UK SRS consultation · DBT and FCA · outcome recorded 30 September 2026
The UK SRS consultations: what was asked, and what came back
The UK SRS consultation was two consultations, by two bodies, asking two different questions.
The Department for Business and Trade asked whether these were the right standards; it published UK SRS S1 and S2 on 25 February 2026.
The FCA asked who must apply them; its answer, PS26/19, came on 30 September 2026 and differed from its own proposal on the central point.
Two consultations
Two questions, two answers, two dates
Keeping these apart is most of the story: the standards are one document set, and the rules that make listed companies use them are another.
| DBT exposure drafts | FCA CP26/5 | |
|---|---|---|
| The question | Endorse IFRS S1 and S2 for the UK, and with which amendments? | Require listed companies to report against UK SRS, and how? |
| Open | 25 June to 17 September 2025 | 30 January to 20 March 2026 |
| Answered | 25 February 2026: the government response and the final standards | 30 September 2026: PS26/19 and the made instrument |
| What it produced | UK SRS S1 and S2, for voluntary use, with no effective date | Comply-or-explain rules for UKLR 6, 14, 15, 16 and 22, from 1 January 2027 |
| Responses | 209, published | Reported question by question |
The exposure drafts ran alongside two sibling consultations — one on an oversight regime for sustainability assurance, and one on transition-plan requirements — which is why the same dates recur in three places.
The standards themselves are on UK SRS S1 and S2, and the whole sequence of dates on the UK SRS timeline.
The government’s half
The exposure drafts, and who answered
The exposure-draft consultation ran from 1pm on 25 June to 11:59pm on 17 September 2025, a little over twelve weeks.
It asked whether to endorse the ISSB’s IFRS S1 and S2 for UK use, put six specific amendments to consultees, and gathered evidence on costs and benefits for later decisions about requiring the standards.
The six amendments came from two committees: four from the Technical Advisory Committee, hosted by the FRC, whose final recommendations were published on 18 December 2024, and two from the Policy and Implementation Committee.
The government response counts 209 responses: 170 through an online survey and 39 sent directly to DBT by email.
Of the respondents, 199 were organisations and 10 were individuals.
Demographic information exists only for the 170 survey respondents, which is why the response’s breakdowns are out of 170 rather than 209.
Companies, listed and unlisted, were more likely to class themselves as preparers only, while those who only use reports were the least common group, according to the response’s ¶1.8.
Who answered
Most respondents already report, which shaped the answers
The government’s response gives demographic detail only for the 170 respondents who used the online survey.
The largest single sector among them was financial and insurance services, at 25% (42 of 170), and the next was professional, scientific and technical activities, at 11% (18 of 170).
Those who named an organisation type were most likely to be listed companies or representative bodies, followed by unlisted companies and investors.
The more telling table is what respondents already report under: 45% were already inside SECR, and 35% inside the Companies Act’s TCFD-aligned climate disclosures.
So most respondents were not being asked to start reporting; they were being asked to change the standard they report to.
That explains the shape of the consultation: little argument about principle, and a great deal about mechanics — reliefs, timing, and what a company may claim.
It also explains the split on roles: nearly a third both prepare and read these reports, which is a more technical audience than a consultation answered by one side of the table.
| Respondents who already report under | Of 170 |
|---|---|
| Streamlined Energy and Carbon Reporting (SECR) | 76 (45%) |
| TCFD-aligned rules in the Companies Act | 59 (35%) |
| Role: preparer only | 49 (29%) |
| Role: user only | 27 (16%) |
| Role: both preparer and user | 53 (31%) |
| Role: neither | 41 (24%) |
How consultees voted
The support behind each proposal
Percentages are given per question, on different bases; a figure out of 184 and one out of 166 are not directly comparable, and the response gives both numbers every time.
The relief-linkage proposal was the most strongly supported in the consultation; respondents called it pragmatic and flexible, and said it would encourage voluntary reporting.
Its drafting was not: respondents said it was not clear how a voluntary user could use the reliefs, or whether such a user could still claim compliance — the concern that produced paragraphs 73A and 73B.
On the SASB change, supporters argued that the SASB materials had not received the same due process as the IFRS standards; the government kept the change and said it would review it through the Policy and Implementation Committee.
It also reverted one instance: paragraph 37 of UK SRS S2 keeps “shall”, because it refers to industry-based metrics in general rather than to the SASB-based guidance.
What the responses changed
Six proposals in, a different set out
Six was the number of amendments proposed, in the present tense of a consultation: the government “proposes 6 minor amendments”.
It is not the number that landed, and no count of the final set exists: Annex A maps every difference and says that where a requirement is not listed, there is no difference.
The biggest change was one nobody consulted on: rather than lengthen the climate-first relief, the government removed the time periods from the non-climate and Scope 3 reliefs, so the standards “no longer specify how long” they may be used.
For voluntary users that means the reliefs can be used indefinitely; for listed companies the FCA has since set the lengths at two years and one year.
Paragraph B59A, requiring an explanation where financed emissions cannot be estimated for the same period as the accounts, was added after the consultation closed; it is the one place the UK text asks for more than IFRS S2.
