UK SRS readiness · self-check · nothing stored
UK SRS readiness: what could you disclose today?
This UK SRS readiness assessment asks one question of each thing a first report needs: could you disclose it now?
Where the answer is no, the FCA’s final rules give three routes — disclose, use a relief and say so, or explain — and the check drafts which one each gap would take.
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How it works
Three outcomes, not a score
Under the FCA’s rules every UK SRS disclosure is comply or explain, so being “not ready” has a defined consequence rather than a penalty.
That makes readiness a drafting question: for each item, which of the three routes will your first report take?
The checks follow the four content areas of UK SRS S2, the UK SRS S1 matters beyond climate, and the three statements UKLR 6.6.6R(8) adds.
A good answer is specific: “we cannot yet measure category 1 of Scope 3” is a readiness finding; “we are at level 4” is not.
If you are not sure the rules reach you, start with who is in scope; the standards themselves are on UK SRS S1 and S2.
| If you could… | The report says |
|---|---|
| Disclose it now | The disclosure |
| Not, and a relief covers it | That you use the relief — nothing more during the relief period (PS26/19 ¶3.20) |
| Not, and no relief covers it | A summary of what is not met, the reasons, and the steps planned (UKLR 6.6.6R(7A)(b)) |
| Not make a required statement | There is no alternative: location, assurance and transition-plan statements are made |
The self-check
Fifteen checks, one draft
Answer as many as you like.
The draft below updates as you go and lists, for each gap, what your report would say instead.
Your draft
Answer any item above and the statement your first report would need appears here.
Nothing you choose is stored or sent anywhere. This is a self-check against the rules as written, not advice.
The checks, written out
Every check, its source and its fallback
The same list as the self-check, as plain text, so nothing here depends on a script.
| Check | Rests on | If you cannot yet disclose it |
|---|---|---|
| Governance body. Can you name the board or committee responsible for oversight of climate-related risks and opportunities, and say how it exercises it? | UK SRS S2 governance content area | Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Management’s role. Can you describe management’s role in monitoring and managing those risks and opportunities? | UK SRS S2 governance content area | Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Risks and opportunities. Have you identified the climate-related risks and opportunities that could reasonably be expected to affect your prospects, with short-, medium- and long-term horizons? | UK SRS S2 strategy content area | Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Financial effects. Can you describe their current and anticipated effects on your financial position, performance and cash flows? | UK SRS S2 ¶9(d) and ¶¶15–21 | Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Scenario analysis. Have you assessed climate resilience with scenario analysis proportionate to your circumstances (qualitative narratives count)? | UK SRS S2 ¶22 and ¶B15 | Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Transition plan information. If you have a climate transition plan, can you describe it, with its key assumptions and dependencies? | UK SRS S2 ¶14(a)(iv) — only if you have a plan | If you have a plan but cannot yet describe it: Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. If you have no plan, S2 asks nothing here; the listing-rule statement below still applies. |
| Risk processes. Can you describe how you identify, assess, prioritise and monitor climate-related risks and opportunities, and how that sits within overall risk management? | UK SRS S2 risk management content area | Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Scope 1 and 2. Can you measure Scope 1 and Scope 2 greenhouse gas emissions for the whole reporting entity, under the GHG Protocol? | UK SRS S2 ¶29(a) | Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Scope 3. Can you measure Scope 3 emissions, having considered all 15 categories? | UK SRS S2 ¶29(a)(i)(3), ¶B32 | In your first period, use the one-year Scope 3 relief and state that you are doing so; no further explanation is needed (PS26/19 ¶¶3.14, 3.20). Otherwise: Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Targets and industry metrics. Can you disclose the climate targets you have set, your progress, and the industry-based metrics relevant to your business? | UK SRS S2 metrics and targets content area | Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Other sustainability matters. Have you identified sustainability-related risks and opportunities beyond climate that meet the UK SRS S1 ¶3 test, and could you disclose them? | UK SRS S1 ¶3; UKLR 6.6.6R(7B) | For your first two periods, use the S1 relief (“climate-first” reporting) and state that you are doing so (PS26/19 ¶¶3.14, 3.20). Otherwise: Explain under UKLR 6.6.6R(7B)(b): the risks or opportunities you have identified but not disclosed, and the reasons. |
| Same entity, same time. Can your sustainability figures cover the same reporting entity and period as your financial statements, and be published with them? | UK SRS S1 ¶20; IFRS S1 ¶E4 has no UK equivalent | Explain under UKLR 6.6.6R(7A)(b): a summary of the UK SRS S2 requirements not met, the reasons, and the steps you are taking or plan to take. |
| Location statement. Can you say where in the annual financial report (or by cross-reference) the disclosures are? | UKLR 6.6.6R(8)(c); UK SRS S1 ¶¶B45–B47 | This is a statement, not a disclosure you can explain away: it has to be made. |
| Assurance statement. Can you say whether you obtained third-party assurance and, if so, the provider, what was assured, the level, and the standards used? | UKLR 6.6.6R(8)(d) | This statement has to be made; obtaining assurance is not required, only saying whether you did. |
| Transition-plan statement. Can you say whether you have published a climate transition plan, where, or why not? (UKLR 6, 16 and 22 only.) | UKLR 6.6.6R(8)(e) | This statement has to be made by UKLR 6, 16 and 22 companies; “why not” is enough, and the FCA sets no content for it. |
Reading the result
Where the gaps usually are, and which are cheap
The three listing-rule statements cost nothing but a decision: say where the disclosures are, whether you obtained assurance, and whether a transition plan is published.
