UK SRS reporting · the disclosure checklist
UK SRS reporting: the disclosure checklist
UK SRS reporting means disclosures under UK SRS S1 and UK SRS S2 about the sustainability risks and opportunities that could affect an entity’s cash flows, access to finance or cost of capital.
This page is the checklist: each disclosure with the paragraph that asks for it, and then the statements the FCA’s final rules add for listed companies from 2027.
It is a reference to the text, not a substitute for it; every row points back to the standard.
Location
Not a separate report: the annual financial report
UK SRS disclosures are for the same reporting entity as the financial statements (UK SRS S1 ¶20) and are reported at the same time.
They may sit beside other regulatory information, provided they are clearly identifiable and not obscured (¶62).
They may be included by cross-reference to another report the entity publishes, if that report is available on the same terms and at the same time and the whole is no less understandable (¶63, B45–B47).
Placement also decides liability: the government has confirmed that UK SRS disclosure included in the strategic report falls within the section 463 protection for directors, and disclosure elsewhere does not.
The same data and assumptions as the accounts are expected (¶23), which is why UK SRS S1’s connected-information rules make this a finance-led exercise.
The FCA has kept the requirement for climate disclosures, or the explanations, to be in the annual report, and allows cross-referencing where UK SRS S1 permits it, at B45 to B47.
Source: PS26/19, response after ¶2.24
Track a draft
The checklist, as a working tool
The panel carries every row of the checklist below as a tick-list, grouped by content area, with the paragraph each one comes from.
It starts from the first-period position of a listed company that uses both reliefs, because that is the report most preparers will write first.
With the climate-first relief on, the UK SRS S1 topic rows come off the list and the statements and the S2 rows stay.
With the Scope 3 relief on, the Scope 3 row is replaced by the relief statement, because using the relief is disclosed rather than explained.
Anything still open when the report is signed off has one of two destinations: a judgement that it is not material, which ¶B25 of UK SRS S1 allows, or a named gap in the explanation the FCA’s rule asks for.
The list is not a claim that every row applies to every company: materiality decides that, and UK SRS sets no numerical threshold for it (¶B19).
The report, disclosure by disclosure
3 of 21 drafted · 18 open · Scope 3 covered by the relief statement
Still open: S1 ¶¶72–73A; S1 ¶¶60–63, B45–B47; UKLR 6.6.6R(8)(d); UKLR 6.6.6R(8)(e); S1 ¶70; S2 ¶6(b); and 12 more.
Anything still open at sign-off is either judged not material (S1 ¶B25), or named in the explanation with reasons and steps (UKLR 6.6.6R(7A)(b) or (7B)(b)).
Paragraphs from UK SRS S1 and S2 (DBT, 25 February 2026) and the statements from FCA PS26/19 Appendix 1, shown for UKLR 6; other categories have equivalent rules.
A tracking aid only — your ticks stay on this page.
Checklist · 1 of 5
Governance disclosures
| Paragraph | Disclose | Evidence usually held in |
|---|---|---|
| S1 ¶27(a) | The body or individual overseeing sustainability-related risks and opportunities, and how its terms of reference reflect it | Board or committee minutes, terms of reference |
| S1 ¶27(a) | How it ensures the skills and competencies to oversee are available, and how often it is informed | Board skills matrix, reporting calendar |
| S1 ¶27(b) | Management’s role, and the controls and procedures supporting oversight | Delegations, internal control documentation |
| S2 ¶¶5–7 | The same, for climate, including how climate is considered in strategy, major transactions and remuneration | As above, plus remuneration policy |
Checklist · 2 of 5
Strategy disclosures
| Paragraph | Disclose | Evidence usually held in |
|---|---|---|
| S1 ¶¶30–31 · S2 ¶10 | The risks and opportunities, each with its time horizon; for climate, whether physical or transition, and how the horizons are defined | Risk register, planning horizons |
| S1 ¶32 · S2 ¶13 | Effects on the business model and value chain, and where they are concentrated | Value-chain map |
| S1 ¶33 · S2 ¶14 | How strategy and decision-making respond, including any climate transition plan (S2 ¶14(a)(iv)) | Strategy papers, transition plan if any |
| S1 ¶¶34–40 · S2 ¶¶15–21 | Current and anticipated effects on financial position, performance and cash flows | Impairment, provisions, capital plan |
| S1 ¶¶41–42 · S2 ¶22 | Resilience; for climate, assessed with scenario analysis commensurate with the entity’s circumstances | Scenario analysis record |
Strategy is the longest area in both standards and the one where the resilience assessment lives; UK SRS S2 takes paragraph 22 apart.
