UK SRS requirements, pillar by pillar
UK SRS requirements come down to four pillars, applied first to climate and later to everything else material.
Governance, strategy, risk management, metrics and targets.
For in-scope listed companies, UK SRS S2 climate disclosure is proposed to apply for accounting periods beginning on or after 1 January 2027.
Scope 3 follows on comply-or-explain, and UK SRS S1’s wider sustainability topics after that.
It is not a separate sustainability report
This is the first thing to get straight about the UK SRS requirements.
The disclosures belong inside the annual report, published at the same time as the financial statements.
And they must connect to those statements: the significant assumptions and data behind the sustainability disclosures have to be consistent with the ones used in the accounts.
That connectivity requirement is a UK-specific amendment built on IFRS S1, and it is the reason a UK SRS programme is a finance-function project rather than a communications one.
The four UK SRS requirements pillars
Every UK SRS disclosure hangs off one of four pillars.
Each tab below sets out what the standard asks for, what that means in practice, and the evidence a reader or an assurer will look for.
Who the UK SRS requirements bind
Scope is set by UK Listing Rules category, not by company size.
Three categories would carry the full obligation, two would owe only a transparency statement, and several sit outside the proposals entirely.
What actually goes in the report
A working checklist, grouped the way the report itself is structured.
Scope 1, Scope 2 and the fifteen Scope 3 categories
The metrics pillar is where most of the measurement effort goes.
Two of the three scopes carry no relief at all, and the third carries a relief that is widely misdescribed.
When each requirement bites
Three dates, two of them softened by comply-or-explain.
And comply-or-explain is a good deal more demanding than it sounds.
Assurance over UK SRS disclosures
The UK assurance standard already exists, which surprises people who last looked in 2025.
Six questions to place yourself
Tap the ones that are already true.
The result is a band and a next step, not a score — there is no scored standard to measure yourself against.
UK SRS requirements — framework overview
The UK SRS requirements are set by two standards: UK SRS S1 for sustainability-related financial disclosure generally, and UK SRS S2 for climate specifically.
Both were published by the Department for Business and Trade on 25 February 2026 and are available for voluntary use by any UK entity (DBT).
They are the UK’s endorsement of IFRS S1 and IFRS S2, issued by the ISSB, with six UK-specific amendments.
What turns them into an obligation for listed companies is the FCA’s proposal in CP26/5, on which a policy statement is expected in autumn 2026.
Until that lands, every mandatory date is a proposal — see the UK SRS consultation record and the CP26/5 tracker.
For the standards themselves, start with what UK SRS S1 and S2 are; to test whether they reach you, use the scope checker or read who is in scope and the thresholds guide.
UK SRS requirements — what companies must disclose
The four-pillar architecture comes from TCFD by way of IFRS S1: governance, strategy, risk management, metrics and targets.
Under the governance pillar, a company discloses the processes, controls and procedures used to monitor and oversee sustainability-related risks and opportunities.
Under strategy, it discloses the effects of those risks and opportunities on the business model, strategy, cash flows, access to finance and cost of capital, across short, medium and long horizons.
Under risk management, it discloses the processes used to identify, assess, prioritise and monitor them — and, critically, whether those processes are integrated into overall risk management.
Under metrics and targets, it discloses the measures used to manage performance, which under S2 includes gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions calculated on a GHG Protocol basis using the annual DESNZ conversion factors.
Connectivity to the financial statements is a UK SRS-specific amendment built on IFRS S1: significant assumptions and data underlying the sustainability disclosures must be consistent with those used in the accounts.
Industry-based metrics referencing the SASB standards may be applied but are not required — one of the six UK amendments.
UK SRS reporting guidance — the official sources
The standards and the government’s own guidance sit on GOV.UK.
The FCA’s proposed rules, the transitional reliefs and the scope analysis are in CP26/5, with the listing categories defined in the UK Listing Rules sourcebook.
