UK SRS regulations — FCA DTR + UKLR rule mechanics
The UK SRS regulationsare the FCA rulebook provisions — amendments to the Disclosure and Transparency Rules (DTR) and the UK Listing Rules (UKLR)— that make UK SRS S1 and S2 enforceable for in-scope listed companies. Distinct from UK SRS legislation (the DBT-published standards themselves), the regulations are the operating mechanism. Proposed under CP26/5; expected in force 1 January 2027.
UK SRS regulations — what they are
UK SRS regulations are the FCA rulebook provisions that make UK SRS S1 and S2 enforceable. Distinct from UK SRS legislation, which is the underlying DBT-endorsed standards.
The UK SRS regulations are the operating rules that convert the DBT-published UK SRS S1 and S2 standards into binding obligations on UK-listed companies. The substantive standards live in the DBT publication of 25 February 2026 (see UK SRS legislation). The regulations are the FCA rulebook amendments — specifically to the Disclosure and Transparency Rules (DTR) and the UK Listing Rules (UKLR) — that catch in-scope issuers under 1 CP26/5.
The distinction matters in practice. The standards tell you what to disclose; the UK SRS regulations tell you which companies must disclose it, where in the annual report, by when, and what happens if you don’t. For the full FCA route see UK SRS FCA; for the consultation timetable see UK SRS consultation.
Where the UK SRS regulations live in the FCA rulebook
CP26/5 proposes amendments across three rulebook sections. Each does a distinct job in making UK SRS S2 enforceable.
- DTR (Disclosure and Transparency Rules) Primary anchor
- Proposed new DTR provision requiring in-scope issuers to apply UK SRS S2 for accounting periods beginning on or after 1 January 2027 and to disclose climate-related information in the annual report. This is where the substantive obligation lives.
- UKLR (UK Listing Rules) Scope perimeter
- UKLR rule references identifying the categories of issuer caught by the DTR provision — categories 6 (commercial equity), 16 (closed-ended funds), and 22 (open-ended funds). CP26/5 proposes rule references to bind in-scope categories without re-opening the wider UKLR scope.
- FCA Handbook glossary Terminology
- Definitions of 'UK SRS S1', 'UK SRS S2', 'climate-related disclosure' and supporting terms. Aligns the rulebook vocabulary with the DBT standards' vocabulary.
- Transitional provisions First reporting cycle
- Proposed disclose-or-explain reliefs for Scope 3 emissions, climate-related scenario analysis and assurance scope in the first reporting cycle. Phased in over 2027–2028 with full compliance from FY 2028 onward.
- Connectivity to financial statements Cross-reference
- UK SRS regulations require the climate disclosure to be connected to the financial statements — same reporting entity, same reporting period, same significant assumptions. Cross-references to FRS 102 and IFRS where applicable.
UK SRS legislation vs UK SRS regulations
The two terms get used interchangeably but mean different things. Here's the clean split.
The standards say what to disclose. The regulations make it stick.
UK SRS rulebook mechanics · June 2026
How UK SRS regulations are enforced
Once in force, breaches sit inside the FCA's standard supervisory toolkit. Censure, fines, suspension of listing — with disclose-or-explain reliefs in the first cycle.
- Routine supervisory engagement First step
- FCA monitoring of UK SRS disclosures in annual reports, sample reviews, thematic reviews. Companies receive private feedback on first-cycle disclosures.
- Private warning Step 2
- Confidential letter from the FCA flagging concerns about UK SRS disclosure quality. Common in first cycles of new regimes; rarely public.
- Public censure Step 3
- Public statement criticising the issuer's UK SRS compliance. Reputational rather than financial penalty, but published on the FCA website and picked up by ratings agencies and proxy advisers.
- Financial penalty Step 4
- FCA fine under the standard rule-breach framework. Quantum varies with the size and seriousness of the breach. UK SRS regulation fines would follow the FCA's published penalty principles.
- Suspension of listing Step 5 (rare)
- Ultimate sanction for sustained non-compliance with UK SRS regulations. Extremely rare in practice; reserved for egregious failures.
