UK SRS and the FCA: the final rules, provision by provision

The FCA consulted in CP26/5 from 30 January to 20 March 2026 and answered it in PS26/19, 194 days after the consultation closed.

The CP26/5 consultation page still carries its original “next steps” wording, so read the policy statement, not the consultation page, for the rules.

The final rules adopt a comply-or-explain approach across all categories of disclosure, which brings UK SRS S2 into line with the basis the FCA had already proposed for Scope 3 and for UK SRS S1.

PS26/19 says in terms that these rules will replace the existing TCFD-aligned disclosures.

Listing rules are Part 6 rules, which the FCA makes under section 73A of the Financial Services and Markets Act 2000; the Act itself is at legislation.gov.uk.

The standards the rules point at are the ones the Department for Business and Trade published on 25 February 2026, and UK SRS S1 and S2 carry no effective date of their own.

The government removed those dates deliberately, and its letter to the FCA of 5 January 2026 explains that timing and reliefs would be set by FCA rules or regulations instead — which is what UKLR TP 16 now does.

The rule text is on the FCA Handbook; until 1 January 2027 the Handbook shows the TCFD statement that still governs current periods.

The explanation differs by standard, and the difference is deliberate.

For UK SRS S2 the company summarises the disclosure requirements it has not met.

For UK SRS S1 it names the risks or opportunities, of the kind the standard’s ¶3 describes, that it has not disclosed — not every S1 paragraph it has left out.

Both explanations give the reasons and any steps the company is taking or plans to take.

The FCA consults on how much detail it expects in draft Technical Note 803.1, published with Primary Market Bulletin 66.

The draft note also settles how the rules sit with the standards’ own statement of compliance under UK SRS S1 ¶¶72–73B.

A company that explains cannot make an explicit and unreserved statement of compliance with the standard it has not met; a company that uses an explanation the standard itself provides for, such as S2 ¶21, has not left the standard.

The FCA also reminded issuers that where climate risk is among their principal risks and uncertainties, they should consider how that is reflected when they choose to explain.

How to write a usable explanation is the subject of UK SRS compliance, and UK SRS reporting goes through what a full disclosure contains.

The years in the timeline are the calendar years in which an accounting period begins, and the provisions quoted are UKLR 6’s.

For a period beginning in 2027, UKLR TP 16.4R lets a company omit its Scope 3 emissions under UK SRS S2 ¶C4, and report climate-first under UK SRS S1 ¶E3, provided it states that it is relying on the transitional provision and the relief.

For a period beginning in 2028, TP 16.5R keeps the climate-first relief and drops the Scope 3 one.

From 1 January 2029 no FCA relief is left, and every limb is comply or explain; nothing becomes mandatory when a relief expires.

A company using a relief states it and explains nothing further during the relief period, because use of a relief does not engage the explain rules.

The standards’ own greenhouse gas measurement relief, UK SRS S2 ¶C3, stays available in the first period, and comparative Scope 3 figures are needed only from the period after the first in which Scope 3 is disclosed.

A company already disclosing Scope 3 under the TCFD rules may keep doing so while the relief is open; PS26/19 says the rules do not prevent it.

The Scope 3 detail — the fifteen categories and what “consider” means — is on UK SRS Scope 3 reporting, and every date sits in the dated register of UK SRS events.

The guidance is not final.

Draft TN 803.1 will replace the listing-rule guidance in TN 801.4, and TN 802.3, the FCA’s TCFD technical note, is to be deleted once TN 803.1 is finalised; the FCA aims to finish before the rules come into force.

The FCA is responsible for monitoring and enforcing the rules, along with the FRC, and intends to update its supervisory approach in the second half of 2027.

A breach of a listing rule falls under section 91 of the Financial Services and Markets Act 2000, which lets the FCA impose a penalty on an issuer or publish a statement censuring it instead.

PS26/19 sets no UK SRS-specific penalty, and we do not suggest one.

Assurance is a statement, not a duty: the FCA will keep the case for mandating it under review, and the FRC’s ISSA (UK) 5000 governs how an engagement is done if one is commissioned; sustainability assurance and UKAS accreditation explain the market.

The FCA’s own cost-benefit analysis puts the net present value of its final rules at £174.10m (PS26/19, Chapter 4).