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UK SRS · the Companies Act route

UK SRS and the MCR consultation: will it reach private companies?

The government’s Modernising Corporate Reporting consultation, open until 30 November 2026, is where a Companies Act route to UK SRS would begin.

On UK SRS it says one thing: the government “will consider” how the standards should be reflected in the Companies Act 2006.

That is not a proposal, and today the only UK SRS obligation is the FCA’s, for listed companies, on a comply-or-explain basis.

The short answer

What the consultation says about UK SRS

The consultation contains no UK SRS proposal, no mechanism and no date.

It ties the government’s thinking to a review of the 2022 climate disclosure regulations, due to be completed by spring 2027, and says it does not include proposals on the future of those requirements (¶¶147–148).

So nothing in it changes who reports under UK SRS S1 and S2.

The government’s guidance still says the standards are available for voluntary use by any entity.

The consultation as a whole — the directors’ report, the strategic report and SECR — is read paragraph by paragraph on Modernising Corporate Reporting.

¶¶154–155, verbatim

“The government published the UK Sustainability Reporting Standards (UK SRS 1 and UK SRS 2) in February 2026.”

“Looking ahead, the government will consider how UK SRS should be reflected in the Companies Act 2006, taking into consideration feedback to this consultation, the CFD PIR and related processes.”

Source: consultation document, p43

The routes

Three ways a UK SRS duty can arise, and where each stands

UK SRS carries no effective date.

Both standards say that where an entity is required to apply them under UK law, how they apply is set by the Companies Act, the FCA or another UK authority (UK SRS S1 ¶E5, S2 ¶C6).

Sources: UK SRS S1 ¶E5 · UK SRS S2 ¶C6 · FCA PS26/19 · MCR consultation ¶155
RouteWho it would reachStatus on 30 September 2026
FCA listing rulesCompanies listed in UKLR 6, 14, 15, 16 and 22Made · comply or explain from periods beginning 1 Jan 2027
Companies Act 2006Companies generally, by size or type“Will consider” · no proposal
Another UK regulator—None made or proposed

The FCA route is set out in full on UK SRS and the FCA; the FCA consulted on it in CP26/5 and finalised it in PS26/19.

The law that does exist around UK SRS — the Companies Act duties, the listing rules and the standards’ own transition clauses — is on UK SRS legislation.

Company law today

Where UK SRS already touches the Companies Act

Section 414CB(6)

Large companies must make climate-related financial disclosures in the strategic report under section 414CB.

The government confirmed in February 2026 that UK SRS S2 is a national reporting framework for section 414CB(6), so a company reporting under it need not duplicate those disclosures.

¶158 says the government will make that clear for UK SRS, subject to the FCA’s outcome.

Section 463

The directors’ liability safe harbour covers statements in the strategic report.

The government’s UK SRS response confirmed it applies to UK SRS disclosure placed there.

¶160 adds that, unless section 463 is expanded, only UK SRS disclosures in the strategic report are covered.

Assurance

¶178: the government has no plans “at this stage” to require assurance over future UK SRS reporting, calling it disproportionate given the costs and the nascency of the market.

The FCA’s rules

¶156 expected final listing rules in autumn 2026.

They came on 30 September 2026, on comply or explain rather than the mandatory S2 the paragraph described.

The statute is on legislation.gov.uk, and what a UK SRS report itself contains is on UK SRS reporting.

The programme

Modernising Corporate Reporting, from announcement to consultation

The programme was announced in the government’s written statement of 21 October 2025, which called it the Modernisation of Corporate Reporting and promised a broad consultation in 2026.

The government’s UK SRS response of February 2026 set UK SRS “within the context of the Modernising Corporate Reporting (MCR) programme” and said further information would come in that consultation.

The consultation came on 7 September 2026, published by the Department for Business, Innovation, Science and Trade; the UK SRS documents of February 2026 were the Department for Business and Trade’s.

Its wider proposals — removing the directors’ report and replacing most strategic report requirements with a baseline set — change where narrative sustainability information sits, not whether UK SRS applies.

  1. 21 Oct 2025
    Written statement HCWS973

    The programme announced; a consultation promised for 2026.

  2. 25 Feb 2026
    UK SRS published

    The government response sets UK SRS within the MCR programme.

  3. 7 Sep 2026
    Consultation published

    By BIST.

  4. 30 Sep 2026
    FCA PS26/19

    Listed-company rules final.

  5. 30 Nov 2026
    Consultation closes
  6. Spring 2027
    Climate disclosure review due

    Post-implementation review of SI 2022/31.

Where UK SRS sits in a report

The strategic report as management commentary

The strategic report is the UK’s management commentary: the narrative on business model, strategy, performance and principal risks that sits in front of the accounts.

UK SRS disclosures can sit in the same place as information required by other rules, provided they are clearly identifiable, and can be included by cross-reference to another report (UK SRS S1 ¶¶62–63).

Placing them in the strategic report brings section 463’s cover; placing them elsewhere does not, on the current law.

The FRC’s guidance on the strategic report is the practical reference for the narrative itself, and the FRC keeps a running account of UK SRS in its sustainability reporting FAQs.

