Listed in UKLR 6, 14, 15, 16 or 22
Comply or explain against UK SRS S1 and S2 for periods beginning on or after 1 January 2027.
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UK SRS S1 · Reporting requirements
The UK SRS S1 reporting requirements are the general requirements for disclosing sustainability-related financial information, published by the Department for Business and Trade on 25 February 2026 as a voluntary standard.
For companies listed in UKLR 6, 14, 15, 16 and 22, the FCA’s final rules in PS26/19 apply them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
This page sets out each duty with its paragraph, the scope test, the timetable and how the S1 explanation works.
In brief
UK SRS S1 is the general standard: it sets out what a sustainability-related financial disclosure must contain and how it is presented, and UK SRS S2 then applies those rules to climate.
Its test is financial: UK SRS S1 ¶3 reaches every sustainability-related risk and opportunity that could reasonably be expected to affect the entity’s cash flows, its access to finance or cost of capital over the short, medium or long term.
The standard is available for voluntary use by any entity, and it contains no effective date.
The obligation to report against it comes from elsewhere, and today only the FCA’s listing rules create one.
The paragraph-level reading of the standard is on the UK SRS S1 guide; this page is about who must report, what, where and when.
In one table
The duties in the order a preparer meets them, each with its paragraph in UK SRS S1 or the FCA rule.
| Requirement | What it asks | Provision |
|---|---|---|
| Identify risks and opportunities | All sustainability-related risks and opportunities that could reasonably be expected to affect cash flows, access to finance or cost of capital | S1 ¶3, ¶¶B6–B12 |
| Apply materiality | Disclose material information only; no thresholds; reassess at each reporting date | S1 ¶¶17–19, B19, B25, B28 |
| Governance | The body or individual with oversight, how it is informed and skilled, and management’s role | S1 ¶¶26–27 |
| Strategy | Risks and opportunities, business model and value chain, strategy, financial effects, resilience | S1 ¶¶28–42 |
| Risk management | Processes to identify, assess, prioritise and monitor, and their integration | S1 ¶¶43–44 |
| Metrics and targets | Metrics required by a standard, entity-specific metrics, targets and progress | S1 ¶¶45–53 |
| Connect to the accounts | Same reporting entity, consistent data and assumptions, same presentation currency | S1 ¶¶20–24 |
| Location | Part of the general purpose financial reports; cross-reference on conditions | S1 ¶¶60–63, B45–B47 |
| Timing | Same time and same period as the financial statements | S1 ¶64 |
| Comparatives | Preceding period for all amounts; none in the first year | S1 ¶70, ¶E1 |
| Statement of compliance | Explicit and unreserved, only if every requirement is met; not available to a climate-only reporter | S1 ¶¶72–73A |
| Listed companies: disclose or explain | S1 disclosures, or the risks not disclosed on, why, and the steps planned | UKLR 6.6.6R(7B) |
| Listed companies: location, assurance, transition plan | Say where the disclosures are, whether assurance was obtained, and whether a transition plan is published | UKLR 6.6.6R(8)(c)–(e) |
The climate counterpart of this table is on the UK SRS S2 reporting requirements page, and both standards together are on the UK SRS reporting requirements page.
Who reports
The scope test is a listing category, not a size threshold.
PS26/19 ¶3.6 names five: equity shares of commercial companies (UKLR 6), international commercial companies with a secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16) and the transition category (UKLR 22).
Paragraph 3.7 leaves out closed-ended investment funds and open-ended investment companies (UKLR 11 and 12), shell companies (UKLR 13) and UKLR 17, 18 and 19.
The FCA rejected a size threshold in PS26/19, saying the impact of climate risk depends on a company’s business model and industry, not its size.
AIM companies are outside these rules because AIM securities are not admitted to the Official List, although those with more than 500 employees are within the Companies Act climate disclosure regime covered on the CFD reporting requirements page.
The FCA gives no count of in-scope companies in PS26/19; the scope tests are worked through on the who is in scope page.
Comply or explain against UK SRS S1 and S2 for periods beginning on or after 1 January 2027.
FCA PS26/19 ¶3.6May apply UK SRS S1 voluntarily, with its reliefs available without a time limit.
GOV.UK guidance; FRC FAQsNo duty to report against UK SRS; the government is consulting on the wider framework.
Open to 30 November 2026What to disclose
UK SRS S1 ¶25 requires disclosures about governance, strategy, risk management, and metrics and targets, the same four areas the TCFD used.
Governance under ¶27 asks for the body or individual responsible for oversight, how responsibilities sit in terms of reference, how skills are assured, how and how often the body is informed, how trade-offs are considered, and whether related metrics feed remuneration.
Strategy under ¶29 runs in five limbs: the risks and opportunities, the business model and value chain, strategy and decision-making, financial position, performance and cash flows, and resilience.