Each difference, paragraph by paragraph, is on UK SRS amendments; the Scope 3 consequences are on UK SRS Scope 3 reporting.
| Proposed in June 2025 | What became of it |
|---|---|
| Remove the first-year later-publication relief (IFRS S1 ¶E4) | Made |
| Extend the climate-first relief from one year to two | Replaced: the time limit was removed altogether |
| Remove the GICS requirement | Withdrawn: the ISSB changed IFRS S2 itself in December 2025 |
| Remove the effective date | Made |
| SASB: “shall” to “may” | Made, with ¶37 reverted |
| Link reliefs to mandatory commencement | Made, and extended with ¶¶73A, 73B, E5 and C6 |
The six proposals, one by one
What each proposal asked, and what came back
Four proposals came from the Technical Advisory Committee and two from the Policy and Implementation Committee.
The government response and its Annex A record what became of each.
1 · TAC · made
Report at the same time as the accounts.
IFRS S1 ¶E4 lets a first-year reporter publish its sustainability information after its financial statements.
The UK removed it, and UK SRS S1 has no counterpart.
A minority wanted the flexibility; the majority pointed to users’ wish for connected information and to years of UK practice under the Companies Act and the listing rules.
2 · TAC · replaced
Climate-first for two years, not one.
Most respondents agreed; objectors said entities should report whatever is most financially material rather than assume it is climate.
After the consultation the government removed the time periods altogether, so UK SRS S1 ¶¶E3 and E5 leave the length to whoever requires reporting.
3 · TAC · withdrawn
Remove the GICS requirement.
Very few disagreed, and several said the UK should wait for the ISSB, which was consulting on the same point.
The ISSB amended IFRS S2 itself in December 2025, the UK took that change, and there is no longer a difference to record in Annex A.
4 · TAC · made
Delete the effective date.
IFRS S1 and S2 carry 1 January 2024.
UK SRS carries no effective date, so that timing can be set by law or regulation.
A standard with no effective date cannot commence on its own; the FCA’s 1 January 2027 is a date in the FCA’s rules, not in the standards.
5 · PIC · made, narrowed
SASB: “shall” becomes “may”.
At UK SRS S1 ¶¶55(a) and 58(a) and UK SRS S2 ¶¶12, 23 and 32, with 70% support (122 of 175).
UK SRS S2 ¶37 and ¶B65(d) keep “shall”, because they refer to industry-based metrics generally, not to the SASB-based guidance.
6 · PIC · made, extended
Tie the reliefs to when reporting starts.
The most supported proposal: 83% (138 of 166).
Respondents asked who controls the reliefs and what a user of them may claim.
The answer was UK SRS S1 ¶E5 and UK SRS S2 ¶C6, subjecting the reliefs to the Companies Act, the FCA or another authority, and the new ¶¶73A and 73B.
The pattern is that the consultation settled the standards’ words and left their force to others.
Proposals 4 and 6 together are why the UK SRS deadline question has no answer inside the standards: the date and the reliefs’ length both come from the rule that requires reporting.
For a voluntary user nothing expires; for a listed company, the FCA has now set one year for Scope 3 and two years for non-climate matters.
After the consultation closed
Three changes nobody consulted on
The government told readers to “take note of the final amendments”, because some were made after the consultation closed.
The first came from questions 2 and 3, on financed emissions: only 50% (73 of 146) agreed that using data from a different period gave decision-useful information, and 82 respondents gave a range of views on the next question.
The Technical Advisory Committee gave further advice on 26 January 2026, and the government accepted its recommendation to add a mechanism for financial institutions to explain why they have not met the financed-emissions requirement.
That became ¶B59A, the one place the UK text asks for more than IFRS S2 does, since it adds a plan with a timeline rather than a relief.
The second and third, ¶¶73A and 73B, answer the drafting worry behind proposal 6: what a company may call compliance while it uses a relief.
¶73A is asymmetric, which is why it is often misstated: the climate-first relief costs the S1 compliance statement, while the Scope 3 and measurement-method reliefs cost nothing if they are disclosed.
UK SRS S2 also contains the ISSB’s own December 2025 amendments, including the jurisdictional reliefs on measurement methods, and Annex A records these as consistent with the ISSB’s text rather than as UK differences.
| Paragraph | What it does |
|---|---|
| UK SRS S2 ¶B59A | Where financed emissions cannot be reliably estimated for the same period as the accounts: explain why, the approach taken and how you plan to comply |
| UK SRS S1 ¶73A | Using the climate-first relief: no statement of compliance with UK SRS S1, and the relief disclosed; using S1 ¶E3 or S2 ¶¶C3 and C4 does not prevent a UK SRS S2 compliance statement if disclosed |
| UK SRS S1 ¶73B | Puts the question of reliefs under whichever authority requires the reporting |
The regulator’s half
CP26/5: what the FCA proposed
CP26/5 opened on 30 January 2026 and closed on 20 March 2026.
It proposed replacing the FCA’s TCFD-aligned listing rules with a requirement to report UK SRS S2 on a mandatory basis, except Scope 3, with Scope 3 and UK SRS S1 on comply or explain.