The FRC’s sustainability reporting FAQ covers assurance, ISSA (UK) 5000 and the interim practitioner register.
Emissions methodology sits with the GHG Protocol suite and the Scope 3 Standard in particular.
Climate scenario references commonly used in UK disclosures include the IPCC AR6 pathways and the IEA Net Zero by 2050 scenario.
The TCFD recommendations remain the origin of the four-pillar structure, though the task force itself has been disbanded and its monitoring role passed to the ISSB.
Climate reporting requirements under UK SRS S2
S2 applies the four pillars to climate, and it is the standard that bites first.
Governance disclosures identify the body with oversight of climate-related risks and how often it considers them.
Strategy disclosures require climate scenario analysis — the resilience of the strategy tested against more than one plausible future, not merely asserted.
Where a transition plan exists, it is disclosed, including the decarbonisation pathway and the capital allocated to it.
Risk-management disclosures explain how climate risk is identified and assessed, and whether that sits inside the enterprise risk process or beside it.
Metrics disclosures carry gross Scope 1 and Scope 2 emissions with the methodology stated, Scope 3 subject to the transitional relief, climate targets with their base years, and performance against them.
Deep dives: UK SRS S2 in detail and Scope 3 under UK SRS.
Broader sustainability reporting under UK SRS S1
S1 is the umbrella standard: the same four pillars, applied to every sustainability-related risk and opportunity that could reasonably be expected to affect the company’s prospects.
It is not a fixed topic list.
The company identifies what is material to it, which is why S1 work usually begins with a materiality process rather than a data-collection exercise.
Under the FCA’s proposals, S1’s wider topics arrive on a comply-or-explain basis for accounting periods beginning on or after 1 January 2029, after a two-year relief.
Climate-first phasing is deliberate — one of the six UK amendments — so preparers build one capability at a time.
See UK SRS S1 in detail, and CSRD vs UK SRS if your group also reports in the EU, where double materiality and a far wider topic scope apply.
Reporting process and filing requirements
UK SRS disclosures form part of the annual report, published with the financial statements rather than separately afterwards.
That single publication date is the practical constraint on the whole programme, because sustainability data has to be ready on the same timetable as the accounts.
Working back from it: data collection and methodology decisions in the reporting year, consolidation and review alongside the year-end close, and drafting to the standard’s own paragraph structure so that comply-or-explain positions can be stated precisely.
Where a disclosure is not made, the explanation must identify the specific paragraphs not met, give reasons, and set out steps and a timeframe.
For the dates in one place see the implementation timeline and the UK SRS deadline, and for the wider compliance framing the compliance guide.
Assurance and verification framework
The UK sustainability assurance standard is ISSA (UK) 5000, published by the FRC on 12 November 2025.
It is effective for assurance engagements covering periods beginning on or after 15 December 2026 (FRC).
CP26/5 does not impose assurance on UK SRS disclosures at the outset, though the FCA sought views on it.
The FRC’s interim register of sustainability assurance practitioners was targeted for mid-2026; as at 28 July 2026 it has not been confirmed operational, and it is voluntary in any case rather than a precondition for performing engagements.
Limited assurance gives a negative conclusion based on enquiry and analytical procedures; reasonable assurance gives a positive opinion and requires substantially deeper testing.
Limited assurance is the realistic starting point for a first cycle, and initial expectations focus on GHG data and quantitative climate metrics.
The deep dive is UK SRS sustainability assurance.
Practical implementation guidance
The documentation pillars come first because they need no new measurement: governance oversight, and the integration of climate risk into the existing enterprise risk process.
Next is a complete Scope 1 and Scope 2 inventory for a full reporting year, with the methodology and emission factors written down as the data is collected rather than reconstructed later.
Scope 3 begins with a materiality screen across the fifteen categories, so that effort concentrates where the emissions actually are.
Scenario analysis and the transition plan take the longest lead time and usually need external input, so they should start before the first mandatory year rather than during it.
