UK SRS reporting requirements in the UK: who reports, what, where and when

UK SRS S1 and S2 are voluntary standards, published on 25 February 2026, and they create no duty by themselves.

The requirement comes from the FCA’s final rules in PS26/19: companies listed in UKLR 6, 14, 15, 16 and 22 must, for accounting periods beginning on or after 1 January 2027, either disclose in accordance with UK SRS S2 and S1 or explain what they have not disclosed, why, and what they are doing about it.

They must also say where the disclosures are, whether assurance was obtained, and whether they have published a transition plan.

No entity is required to report against UK SRS by the standards themselves; GOV.UK says they are available for voluntary use by any entity.

For listed companies in the five UK Listing Rules categories, PS26/19 sets a comply-or-explain obligation, not a duty to comply in full.

Everyone else may use the standards voluntarily.

Companies with listed equity shares in the commercial companies category (UKLR 6), international commercial companies with a secondary listing (UKLR 14), issuers of depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16) and the transition category (UKLR 22).

The investment-fund categories (UKLR 11 and 12), shell companies (UKLR 13) and the categories for debt, securitised derivatives and other miscellaneous securities (UKLR 17, 18 and 19) are excluded.

Not under PS26/19, because AIM securities are not admitted to the Official List and the rules sit in the Official List categories.

An AIM company with more than 500 employees is, however, inside the Companies Act climate-related financial disclosure regime under section 414CA(1)(e), and may use UK SRS S2 to meet it.

The FCA’s rules come into force on 1 January 2027 and apply to accounting periods beginning on or after that date.

For a calendar-year company the first period runs through 2027, and the FCA expects first reporting in 2028.

Under UKLR 6.6.6R(7A)(b) it must set out a summary of the UK SRS S2 requirements it has not met, the reasons for not making those disclosures, and any steps it is taking or plans to take to make them in future.

The draft Technical Note 803.1 proposes that the explanation can be short and proportionate but should not omit material information, and that no timeframe is required.

For S1 the explanation works at the level of risks and opportunities, not requirements.

Under UKLR 6.6.6R(7B) a company that has identified sustainability-related risks or opportunities but not disclosed them must name those risks or opportunities, give its reasons, and set out its steps; if it has identified none, it says so under (7B)(c).

For accounting periods beginning in 2027, a company need not disclose Scope 3 emissions and may report on climate only, under UKLR TP 16.4R(2) for commercial companies, relying on UK SRS S2 ¶C4 and UK SRS S1 ¶E3.

The Scope 3 relief lasts one year and the climate-first relief two years from initial application, and the company must state in its annual financial report that it is using them.

No. PS26/19 says use of the transitional reliefs does not engage the explain rules, so a company states that it is relying on the relief and needs give no further explanation during the relief period.

In the annual financial report, with cross-referencing to another report allowed where UK SRS S1 ¶¶B45–B47 are met.

UK SRS S1 ¶64 also requires the disclosures to be reported at the same time as, and for the same period as, the related financial statements.

No. UKLR 6.6.6R(8)(d) requires a statement of whether third-party assurance was obtained and, if so, the provider, scope, level, standards and where the report is; the FCA says it will not require an explanation where assurance is not sought.

The government said in September 2026 that it has no plans at this stage to require assurance over UK SRS reporting.

No. The FCA says it is not requiring listed companies to produce transition plans, and UK SRS S2 requires disclosure only about a plan a company already has.

UKLR 6.6.6R(8)(e) requires a statement of whether a climate-related transition plan has been published and where, or why not.

Yes.

For periods beginning before 1 January 2027 a listed company can either keep to the TCFD-aligned rules in force before that date or apply UK SRS voluntarily under UKLR TP 16.3R, and early adopters may use the same transitional reliefs.

Not yet.

The Companies Act duty in section 414CB(2A) remains, but the government confirmed in February 2026 that UK SRS S2 is a national reporting framework for section 414CB(6), so a company can rely on its UK SRS S2 disclosures instead of duplicating them.

The future of the Companies Act duty is under a post-implementation review due by spring 2027.

Nothing proposes it.

The Modernising corporate reporting consultation, open until 30 November 2026, says only that the government will consider how UK SRS should be reflected in the Companies Act 2006, taking into account the consultation feedback and the review of the climate disclosure regulations.

The FCA monitors and enforces its listing rules, with the FRC, as PS26/19 says.

A breach of the listing rules can lead to a penalty on the issuer or a director knowingly concerned, or a public censure, under section 91 of the Financial Services and Markets Act 2000.

Yes, for periods beginning on or after 1 January 2027.

PS26/19 says the new rules replace the existing TCFD-aligned disclosures, and the TCFD itself was disbanded in 2023.