 19,900 UK entities and has done since 2019. Whatever UK SRS becomes, the consultation that has closed would not make it a broad-based reporting regime — it would make it a listed-markets one.
That is precisely why the Modernising Corporate Reporting programme matters more to most readers of this page than CP26/5 does. If UK SRS ever reaches private companies, it will be through the Companies Act, and the government has said MCR “will include consideration of the need for requirements within the Companies Act for private entities to report against UK SRS”. That consultation was promised for 2026 and, as at 14 August 2026, has not appeared.
The decision flow, across all three regimes
Because most organisations asking about UK SRS are already inside SECR, ESOS or both, the useful question is not “does UK SRS apply” in isolation but which of the three regimes reaches you and in what order. This is the site’s standard scope diagram.
If · ListingListed on a UK market?
If · SizeLarge under SECR — 2 of 3?
If · EnergyESOS qualification?
Two cautions on reading it. The UK SRS S2 branch is marked Proposed because that is what it is — it describes CP26/5, not a rule. And the SECR and ESOS branches are current law, which means an organisation can quite easily be in scope of two regimes today and a third only hypothetically. If the SECR thresholds are the live question for you, the thresholds guide works through them properly.
Photo: Unsplash / @name_ gravityHow UK SRS differs from the ISSB baseline, paragraph by paragraph
Annex A of the government response, reproduced in full. This is the authoritative answer, and it does not come with a headline number.
Annex A carries its own scope note, and it is the most useful sentence in the document: “Where requirements in the standards are not included in the table, there are no differences between the two.”
So this is not a summary of the main changes. It is the complete set. If a paragraph is not below, UK SRS says exactly what the ISSB standard says.
One general change applies throughout and is not tabulated: references to IFRS Sustainability Disclosure Standards become references to UK Sustainability Reporting Standards. Additional UK paragraphs also follow the ISSB’s own December 2025 numbering convention, deliberately, so the two documents stay comparable paragraph for paragraph.
IFRS S1 → UK SRS S1
IFRS S2 → UK SRS S2
Neither the GICS change nor the Global Warming Potential and GHG Protocol methodology reliefs appear as differences in Annex A, and both are routinely described as UK amendments. They are not. GICS was withdrawn once the ISSB made its own amendment; the GWP and methodology reliefs are ISSB changes from December 2025 that UK SRS S2 inherited by being published afterwards. A difference table is the right place to settle this: if a change is not in Annex A, it is not a UK divergence.
Two of the rows above are hard enough to apply that they get their own working tools below: what you may claim once you have taken a relief, and which reporting periods need comparative information. Both compute from the paragraphs in these tables rather than from a lookup.
Take a relief, and what can you still call compliance?
Paragraph 73A is asymmetric, and almost every summary of it states the symmetric version.
There are three transitional reliefs across the two standards, and the compliance statement you may make depends on which you use, not how many.
The climate-only relief at UK SRS S1 paragraph E3 costs you an S1 compliance statement. The Scope 3 relief at S2 paragraph C4 and the GHG-Protocol-alternative relief at S2 paragraph C3 cost you nothing at all — provided you disclose that you are using them.
Nothing is sent anywhere. The whole calculation runs in your browser.
Which reporting periods need comparative information?
Paragraph E4(b) does not start its clock at first application. It starts it when you stop taking the climate-only relief.
This is the single most misread row in Annex A. IFRS S1 required comparatives for wider sustainability matters in the second annual reporting period. UK SRS S1 requires them in the second annual reporting period in which the entity no longer applies the paragraph E3 relief — which can be years later, or never.
Because the relief itself lost its time limit, a voluntary reporter reporting on climate alone holds that clock at zero indefinitely. The grid recomputes as you change the inputs.
What happens if the policy statement slips
Not a prediction. A description of what each outcome would mean, so you can recognise which one you are in when it arrives.
The FCA said autumn 2026 and it said “aim to”. Autumn is not over. But the proposed commencement is 1 January 2027, and the gap between those two things is now small enough that the sequencing itself is a live question. Four things can happen. None of them is more likely than the others on any published evidence, and this page does not pretend otherwise.
What follows from all four is the same practical point, and it is the reason this page does not end in a scare. Under every scenario, the standards themselves are unchanged and available today. An organisation that wants to be ready is not waiting for the FCA — it can apply UK SRS voluntarily, in whole or in part, now, and use the reliefs indefinitely while doing so. The policy statement decides who is compelled, not what good looks like.
