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Materiality · the UK standard

UK SRS materiality: the S1 test, the missing thresholds and the ISSB link

UK SRS materiality is single (financial) materiality: information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions of investors, lenders and other creditors.

UK SRS S1 sets no numeric threshold, lets immaterial “minimum requirements” go undisclosed and asks for the judgement to be reassessed at every reporting date.

It is the ISSB’s test, endorsed for the UK, and it is not the EU’s double materiality.

The test

UK SRS materiality in two paragraphs

UK SRS S1 ¶17 says what goes in: “An entity shall disclose material information about the sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s prospects.”

¶18 says what material means: information is material “if omitting, misstating or obscuring that information could reasonably be expected to influence decisions that primary users of general purpose financial reports make on the basis of those reports”.

Read ¶¶3, 17–19 and the definition of primary users

¶18 continues that those reports “include financial statements and sustainability-related financial disclosures and … provide information about a specific reporting entity.”

¶3 frames the risks and opportunities in scope as those that “could reasonably be expected to affect the entity’s cash flows, its access to finance or cost of capital over the short, medium or long term.”

¶19 then sends the reader to the application guidance: “To identify and disclose material information, an entity shall apply paragraphs B13–B37.”

Appendix A defines primary users as “existing and potential investors, lenders and other creditors”, which is why the test is about financial decisions.

¶2 explains where impacts come in: the entity’s dependencies on resources and relationships, and its impacts on them, “give rise to sustainability-related risks and opportunities for the entity.”

So an impact enters UK SRS reporting as the source of a risk or opportunity, never for its own sake.

Where these paragraphs sit in the Standard is mapped on UK SRS S1, paragraph by paragraph.

The S1 testExplore

Module 01 / 04

¶17 what to disclose

Material information about the sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s prospects.

Name the lens

Single (financial) materiality, not enterprise value, not double

“Single materiality” is a descriptive label, not a test any standard defines, so the accurate name for the UK test is single (financial) materiality, quoting ¶3 and ¶18.

The phrase “enterprise value” does not appear in UK SRS S1.

Read why enterprise value went, and why double materiality is a different test

“Enterprise value” was exposure-draft language: the IFRS S1 Basis for Conclusions records at BC34(b) that the ISSB removed “the definition of ‘enterprise value’ and the words ‘to assess enterprise value’ from the objective of IFRS S1 and the description of the assessment of materiality”.

BC67 explains why: the ISSB aligned its definition with the IASB’s definitions of “material information” and “material”, “which do not refer to enterprise value”.

BC40 adds that the ISSB’s approach and its focus on users of general purpose financial reports “remained unchanged”.

Double materiality is a second question, not a harder version of the first: revised ESRS 1 ¶35 says impacts “can be material exclusively from an impact perspective, irrespective of whether they are financially material”.

UK SRS asks only the first question, and single and double materiality compared sets the two side by side.

The financial half of the EU test is close to the UK one: financial materiality covers both, and impact materiality covers the half the UK does not ask for.

Whose decisions?

UK SRS and the ISSB

Financial: primary users of general purpose financial reports.

UK SRS S1 ¶¶3, 18.

ESRS

Double: impacts on people and the environment, or financial effects, or both.

Revised ESRS 1 ¶35.

GRI

Impact: the organisation’s most significant impacts.

GRI 3.

Read the primary source

No thresholds

UK SRS materiality has no number

¶B19 is explicit: UK SRS S1 “does not specify any thresholds for materiality or predetermine what would be material in a particular situation.”

The judgement is the entity’s, made against its own facts and its own primary users.

Read ¶¶B19, B23, B25 and B32

¶B23 is a warning about aggregation: even where no single source of supply-chain disruption is material, “the aggregate risk—the risk of supply chain disruption from all sources—might be material.”

¶B25 limits over-reporting: “An entity need not disclose information otherwise required by a UK Sustainability Reporting Standard if the information is not material. This is the case even if the UK Sustainability Reporting Standard contains a list of specific requirements or describes them as minimum requirements.”

¶B32 works the other way: material information is disclosed “even if law or regulation permits the entity not to disclose such information”.