Companies with a secondary listing (UKLR 14) or depositary receipts (UKLR 15) would have made only a statement signposting the requirements of their home jurisdiction.
The FCA framed the proposals as supporting “the Government’s Leeds Reforms as well as the UK’s position as a global financial centre”, by boosting comparability and reducing duplicative rules.
The consultation’s cost-benefit analysis estimated that around 600 listed companies would be affected, of whom 515 would have been on the full route — figures that now describe the proposal, not the rules.
Premium and standard listing no longer exist: the UK Listing Rules replaced them on 29 July 2024, so any account of this scope in those terms is working from a superseded structure.
The consultation’s timetable and its questions are tracked on the CP26/5 tracker.
| Population in CP26/5 | Companies |
|---|---|
| Affected in total | Around 600 |
| Full route: UKLR 6, 16 and 22 | 515 |
| Statement route: UKLR 14 and 15 | 89 |
What the FCA heard
CP26/5’s responses, question by question
PS26/19 reports its feedback question by question, and the numbers show where the FCA moved and where it did not.
The constituencies split in a way most summaries reverse: many respondents, “particularly buy-side and professional service firms, supported mandatory climate disclosures”.
Views among listed companies “were more mixed”, and some asked for a threshold that would let smaller issuers fall out of scope.
The FCA rejected a size threshold, because the impact climate risks have on a company “depends on the company’s business model and industry specific climate vulnerabilities, not its size”.
It rejected a mandatory approach too: given feedback that full UK SRS disclosure “is not yet feasible for certain smaller issuers”, it said mandating it “may be disproportionately burdensome for small companies”.
Investor bodies had asked for something different again: the PRI wanted “an additional year to phase in” Scope 3 and non-climate reporting instead of comply or explain, and UKSIF a pathway to mandatory Scope 3, for example from 2030, or a review clause.
The final rules went comply or explain anyway, and the FCA said it would keep the case for mandatory assurance under review; on secondary listings they moved towards what those investors had asked for.
| Question in CP26/5 | Support recorded in PS26/19 |
|---|---|
| Scope: UKLR 6, 16 and 22 | 94 of 110 (¶2.7) |
| Replace the TCFD-aligned rules with UK SRS | Over 90% of respondents to Q2 (¶2.13) |
| Comply or explain for UK SRS S2 | Over two thirds of those answering Q4 (¶2.17) |
| Comply or explain for UK SRS S1 | 78 of 113 (¶2.28) |
| Transition-plan statement | Over 80% on Q8; 77 of 82 on Q9 (¶2.39) |
| Assurance transparency statement | Over 90% (¶2.47) |
| Secondary listings and depositary receipts | 66 responses; two thirds supported, one third wanted more (¶2.64) |
PS26/19
What the FCA decided, proposal by proposal
The FCA published its final rules on 30 September 2026, and on the central question it moved: comply or explain across all of UK SRS.
| Proposed in CP26/5 | Decided in PS26/19 | Where |
|---|---|---|
| UK SRS S2 mandatory, except Scope 3 | Comply or explain across all categories of disclosure | ¶¶1.2, 1.7 |
| UKLR 14 and 15: signposting statement only | Report against UK SRS on comply or explain | ¶1.7(2), response after ¶2.67 |
| Early adopters lose the transitional reliefs | Early adopters keep them | ¶3.19 |
| Apply listed UK SRS S1 paragraphs, as a rule | Made as guidance, UKLR 6.6.6A G | Appendix 1 |
| Scope 3 relief one year; S1 non-climate relief two years | Confirmed | ¶3.14 |
| Transition-plan statement for UKLR 6, 16, 22 | As consulted; UKLR 14 and 15 stay out | Response after ¶2.44 |
| Statement of whether assurance was obtained | As consulted; no duty to obtain assurance | Response after ¶2.51 |
| Rules from 1 January 2027 | Confirmed; instrument made 24 September 2026 | ¶3.12, Appendix 1 |
| Around 600 affected, 515 on the full route | No total given; the 89 secondary issuers are under the same requirements | ¶4.35 |
The change on secondary listings came directly from the responses: the FCA received 66 responses to its question on them, two thirds supporting the proposal and one third calling for more.
Those seeking more warned that lighter rules for international companies could encourage UK companies to move or downgrade their listings; the FCA agreed, and required international companies to report against UK SRS on comply or explain, relying on home-jurisdiction reporting where it aligns.
What the rules now require, limb by limb, is on the FCA and UK SRS, and what an explanation must say on UK SRS compliance.
The FCA’s arithmetic
The cost-benefit analysis, as modelled
The FCA estimates a positive net present value of £174.10 million for its final rules over a ten-year appraisal period, about £60 million lower than its estimate for the CP26/5 proposals (PS26/19 ¶¶4.4, 4.28).
The present value of costs falls from £285.59 million under the proposals to £233.49 million under the final rules, with an equivalent annual net direct cost to business of £27.12 million.
The per-company figures are the FCA’s modelled averages of the incremental cost of UK SRS over TCFD-aligned reporting, not prices and not a quote for any company.
Respondents noted that the averages rest on a small sample of financial-sector issuers, and the FCA accepted limits in its data.
