UK SRS legislation and regulations: what binds you today
UK SRS is not a statute and it is not a statutory instrument. The Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026 for voluntary use, and the IFRS Foundation’s own UK snapshot puts it plainly: they “do not in themselves set legal obligations”.
So the useful question is not whether UK SRS is law. It is which of the instruments already sitting on your desk is binding this financial year — and the answer, for most UK companies, is a longer list than they expect and does not include UK SRS.
See the nine provisions that bind you, and the one that does not Instrument by instrument · in force or proposed · every one linked to its own textUK SRS legislation is a published standard, not an Act of Parliament
People searching for “UK SRS legislation” are usually looking for a statute with that name. There is not one, and there was never going to be one.
UK SRS S1 and UK SRS S2 are technical standards. The Secretary of State for Business and Trade endorsed IFRS S1 and IFRS S2 and published the UK versions on 25 February 2026, and that publication is the instrument people mean by “UK SRS legislation”.
It is a real, dated, citable government act. It is not a source of legal obligation.
That third category is the one nearly every guide skips, and it is the one that decides what you file this year.
This page is the inventory: what each instrument is, whether it binds you today, whether it requires UK SRS, and what changes if the FCA confirms its proposals in the autumn.
Two clocks are running.
One has finished. The other has not started.
Almost every guide reads the first as the second
What “not law” means, precisely
“UK SRS is voluntary” is true and it is nearly useless on its own, because it does not tell you whether anything changes when you adopt it.
Three independent bodies have said the same thing in three different registers, and reading them together is what makes the position usable.
The UK SRS are available for voluntary use by UK companies… and will form the basis for any future requirements in, or amendments to, UK legislation and regulation. They do not in themselves set legal obligations for companies to use UK SRS. IFRS Foundation, Jurisdictional Snapshot: United Kingdom, updated 18 June 2026[3]
So “voluntary” describes the obligation to adopt, not the consequences of adopting.
Adopt UK SRS S2 and one existing statutory duty gets shorter — which is chapter 07, and is the single most under-written fact in this whole subject.
There is no Sustainability Act, and there is no SRS Act
A meaningful share of the traffic to this page arrives on “sustainability act”, “srs act” and “srs law”. The honest answer is that no such statute exists in the United Kingdom, and the useful answer is what people find when they go looking for one.
UK corporate sustainability reporting is not built on a dedicated Act.
It is built by amendment — three statutory instruments that inserted duties into the Companies Act 2006, plus a financial-services statute that gives the FCA power to write rules for listed issuers.
That is why searching the statute book for “sustainability” returns almost nothing useful.
The duties are there, but they are called non-financial and sustainability information, climate-related financial disclosure and energy and carbon report, and they live inside a company-law statute written twenty years ago.
Nine provisions bind you today. None of them requires UK SRS
Two questions can be asked of every instrument in this subject, and they are independent of each other: is it binding in law today, and does it require UK SRS.
Set them against each other and the grid has four cells.
The cell where both answers are yes is empty, and that emptiness is the whole legal position in one picture.
Statuses read from legislation.gov.uk, the FCA Handbook and FCA CP26/5 on 9 August 2026.[5][6][7][2] Not legal advice — whether a particular provision reaches a particular entity is a question for your own advisers.
Read the top-right cell as the argument of this page.
Nothing that binds a UK company today asks for UK SRS, and the one instrument that would is a consultation whose Policy Statement has not been published.
The duty lives in the strategic report, not in a sustainability statute
Two sections of the Companies Act 2006 carry almost the whole of UK corporate sustainability reporting law, and both were inserted by amendment.
Alongside the statement duty runs a size filter, and it is not the SECR filter.
A company that is not otherwise caught is brought in as a high turnover company — turnover above £500 million, or a group headed by it with aggregate net turnover above that figure — and is taken back out where it had no more than 500 employees in the financial year.[5]
The wider legal landscape sits around this rather than replacing it.