The one thing worth actively watching is the Modernising Corporate Reporting consultation, because it reaches far more organisations than CP26/5 does. If UK SRS is ever going to apply to a large private company, that is the document that will say so. It was promised for 2026 and has not appeared.
Photo: Unsplash / Nikola Jovanović
How to respond to a UK consultation, and what actually happens to responses
This one is closed. The next one is not, and the record shows responses moved real outcomes here.
Both consultations on this page have closed, so there is nothing to respond to today. But the Modernising Corporate Reporting consultation is promised, the FCA consults continually, and the record of this particular exercise is unusually good evidence that responding is worth the time.
What responses actually changed here
It is easy to be cynical about consultations. On this one, the paper trail does not support the cynicism. At least four substantive changes are directly traceable to what consultees said:
What a UK consultation response looks like
UK government consultations are typically run through an online survey with a parallel email route, and both count. On this one, 170 of the 209 responses came through the survey and 39 by email direct to DBT. Neither route was privileged, and the email responses are represented throughout the response document alongside the survey answers.
Three things are worth knowing before you write one.
Responses are published in summary rather than in full: this consultation’s response document lists responding organisations in Annex B but does not reproduce individual submissions, and individuals are excluded from the list unless they asked to be named. If you need your position on the public record verbatim, publishing it yourself is the only reliable route.
Both consultations have closed. The Department for Business and Trade finished its half and published UK SRS S1 and S2 for voluntary use, with no effective date in either. The FCA has not finished its half: as at 14 August 2026 there is no policy statement, no change to the UK Listing Rules, and no UK entity under any obligation to report against UK SRS.
The bottom line · Photo: Unsplash / Zac Wolff
The consultation is closed and the standards are written. The only question left for you is whether they reach you, and when.
See whether UK SRS reaches you Or follow CP26/5 until the policy statement lands
Photo: Unsplash / Quokkabottles
The UK SRS consultation in reference form
The same story restated for lookup rather than reading — key facts, the responses, what is decided and what is open, then the FAQs, the glossary and every source.
The UK SRS consultation — the short version
Every figure below appears earlier on this page with its source. Nothing is introduced here for the first time.
Who answered the UK SRS exposure draft consultation, and how they voted
Every percentage DBT published, in one place, with the number of respondents each is calculated on.
Response rates differ question by question, which matters: a percentage on 184 responses and a percentage on 146 are not directly comparable, and the response document is careful to give both numbers every time. So is this table.
125 of 184 Amendments 1 and 4 made as consulted. Amendment 2 later replaced by removing the time period entirely. Amendment 3 withdrawn.
73 of 146 The most evenly split question in the consultation. Led to fresh TAC advice and new paragraph B59A.
range of views Detailed drafting suggestions, several arguing the requirement was impracticable as drafted.
122 of 175 Made. Many respondents on both sides asked for it to be revisited once the ISSB finishes its own industry-guidance work.
138 of 166 The most strongly supported proposal in the consultation. Made, and extended with paragraphs 73A, 73B, E5 and C6.
What the consultation settled, and what it did not
The most useful distinction on this subject, and the one a headline cannot carry.
Settled
Open
UK SRS consultation FAQs
The questions people actually search for on this subject, answered from the primary documents rather than from each other.
It is two separate consultations that are often spoken of as one. The Department for Business and Trade consulted on exposure drafts of UK SRS S1 and S2 from 25 June to 17 September 2025, asking whether to endorse the ISSB’s IFRS S1 and IFRS S2 for UK use and what to amend. The Financial Conduct Authority separately consulted through CP26/5, from 30 January to 20 March 2026, on whether to change the UK Listing Rules so that listed companies must report under UK SRS S2. Both have closed. DBT published its final standards on 25 February 2026; the FCA has published nothing further.
Yes, both of them. The DBT exposure draft consultation closed on 17 September 2025 and its outcome page records it as concluded. FCA CP26/5 closed on 20 March 2026. There is no open UK SRS consultation to respond to as at 14 August 2026, although the government has promised a consultation on Modernising Corporate Reporting which would cover whether private companies must report against UK SRS.
FCA CP26/5 is the Financial Conduct Authority’s consultation paper Aligning listed issuers’ sustainability disclosures with international standards. It proposes replacing the FCA’s existing TCFD-aligned Listing Rules with requirements based on UK SRS S2. It opened on 30 January 2026 and closed on 20 March 2026. The FCA has not published a response count, a summary of responses, or a policy statement.