The ISSB’s educational material repeats the point that “ISSB Standards do not specify any thresholds for material information”.

A percentage from audit practice, such as five per cent of profit, is an auditor’s example for financial statements and has no footing here; what materiality means sets the audit and sustainability tests side by side.

The application guidanceExplore

Module 01 / 04

¶B19 no thresholds

The Standard does not specify thresholds or predetermine what is material.

Every reporting date

Reassessing UK SRS materiality across the year

¶B28 makes materiality a recurring judgement: “An entity shall reassess its materiality judgements at each reporting date”.

The sequence below is an illustration of how a UK listed company might organise that work; UK SRS S1 prescribes the judgement, not the calendar.

  1. 01 / Context01

    Confirm the reporting entity

    The same entity as the financial statements, and the same primary users.

    UK SRS S1 ¶20

  2. 02 / Identify02

    List risks and opportunities

    Those that could reasonably be expected to affect cash flows, access to finance or cost of capital.

    UK SRS S1 ¶3

  3. 03 / Sources03

    Consider sources of guidance

    SASB topics may be considered; GRI and the ESRS may be considered as guidance.

    UK SRS S1 ¶¶55, C2

  4. 04 / Assess04

    Judge what is material

    No threshold is set; consider individually and in aggregate.

    UK SRS S1 ¶¶B19, B23

  5. 05 / Disclose05

    Disclose material information only

    Immaterial minimum requirements can be left out; name the sources applied.

    UK SRS S1 ¶¶B25, 59

  6. 06 / Reporting date06

    Reassess the judgements

    Check the conclusions again before the report is signed.

    UK SRS S1 ¶B28

Industry topics and other frameworks

SASB may be used; if it is, you must say so

Industry context is where most long lists start, and UK SRS S1 deliberately loosens the ISSB’s wording here.

¶55(a) says an entity “may refer to and consider the applicability of the disclosure topics in the SASB Standards”, where IFRS S1 ¶55(a) says “shall”.

Read the SASB, GRI and ESRS provisions

¶58(a) makes the same change for the metrics associated with the SASB topics, and both paragraphs add that an entity “might conclude” the SASB material is not applicable in its circumstances.

The permission runs one way only: ¶59 says an entity “shall identify” the specific standards, pronouncements, industry practice and other sources it applied, including any SASB disclosure topics.

The SASB Standards are now the ISSB’s, and the SASB Standards guide explains the 77 industries and the Materiality Finder.

¶C2 lists the GRI Standards and the European Sustainability Reporting Standards among the sources an entity may consider.

¶C3 sets the limit: applying those frameworks without UK SRS does not allow an explicit and unreserved statement of compliance.

The GRI Standards page and the ESRS page explain what each would bring to the long list.

Sources of guidanceExplore

Module 01 / 04

¶55(a) SASB topics

An entity “may” refer to and consider the SASB disclosure topics.

ISSB materiality and IFRS S1 materiality

The ISSB’s test is the UK’s test

UK SRS S1 endorses the ISSB’s general requirements standard, and Annex A of the government’s response, which lists every difference, lists none in the materiality paragraphs.

So “ISSB materiality” and “IFRS S1 materiality” describe the same single (financial) materiality the UK applies.

Read the ISSB’s reasoning and its educational material

BC67 of the Basis for Conclusions confirms the definition is aligned with the IASB’s “material information” and “material”, which do not refer to enterprise value.

BC69 is the caution: “Materiality judgements for sustainability-related financial disclosures will inevitably differ from those for financial statements.”

The reason given is that sustainability disclosures concern prospects over longer horizons and are not bounded by the recognition criteria for assets and liabilities.

The ISSB published educational material on 19 November 2024, which describes a four-step approach: identify, assess, organise and review.

It says of itself that it “is not part of IFRS Sustainability Disclosure Standards and does not add to or change the requirements in the Standards”.

The international picture, including adoption by jurisdiction, is on the ISSB framework, and the standard itself on IFRS S1 explained.

  1. 1

    Identify

    Information about sustainability-related risks and opportunities that has the potential to be material.