Checklist · 3 of 5
Risk management disclosures
| Paragraph | Disclose | Evidence usually held in |
|---|---|---|
| S1 ¶44 · S2 ¶25 | The processes and inputs used to identify, assess, prioritise and monitor the risks and opportunities | Risk methodology |
| S1 ¶44 · S2 ¶25 | Whether and how those processes are integrated into overall risk management | Enterprise risk framework |
Checklist · 4 of 5
Metrics and targets, including greenhouse gases
| Paragraph | Disclose | Evidence usually held in |
|---|---|---|
| S2 ¶29(a) | Gross Scope 1, 2 and 3 emissions in tonnes CO₂e, measured under the GHG Protocol, with the approach, inputs and assumptions | Energy and fuel data, conversion factors, supplier data |
| S2 ¶29(a)(v), B30–B31 | Scope 2 location-based; contractual-instrument information where it exists; market-based optional | Meter data, energy contracts |
| S2 ¶29(a)(vi) | Scope 3 categories included; financed emissions for banks, insurers and asset managers, or a B59A explanation | Scope 3 screening |
| S2 ¶29(b)–(g) | Transition- and physical-risk exposure, opportunities, capital deployment, internal carbon price, remuneration link | Finance and HR systems |
| S1 ¶¶46–53 · S2 ¶32 | Metrics used to measure performance, including industry-based metrics the entity may use | Management information |
| S2 ¶¶33–37 | Targets: metric, period, base year, milestones, progress; planned use of carbon credits (¶36(e)) | Target methodology |
Emissions are gross; carbon credits never reduce them and appear only as planned use against a net target.
UK preparers usually apply the government’s conversion factors, and the GHG Protocol’s standards set the boundaries.
Scope 3 has a one-year relief under the FCA’s rules and its own page, UK SRS Scope 3 reporting.
Industry metrics come from the SASB Standards, which UK SRS makes optional.
Checklist · 5 of 5
The statements a listed company adds
For companies in UKLR 6, 14, 15, 16 and 22 the FCA’s rules add statements that sit alongside the disclosures.
The first two come from the standards and apply to anyone claiming compliance.
| Provision | State | Source |
|---|---|---|
| S1 ¶72 | An explicit and unreserved statement of compliance, only if every requirement is met | UK SRS S1 |
| S1 ¶73A · S2 ¶C5 | Which reliefs are used, alongside the statement of compliance | UK SRS S2 |
| UKLR 6.6.6R(7A)(b) | For S2: requirements not met, reasons, steps | PS26/19 App 1 |
| UKLR 6.6.6R(7B)(b) | For S1: risks or opportunities not disclosed, reasons, what is being done | PS26/19 App 1 |
| PS26/19 ¶3.20 | Use of a transitional relief, stated; no further explanation | PS26/19 |
| UKLR 6.6.6R(8)(c) | Where the disclosures can be found, including by cross-reference | UKLR 6.6 |
| UKLR 6.6.6R(8)(d) | Whether third-party assurance was obtained; if so, provider, scope and level, standards, where the report is | PS26/19 App 1 |
| UKLR 6.6.6R(8)(e) | Whether a climate transition plan is published, and where — or why not (UKLR 6, 16 and 22 only) | PS26/19 App 1 |
An explanation under (7A) asks for steps; the made rule text sets no timeframe for them.
What a good explanation contains is the subject of draft Technical Note 803.1, out for comment until 28 October 2026; UK SRS compliance covers the explanation in detail.
Assurance is a statement, not a requirement; sustainability assurance explains the choices, and ISSA (UK) 5000 is the standard a provider may use.
The transition-plan statement
Draft the transition-plan statement
Two separate things are asked about transition plans, and they are often run together.