SECR is a Companies Act requirement in its own right[8], ESOS is established in regulation and enforced by the Environment Agency[9], and the UK legislated for the first time to regulate ESG ratings providers via an Order signed into law on 15 December 2025[10].
Eight climate disclosures — and four you may leave out
Section 414CB(2A) is a definition, not a designation. It lists, at (a) to (h), the eight things a climate-related financial disclosure consists of.
Companies Act 2006 s.414CB(2A)(a)–(h), with the omission power at s.414CB(4A) and the explanation duty at s.414CB(4B).[5]
The omission power is narrower than it looks and wider than most companies use.
Directors may omit the whole or part of a disclosure required by (2A)(e), (f), (g) or (h) where they “reasonably believe” that, having regard to the nature of the business and the manner in which it is carried on, it “is not necessary for an understanding of the company’s business”.[5]
Where they do, subsection (4B) requires the statement to give “a clear and reasoned explanation of the directors’ reasonable belief”.
That is a comply-or-explain mechanism written into primary legislation, four years before anybody used the phrase about UK SRS — and the four items it covers are exactly the forward-looking ones: strategy impact, scenario resilience, targets and KPIs.
Governance, risk identification, risk integration and the principal risks are not omittable at all.
The one place voluntary adoption already pays
If UK SRS is voluntary and nothing requires it, there has to be a reason to adopt it early. There is exactly one, it is statutory, and it is in force now.
If information required by subsections (1) to (5) to be included in the statement is published by the company by means of a national, EU-based or international reporting framework, the statement must specify the framework or frameworks used, instead of including that information. Companies Act 2006, section 414CB(6)[5]
The FRC has confirmed which framework that is, for climate.
UK SRS S2 is a national reporting framework and… it will not be necessary for UK entities to duplicate climate-related financial disclosure requirements. FRC, Sustainability reporting developments FAQ, updated 26 February 2026[4]
Two conditions travel with it, and both are the FRC’s own.
This is the argument for early adoption, and it is not a soft one.
A company already inside the s.414CA duty can report once, under UK SRS S2, and point the strategic report at it — rather than maintaining a UK SRS S2 disclosure and a separate Companies Act climate narrative that say the same things in different shapes.
Note what this is not: it is not an exemption, it is not a safe harbour, and it does not make UK SRS mandatory by the back door. It is a substitution.
AIM is inside the Companies Act duty and outside the FCA’s proposal
The two regimes have different perimeters, and the gap between them catches two populations that are routinely told they are out of scope.
So the sentence “AIM is out of scope” is true of one regime and false of the other.
An AIM company above the size thresholds has a live statutory climate-disclosure duty today, can use section 414CB(6) to satisfy it through UK SRS S2 voluntarily, and would still not be caught if the FCA confirms CP26/5 in the autumn.
For that population, voluntary adoption is the only route there is — and it is the population most likely to have been told the subject does not concern them.
Adopting UK SRS subtracts nothing
A reader who adopts UK SRS voluntarily does not thereby exit any existing regime. Every instrument that applied before still applies after.
SECR is the clearest case.
SI 2018/1155 remains in force and unamended by anything in the UK SRS programme, and DBT confirmed to the FCA in January 2026 that SECR continues alongside UK SRS.[12]
The Government has said it will consider how the two interact to reduce duplication once UK SRS becomes mandatory, but it has not said whether SECR would be reformed or replaced.[13]
The practical consequence is a stack, not a swap.
For a large unquoted company the stack is SECR plus, if it is big enough, the strategic report climate duty — and UK SRS S2 sits on top as an optional way of discharging the second of those. For the detail of the energy and carbon side, our energy and carbon reporting guide is the reference.
Two routes to mandatory, and only one has a date
There are exactly two ways UK SRS could stop being voluntary, they run through different institutions, and they would catch different companies.
The distinction is not academic.
The FCA route affects listed companies only and operates through regulatory requirements; extension to large private companies would require legislation under the Companies Act, making it a broader statutory obligation.[13]
If your company is not listed, no live process would make UK SRS mandatory for you.
Not a delayed one — an unstarted one.