  2. 2

    Assess

    Whether the potentially material information is material.

  3. 3

    Organise

    The information within the draft disclosures.

  4. 4

    Review

    The draft sustainability-related financial disclosures.

ISSB educational material, November 2024

ISSB double materiality?

The ISSB does not apply double materiality, and says why

“ISSB double materiality” is a common search, and the answer is no.

The joint statement by GRI and the IFRS Foundation of 26 May 2026 says ISSB Standards provide investors with “material information about sustainability-related risks and opportunities that could reasonably be expected to affect an entity’s prospects”.

Read the joint statements in full

The same joint statement says: “ISSB Standards require the disclosure of information about impacts only in so far as this provides material information for investors with respect to sustainability-related risks and opportunities for the entity.”

It describes GRI’s purpose separately: information “about their most significant impacts on the economy, environment and people, and their contributions to sustainable development.”

The ESRS–ISSB interoperability guidance of 2 May 2024 says the definition of financial materiality in ESRS “is aligned with the definition of materiality in IFRS S1”.

The regimes still differ because ESRS materiality “covers also the impact materiality lens”, so an aligned definition is not an identical regime.

The guidance maps the 2023 ESRS paragraph numbers, so check any mapping against the revised ESRS before relying on it.

The EU side is set out on double materiality.

Impacts in the ISSB StandardsExplore

Module 01 / 04

Investor purpose

Material information about risks and opportunities affecting prospects.

TCFD materiality

What TCFD said about materiality, and what replaces it

The TCFD’s October 2021 annex left the recommendations alone and changed the guidance on one point that matters here.

It says the Task Force “has not modified its four overarching recommendations … however, it has updated the guidance for all sectors and now asks organizations to disclose their GHG emissions independent of a materiality assessment.”

Read what changes for UK listed companies

That is why “TCFD materiality” causes confusion: the GHG disclosure sat outside a materiality gate while the recommendation above it still spoke of information “where such information is material”.

For UK listed companies the question is moving on: the FCA says in PS26/19 ¶1.10 that its new rules “will replace the existing TCFD aligned disclosures”.

Climate disclosures then follow UK SRS S2, read with the materiality test in UK SRS S1.

The mapping from the eleven TCFD disclosures is on moving from TCFD to UK SRS, and the framework itself on the TCFD guide.

From TCFD to UK SRSExplore

Module 01 / 04

2021 annex

GHG emissions to be disclosed independent of a materiality assessment.

The FCA’s rules

What comply or explain adds to UK SRS materiality

The FCA’s PS26/19, published on 30 September 2026, asks listed companies in UKLR categories 6, 14, 15, 16 and 22 to report against UK SRS on a comply-or-explain basis.

The rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028.

Read how the explain rule interacts with materiality

Materiality decides what complying means: an entity complies with UK SRS by disclosing material information, and immaterial information was never required.

For UK SRS S1, the explain limb in UKLR 6.6.6R(7B) works on risks and opportunities, not requirements: where a company has identified risks or opportunities of the kind in S1 ¶3 but not disclosed on them, it states which, why, and the steps it is taking or plans to take.

For UK SRS S2, UKLR 6.6.6R(7A) asks instead for a summary of the S2 disclosure requirements not met, the reasons and the planned steps.

The FCA’s view, at ¶1.3, is that “a proportionate explanation of their reasoning and judgement can itself provide useful information to investors.”

¶3.14 gives two reliefs from initial application: two years for UK SRS S1 matters beyond climate, and one year for Scope 3 under UK SRS S2.

¶3.20 says using a relief needs a statement, not an explanation, because it “does not engage our ‘explain’ rules”.

When a relief ends, the comply-or-explain rule applies; nothing becomes unconditional.

The rules are read provision by provision on the FCA’s UK SRS rules, who they cover on who is in scope, and what an explanation must say on UK SRS compliance.

UKLR 6.6.6RExplore

Module 01 / 04

(7A) S2

Disclose under UK SRS S2, or summarise the requirements not met, why, and the steps planned.