UK SRS S2 ¶14(a)(iv) asks for information about any climate-related transition plan the entity has, including its key assumptions and dependencies.
UKLR 6.6.6R(8)(e) asks a listed company to say whether it has published a climate-related transition plan, in its annual financial report or elsewhere, and where — or why it has not.
The listing-rule statement applies to UKLR 6, 16 and 22 only; PS26/19 kept secondary listings and depositary receipts out of it, as CP26/5 had proposed.
Neither creates a duty to have a plan: the FCA says in PS26/19 that it is not requiring listed companies to produce transition plans, and the government’s implementation routes paper says UK SRS S2 will not require one.
For content, the FCA points to the IFRS Foundation’s guidance on transition plan disclosures, and the Transition Plan Taskforce’s disclosure framework is the fuller UK reference.
UK SRS transition plans covers what a plan contains; the panel drafts only the statement.
Listing rules · transition-plan statement · draft builder
A starting draft
The Company has published a climate-related transition plan. It is available at [web address or document].
The rule asks whether a plan is published and where, or why not.
It does not require you to have a plan, and it does not prescribe where one is published.
Rule: UKLR 6.6.6R(8)(e) and its equivalents for UKLR 16 and 22, made by the FCA on 24 September 2026 (PS26/19) and in force from 1 January 2027.
A drafting aid in plain words, not FCA model wording.
Nothing is stored or sent.
Inside the annual report
Where each piece usually sits
| Piece | Usual home | Rule behind it |
|---|---|---|
| UK SRS disclosures or the explanation | Annual financial report, often the strategic report; cross-reference allowed | UKLR 6.6.6R(7A)–(7B); UK SRS S1 ¶¶60–63, B45–B47 |
| Location, assurance and transition-plan statements | Beside the disclosures | UKLR 6.6.6R(8)(c)–(e) |
| Principal risks and uncertainties | Management report | DTR 4.1.8R |
| Responsibility statement | Annual financial report | DTR 4.1.12R |
| Companies Act climate disclosures | Strategic report | CA 2006 s.414CB |
| SECR energy and carbon report | Directors’ report (the MCR consultation proposes moving it) | SI 2018/1155; MCR ¶149 |
The FCA’s rules do not name a section of the annual report; they require the disclosures or explanations to be in the annual financial report, and let a company cross-refer where UK SRS S1 permits.
The strategic report is the natural home, because that is where the TCFD-aligned disclosures and the Companies Act climate disclosures already sit, and because the section 463 protection follows the strategic report.
The annual financial report must be public within four months of the year end (DTR 4.1.3R), so that is the clock the UK SRS disclosures run to.
The principal-risks description in the management report and the UK SRS risk disclosures describe the same business, and a reader will compare them.
PS26/19 sets no digital tagging requirement for the sustainability disclosures; the FCA says it continues to engage with the government on digital reporting.
The directors’ report may not exist for much longer: the Modernising corporate reporting consultation proposes to abolish it and let SECR disclosures sit in the first half of the annual report.
A first report, in outline
What a first-period UK SRS report says, in order
Take a calendar-year commercial company in UKLR 6 reporting for 2027, using both reliefs and without assurance.
Its statement section says that its climate-related financial disclosures are prepared in accordance with UK SRS S2, that it relies on UKLR TP 16.4R(2)(a) and UK SRS S2 ¶C4 and so does not disclose Scope 3, and that it relies on UKLR TP 16.4R(2)(b) and UK SRS S1 ¶E3 for matters beyond climate.
Because of the second relief, it does not assert compliance with UK SRS S1; it may assert compliance with UK SRS S2, with the reliefs disclosed alongside (S1 ¶73A).
It says where the disclosures are, that no third-party assurance was obtained, and whether it has published a transition plan and where, or why not.
The body then follows UK SRS S2: governance, strategy with the resilience assessment, risk management, and metrics and targets with gross Scope 1 and location-based Scope 2.
No comparatives are needed for the first period (UKLR TP 16.6G(2)).
If any S2 requirement is not met, the statement becomes an explanation: the requirements not met, the reasons and the steps, under UKLR 6.6.6R(7A)(b).