No. As at 14 August 2026 no policy statement responding to CP26/5 has been published. The CP26/5 page still carries the FCA’s original wording — “we will review the feedback and aim to publish a Policy Statement in autumn 2026, subject to the final UK SRS, with the rules coming into force from 1 January 2027” — and that page has not been substantively updated since 5 June 2026.
That in-scope listed companies disclose climate-related risks and opportunities in accordance with UK SRS S2, applying UK SRS S1 provisions so far as relevant to those disclosures. UK SRS S2 excluding Scope 3 would be mandatory; Scope 3 emissions and sustainability matters beyond climate would be comply or explain. Implementation would be phased, taking effect from 1 January 2027. That summary is DBT’s own, at paragraph 1.15 of its government response.
The UK SRS exposure draft was the consultation version of UK SRS S1 and UK SRS S2, published by DBT on 25 June 2025 alongside marked-up drafts showing the proposed amendments to the ISSB baseline. It proposed six minor amendments for a UK context. The exposure drafts have been superseded by the final standards, published 25 February 2026 — and the final versions differ from the drafts in several respects.
From 1pm on 25 June 2025 to 11:59pm on 17 September 2025 — twelve weeks. It was published as part of the government’s response to the Mansion House package of November 2024, alongside consultations on transition plans and on the oversight of sustainability assurance providers.
DBT received 209 responses to the exposure draft consultation: 170 through an online survey and 39 emailed directly to the department. 199 were organisations and 10 were individuals. That figure belongs to DBT’s consultation only. The FCA has published no response count for CP26/5, so any page attributing 209 responses to the FCA has confused the two.
Six were proposed — DBT’s consultation says “the government proposes 6 minor amendments”, being four from the Technical Advisory Committee and two from the Policy and Implementation Committee. But six is not what landed. One was withdrawn, one was replaced by a broader change, and further amendments were added after the consultation closed. The government publishes no count of the differences in the final standards; Annex A of its response is a paragraph-by-paragraph mapping and is the authoritative answer.
The proposal to remove the Global Industry Classification Standard (GICS) requirement from UK SRS S2. Respondents who agreed with it largely argued the UK should align with whatever the ISSB decided rather than diverge alone. The ISSB finalised its own amendment in December 2025 on an approach “broadly consistent with the intention behind the UK’s proposed amendment”, so the government incorporated the ISSB change and dropped its own. GICS does not appear in Annex A, because there is no longer a difference to record.
No, and that is deliberate. IFRS S1 and IFRS S2 each carry an effective date of 1 January 2024. Both were removed from UK SRS “to avoid any confusion with the introduction of any reporting requirements”. Annex A states the consequence: entities can apply the standards when they choose, unless required by UK law or regulation to apply them from a specific reporting period. The requirement to apply S1 and S2 at the same time survives.
No. UK SRS S1 and S2 are available for voluntary use by any entity, in whole or in part. No UK entity is under any legal obligation to report against them. The FCA has proposed rules that would make UK SRS S2 mandatory for certain listed companies, but those rules have not been made.
There is no date. The frequently quoted 1 January 2027 is the date from which the FCA proposed its Listing Rules changes would come into force — in a consultation that closed in March 2026 and has not been answered. The FCA’s own sentence hedges it twice: it “aims to” publish a policy statement, “subject to the final UK SRS”. Until that policy statement exists, no commencement date exists.
CP26/5’s Cost Benefit Analysis puts around 600 listed companies in scope. Of those, 515 — in UK Listing Rules categories 6 (commercial companies), 16 (non-equity and non-voting equity shares) and 22 (transition) — “will be required to comply”. The remaining 89, in categories 14 (secondary listing) and 15 (depositary receipts), would instead disclose which climate or sustainability requirements apply in their primary listing location or place of incorporation. Quoting 515 as the scope leaves the 89 out.
They asked different questions. DBT asked whether these are the right standards — whether to endorse IFRS S1 and S2 for UK use and what to amend. It finished, and published UK SRS S1 and S2 on 25 February 2026. The FCA asked who must use them — whether to change the UK Listing Rules so listed companies report under UK SRS S2. It has not finished. Confusing the two is why the “209 responses” figure is so often misattributed.
Yes, in the sense that matters: the standards exist and are final. UK SRS S1 and UK SRS S2 were published on 25 February 2026 and any entity may use them today. What has not happened is mandation — the FCA’s proposals to require listed companies to use them are still unanswered, and no route to private companies has been consulted on.
It is an informal name for the same thing: the UK Sustainability Reporting Standards, UK SRS S1 and UK SRS S2, published by the Department for Business and Trade on 25 February 2026. They are the UK-endorsed versions of the ISSB’s IFRS S1 and IFRS S2, with a small number of UK-specific amendments recorded in Annex A of the government’s consultation response.