Scope 1 and 2 figures come first because nothing else in metrics and targets stands without them, and they are measured under the GHG Protocol Corporate Standard.
The reliefs buy time only where they apply: Scope 3 in the first period, and UK SRS S1 beyond climate in the first two; see UK SRS Scope 3 reporting for what the Scope 3 relief does and does not cover.
Two gaps are commonly underestimated: the financial effects of climate risks (UK SRS S2 ¶9(d) and ¶¶15–21), and producing sustainability figures for the same entity and period as the accounts, at the same time — the UK removed IFRS S1’s first-year permission to publish later.
Scenario analysis is less demanding than it is often described: paragraph 22 asks for an approach commensurate with your circumstances, and paragraph B15 accepts qualitative narratives.
How an explanation should read is the subject of the FCA’s draft Technical Note 803.1, open for comment to 28 October 2026; UK SRS compliance covers the statement.
The FCA’s nine steps
The regulator’s own list, set against the checks
Primary Market Bulletin 66, published with the final rules, lists nine things the FCA encourages listed companies to do to prepare.
They are encouragement, not rules — and each maps onto checks in the self-check above.
| FCA step (PMB 66) | What it points at | Where it lands in the report |
|---|---|---|
| 1 · Understand and engage with the new requirements | Which limbs apply to your category | UKLR 6.6.6R(7A), (7B), (8) and equivalents |
| 2 · Identify financially material risks and opportunities | The S1 ¶3 test and the climate risks | UK SRS S1 and S2, strategy |
| 3 · Review governance arrangements | Board and management oversight | UK SRS S2 ¶6; S1 ¶¶26–27 |
| 4 · Integrate risks and opportunities into strategy | Business model, value chain, transition plan if any | UK SRS S2 ¶¶13–14 |
| 5 · Assess resilience | Scenario analysis proportionate to your circumstances | UK SRS S2 ¶22 |
| 6 · Develop data, metrics and targets | Scopes 1–3, cross-industry and industry metrics, targets | UK SRS S2 ¶¶29–36 |
| 7 · Establish internal controls and review | A trail an assurance provider or the FRC could follow | The assurance statement, UKLR 6.6.6R(8)(d) |
| 8 · Build capabilities and training | Who owns each disclosure | All of it |
| 9 · Engage with investors | What users expect to see, and in what order | Prioritising disclosures and explanations |
The FCA also reminded issuers that Listing Principle 1 and the management report’s duty to describe principal risks (DTR 4.1.8R) already apply, so climate risks that are principal risks belong in the report whatever UK SRS says.
Read in order, the nine steps are a reasonable first-year plan; nothing in them sets a date, and no UK regulator publishes a preparation timetable.
Gaps become explanations
Turn a gap into an explanation that meets the rule
A readiness result with “not yet” on it is not a failure under the FCA’s rules, because a company may explain instead of disclosing.
What it does create is a drafting job: each gap needs a statement of what is not met, why, and the steps planned.
The tool beside this text takes a draft explanation and checks it against those three limbs, then against the features the FCA’s draft Technical Note 803.1 proposes for a good one.
The limbs are rule; the features are proposed guidance until the FCA finalises it, and the tool says which is which.
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Test your explanation · rule and draft guidance
Rule (7A)(b)(iii): the statement must set out any steps being taken or planned to make them in future.
Draft guidance: make the reasons issuer-specific rather than generic.
Draft guidance: naming the headings or paragraphs not met is enough; no requirement-by-requirement explanation is needed.
No timeframe is fine: the rule does not ask for one, and the draft guidance says it helps only where one is known or estimated.
Rule: UKLR 6.6.6R(7A)(b) and (7B)(b), and the UKLR 14, 16 and 22 equivalents (FCA PS26/19 Appendix 1).
Guidance: the FCA’s draft Technical Note 803.1, proposed, comments to 28 October 2026.
Your ticks stay on this page.
Starting from TCFD
If you already report under TCFD, most of the frame is there
A company already reporting under the FCA’s TCFD-aligned rule, or the Companies Act climate duty, has the four content areas in place.
IFRS S2, on which UK SRS S2 is built, is consistent with the TCFD recommendations and then asks for more: industry-based metrics, planned use of carbon credits, more on financed emissions, and Scope 3 as a requirement rather than “if appropriate”.
Those additions, and the link to the financial statements, are where a TCFD reporter’s checks are most likely to come back “partly”.
The general standard, UK SRS S1, then asks the same four questions about every material sustainability topic, not only climate — after the two-year relief.
The succession is on TCFD and UK SRS, and every date in the dated register.