The FCA does not expect to carry out a formal post-implementation review of the rules.
How a board plans its own first year is on the readiness self-check.
| Reporting behaviour (large issuer) | One-off | Each year |
|---|---|---|
| Comply with all of UK SRS | £127,900 | £194,700 |
| Comply with UK SRS S2 only, excluding Scope 3 (aligned part) | £40,400 | £61,500 |
| Explain against all of UK SRS | £22,200 | £8,900 |
Proposed against final
Every proposal in both consultations, and its fate
Filter to one consultation or one outcome, or search for a paragraph. Each row repeats a finding set out and cited above.
Filter by consultation or outcome
Showing 17 of 17
| Consultation | Proposal | Outcome | Where recorded |
|---|---|---|---|
| DBT | Remove first-year later publication (IFRS S1 ¶E4) | Made | Response; Annex A |
| DBT | Extend climate-first relief from one year to two | Time limit removed instead | UK SRS S1 ¶¶E3, E5 |
| DBT | Remove the GICS requirement | Withdrawn; the ISSB changed IFRS S2 itself | Response; Annex A |
| DBT | Remove the effective dates | Made | Response ¶1.21; Annex A |
| DBT | SASB “shall” to “may” | Made; ¶37 and ¶B65(d) keep “shall” | Response ¶¶1.31–1.34 |
| DBT | Link reliefs to mandatory commencement | Made and extended | UK SRS S1 ¶E5; UK SRS S2 ¶C6 |
| DBT | Financed-emissions explanation | New ¶B59A | Response ¶¶1.23–1.28 |
| DBT | Compliance statements under reliefs | New ¶¶73A and 73B | Annex A |
| FCA | UK SRS S2 mandatory, except Scope 3 | Comply or explain across UK SRS | PS26/19 ¶¶1.2, 1.7 |
| FCA | UKLR 14 and 15: signposting statement | Report against UK SRS on comply or explain | PS26/19 ¶1.7(2) |
| FCA | Early adopters lose the reliefs | Early adopters keep them | PS26/19 ¶3.19 |
| FCA | S1 paragraphs to apply, as a rule | Made as guidance, UKLR 6.6.6A G | PS26/19 Appendix 1 |
| FCA | One-year Scope 3 and two-year S1 reliefs | Confirmed | PS26/19 ¶3.14 |
| FCA | Transition-plan statement, UKLR 6, 16 and 22 | As consulted; UKLR 14 and 15 out | PS26/19, response after ¶2.44 |
| FCA | Statement of whether assurance was obtained | As consulted | PS26/19, response after ¶2.51 |
| FCA | No digital tagging requirement | As consulted | PS26/19, response after ¶2.81 |
| FCA | Rules from 1 January 2027 | Confirmed; instrument made 24 September 2026 | PS26/19 ¶3.12; Appendix 1 |
Sources: DBT government response and Annex A (25 February 2026); FCA PS26/19 (30 September 2026).
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Test yourself
Seven claims about the consultations, checked
Each statement here appears in commentary on the UK SRS consultations, and each is settled by the document named beside it.
The first two confuse the two consultations, or a count of proposals with a count of outcomes.
The third and fourth are the most expensive errors, because they tell a company it has a duty the rules do not impose.
The last three describe decisions taken on 30 September 2026, which is why pages written earlier cannot be relied on for them.
The UK SRS consultations: true or false?
The FCA received 209 responses to CP26/5.
UK SRS contains six UK-specific amendments to the ISSB standards.
UK SRS S1 and S2 have an effective date of 1 January 2027.
The FCA’s final rules make UK SRS S2 mandatory for listed companies.
Companies with a secondary listing in UKLR 14 report against UK SRS under the final rules.
The FCA considered and rejected a size threshold.
The draft Technical Note requires a timeframe for future compliance.
0 of 7 answered.
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Still open
The consultations still running
The FCA’s rules are final, but its guidance is not: alongside PS26/19 it is consulting in Primary Market Bulletin 66 on draft Technical Note 803.1, on how to apply comply or explain, with updates to TN 801.4 and the deletion of TN 802.3.
Comments go to primarymarketbulletin@fca.org.uk by 28 October 2026, and the FCA aims to finalise the guidance before the rules come into force (PS26/19 ¶1.9).
The government’s Modernising Corporate Reporting consultation, published on 7 September 2026 by the Department for Business, Innovation, Science and Trade, is open until 30 November 2026.
It says the government “will consider how UK SRS should be reflected in the Companies Act 2006”; it proposes no UK SRS duty for private companies, and the MCR page reads it in full.
The same document records that DESNZ intends to consult on SECR and ESOS later in 2026; no document has appeared.
The transition-plan consultation closed on 17 September 2025 and is still unanswered.
The government’s wider list of open consultations is at GOV.UK consultations, and the FCA’s at FCA publications.
- 19 Oct 2026FCA webinar
On the final rules.
- 28 Oct 2026Draft TN 803.1 comments close
Primary Market Bulletin 66.
- 30 Nov 2026Modernising Corporate Reporting closes
BIST consultation on company reporting.