The dates

UK SRS materiality by date

The test itself has not moved since the ISSB issued it; what has moved is who applies it in the UK and on what basis.

Dates are as at 11 October 2026.

  1. June 202301

    IFRS S1 issued

    The ISSB’s general requirements, with “enterprise value” removed from the final materiality wording.

    IFRS S1 Basis for Conclusions

  2. 19 November 202402

    ISSB educational material

    Material information explained in four steps; adds no requirement.

    IFRS S1 supporting materials

  3. 25 February 202603

    UK SRS S1 and S2 published

    Published for voluntary use, with SASB references made permissive.

    DBT publication page

  4. 30 September 202604

    FCA final rules

    PS26/19: comply or explain across UK SRS for five listing categories.

    FCA PS26/19

  5. Periods from 1 January 202705

    First reporting periods

    The rules apply, with first reports in 2028; the reliefs start.

    PS26/19 ¶3.12

  6. Periods from 1 January 202806

    Scope 3 relief has expired

    Scope 3 falls within comply or explain.

    PS26/19 ¶3.23

  7. Periods from 1 January 202907

    S1 climate-first relief has expired

    S1 matters beyond climate fall within comply or explain.

    PS26/19 ¶3.24

UK groups with EU reach

One assessment, two materiality tests

A UK group with an EU subsidiary in CSRD scope may run the EU’s double materiality assessment and also report against UK SRS.

The financially material subset of the EU work is the natural starting point for UK SRS S1, and the impact-only findings stay on the EU side.

Read how the two tests share evidence

EFRAG’s IG 1 guidance says an assessment reflecting both perspectives “need not perform two separate and independent processes”, though it is non-authoritative and written for the 2023 ESRS.

The method for the EU side is on the double materiality assessment, and a framework-neutral process is on running a materiality assessment.

When the group’s routes into each regime are unclear, CSRD and UK SRS for one group and UK SRS against the ESRS set out the differences.

A presentation choice such as a materiality matrix is required by neither regime.

Reusing the workExplore

Module 01 / 04

Financial subset

The ESRS financial definition is aligned with IFRS S1, so the financially material matters carry over.

Worked example

A UK listed retailer applies the test

This example is illustrative and its facts are invented.

The company is a UK listed retailer in the UKLR 6 category, reporting for its first period beginning on 1 January 2027.

Illustrative. Rules from UK SRS S1 ¶¶2, 3, 18, B23, B25 and B28.
MatterThe UK SRS questionJudgementResult
Supplier factories in flood-prone regionsCould disruption affect cash flows over the medium term?Several suppliers are individually small, but together they supply a large share of stock (¶B23).Material: disclose under UK SRS S2
Packaging waste in its own storesCould it affect cash flows, access to finance or cost of capital?Costs are small and no lender or regulatory pressure is identified.Not material: not disclosed (¶B25)
Working hours in a garment supply chainIs there a risk to the company, not only an impact on workers?A major customer contract requires audits; losing it would move revenue.Material as a risk; the impact matters through the risk (¶2)
Water use in head officeAny effect on prospects?None identified after review.Not material; reassessed at the next reporting date (¶B28)

Two points carry the example.

The garment-supply matter is material because of the risk to the company, which is the UK test, not because of the severity of the impact on workers, which is the EU’s additional question.

The company uses the two-year relief for S1 matters beyond climate, so for its first period it states that it is using the relief rather than explaining the omission (PS26/19 ¶3.20).

This is a provisional illustration of the method, not a finding about any company.

What goes wrong

Eight UK SRS materiality mistakes

Calling it enterprise-value materiality

The phrase is not in UK SRS S1; the ISSB removed it (BC67).

Say single (financial) materiality.

Borrowing an audit percentage

The Standard sets no thresholds (¶B19).

Disclosing every minimum requirement

Immaterial information need not be disclosed, even if listed as a minimum (¶B25).

Judging items only one by one

Individually immaterial items can be material together (¶B23).

Treating impacts as reportable in themselves

An impact enters as a source of risk or opportunity (¶2).