Where the FCA’s power comes from, and where it stops
The FCA can make UK SRS mandatory for listed companies through its regulatory powers over the Listing Rules.[2] It can do that because Parliament gave it the power in 2000, and the same statute defines the edge of what it can reach.
Part 6 of the Financial Services and Markets Act 2000 makes the FCA the competent authority for listing, and section 73A is the general rule-making power under which the UK Listing Rules, the Disclosure and Transparency Rules and the Prospectus Rules are made.[7]
That perimeter is the reason there are two routes rather than one.
One correction worth carrying, because it dates a page instantly.
“Premium listed” and “standard listed” are not present-tense categories: they were abolished on 29 July 2024 when the UK Listing Rules replaced the old Listing Rules sourcebook.[14] For the regulator’s overall approach see UK SRS FCA.
UK SRS regulations — the FCA rule mechanics
The UK SRS regulations are the FCA rulebook provisions — amendments to the Disclosure and Transparency Rules and the UK Listing Rules, proposed under CP26/5 — that would make the DBT-published standards enforceable.
The standards tell you what to disclose.
The regulations tell you which companies must disclose it, where in the annual report, by when, and what happens if you do not.
The substantive standards live in the DBT publication of 25 February 2026; the regulations are the amendments to the Disclosure and Transparency Rules (DTR) and the UK Listing Rules (UKLR) proposed under FCA CP26/5, exercising the rule-making powers under the Financial Services and Markets Act 2000.
Rule mechanics as proposed in FCA CP26/5, published 30 January 2026, consultation closed 20 March 2026, no Policy Statement published as at 9 August 2026.[2] For the consultation timetable see our CP26/5 tracker.
The word “regulations” is doing unusual work here and it is worth being exact about it.
These are not statutory instruments. They are rules in a regulator’s handbook, made under a statutory power, and they bind the firms the regulator supervises rather than the world at large.
The Companies Act route has no dates at all
Everything published about 2027 concerns listed issuers. For the rest of the UK corporate population there is no timetable, because there is no consultation.
The vehicle would be the Government’s Modernising Corporate Reporting programme, on which DBT is expected to consult later in 2026.[13]
The IFRS Foundation records the same division of labour: the FCA holds responsibility for listed companies, while “the UK government will consider decisions regarding future Companies Act requirements at a later date”.[3]
Our Modernising Corporate Reporting programme page tracks what DBT has said about the strands.
For a private company the practical reading is that any UK SRS obligation is at least two formal steps away, and the reasons to adopt now are commercial and statutory-substitution reasons, not compliance ones.
One clock has finished. The other has not started
The single most common error in this subject is reading the completion of the endorsement process as the commencement of a mandate. They are different processes, run by different bodies, and only one of them is over.
The third lane is the one nobody draws, because it has nothing in it yet.
Endorsement dates from the IFRS Foundation UK jurisdictional snapshot, updated 18 June 2026[3] and GOV.UK[1]; mandation dates from FCA CP26/5 as it stood on 9 August 2026.[2] Dates on the mandation lane are proposed.
Read the gap between the lanes rather than either lane on its own.
Endorsement finished on 25 February 2026 and produced a standard nobody has to use. Mandation would start when a Policy Statement is published, and the FCA has said only that it aims to publish one in the autumn, subject to the final UK SRS.
Between those two events sits the whole of 2026, and section 414CB(6) is the only thing in that gap that gives voluntary adoption a legal effect.
The reliefs are not symmetrical, and the asymmetry favours volunteers
Both standards carry transition provisions, and they are written in the standards themselves rather than in any FCA rule. That placement is what produces the asymmetry.
Now put the FCA determination beside it.
CP26/5 §3.9 proposes a one-year deferral for Scope 3 — accounting periods beginning on or after 1 January 2028 — and a two-year deferral for the non-climate content of UK SRS S1, to 1 January 2029.[19]
Those numbers apply to issuers the FCA determines them for.
A voluntary adopter is not an issuer the FCA has determined anything for.