The same company in its 2028 report has lost the Scope 3 relief: Scope 3 is disclosed or explained, and Scope 3 comparatives are needed only from the period after the first in which Scope 3 is disclosed.
This outline is our reading of the made rules; the FCA’s draft Technical Note 803.1, open until 28 October 2026, is the guidance to check it against, and Primary Market Bulletin 66 sets out the FCA’s preparation steps.
Timing
When each part applies
The government’s guidance puts voluntary reporting open to anyone now.
For listed companies PS26/19 ¶3.12 applies the rules to accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
¶3.14 gives one year’s Scope 3 relief and two years’ relief for UK SRS S1 beyond climate, and ¶3.20 lets a company using them simply say so.
CP26/5 had proposed a mandatory UK SRS S2; the final rules put every disclosure on comply or explain, and the consultation is tracked on the CP26/5 tracker.
Every date, with its instrument, is on the dated UK SRS register, and a single company’s first period on the UK SRS deadline.
- NowVoluntary
Any entity may report against UK SRS.
- 1 Jan 2027FCA rules in force
Periods beginning on or after: comply or explain.
Both reliefs available.
- 2028First reports
Periods beginning from 1 January 2028 carry no Scope 3 relief.
- 1 Jan 2029Reliefs gone
Every disclosure comply or explain.
Official sources
UK SRS reporting guidance from the owners
The standards and their application guidance are on the government’s UK SRS publication page, and its guidance page explains their status.
The FRC answers common questions in its sustainability reporting FAQs.
The FCA’s rules are in PS26/19, with the listing categories defined in the UK Listing Rules sourcebook.
The international originals are on the IFRS Sustainability Standards Navigator, and the four-area structure goes back to the TCFD, disbanded in 2023.
How the UK text differs from IFRS is on UK SRS amendments, and how it came to be on the UK SRS consultation.
Next
From the checklist to the work
Whether you report at all is settled on who is in scope and UK SRS thresholds.
The two standards together are on UK SRS S1 and S2, and the plan of work on UK SRS compliance and the readiness assessment.
Groups also reporting in the EU should read CSRD and UK SRS; the whole site starts at the UK SRS reference homepage.
Questions and corrections to hello@uksrs.org.uk; see the privacy policy and terms of service.
Frequently asked
UK SRS reporting, answered
What does UK SRS reporting require?
Disclosures about the sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s cash flows, access to finance or cost of capital, organised as governance, strategy, risk management, and metrics and targets under UK SRS S1, with the climate specifics of UK SRS S2: greenhouse gas emissions, scenario analysis, transition plans and climate metrics.
Where do UK SRS disclosures go?
For a listed company under the FCA’s rules, in the annual financial report, with cross-referencing permitted where UK SRS S1 allows it at B45 to B47.
The company also states where the disclosures can be found.
Disclosures placed in the strategic report fall within the section 463 safe harbour for directors.
When does UK SRS reporting start?
Voluntary reporting can start now.
Under the FCA’s final rules, listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS or explain for accounting periods beginning on or after 1 January 2027, with first reports in 2028.
What if a company cannot make a UK SRS disclosure?
Under the FCA’s rules it explains.
For UK SRS S2 it gives a summary of the requirements not met, the reasons and the steps it is taking or plans to take.
For UK SRS S1 it names the risks or opportunities it has identified but not disclosed, the reasons, and what it is doing about them.
Is Scope 3 required in a UK SRS report?
UK SRS S2 requires it.
Under the FCA’s rules a listed company may use a one-year relief, stating that it does so without further explanation.
After that Scope 3 is comply or explain, like every other disclosure.
Does a UK SRS report need assurance?
No. A listed company states whether it obtained third-party assurance and, if so, the provider, which disclosures and at what level, the standards used and where the report can be found.
Obtaining assurance is not required.
What statement of compliance does a UK SRS report make?
Under UK SRS S1 paragraph 72, an entity whose disclosures meet all the requirements makes an explicit and unreserved statement of compliance, and may not describe them as complying unless they do.
An entity using reliefs discloses them alongside the statement; one using the climate-only relief may not assert compliance with UK SRS S1.