Assuming SASB is mandatory, or silent

Using SASB is permissive (¶55(a)); naming the sources used is not (¶59).

Calling UK SRS reporting mandatory

PS26/19 is comply or explain; a relief needs a statement, not an explanation.

Fixing the assessment once

Judgements are reassessed at each reporting date (¶B28).

If you are starting from scratch

Read ¶¶17–19 and B13–B37 of UK SRS S1 first, then decide which sources of guidance you will consider and record them.

The wider meaning of the word, across accounts, audit and the EU, is on materiality explained, and the whole UK standard on UK SRS S1 and S2.

Frequently asked

Questions people ask

What is UK SRS materiality?

It is the test in UK SRS S1 ¶¶17–18.

An entity discloses material information about the sustainability-related risks and opportunities that could reasonably be expected to affect its prospects, and information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users of general purpose financial reports make on the basis of those reports.

Paragraph 3 frames the effects as the entity’s cash flows, its access to finance or cost of capital over the short, medium or long term.

Is UK SRS single materiality or double materiality?

Single (financial) materiality.

“Single materiality” is a descriptive label, so the accurate statement is that UK SRS S1 applies financial materiality to the decisions of primary users, by reference to cash flows, access to finance or cost of capital.

Double materiality, which adds impacts on people and the environment in their own right, is the EU’s test under the ESRS.

Does UK SRS use enterprise-value materiality?

No. The phrase does not appear in UK SRS S1.

The ISSB removed the definition of “enterprise value” and the words “to assess enterprise value” from the final IFRS S1, as its Basis for Conclusions records at BC34(b), BC39 and BC67, and aligned its definition of material with the IASB’s.

Does UK SRS set a materiality threshold?

No. UK SRS S1 ¶B19 says the Standard “does not specify any thresholds for materiality or predetermine what would be material in a particular situation.”

Materiality is an entity-specific judgement, and a percentage borrowed from audit practice has no footing in the Standard.

Do I have to disclose every UK SRS requirement?

Not if the information is not material.

UK SRS S1 ¶B25 says an entity need not disclose information otherwise required if it is not material, “even if the UK Sustainability Reporting Standard contains a list of specific requirements or describes them as minimum requirements.”

How often must UK SRS materiality be reassessed?

At each reporting date.

UK SRS S1 ¶B28 says an entity “shall reassess its materiality judgements at each reporting date”.

Who are the primary users in UK SRS S1?

Appendix A of UK SRS S1 defines them as existing and potential investors, lenders and other creditors.

Their decisions are about providing resources to the entity, which is why the test is financial.

What is ISSB materiality, and is it the same as UK SRS materiality?

The ISSB test in IFRS S1 is the same test.

UK SRS S1 endorses IFRS S1, and the materiality paragraphs carry the same wording.

The ISSB aligned its definition with the IASB’s definition of material for financial statements, while noting at BC69 that materiality judgements for sustainability disclosures “will inevitably differ” from those for financial statements.

Does the ISSB use double materiality?

No. The ISSB Standards apply financial materiality for investors.

The joint GRI and IFRS Foundation statement of 26 May 2026 says ISSB Standards require information about impacts “only in so far as this provides material information for investors with respect to sustainability-related risks and opportunities for the entity.”

Double materiality is the ESRS test.

What is TCFD materiality?

The TCFD’s October 2021 annex left its four recommendations and eleven disclosures unchanged but asked organisations to disclose their GHG emissions “independent of a materiality assessment”.

Under the FCA’s final rules, UK SRS reporting replaces the existing TCFD-aligned disclosures for listed companies, and UK SRS S1 applies its own materiality test.

Must I use the SASB Standards to assess materiality under UK SRS?

No, but you must say if you did.

UK SRS S1 ¶55(a) and ¶58(a) say an entity “may” refer to and consider the SASB disclosure topics and metrics, where IFRS S1 says “shall”.

Paragraph 59 then requires the entity to identify the standards, pronouncements and industry practice it applied, including any SASB topics.

Can I use GRI or the ESRS to identify material information under UK SRS?

They can be considered as sources of guidance.