- Later in 2026SECR and ESOS consultation
Promised by DESNZ; not yet published.
- H2 2027FCA supervisory approach
Ahead of the first reporting season.
The live consultation
Draft TN 803.1: what an explanation would contain
The rules say what an explanation must cover; the draft Technical Note says how the FCA proposes to read one.
It proposes that an explanation “can be a short, proportionate explanation” that “should not omit material information”.
It says the rules “do not require an explanation for each requirement of the UK SRS that has not been met”, and that an explanation could point to headings or paragraphs instead.
It does not require a timeframe for future disclosure, though one “would be helpful” where it is known.
And it says there is no separate requirement for a compliance statement under the listing rules, while noting that a company explaining an unmet UK SRS S2 requirement cannot make an unreserved statement of compliance with the standard.
All of this is proposed guidance: comments go to primarymarketbulletin@fca.org.uk by 28 October 2026, and the FCA aims to finalise before 1 January 2027.
The draft Technical Note is short, and the paragraphs a reporting team most needs are the ones on proportionality and on compliance statements.
The FCA’s nine preparation steps (PMB 66)
- Understand and engage with the new requirements
- Identify financially material sustainability and climate-related risks and opportunities
- Review governance arrangements
- Integrate those risks and opportunities within corporate strategy
- Assess the resilience of the business model and strategy
- Develop the data, metrics and targets needed
- Establish internal controls and review processes
- Build capabilities and provide training
- Engage with investors on their expectations
Source: FCA Primary Market Bulletin 66.
Encouragement, not rules.
Try the draft guidance
Test an explanation against the rule and the draft
The live consultation is easiest to answer once you have tried to write the thing it governs.
The tool beside this text takes a draft explanation and checks it against the three limbs the made rule requires — what is not met, why, and the steps planned.
It then checks the features the draft Technical Note says a good explanation has, such as being specific to the issuer rather than boilerplate.
The limbs are rule; the features are proposed guidance, and the tool labels which is which.
If the draft guidance reads differently once you have used it, that is a comment worth sending to the FCA before 28 October 2026.
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Test your explanation · rule and draft guidance
Rule (7A)(b)(iii): the statement must set out any steps being taken or planned to make them in future.
Draft guidance: make the reasons issuer-specific rather than generic.
Draft guidance: naming the headings or paragraphs not met is enough; no requirement-by-requirement explanation is needed.
No timeframe is fine: the rule does not ask for one, and the draft guidance says it helps only where one is known or estimated.
Rule: UKLR 6.6.6R(7A)(b) and (7B)(b), and the UKLR 14, 16 and 22 equivalents (FCA PS26/19 Appendix 1).
Guidance: the FCA’s draft Technical Note 803.1, proposed, comments to 28 October 2026.
Your ticks stay on this page.
Who the outcome reaches
CP26/5 had two branches; PS26/19 has one
The consultation sorted listed companies onto a full route and a statement route.
The final rules put every in-scope category on the same comply-or-explain footing.
| Listing category | Under CP26/5 | Under PS26/19 |
|---|---|---|
| UKLR 6 — commercial companies | Full route: S2 mandatory except Scope 3 | Comply or explain across UK SRS; transition-plan statement |
| UKLR 16 — non-equity and non-voting equity shares | Full route | Comply or explain; transition-plan statement |
| UKLR 22 — transition | Full route | Comply or explain; transition-plan statement |
| UKLR 14 — secondary listing | Statement signposting home-country rules | Comply or explain; may rely on aligned home reporting; no transition-plan statement |
| UKLR 15 — depositary receipts | Statement signposting home-country rules | As UKLR 14 |
| UKLR 11, 12, 13, 17, 18, 19 | Out | Out (¶3.7) |
| AIM, unlisted and private companies | Out | Out; UK SRS voluntary |
Whether a particular company is in one of these categories is a question about its listing, not its size, and the scope checker walks it through.
The timetable the consultation set held: the FCA had said it aimed to publish a Policy Statement in autumn 2026 for rules from 1 January 2027, and it did both.
Pages and papers written before 30 September 2026 that plan for a slipped Policy Statement, or for “mandatory S2”, are describing a contingency that did not happen.
Out of scope
What neither consultation touched
Neither consultation changed SECR, which still applies under SI 2018/1155 as described in the Environmental Reporting Guidelines.
Neither changed ESOS, run by the Environment Agency under its own Phase 4 timetable.
Neither amended the Companies Act 2006, whose climate disclosures and filing duties at Companies House carry on as before.
The standards replace nothing statutory; the rules replace the FCA’s own TCFD-aligned listing rule, the successor to a framework the TCFD itself stopped maintaining when it disbanded in 2023.
The statutory machinery is on UK SRS legislation, and whether any of it reaches your company on UK SRS thresholds.
Where things stand on 30 September 2026
What the consultations settled, and what they left open
Settled
The text of UK SRS S1 and S2, issued on 25 February 2026 for voluntary use.
That the standards carry no effective date and leave reliefs to the rule that requires reporting.
The FCA’s rules: comply or explain across UK SRS for UKLR 6, 14, 15, 16 and 22, for periods beginning on or after 1 January 2027.
