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.
“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).
| Route | Who it would reach | Status on 30 September 2026 |
|---|---|---|
| FCA listing rules | Companies listed in UKLR 6, 14, 15, 16 and 22 | Made · comply or explain from periods beginning 1 Jan 2027 |
| Companies Act 2006 | Companies 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.
- 21 Oct 2025Written statement HCWS973
The programme announced; a consultation promised for 2026.
- 25 Feb 2026UK SRS published
The government response sets UK SRS within the MCR programme.
- 7 Sep 2026Consultation published
By BIST.
- 30 Sep 2026FCA PS26/19
Listed-company rules final.
- 30 Nov 2026Consultation closes
- Spring 2027Climate 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.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation page
Published 7 September 2026; closes 30 November 2026.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document (PDF), ¶¶147–161, 178
Every statement about UK SRS on this page.
- UK ParliamentWritten statement HCWS973, 21 October 2025
The programme’s announcement; “a broad consultation will be delivered in 2026”.
- Department for Business and TradeGovernment 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.
- Department for Business and TradeGovernment 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.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
“The standards are available for voluntary use, by any entity that chooses to do so.”
- Department for Business and TradeUK 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.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF) — ¶C6
The same machinery for the climate standard.
- legislation.gov.ukCompanies Act 2006, section 414CB
The climate-related financial disclosure duty and the s.414CB(6) national-framework route.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
The one UK SRS obligation made so far: comply or explain for listed companies.
- Financial Reporting CouncilGuidance on the Strategic Report
The FRC’s guidance on the narrative report where UK SRS disclosure would sit.
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
The FRC’s running account of UK SRS, including its voluntary use.