UK SRS S1 ¶C2 lists the GRI Standards and the ESRS among the sources an entity may consider. ¶C3 says that applying them without UK SRS prevents an explicit and unreserved statement of compliance.

What happens if a listed company decides information is not material?

It does not disclose it, and nothing needs explaining for that reason alone.

The FCA’s explain rule bites where a company has identified a risk or opportunity of the kind in UK SRS S1 ¶3 but has not disclosed on it, in full or in part.

UKLR 6.6.6R(7B) then asks for the risks or opportunities left out, the reasons and the steps it plans to take.

Is UK SRS reporting mandatory for listed companies?

No: it is comply or explain.

Under PS26/19, listed companies in UKLR categories 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

A relief of two years covers S1 matters beyond climate and a relief of one year covers Scope 3.

Can a UK group reuse its ESRS double materiality assessment for UK SRS?

Its financially material subset is the natural starting point.

The joint ESRS–ISSB guidance says the ESRS definition of financial materiality is aligned with IFRS S1, on which UK SRS S1 is built.

Impacts found material only from the impact perspective stay on the EU side unless they could affect cash flows, access to finance or cost of capital.

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.

Checked against 15 sources fromDepartment for Business and TradeIFRS FoundationEFRAG / IFRS FoundationGRI and the IFRS FoundationTCFDFinancial Conduct Authority
  1. Department for Business and Trade
    UK SRS S1 General Requirements — ¶¶3, 17–19, B19, B23, B25, B28, B32, C2–C3, Appendix A

    The UK materiality test and its application guidance, read in the published PDF.

  2. Department for Business and Trade
    UK SRS S1 — ¶¶55(a), 58(a) and 59

    An entity “may” refer to the SASB Standards, and “shall” identify the sources it applied.

  3. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 (publication page)

    Published 25 February 2026 for voluntary use; a framework such as the FCA’s rules decides who reports.

  4. IFRS Foundation
    IFRS S1 Basis for Conclusions — BC34(b), BC39, BC67, BC69

    Why “enterprise value” was removed, and why sustainability materiality judgements differ from financial-statement ones.

  5. IFRS Foundation
    Sustainability-related risks and opportunities and the disclosure of material information — educational material, November 2024

    Explanatory, not part of the Standards; a four-step approach to identifying material information.

  6. IFRS Foundation
    IFRS S1 supporting materials

    Lists the educational material at 19 November 2024.

  7. IFRS Foundation
    IFRS S1 General Requirements

    The ISSB standard UK SRS S1 endorses.

  8. IFRS Foundation
    SASB Standards

    Industry disclosure topics the ISSB is responsible for.

  9. EFRAG / IFRS Foundation
    ESRS–ISSB Standards Interoperability Guidance, 2 May 2024 — §1.1

    The ESRS financial-materiality definition is aligned with IFRS S1; the ESRS regime adds the impact lens.

  10. GRI and the IFRS Foundation
    Facilitating efficient reporting when using the GRI and ISSB Standards, 26 May 2026

    States the investor purpose of the ISSB Standards beside the impact purpose of GRI.

  11. TCFD
    Implementing the Recommendations of the TCFD — October 2021 Annex, p. 3

    Asks organisations to disclose GHG emissions independent of a materiality assessment.

  12. Financial Conduct Authority
    PS26/19 — Aligning listed issuers’ sustainability disclosures with international standards

    Final rules of 30 September 2026: UK SRS on a comply-or-explain basis for five listing categories.

  13. Financial Conduct Authority
    PS26/19 (PDF) — ¶¶1.3, 3.12, 3.14, 3.20, 3.23–3.24 and Appendix 1 (UKLR 6.6.6R(7A), (7B))

    What an explanation must say, and when the reliefs end.

  14. EUR-Lex
    Commission Delegated Regulation (EU) 2026/1563 — revised ESRS 1 ¶35

    The EU’s double materiality, for comparison; impacts can be material on their own.

  15. EFRAG
    IG 1: Materiality Assessment Implementation Guidance, ¶65

    One assessment can serve both perspectives; non-authoritative and written for the 2023 ESRS.

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