Support
Where help exists, if you want it
Data is usually the constraint: carbon reporting software compares platforms, and the SECR reporting guide covers the energy and carbon figures many companies already produce.
Independent consultancies and specialists work in this area; the guide to sustainability consulting firms and ESG consultants describe what they do, and the ESG reporting manager role what an in-house owner of the report does.
If you are weighing whether to obtain assurance, sustainability assurance explains ISSA (UK) 5000, which the FRC lists among its assurance standards.
Professional bodies publish their own material: the ICAEW and ACCA among them; the regulators and standard-setters are the FCA, the FRC, DBT and the ISSB, and the FCA’s consultation is on the CP26/5 page.
The wider reporting picture, beyond UK SRS, is on sustainability reporting.
A network of independent specialists exists for implementation work.
If you would like to talk through your result, you can book a free 15-minute call.
Frequently asked
Questions people ask
What is a UK SRS readiness assessment?
A check of whether an organisation could make each disclosure UK SRS asks for, and each statement the FCA’s listing rules add, in its first reporting period.
For a listed company in scope, the useful output is not a score but a list: what it can disclose, where it will use a relief and say so, and what it will have to explain.
What does an ESG readiness assessment cover under UK SRS?
The four content areas of UK SRS S2 — governance, strategy, risk management, and metrics and targets — including financial effects, scenario analysis and Scope 1, 2 and 3 emissions; the UK SRS S1 matters beyond climate; whether the figures cover the same entity and period as the accounts; and, for listed companies, the location, assurance and transition-plan statements in UKLR 6.6.6R(8).
What happens if we are not ready by 2027?
For a listed company in scope, the rules are comply or explain.
Where a UK SRS S2 disclosure cannot be made, the report states a summary of the requirements not met, the reasons, and the steps being taken or planned.
In the first period, Scope 3 may be left out under a one-year relief, and UK SRS S1 matters beyond climate under a two-year relief, provided the company states that it is using them.
How long does it take to get ready for UK SRS?
No regulator publishes a timetable, and it depends on where you start.
The fixed point is the date: the FCA’s rules apply to accounting periods beginning on or after 1 January 2027, so a company with a calendar year end is already collecting data for its first UK SRS year from that date.
Do we need assurance to be ready?
No. Assurance is not required by UK SRS or the FCA’s rules.
A listed company states whether it obtained third-party assurance and, if it did, the provider, what was assured and to what level, and the standards used.
ISSA (UK) 5000 is for voluntary use.
Is anything I enter in the self-check saved?
No. The self-check runs only in your browser.
It stores nothing and sends nothing, and your answers disappear when you close the page.
Does a company outside the FCA’s rules need a readiness assessment?
There is no requirement to have one, because no UK SRS duty applies outside the five listing categories.
Companies that use UK SRS voluntarily — for example to meet the Companies Act climate duty through section 414CB(6), or for investors and lenders — can use the same check.
Has the FCA published a checklist for preparing for UK SRS?
Not a checklist, but a list of nine steps it encourages listed companies to take, in Primary Market Bulletin 66: understand the new requirements; identify financially material sustainability and climate-related risks and opportunities; review governance; integrate those risks and opportunities into strategy; assess the resilience of the business model and strategy; develop the data, metrics and targets needed; establish internal controls and review processes; build capabilities and training; and engage with investors on their expectations.
They are encouragement, not rules.
Is a readiness assessment the same as a gap analysis?
In practice, yes: both compare what a company could disclose today with what the requirements ask.
Under the FCA’s rules the gaps that remain at the first period are not failures in themselves — they are explained, with the reasons and the steps planned — so a readiness assessment is also the first draft of those explanations.
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.
- Financial Conduct AuthorityPrimary Market Bulletin 66
Nine preparation steps the FCA encourages; draft TN 803.1 for comment by 28 October 2026.
- Financial Conduct AuthorityPS26/19 (PDF): ¶¶1.2, 3.12, 3.14, 3.19, 3.20 and Appendix 1 (UKLR 6.6.6R(7A), (7B), (8))
What a listed company must disclose or explain, the reliefs, and the three statements.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Published 30 September 2026.
- Financial Conduct AuthorityCP26/5: consultation page
The consultation the final rules answer.
- FCA HandbookUKLR 6.6 — the annual financial report
Where the disclosures and statements sit from 1 January 2027.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF)
The four content areas and the paragraphs each check refers to.
- Department for Business and TradeUK SRS S1 General Requirements (PDF) — ¶¶3, 20, B45–B47
The materiality test, the reporting entity and cross-referencing.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
Both standards, for voluntary use since 25 February 2026.
- Department for Business and TradeGovernment response (PDF), Annex A
IFRS S1’s first-year later-publication relief does not exist in UK SRS S1.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
The FRC’s sustainability assurance standard, for voluntary use.
- Financial Reporting CouncilAssurance standards
Where the FRC lists ISSA (UK) 5000.
- IFRS FoundationTCFD and the ISSB
What IFRS S2 asks beyond the TCFD recommendations.
- GHG ProtocolCorporate Standard
The basis for measuring Scope 1 and 2 emissions.