A company that wants its data in order before any duty arrives can start with the systems described on carbon reporting software.

Private companies

Using UK SRS without being required to

A private company can use UK SRS now; the government response says that for voluntary reporters “UK SRS is available to use immediately”.

A company that meets every requirement may make an explicit and unreserved statement of compliance under UK SRS S1 ¶72.

A company that reports on climate only, under the climate-first relief, may state compliance with UK SRS S2 but not with S1 (¶73A), and a voluntary user can use the reliefs without a time limit.

What full compliance involves is set out on UK SRS compliance, and the general standard on UK SRS S1.

When the government publishes its response, the dated register of UK SRS events will carry it; the regulators involved are the FCA for listed companies and the department for company law.

Frequently asked

UK SRS and MCR, answered

What is the MCR consultation?

The government’s Modernising Corporate Reporting consultation, published on 7 September 2026 by the Department for Business, Innovation, Science and Trade and closing on 30 November 2026.

It covers the directors’ report, the strategic report, a possible “very large” company category and where sustainability information should sit. It changes no law.

Does the MCR consultation make UK SRS mandatory?

No. On UK SRS it says only that the government “will consider how UK SRS should be reflected in the Companies Act 2006”, taking account of the consultation, the review of the climate disclosure regulations and related processes (¶155).

There is no proposal, mechanism or date.

Who has to report under UK SRS?

Only listed companies in five categories, under the FCA’s final rules in PS26/19, and then on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

No private or unlisted company has a UK SRS duty, and no government document proposes a threshold or date for one.

Can a private company use UK SRS now?

Yes.

The government says the standards are available for voluntary use by any entity.

A company that uses them voluntarily and meets all their requirements may state compliance; one that reports on climate only may state compliance with UK SRS S2 but not S1.

Can UK SRS S2 satisfy the Companies Act climate disclosure duty?

Yes.

The government confirmed in February 2026 that UK SRS S2 is a national reporting framework for section 414CB(6), so a company reporting under it need not duplicate its section 414CB(2A) disclosures.

The MCR consultation says the government will make that clear for UK SRS, subject to the FCA’s outcome.

Are UK SRS disclosures covered by the directors’ safe harbour?

Only if they are in the strategic report.

Section 463 of the Companies Act limits directors’ liability for statements in the strategic report, and the consultation notes that, unless the section is expanded, only UK SRS disclosures included there are covered.

Will UK SRS reports have to be assured?

Not on current plans.

The MCR consultation says the government has no plans at this stage to require assurance over future UK SRS reporting, and the FCA’s rules require only a statement of whether assurance was obtained.

Is it “Modernising” or “Modernisation” of Corporate Reporting?

Both are government usage.

The October 2025 written statement calls the programme the Modernisation of Corporate Reporting; the government’s UK SRS response and the 2026 consultation call it Modernising Corporate Reporting (MCR).

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 13 sources fromDepartment for Business, Innovation, Science and TradeUK ParliamentDepartment for Business and Tradelegislation.gov.ukFinancial Conduct AuthorityFinancial Reporting Council
  1. Department for Business, Innovation, Science and Trade
    Modernising corporate reporting — consultation page

    Published 7 September 2026; closes 30 November 2026.

  2. Department for Business, Innovation, Science and Trade
    Modernising corporate reporting — consultation document (PDF), ¶¶147–161, 178

    Every statement about UK SRS on this page.

  3. UK Parliament
    Written statement HCWS973, 21 October 2025

    The programme’s announcement; “a broad consultation will be delivered in 2026”.

  4. Department for Business and Trade
    Government response to the UK SRS consultation (PDF) — ¶¶1.16, 1.21 and Chapter 3

    UK SRS set within the MCR programme; available for voluntary use immediately.

  5. Department for Business and Trade
    Government response to the UK SRS consultation (web version)

    UK SRS S2 confirmed as a s.414CB(6) national reporting framework; s.463 applies to UK SRS disclosure in the strategic report.

  6. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2

    Published 25 February 2026.

  7. Department for Business and Trade
    UK Sustainability Reporting Standards — guidance

    “The standards are available for voluntary use, by any entity that chooses to do so.”

  8. Department for Business and Trade
    UK SRS S1 General Requirements (PDF) — ¶¶60–63, 72–73B and ¶E5

    Where disclosures may sit, the statement of compliance, and the clause that lets UK law set how the standard applies.

  9. Department for Business and Trade
    UK SRS S2 Climate-related Disclosures (PDF) — ¶C6

    The same machinery for the climate standard.

  10. legislation.gov.uk
    Companies Act 2006, section 414CB

    The climate-related financial disclosure duty and the s.414CB(6) national-framework route.

  11. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    The one UK SRS obligation made so far: comply or explain for listed companies.

  12. Financial Reporting Council
    Guidance on the Strategic Report

    The FRC’s guidance on the narrative report where UK SRS disclosure would sit.

  13. Financial Reporting Council
    Sustainability reporting developments — frequently asked questions

    The FRC’s running account of UK SRS, including its voluntary use.

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