What goes in a UK SRS annual report?
For a listed company: the UK SRS S2 climate disclosures or an explanation of what is missing; the UK SRS S1 disclosures, an explanation, a statement that no other risks were identified, or a statement that the climate-first relief is used; where the disclosures can be found; whether assurance was obtained; and, for UKLR 6, 16 and 22, whether a transition plan is published.
What is comply or explain under UK SRS?
It is the basis of the FCA’s rules in PS26/19.
A listed company in scope either makes the disclosures in accordance with UK SRS or states what it has not disclosed, why, and the steps it is taking or plans to take.
For UK SRS S2 the explanation works by requirement; for UK SRS S1 it works by risk or opportunity.
How many companies are affected by UK SRS reporting requirements?
PS26/19 gives no total.
The consultation, CP26/5, estimated that around 600 listed companies would be affected; that was the consultation’s estimate.
PS26/19 says the 89 issuers in the secondary-listing and depositary-receipt categories are now under the same requirements as domestic listed issuers.
Are there any exemptions from UK SRS reporting?
There is no size exemption.
Six listing categories are outside the FCA’s rules, including closed-ended funds, open-ended investment companies, shell companies and debt securities.
Within scope there are time-limited reliefs for Scope 3 and for UK SRS S1 beyond climate, and UK SRS S1 paragraph B25 lets an entity leave out information that is not material.
Do UK SRS disclosures have to be in the strategic report?
The FCA’s rules require them, or the explanations, in the annual financial report and allow cross-reference where UK SRS S1 permits it.
They do not name a section.
The government has confirmed that UK SRS disclosure in the strategic report falls within the section 463 protection for directors.
Must UK SRS disclosures be digitally tagged?
No. PS26/19 says the FCA is not proposing requirements for issuers to tag their sustainability disclosures digitally.
The existing iXBRL duty in DTR 4.1.18R applies to IFRS consolidated financial statements.
Is there official UK SRS reporting guidance?
The standards carry their own application guidance in their appendices.
The government publishes a UK SRS guidance page, the FRC publishes FAQs, and the FCA is consulting until 28 October 2026 on draft Technical Note 803.1 on how to explain under its rules. That note is proposed guidance, not final.
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 and TradeUK SRS S1 (PDF) — ¶¶3, 18, 20–24, 25–53, 62–63, 72–73A, B45–B47
The general requirements every item in the checklist is keyed to.
- Department for Business and TradeUK SRS S2 (PDF) — ¶¶5–37, B30–B31, B59A, B70–B71, Appendix C
The climate disclosures.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
The government’s own guidance page; voluntary use by any entity.
- Department for Business and TradeGovernment response on UK SRS — Chapter 3
The s.463 safe harbour applies to UK SRS disclosure placed in the strategic report.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
The final rules, 30 September 2026.
- Financial Conduct AuthorityPS26/19 (PDF), ¶¶3.12, 3.14, 3.20 and Appendix 1 (UKLR 6.6.6R(7A), (7B), (8)(c)–(e))
What a listed company must disclose or state, and when.
- FCA HandbookUK Listing Rules, UKLR 6.6
Where the new limbs sit in the annual financial report rules.
- GHG ProtocolCorporate Accounting and Reporting Standard
The measurement basis for Scope 1, 2 and 3 under UK SRS S2 ¶29(a).
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The Scope 3 categories.
- GOV.UK (DESNZ)Government conversion factors for company reporting
The factors UK preparers usually apply to activity data.
- FCA HandbookDTR 4.1.3R, 4.1.8R and 4.1.12R
The four-month deadline, the management report and the responsibility statement.
- Financial Conduct AuthorityDraft Technical Note TN 803.1 (September 2026, for consultation)
Proposed guidance on explanations; comments to 28 October 2026.
- IFRS FoundationGuidance on transition plan disclosures under IFRS S2 (PDF)
The material the FCA points transition-plan preparers to.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document, ¶149
The proposal to remove the directors’ report and relocate SECR.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
The assurance standard a provider may use; voluntary.
- legislation.gov.ukCompanies Act 2006, section 414CB
The climate duty in the strategic report, which UK SRS S2 can discharge.