C4 has no expiry written into it, and C6 subjects its availability to an FCA determination that does not reach a company outside the FCA’s perimeter — so for a voluntary adopter the Scope 3 relief is not on a clock.
The practical shape of it: an unlisted company adopting UK SRS S2 voluntarily to discharge its section 414CB duty can use C4 and disclose Scope 3 when it is ready, while a listed issuer inside a confirmed CP26/5 regime would be working to the FCA’s determination.
Which is the opposite of the usual assumption that voluntary adopters are on the tighter leash.
Which instruments bind your entity, this financial year
Three inputs, all of which you already know: your listing status, whether you meet the SECR two-of-three test, and whether you meet the strategic report climate test.
It returns the named instruments binding you this financial year, and a second column for what would change if the CP26/5 Policy Statement lands as proposed.
Tests from Companies Act 2006 ss.414CA and 414CB[5], SI 2018/1155[6] and FCA CP26/5.[2] Nothing you enter leaves your browser. An entity’s obligations are a question for its own advisers.
The rule the resolver is built on is worth stating in words as well.
An entity’s obligation is the union of several regimes, not the newest one.
Adopting UK SRS voluntarily adds a reporting framework and, through section 414CB(6), substitutes for part of one existing duty. It does not remove SECR, it does not remove the strategic report, and it does not remove ESOS.
What the fines are, and what they are actually for
There is no penalty for not adopting UK SRS. There cannot be, because nothing requires it. The penalties that exist in this area attach to the Companies Act filing and reporting duties, and they are real.
Two things follow that are worth saying plainly.
The largest exposure today is a filing failure, not a disclosure failure — the criminal offence in section 451 is about not filing at all, and it lands on every director personally.
And a defective climate disclosure is treated as a corporate reporting quality question by the FRC rather than as an offence, which is a different risk with a different remedy.
What a director is actually liable for in a sustainability disclosure
Forward-looking climate disclosure asks directors to publish scenario analysis and targets. The obvious worry is what happens when those turn out to be wrong. The Companies Act answers it, and the answer is more protective than most people assume.
A director of a company is liable to compensate the company for any loss suffered by it as a result of… any untrue or misleading statement in a report… or the omission from a report… of anything required to be included in it. Companies Act 2006, section 463(2)[25]
The incumbent guides call this a “safe harbour”, and the label is fair as far as it goes.
What it does not do is protect against the filing offences in chapter 17, against FCA action if a listing rule is breached, or against liability under other regimes such as the market-abuse framework.
How a standard becomes UK SRS — and why the next one will not be automatic
The UK Secretary of State for Business and Trade is responsible for endorsing IFRS Sustainability Disclosure Standards to create UK SRS.[3] The route runs through a committee most readers have never heard of.
The important consequence is forward-looking.
New or amended ISSB standards — nature, human capital — do not automatically apply in the UK. Each would have to go through this same endorsement process first.[4]
So a UK company reading an ISSB announcement is reading news about a standard that has no UK status until the Secretary of State gives it one.
For what the UK changed in the ISSB text on endorsement, see our page on the UK-specific amendments to UK SRS.
There is no Scottish or Welsh corporate reporting duty
Company law is a reserved matter. The Companies Act 2006 applies across the United Kingdom, and so do the statutory instruments that amended it.
That is why a company in Glasgow, Cardiff or Belfast has exactly the same strategic report, SECR and climate disclosure duties as one in Leeds.
The devolved legislatures do legislate on climate, and it is worth being precise about what those Acts do.
Public-sector bodies are a different story and a different regime.
If you are a Scottish public body with a climate change reporting duty, that duty comes from the 2009 Act and its regulations, not from the Companies Act and not from UK SRS.
Where the rest of the sustainability rulebook lives
This page is about the instruments that create sustainability reporting duties. The broader set of UK sustainability rules is larger, and it has its own reference page.
Three families sit alongside the reporting duties and are commonly confused with them.
For the full picture of what the standards landscape looks like across those families, our sustainability regulations reference is the page that owns it.
This page stays with the eight instruments that decide what goes in an annual report.
