UK SRS reporting — UK sustainability reporting guidance
What UK Sustainability Reporting Standards actually require in practice — disclosure architecture, the four-pillar reporting model, and the filing process. Standards published 25 February 2026; proposed mandatory via FCA CP26/5 from 1 January 2027 for in-scope UK-listed companies, with Scope 3 and broader S1 on comply-or-explain.
UK SRS reporting requires listed companies to disclose climate-related information under UK SRS S2 from 1 January 2027 (proposed), covering governance, strategy, risk management, and GHG emissions metrics. UK SRS S1 wider sustainability topics follow on comply-or-explain from 1 January 2029. Scope 3 emissions apply on comply-or-explain from 1 January 2028.
Compliance roadmap · Who must report · Scope 3 reporting guide · Full timeline
UK SRS reporting — the annual disclosure cycle
UK SRS reporting is an annual disclosure cycle published inside the annual report — same reporting entity, same reporting period as the financial statements, signed by the board.
UK SRS reporting is the annual disclosure of sustainability-related financial information under UK SRS S1 and S2. The disclosure sits inside the annual report and accounts, covers the same reporting entity and accounting period as the financial statements, and is signed by the board. For in-scope listed companies (UKLR 6, 16, 22), UK SRS reporting is proposed to become mandatory from accounting periods beginning on or after 1 January 2027under the FCA’s CP26/5 proposal.
The four-pillar architecture comes from TCFD: governance, strategy, risk management, metrics and targets. Connectivity to the financial statements is a UK SRS-specific amendment built on IFRS S1 — significant assumptions and data underlying UK SRS reporting must be consistent with those used in the financial statements.
UK SRS reporting — framework overview
Published 25 February 2026 by DBT; proposed mandatory for ~500 listed companies from 1 January 2027 via FCA CP26/5. First UK SRS reporting falls in 2028 annual reports covering the 2027 year.
Four-pillar disclosure architecture
Governance, Strategy, Risk management, Metrics and targets — six disclosure elements that anchor every UK SRS report, applied to climate under S2 and to broader sustainability topics under S1.
- Governance disclosuresPillar 1
- Board oversight arrangements, committee structures, management accountability and expert appointments — clear documentation of the sustainability governance framework.
- Strategy integrationPillar 2
- Business model impact assessment, capital allocation implications, risk and opportunity identification, and long-term strategic planning aligned with sustainability considerations.
- Risk managementPillar 3
- Risk identification methodology, assessment framework, integration with enterprise risk management, and monitoring and control processes across sustainability topics.
- Metrics and targetsPillar 4
- Performance measurement systems, target-setting methodologies, progress monitoring and third-party verification requirements for quantitative disclosures.
- Climate emissionsS2 specific
- Scope 1, 2 and 3 GHG emissions using GHG Protocol standards with calculation methodologies, data sources and verification arrangements documented.
- Scenario analysisS2 specific
- Climate resilience assessment using multiple scenarios covering physical and transition risks, with quantitative impact assessment where feasible.
Climate reporting requirements under UK SRS S2
Proposed mandatory from 1 January 2027 covering comprehensive climate-related financial disclosures — governance, strategy, risk and metrics, with GHG emissions across all three scopes and climate scenario analysis.
- Scope 1 emissionsDirect
- Direct GHG emissions from owned or controlled sources — combustion, process emissions, company vehicles, fugitive emissions. Calculated using GHG Protocol Corporate Standard methodology.
- Scope 2 emissionsIndirect — energy
- Indirect GHG emissions from purchased electricity, steam, heating and cooling. Both location-based and market-based methods required under the GHG Protocol Scope 2 Guidance.
- Scope 3 emissionsIndirect — value chain
- Value-chain emissions across all 15 GHG Protocol categories. Comply-or-explain relief for 2027, full mandatory coverage from 2028 across material categories with supplier engagement and data-collection requirements 6.
- Climate scenario analysisS2 strategy
- Required climate resilience assessment using scenarios covering physical risks (acute and chronic) and transition risks (policy, technology, market, reputation) across multiple time horizons — including a 1.5°C pathway aligned with 8 Paris Agreement goals.
- Assurance under developmentFRC interim register
- Assurance standards under development by 7 FRC with interim practitioner register expected mid-2026, providing oversight framework for verification quality and competence.
Broader sustainability reporting under S1
Proposed comply-or-explain from ~2029 covering sustainability topics beyond climate — biodiversity, water, workforce, supply chain, governance ethics, human rights — under a materiality-based approach.
- Materiality assessmentMethod
- Systematic identification and assessment of material sustainability risks and opportunities using established frameworks including 9 SASB industry standards, with consideration of enterprise-value impacts affecting cash flows, access to finance and cost of capital.