One-year Scope 3 and two-year non-climate reliefs for listed companies, kept by early adopters.
No duty to have a transition plan, and no duty to obtain assurance.
Open
The final text of TN 803.1, after comments close on 28 October 2026.
How UK SRS is reflected in the Companies Act, under the consultation that closes on 30 November 2026.
The government’s response on transition-plan requirements, unpublished a year after the consultation closed.
The voluntary, opt-in oversight regime for sustainability assurance providers set out in the government’s response of 30 January 2026; no provider register has been announced as live.
The FCA’s supervisory approach, promised for the second half of 2027.
No private-company UK SRS requirement is proposed anywhere, and no size threshold is proposed for one.
Anyone planning on a later mandate is planning on something no document yet proposes, which is worth saying plainly because commentary often implies otherwise.
Responding
How consultations are answered, and why responses count
UK government consultations usually run an online survey with an email route beside it, and both count: 39 of the 209 exposure-draft responses came by email.
The response document is organised question by question, and percentages are reported per question, so an answer tied to a numbered question is easier to count than a general position.
The record here shows responses changing text: paragraphs 73A and 73B exist because respondents said the relief drafting left voluntary users unsure what they could claim.
The FCA publishes its feedback the same way; PS26/19 reports response numbers and the FCA’s answer after each question.
The draft Technical Note is the live opportunity now; a board preparing its first report can use the readiness self-check to see which explanations it would need, and UK SRS reporting to see what the report contains.
Professional bodies and firms published commentary on both consultations — among them the ICAEW, ICAS, ACCA and the CBI, and law and accountancy firms including CMS, Hogan Lovells, Macfarlanes, Slaughter and May, Deloitte and PwC.
Much of it predates PS26/19, and none of it is a source for any figure on this page.
The standard-setters’ own pages remain the primary texts: the ISSB, the IFRS standards navigator, IFRS S1, IFRS S2, the SASB Standards, the GHG Protocol Corporate Standard, the FRC and its sustainability reporting FAQ, the UK Listing Rules, DBT and the government’s October 2025 statement on corporate reporting.
The family’s UK SRS timeline sets these consultations among the other dates, and the scope checker tells you whether the result reaches you.
If something on this page is out of date, write to hello@uksrs.org.uk.
Vocabulary
The consultation’s terms, defined
| Term | Meaning |
|---|---|
| Exposure draft | A draft standard published for comment before it is finalised — here, the draft UK SRS S1 and S2 of June 2025. |
| Endorsement | The Secretary of State’s decision to adopt an ISSB standard for UK use, on the Technical Advisory Committee’s advice. |
| TAC | The UK Sustainability Disclosure Technical Advisory Committee, with the FRC as secretariat; it recommended four of the six amendments. |
| PIC | The UK Sustainability Disclosures Policy and Implementation Committee; it proposed the other two. |
| Annex A | The table in the government response mapping every difference between UK SRS and IFRS S1 and S2. It carries no count. |
| Consultation paper (CP) | An FCA proposal for comment — CP26/5 here. |
| Policy Statement (PS) | The FCA’s response and final rules — PS26/19 here, with the made instrument in Appendix 1. |
| Primary Market Bulletin | The FCA’s channel for guidance on listing matters; PMB 66 carries draft Technical Note 803.1. |
| Comply or explain | Disclose, or state what is not disclosed, why, and the steps planned. The basis of every UK SRS disclosure under PS26/19. |
One practical consequence of the finalised text is worth knowing before a first report: comparative information is not needed in the first period of application, and after the climate-only relief ends, the non-climate comparatives are needed only from the second period in which the relief is no longer used (UK SRS S1 ¶¶E1, E4).
For Scope 3, comparative figures are needed only from the period after the first in which the disclosures are made, and an entity may keep relying on the relief for comparatives (UK SRS S2 ¶C5).
Frequently asked
Questions people ask
What was the UK SRS consultation?
Two consultations, often run together in the telling.
The Department for Business and Trade consulted on exposure drafts of UK SRS S1 and S2 from 25 June to 17 September 2025, and published the final standards on 25 February 2026.
The FCA consulted in CP26/5, from 30 January to 20 March 2026, on requiring listed companies to report against UK SRS, and published its final rules, PS26/19, on 30 September 2026.
How many responses did the UK SRS consultation receive?
DBT received 209 responses to its exposure-draft consultation: 170 through an online survey and 39 by email, from 199 organisations and 10 individuals. That figure belongs to DBT’s consultation only.
The FCA reports responses question by question in PS26/19, for example 66 responses to its question on secondary listings and depositary receipts.
What did the FCA decide after CP26/5?
That listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS S1 and S2 on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
CP26/5 had proposed making UK SRS S2 mandatory and asking secondary listings and depositary receipts only for a signposting statement; the final rules put everything on comply or explain and brought those issuers in.
Early adopters keep the transitional reliefs, which CP26/5 would have withdrawn.
Is the FCA still consulting on UK SRS?
On guidance, yes.
Alongside PS26/19 the FCA is consulting in Primary Market Bulletin 66 on draft Technical Note 803.1, on how to apply the comply-or-explain rules, with updates to TN 801.4 and the deletion of TN 802.3.