Yes, and the government has been unusually expansive about it. The standards are “available for any entity to use, in whole or in part, as they see fit”. Because there is no effective date, there is nothing to be early or late for. And because the time limits were removed from the climate-only and Scope 3 reliefs, a voluntary reporter may use those reliefs indefinitely.
It depends which relief, and the rule is not symmetrical. Under UK SRS S1 paragraph 73A, 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. But using any one or more of the three reliefs — S1 E3, S2 C3 on GHG Protocol alternatives, S2 C4 on Scope 3 — does not prevent an entity asserting compliance with UK SRS S2, provided the reliefs used are disclosed.
A new paragraph with no IFRS S2 counterpart. Where an entity determines it is impracticable to reliably estimate financed emissions for the same reporting period as its related financial statements, B59A requires it to explain why it has not disclosed in line with paragraph B59. It was added after the consultation, following fresh Technical Advisory Committee advice of 26 January 2026, because responses to questions 2 and 3 argued the original timing requirement was not practicable.
No comparatives are required in the first annual reporting period at all. Climate comparatives are required from the second period, as under IFRS S1. The change is to paragraph E4(b): comparatives for wider sustainability matters are required in the second annual reporting period in which the entity no longer applies the paragraph E3 climate-only relief — not the second period of reporting. Since that relief lost its own time limit, the clock can start years after first application.
Yes. IFRS S1 paragraphs 55(a) and 58(a) say an entity “shall refer to and consider” the applicability of the SASB Standards; UK SRS S1 says “may”. The same change was made at UK SRS S2 paragraphs 12, 23 and 32 for the Industry-based Guidance on Implementing IFRS S2. 70% of respondents (122 of 175) agreed. Note that paragraphs 37 and B65(d) of UK SRS S2 still say “shall” — they refer to industry-based metrics in general, not to that guidance document.
Nothing changes for anybody. The existing TCFD-aligned Listing Rules continue to apply to listed companies, UK SRS remains voluntary, and no obligation arises. The practical consequence of a slip is to the proposed 1 January 2027 commencement, which becomes progressively harder to justify on notice grounds the later a policy statement appears. A consultation can also end without rules being made at all.
On GOV.UK, attached to the consultation outcome page for Exposure drafts: UK Sustainability Reporting Standards, in both a web version and a 42-page PDF, published 25 February 2026. Its Annex A is the paragraph-by-paragraph mapping of every difference between IFRS S1/S2 and UK SRS S1/S2, and its Annex B lists the responding organisations.
The UK SRS consultation vocabulary, defined
Fourteen terms that appear on this page and are routinely used loosely elsewhere.
- UK SRS
- UK Sustainability Reporting Standards. Two documents, UK SRS S1 and UK SRS S2, published 25 February 2026 and available for voluntary use by any entity, in whole or in part.
- Exposure draft
- The consultation version of a standard, published for comment before it is finalised. The UK SRS exposure drafts were published 25 June 2025 and are superseded by the final standards.
- Endorsement
- The process by which the UK decides to adopt an international standard for domestic use, with or without amendment. UK SRS is the product of endorsing IFRS S1 and IFRS S2.
- TAC
- The UK Sustainability Disclosure Technical Advisory Committee, which assesses standards against the endorsement criteria. It recommended four of the six proposed amendments.
- PIC
- The UK Sustainability Disclosure Policy and Implementation Committee, which advises on policy and implementation. It recommended the other two, and raised the reliefs question after the consultation closed.
- CP26/5
- The FCA’s consultation paper on aligning listed issuers’ sustainability disclosures with international standards. Closed 20 March 2026; unanswered.
- Policy statement
- The document in which the FCA confirms, modifies or abandons what it consulted on, and makes the final rules. None has been published in response to CP26/5.
- Comply or explain
- An obligation to do something or publish an explanation of why you have not. CP26/5 proposes it for Scope 3 emissions and for sustainability matters beyond climate.
- Transitional relief
- A provision letting an entity omit or defer something in early reporting periods. UK SRS has three: the climate-only relief (S1 E3), the Scope 3 relief (S2 C4) and the GHG-Protocol-alternative relief (S2 C3).
- Climate-only relief
- UK SRS S1 paragraph E3. Lets an entity report on climate alone. Unlike the others it costs the entity its UK SRS S1 compliance statement, under paragraph 73A.
- Statement of compliance
- An entity’s assertion that it has applied a standard. UK SRS S1 paragraphs 73A and 73B govern when one may be made and who may override that.