- Value-chain coverageScope
- Comprehensive assessment of sustainability impacts and dependencies across the value chain — upstream suppliers, downstream customers and end-of-life considerations — where material to the overall sustainability risk and opportunity profile.
- Enterprise-value framingUK approach
- UK SRS uses enterprise-value (financial) materiality — what affects the company — rather than double materiality. Impact materiality required only where mandated by other regulatory requirements.
Reporting process and filing requirements
UK SRS disclosures sit inside the annual reporting cycle, aligned with financial reporting deadlines. Either within the annual report & accounts, or as a separate sustainability report filed simultaneously with cross-referencing.
Assurance and verification framework
FRC interim sustainability-assurance practitioner register expected mid-2026. Initial focus on GHG emissions data and quantitative climate metrics; graduated expansion to broader sustainability disclosures as professional standards develop.
- Practitioner selectionChoosing your assurer
- Technical competence across sustainability topics, independence arrangements, quality-control procedures and coordination capability with existing financial-statement auditors. Early engagement is recommended to support system development and control design.
- Assurance scopeWhat gets assured
- Quantitative metrics including GHG emissions calculation and climate scenario analysis alongside qualitative disclosures covering governance arrangements, strategy integration and risk management processes — with appropriate verification procedures for each disclosure type.
- Limited vs reasonableLevel of assurance
- Initial sustainability assurance is typically limited (ISAE 3000 / ISAE 3410), focused on whether anything came to the practitioner’s attention indicating misstatement. Reasonable assurance — closer to a financial-statement audit — expected to follow as the market matures.
Practical implementation guidance
Project planning, change management, capability building. Governance arrangements need 6–12 months lead time; data systems need 12–18 months; technical capability builds continuously.
- Project planningFramework
- Clear milestone definition, resource allocation, timeline coordination and risk management ensuring systematic progress toward compliance readiness. Should anticipate the FCA Policy Statement (autumn 2026), technical guidance updates and market practice evolution.
- Change managementOrganisational
- Systematic stakeholder engagement across board, management and operational teams with clear communication of regulatory requirements, implementation timeline and capability development needs. Embed sustainability reporting within organisational capabilities rather than treat as standalone compliance.
- Strategic framingCommunication
- Emphasise strategic value creation through sustainability disclosure alongside regulatory compliance — improved risk management, enhanced stakeholder relationships and competitive positioning in sustainability-focused markets.
Continue across the UK SRS guidance set
Compliance enforcement, the underlying standards, readiness assessment and the implementation timeline.
UK SRS compliance guide
Listed-company compliance roadmap and FCA enforcement framework.
StandardsUK SRS S1 + S2 explainer
Full framework explainer covering both standards and the TCFD lineage.
AssessmentUK SRS readiness assessment
Capability evaluation across governance, data, methodology and assurance.
TimelineUK SRS implementation timeline
All implementation milestones from publication through 2029 wider-topic phase-in.
Related guides & references
Frequently asked questions
The questions UK company teams ask most about what UK SRS reporting actually requires and when.
What does UK SRS reporting require?
UK SRS reporting requires disclosures across four pillars — governance, strategy, risk management, and metrics and targets — covering all material sustainability risks and opportunities.
Under UK SRS S2 (climate), this includes GHG emissions across Scope 1 and 2, climate scenario analysis and transition plan disclosure.
Scope 3 and broader UK SRS S1 topics apply on a comply-or-explain basis.
When do listed companies need to start UK SRS reporting?
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 comply-or-explain from 2028.
Wider UK SRS S1 sustainability disclosures apply from 1 January 2029.
The FCA Policy Statement is expected in autumn 2026.
What goes in a UK SRS annual report?
UK SRS disclosures are included in the strategic report section of the annual report.
They must cover board governance for climate and sustainability; strategy disclosures including scenario analysis; risk management integration; and quantitative metrics including GHG emissions and climate targets.
Disclosures must be published simultaneously with the financial statements — not in a separate sustainability report.
Is Scope 3 mandatory under UK SRS?
Scope 3 is mandatory on a comply-or-explain basis.
Companies that do not disclose must identify the specific paragraphs not met, explain their reasons, and commit to a future disclosure timeline.
The FCA proposes a one-year Scope 3 deferral for the first reporting period (2027), making it required on comply-or-explain from 2028.
What is comply-or-explain under UK SRS?
Comply-or-explain means a company either makes the required disclosure or provides a structured explanation covering: which specific paragraphs are not met, the reasons for non-disclosure, and steps and a timeframe to make those disclosures in future.
It applies to Scope 3 and UK SRS S1 wider sustainability topics.
It is not a free pass — unexplained omissions would breach the FCA Listing Rules.
Primary references
Government, regulatory and standards-body sources underpinning every claim on this page.