UK SRS regulation transitional reliefs
The proposed UK SRS regulations include disclose-or-explain reliefs for the hardest content in the first reporting cycle. Designed to give in-scope companies a soft landing.
CP26/5 proposes three categories of transitional relief during the first reporting cycle (FY 2027). Scope 3 emissions are subject to disclose-or-explain rather than full mandatory disclosure, with full compliance from FY 2028. Climate-related scenario analysis may be disclosed in narrative form rather than quantitative form in the first cycle. Third-party assurance is disclose-or-explain in the first cycle — companies must say whether they have obtained limited or reasonable assurance, but neither is mandatory yet.
UK SRS regulations — frequently asked
Six questions that come up most often when UK companies try to separate 'standards' from 'rules' in the UK SRS regime.
What are the UK SRS regulations?
The UK SRS regulations are the FCA rulebook provisions — specifically amendments to the Disclosure and Transparency Rules (DTR) and the UK Listing Rules (UKLR) — that will make UK SRS S1 and UK SRS S2 enforceable for in-scope listed companies.
The substantive standards are the DBT-published UK SRS S1 and S2 themselves; the regulations are the mechanism that converts those standards into binding rules.
CP26/5 sets out the proposed regulation text.
What's the difference between UK SRS regulations and UK SRS legislation?
UK SRS legislation refers to the primary instrument — DBT's endorsement of IFRS S1 and IFRS S2 published 25 February 2026 with six UK-specific amendments.
UK SRS regulations refer to the operating rules through which the FCA makes those standards enforceable — the DTR amendments and UKLR rule changes consulted on through CP26/5.
The standards are the 'what'; the regulations are the 'how do they bite'.
Are the UK SRS regulations in force yet?
Not yet.
The proposed UK SRS regulations are in consultation under FCA CP26/5, which closed 20 March 2026.
The FCA Policy Statement is expected autumn 2026 and will set out the final regulation text.
The regulations are expected to come into force in time for accounting periods beginning on or after 1 January 2027.
Which FCA rulebook sections will the UK SRS regulations sit in?
The proposed amendments cover (a) the Disclosure and Transparency Rules (DTR), specifically a new DTR provision requiring application of UK SRS S2 by in-scope issuers; (b) the UK Listing Rules (UKLR) categories 6, 16 and 22, with corresponding rule references; and (c) the Listing Rules sourcebook glossary.
Cross-references to the FCA Handbook are in CP26/5 Annex A.
How will UK SRS regulations be enforced?
Once in force, non-compliance with UK SRS regulations becomes a breach of the relevant FCA rule — typically a DTR or UKLR breach.
The FCA's standard supervisory toolkit applies: private warnings, public censure, financial penalty, and ultimately suspension of listing in extreme cases.
CP26/5 proposed disclose-or-explain reliefs for Scope 3 emissions and scenario analysis in the first reporting cycle.
Do UK SRS regulations apply to my AIM-listed company?
No.
The proposed UK SRS regulations apply to companies in UKLR categories 6, 16 and 22 — UK Main Market commercial equity and listed fund structures.
AIM is a separate growth market regulated by the London Stock Exchange under the AIM Rules for Companies, not the FCA UKLR.
AIM companies are outside the proposed UK SRS regulations mandatory scope but may adopt UK SRS voluntarily.
Read the standards, regulator and consultation in depth
Four follow-on pages cover the underlying standards, the FCA's overall approach, the consultation timetable and the UK-specific amendments.
UK SRS legislation
The DBT primary instrument — endorsement of IFRS S1/S2 with six UK amendments.
RegulatorUK SRS FCA
FCA approach to making UK SRS enforceable under CP26/5.
ConsultationUK SRS consultation
FCA CP26/5 — the proposed regulation text under consultation.
AmendmentsUK SRS amendments
The six UK-specific amendments to IFRS S1 and S2 inside the standards.
Related guides & references
UK SRS legislation
The DBT primary instrument — endorsement of IFRS S1/S2 with six UK amendments.
UK SRS FCA
FCA approach to making UK SRS enforceable under CP26/5.
UK SRS consultation
FCA CP26/5 — the proposed regulation text under consultation.
UK SRS amendments
The six UK-specific amendments to IFRS S1 and S2 inside the standards.