Comments are due by 28 October 2026.
The rules themselves are final.
Did the consultation change the UK SRS standards?
Yes.
Of the six amendments DBT proposed in June 2025, four were made, one was replaced by a broader change — the relief periods were removed rather than extended — and the GICS amendment was withdrawn after the ISSB made the change itself.
Paragraphs 73A, 73B, B59A and E5 were added after the consultation.
Annex A of the government response maps the final differences and gives no total.
Which proposal had the most support?
Linking the transition reliefs to the date any reporting requirement comes into force: 83% of those answering the question (138 of 166) agreed and 2% (4 of 166) disagreed.
The SASB change from “shall” to “may” drew 70% support (122 of 175), and the four TAC amendments 68% (125 of 184).
Is there a consultation on UK SRS for private companies?
Not as such.
The Modernising Corporate Reporting consultation, published on 7 September 2026 and open until 30 November 2026, says the government will consider how UK SRS should be reflected in the Companies Act 2006.
It proposes no UK SRS requirement, threshold or date for private companies.
What happened to the transition plan consultation?
Nothing has been published.
The consultation on climate-related transition plan requirements ran from 25 June to 17 September 2025, alongside the UK SRS exposure drafts, and its page still read “We are analysing your feedback” when re-checked on 28 September 2026.
What was the UK SRS exposure draft?
The draft UK SRS S1 and UK SRS S2 that the Department for Business and Trade published on 25 June 2025: the ISSB’s IFRS S1 and IFRS S2 with six proposed UK amendments.
The consultation on them closed at 11:59pm on 17 September 2025, and the final standards were published on 25 February 2026.
Who ran the UK SRS consultation?
The Department for Business and Trade ran the consultation on the standards themselves, advised by the Technical Advisory Committee, with the FRC as its secretariat, and the Policy and Implementation Committee.
The Financial Conduct Authority ran the separate consultation, CP26/5, on requiring listed companies to report against the standards.
What was FCA CP26/5?
The FCA’s consultation paper on aligning listed issuers’ sustainability disclosures with international standards, open from 30 January to 20 March 2026.
It proposed replacing the TCFD-aligned listing rules with UK SRS, with UK SRS S2 mandatory except Scope 3.
The FCA’s final rules, PS26/19 of 30 September 2026, put all UK SRS disclosures on comply or explain instead.
How many companies did CP26/5 say would be affected?
Its cost-benefit analysis estimated that around 600 listed companies would be affected, with 515 on the full route and 89 secondary-listing and depositary-receipt issuers on a statement route. Those were the consultation’s estimates.
PS26/19 gives no total and puts the 89 under the same requirements as domestic issuers.
Did investors want UK SRS to be mandatory?
Many did.
PS26/19 records that many respondents, particularly buy-side and professional service firms, supported mandatory climate disclosures, while listed companies were more mixed.
The PRI asked for an extra year to phase in Scope 3 and non-climate reporting rather than comply or explain, and UKSIF asked for a pathway to mandatory Scope 3 or a review clause.
The FCA chose comply or explain on proportionality grounds.
Why did the FCA choose comply or explain?
Because feedback said full UK SRS disclosure is not yet feasible for some smaller issuers, and the FCA judged a mandatory approach could be disproportionately burdensome for them.
It rejected a size threshold instead, saying climate risk depends on a company’s business model and industry, not its size.
What does the FCA’s cost-benefit analysis for UK SRS say?
It estimates a positive net present value of £174.10 million over ten years for the final rules, about £60 million lower than for the CP26/5 proposals, with present-value costs of £233.49 million.
Its per-company figures, such as £194,700 a year for a large issuer that complies in full, are modelled averages of incremental cost over TCFD-aligned reporting, not prices.
What is draft Technical Note 803.1?
The FCA’s proposed guidance on how to apply the comply-or-explain rules, published in Primary Market Bulletin 66 alongside PS26/19.
It proposes that an explanation can be short and proportionate but must not omit material information, that no timeframe is required, and that an explanation need not go requirement by requirement.
Comments are due by 28 October 2026.
How do I respond to the FCA’s UK SRS guidance consultation?
By email to primarymarketbulletin@fca.org.uk by 28 October 2026, commenting on draft TN 803.1, the updates to TN 801.4 and the deletion of TN 802.3.
The FCA is also holding a webinar on 19 October 2026 on the final rules.
What was the GICS amendment?
One of the six proposed UK amendments: removing IFRS S2’s requirement to use the Global Industry Classification Standard.
It was withdrawn because the ISSB amended IFRS S2 itself in December 2025 in a way the government judged broadly consistent with the UK proposal, so no UK difference remains.
Why do UK SRS S1 and S2 have no effective date?
The government removed the 1 January 2024 effective dates in IFRS S1 and S2 to avoid confusion with the introduction of any reporting requirements.
The standards can be used voluntarily at once, and any duty to use them comes from law or regulation — for listed companies, the FCA’s rules from periods beginning on or after 1 January 2027.
What are paragraphs 73A and 73B of UK SRS S1?