- Effective date
- The date from which a standard applies. IFRS S1 and IFRS S2 have one (1 January 2024); UK SRS S1 and UK SRS S2 deliberately have none.
- UKLR
- The UK Listing Rules, which replaced the previous premium and standard listing segments on 29 July 2024. CP26/5 works through categories 6, 14, 15, 16 and 22.
- MCR
- Modernising Corporate Reporting, the DBT programme announced in October 2025 which will consider whether the Companies Act should require private entities to report against UK SRS.
The UK SRS consultation — every source, linked
Primary documents first. Professional commentary is listed separately and is cited on this page for analysis only, never for a fact that a primary source states.
- Exposure drafts: UK Sustainability Reporting Standards — GOV.UK consultation outcome. Ran 25 June to 17 September 2025; government response added 25 February 2026
- CP26/5: Aligning listed issuers’ sustainability disclosures with international standards — FCA. Opened 30 January 2026, closed 20 March 2026; page last updated 5 June 2026
- Government response to the consultation on UK Sustainability Reporting Standards — DBT, 25 February 2026 (PDF, 42 pages). Annex A is the paragraph-by-paragraph difference mapping
- UK Listing Rules sourcebook (UKLR) — FCA Handbook. Replaced the premium and standard listing segments on 29 July 2024
- UK Sustainability Reporting Standards — GOV.UK guidance, last updated 25 February 2026
- UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — GOV.UK, the published standards, 25 February 2026
- CP26/5 consultation paper (PDF) — FCA. The Cost Benefit Analysis at paragraphs 2, 43 and 87 carries the ~600 / 515 / 89 population split
- Draft UK SRS S1 Standard with amendments (PDF) — GOV.UK, 25 June 2025. The marked-up exposure draft
- Draft UK SRS S2 Standard with amendments (PDF) — GOV.UK, 25 June 2025
- Exposure draft of UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 (PDF) — GOV.UK, 25 June 2025
- IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information — IFRS Foundation
- IFRS S2 Climate-related Disclosures — IFRS Foundation
- IFRS Sustainability Standards Navigator — IFRS Foundation
- International Sustainability Standards Board — IFRS Foundation. Issued the targeted amendments to IFRS S2 in December 2025 that UK SRS S2 incorporates
- SASB Standards — IFRS Foundation. Referred to at UK SRS S1 paragraphs 55(a) and 58(a), where “shall” became “may”
- Task Force on Climate-related Financial Disclosures — the framework the FCA’s current Listing Rules are aligned to, and which CP26/5 proposes to replace
- Department for Business and Trade — the department that ran the exposure draft consultation and issued the standards
- Environmental reporting guidelines, including Streamlined Energy and Carbon Reporting guidance — GOV.UK. 45% of consultation respondents already report under SECR
- Energy Savings Opportunity Scheme — GOV.UK / Environment Agency
- Sustainability reporting developments: frequently asked questions — Financial Reporting Council
- Financial Reporting Council — hosts the UK Sustainability Disclosure Technical Advisory Committee, which recommended four of the six proposed amendments and gave fresh advice on financed emissions on 26 January 2026
- UK Sustainability Disclosures Policy and Implementation Committee: meeting minutes — GOV.UK
- FCA publications — where a policy statement responding to CP26/5 will appear when it is published. Nothing had as at 14 August 2026
- Companies Act 2006 — legislation.gov.uk. Named in UK SRS S1 paragraphs 73B and E5 and UK SRS S2 paragraph C6 as one of the authorities that could require UK SRS reporting
- Modernisation of Corporate Reporting — Written Ministerial Statement HCWS973 — UK Parliament, 21 October 2025
- Companies House — GOV.UK
- GHG Protocol Corporate Accounting and Reporting Standard (2004) — the method named in UK SRS S2 paragraph C3
- Sustainability — ICAEW. Analysis only
- Sustainability resources — ICAS. Analysis only
- Sustainability reporting — ACCA. Analysis only
- Sustainability and climate change — PwC UK. Analysis only
- Sustainability reporting and assurance — Deloitte UK. Analysis only
- What we think — Macfarlanes. Analysis only
- Insights — Slaughter and May. Analysis only
- Insights — CMS. Analysis only
- Knowledge — Hogan Lovells. Analysis only
- Confederation of British Industry — representative body. Analysis only
- Open consultations — GOV.UK. Where a Modernising Corporate Reporting consultation would appear when it launches
Where to go next on UK SRS
This page covers the consultations. These cover the regime they produced.