What compliance would look like, if the FCA confirms
This is the shortest useful version. The depth belongs to the page that owns the term.
If CP26/5 is confirmed as proposed, an in-scope listed issuer would report UK SRS S2 climate disclosures for accounting periods beginning on or after 1 January 2027, in the annual report, with Scope 3 and UK SRS S1 content on comply-or-explain and reliefs in the first cycles.[2][16]
For the full treatment — readiness, sequencing and the control environment — see UK SRS compliance, which owns that subject in this cluster.
For the reporting mechanics themselves, UK SRS reporting guidance is the reference.
“ESG regulation” is four separate things in the UK
The phrase covers at least four distinct regimes, and the reason it is hard to answer “what are the UK ESG regulations” is that no single instrument carries that name either.
UK ESG legislation, in the strict sense used on this page, means the Companies Act duties and the statutory instruments that created them — the same nine provisions in chapter 04.
UK ESG regulation, in the wider sense, adds the FCA’s rules for regulated firms, the ESG ratings regime, and the environmental and social duties that sit outside company law entirely.
Those wider families are owned by ESG reporting, which is the page in this cluster that carries them.
The boundary worth holding on to: if it goes in the annual report, it is on this page; if it is an operating licence condition or a product rule, it is not.
ESOS is legislation too, and it is on a different cycle entirely
The Energy Savings Opportunity Scheme is regulation in the strict sense — a statutory instrument, with a regulator, a qualification date and enforcement powers.
It is the instrument most often mistaken for a reporting duty, and it is not one: ESOS is an energy audit obligation on a four-year cycle, discharged by submitting a compliance notification, not by disclosing in the annual report.[9]
Its qualification test is its own — neither the SECR two-of-three nor the strategic report climate test — and it is enforced by the Environment Agency rather than by the FRC or the FCA.
The Energy Act 2023 is the primary legislation that gave the Secretary of State the powers under which the ESOS regulations have since been amended.
The detail belongs to the page that owns it: our ESOS compliance guidance covers qualification, the routes and the deadlines in full.
Four things that would change the inventory
This page is a statement of the position on 9 August 2026. Four published, dated processes could move it, and none of them has concluded.
Two of those four would change what binds you. Two would only change what you have to read.
Our UK SRS implementation timeline tracks the dates as they move, and the UK SRS consultation page holds the exposure-draft record.
Nine provisions, and not one of them names UK SRS.
One subsection makes adopting it worth something anyway.
UK SRS is not law, and the question that matters is not whether it will be but which section of the Companies Act you are already filing under.
Six things worth remembering
If you are inside the section 414CA duty, adopting UK SRS S2 shortens a statutory obligation you already have — and the thing to check first is whether the duty reaches you at all.
See whether the thresholds reach you Or start on UK SRS compliance insteadUK SRS legislation — the DBT-endorsed standards
UK SRS legislation is the instrument that brought UK SRS S1 and UK SRS S2 into existence: the Department for Business and Trade publication of 25 February 2026, endorsing IFRS S1 and IFRS S2 as the UK’s sustainability reporting standards, with UK-specific amendments.
The standards themselves are the substantive content; the “legislation” label captures the DBT-published instrument and the supporting statutory framework.
A clean distinction is useful: UK SRS legislation = the underlying standards as a published instrument; UK SRS regulations = the FCA DTR and UKLR rule amendments that would make them enforceable for in-scope listed issuers.
The legislation exists today; the regulations are proposed to come into force for accounting periods beginning on or after 1 January 2027, once and if the FCA Policy Statement publishes in autumn 2026.
For the full UK Sustainability Reporting Standards reference — including legal status, compliance timeline and who must report — start at the hub.
The instruments, one by one
Every provision named on this page, what it does, and whether it binds a UK company on 9 August 2026.
Key dates
Every date on this page, with its status. Dates marked proposed are not settled and should never be quoted as though they were.
Frequently asked questions
Answers reflect the statute book as in force on 9 August 2026 and FCA CP26/5 as it stood on that date.