Paragraphs added after the consultation.
Paragraph 73A says an entity using the climate-first relief may not assert compliance with UK SRS S1 and must disclose the relief, while using that relief or the UK SRS S2 Scope 3 and measurement-method reliefs does not prevent a statement of compliance with UK SRS S2 if they are disclosed.
Paragraph 73B puts the reliefs under whichever authority requires reporting.
Did the consultation add anything IFRS S2 does not require?
Yes, one thing: paragraph B59A of UK SRS S2.
Where a financial institution cannot reliably estimate financed emissions for the same period as its financial statements, it must explain why, the approach it used and how it plans to comply.
It was added after the Technical Advisory Committee’s advice of 26 January 2026.
Did the FCA set a size threshold for UK SRS?
No. Some listed companies asked for one so smaller issuers could fall out of scope, and the FCA declined, saying the impact of climate risk depends on business model and industry-specific vulnerabilities, not size.
Scope is set by listing category.
What did respondents to the UK SRS consultation already report?
Of the 170 online respondents, 76 (45%) already reported under Streamlined Energy and Carbon Reporting and 59 (35%) under the Companies Act’s TCFD-aligned rules.
Most were being asked to change the standard they report to, not to start reporting.
Has the UK SRS consultation closed?
Both have.
DBT’s consultation on the exposure drafts closed at 11:59pm on 17 September 2025, and the FCA’s CP26/5 closed on 20 March 2026.
What is open now is the FCA’s consultation on draft guidance, Technical Note 803.1, until 28 October 2026, and the government’s Modernising Corporate Reporting consultation, until 30 November 2026.
Is UK SRS still happening?
Yes.
The standards were published on 25 February 2026, and the FCA’s final rules of 30 September 2026 require listed companies in UKLR 6, 14, 15, 16 and 22 to report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reports in 2028.
What is British SRS?
Usually a search for UK SRS: the UK Sustainability Reporting Standards, UK SRS S1 and UK SRS S2, which are the UK-endorsed versions of the ISSB’s IFRS S1 and S2.
There is no separate British standard.
Can I use UK SRS voluntarily?
Yes.
The government’s guidance says the standards are available for voluntary use by any entity that chooses to do so, and its response says that for voluntary reporters UK SRS is available to use immediately.
A voluntary user may rely on the Scope 3 and climate-first reliefs without a time limit.
Which reporting periods need comparative information under UK SRS?
Not the first.
UK SRS S1 does not require comparative information in the first period of application, and UK SRS S2 needs Scope 3 comparatives only from the period after the first one in which the Scope 3 disclosures are made.
For listed companies the FCA’s transitional guidance says the same of the first period reported under its rules.
Where can I read the government response to the UK SRS consultation?
On GOV.UK, as a PDF and as a web version, attached to the exposure-drafts consultation page.
Annex A of the response maps every difference between UK SRS and IFRS S1 and S2.
The FCA’s answer to CP26/5 is PS26/19, on the FCA’s website.
When is the FCA publishing its supervisory approach to UK SRS?
In the second half of 2027, ahead of the first reporting season under the new rules, according to PS26/19.
The FCA and the FRC will monitor compliance with the UK SRS and transition-plan disclosures.
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 TradeExposure drafts: UK Sustainability Reporting Standards — consultation and outcome
Ran 25 June to 17 September 2025; the outcome published 25 February 2026.
- Department for Business and TradeConsultation document: exposure draft of UK SRS S1 and UK SRS S2 (PDF)
“The government proposes 6 minor amendments to the standards for application in a UK context.”
- Department for Business and TradeDraft UK SRS S1 with amendments (PDF)
The exposure draft of the general standard.
- Department for Business and TradeDraft UK SRS S2 with amendments (PDF)
The exposure draft of the climate standard.
- Department for Business and TradeGovernment response to the consultation (PDF), ¶¶1.6, 1.31, 1.35 and Annex A
The response counts, the support for each proposal, and the map of final differences.
- Department for Business and TradeGovernment response — web version
The same response as a web page.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
The finished standards, 25 February 2026.
- GOV.UKUK Sustainability Reporting Standards — guidance
The consultation window and “available for voluntary use, by any entity that chooses to do so”.
- Financial Conduct AuthorityCP26/5: consultation page
Opened 30 January 2026, closed 20 March 2026.
- Financial Conduct AuthorityCP26/5 (PDF) — including the Cost Benefit Analysis, Annex 2 ¶43
The proposals, and the estimate of around 600 listed companies affected.
- Financial Conduct AuthorityPS26/19 (PDF): ¶¶1.2, 1.7, 1.9, 2.44, 2.61–2.67, 3.6, 3.14, 3.19, 4.28, 4.35 and Appendix 1
What the FCA decided, question by question, and why.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Published 30 September 2026; the draft guidance consultation and the 19 October 2026 webinar.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Published 7 September 2026; closes 30 November 2026.
- DESNZ / DBTClimate-related transition plan requirements — consultation
Closed 17 September 2025; no response published.
- Financial Reporting CouncilThe TAC issues its final recommendations, 18 December 2024
The origin of four of the six proposed amendments.