Assurance readiness is a by-product of doing the above properly: a traceable evidence chain from source document to disclosed figure.
To benchmark where you are, use the readiness assessment.
UK SRS requirements — frequently asked questions
UK SRS reporting requires companies to disclose sustainability-related financial information across four pillars: governance, strategy, risk management, and metrics and targets. Under UK SRS S2 (climate), this includes GHG emissions (Scope 1, 2, and Scope 3 on comply-or-explain), climate scenario analysis, and transition planning. UK SRS S1 (wider sustainability) extends to all material sustainability risks beyond climate.
The FCA's proposal under CP26/5 requires in-scope UK-listed companies to begin UK SRS S2 climate disclosures for accounting periods beginning on or after 1 January 2027. Scope 3 emissions apply on a comply-or-explain basis from 2028. Wider UK SRS S1 sustainability disclosures apply on comply-or-explain from 1 January 2029. All of these dates remain proposals until the FCA publishes its policy statement, expected autumn 2026.
UK SRS disclosures are included within the strategic report of the annual report. They must cover: governance arrangements for climate and sustainability oversight; strategy disclosures including scenario analysis and resilience; risk management integration; and quantitative metrics including GHG emissions, climate-related targets, and climate investment data. The disclosures must be published simultaneously with the financial statements.
Scope 3 emissions are subject to comply-or-explain treatment. Companies that do not disclose Scope 3 must explain why, identify the specific paragraphs not met, and set out steps and a timeframe to make those disclosures in future. Two things are often conflated: the FCA proposes a one-year relief for listed issuers, making Scope 3 comply-or-explain from accounting periods beginning on or after 1 January 2028 — while UK SRS itself sets no time limit on the relief, because the government removed the time references in the final standards.
Comply-or-explain means a company either makes the required disclosure, or explains why it has not. For UK SRS, comply-or-explain applies to Scope 3 emissions and wider sustainability disclosures under UK SRS S1. An explanation must identify specific paragraphs not met, give reasons for non-compliance, and commit to a future disclosure timeline — it is not a free pass to omit disclosures without accountability.
On the FCA's own analysis in CP26/5, around 600 listed companies are affected by the proposals, of which approximately 515 would be required to comply. They sit across five UK Listing Rule categories (UKLR 6, 14, 15, 16 and 22), with categories 14 and 15 owing only a transparency statement rather than full UK SRS reporting. Scope is determined by listing category rather than company size, and foreign companies with UK listings are treated the same as domestic entities. Large private companies are not yet in scope.
Exemptions are limited. The main reliefs are transitional: Scope 3 emissions benefit from a one-year comply-or-explain relief under the FCA's proposals (effectively 2028), and wider UK SRS S1 sustainability disclosures follow a two-year relief (effectively 2029). Companies in UKLR categories 14 and 15 — secondary listings and depositary receipts — would not report against UK SRS at all, but would state which standards apply in their primary listing location. AIM companies sit outside the proposed mandatory scope because AIM is regulated by the London Stock Exchange, not the FCA Listing Rules, though they may adopt UK SRS voluntarily.
Primary references
Every obligation and date on this page is cited to one of these.
Continue across the UK SRS guidance set
What is UK SRS
The two standards, their scope, and how they differ from TCFD.
ClimateUK SRS S2
The climate standard in detail, pillar by pillar.
WiderUK SRS S1
General requirements for sustainability-related disclosure.
Scope 3Scope 3 under UK SRS
All fifteen categories and the transitional relief.
AssuranceSustainability assurance
ISSA (UK) 5000, limited versus reasonable assurance.
PlanningReadiness assessment
Capability evaluation across the core reporting domains.
Also: the compliance guide · thresholds · who is in scope · the deadline · scope checker · CSRD vs UK SRS · the consultation record.
Check your scope, or read the standards
Both take a couple of minutes and neither sends anything anywhere.