Risk management under ¶44 covers the processes and related policies used to identify, assess, prioritise and monitor sustainability-related risks and opportunities, and how they are integrated into overall risk management.
Metrics and targets cover the metrics required by an applicable standard, metrics the entity uses itself, and targets with progress towards them.
Who oversees sustainability-related risks and opportunities, and how management supports them.
The risks and opportunities, their effects on the business, the financial statements and resilience.
How they are identified, assessed, prioritised and monitored, and integrated.
Performance, metrics and progress towards any targets set or required by law.
What counts
UK SRS S1 ¶17 requires material information about the sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s prospects.
Paragraph 18 defines material as information whose omission, misstatement or obscuring could reasonably be expected to influence decisions that primary users of general purpose financial reports make on the basis of those reports.
Primary users are existing and potential investors, lenders and other creditors, so this is a single, financial materiality test.
The standard specifies no materiality thresholds (¶B19), and information that is not material need not be disclosed even where a standard lists it as a minimum requirement (¶B25).
Judgements are reassessed at each reporting date (¶B28), and an entity need not undertake an exhaustive search for risks and opportunities (¶B10).
The European standards apply double materiality instead, which is the main structural difference set out on the CSRD and UK SRS comparison.
Where and when
| Question | UK SRS S1 | FCA rules for listed companies |
|---|---|---|
| Where? | Part of the general purpose financial reports (¶60), for example the strategic report (¶61) | In the annual financial report, with cross-reference permitted under ¶¶B45–B47 (UKLR 6.6.6R(8)(c)) |
| Cross-reference? | Allowed if the other report is available on the same terms and at the same time (¶63, ¶B45) | Same; the company states where the disclosures can be found |
| When? | At the same time as the related financial statements, same period (¶64) | Annual financial report within four months of year end (DTR 4.1.3R) |
| Interim reporting? | Not mandated by the standard (¶69) | No interim UK SRS requirement in PS26/19 |
| Comparatives? | Preceding period for all amounts (¶70); none in the first year (¶E1) | None for the first period of disclosure (UKLR TP 16.6G(2)) |
| Same entity? | Same reporting entity as the financial statements (¶20); consistent data and assumptions (¶23) | No change |
Paragraph 64 ties the disclosures to the financial statements, so a standalone sustainability report published later in the year does not meet it.
The government confirmed that UK SRS disclosure included in the strategic report is covered by the directors’ liability protection in section 463 of the Companies Act 2006, and that protection follows location.
The relief
UK SRS S1 ¶E2 requires S1 and S2 to be applied at the same time, and ¶E3 is the exception: an entity may disclose only climate-related risks and opportunities, applying S1 only insofar as it relates to climate.
The standard gives the relief no time limit, because the government removed the time references and left their availability to law or regulation, as its letter to the FCA of 5 January 2026 announced.
The FRC’s FAQs say a voluntary reporter can therefore use the relief indefinitely.
For listed companies the FCA rules set the clock: the relief is available for periods beginning before 1 January 2029 under UKLR TP 16, and the company must state in its annual financial report that it is relying on the transitional provision and on ¶E3.
Using the relief does not engage the FCA’s explain rules during the relief period, PS26/19 ¶3.20 says.
The price is in ¶73A: an entity using ¶E3 is not permitted to assert compliance with UK SRS S1, though it may still assert compliance with UK SRS S2 if it discloses the relief alongside the statement.
When the relief stops, ¶E4(b) defers non-climate comparatives until the second annual reporting period in which the entity no longer uses it.
UK versus IFRS
Annex A of the government’s consultation response is the complete list, and it says that where a requirement is not in the table there is no difference.
| IFRS S1 | UK SRS S1 | Effect |
|---|---|---|
| ¶¶55(a), 58(a): entity “shall” refer to SASB Standards | ¶¶55(a), 58(a): “may” | SASB reference becomes optional |
| None | ¶73A and ¶73B (new) | Climate-only reporters cannot assert S1 compliance; application subject to UK law or FCA rules |
| ¶¶E1–E2: effective 1 January 2024 | ¶E2: no effective date; S1 and S2 applied together | Application set by law or regulation |
| ¶E3: no first-year comparatives | ¶E1 | Retained |
| ¶E4: first-year later publication | Removed | Disclosures always due with the financial statements |
| ¶E5: climate-first relief, first year only | ¶E3 and ¶E5 | No time limit in the standard; availability set by law or regulation |
| ¶E6: comparatives after climate-first | ¶E4 | Non-climate comparatives deferred to the second period after the relief ends |
The government consulted in June 2025 on six proposed amendments to IFRS S1 and S2; the final differences are those in Annex A, which carries no count, and the history is on the UK SRS amendments page.
A new or amended ISSB standard does not apply in the UK until it has been through UK endorsement, as the FRC explains, and the international picture is on the ISSB reporting requirements page.
Listed companies
The S1 limb is UKLR 6.6.6R(7B), made on 24 September 2026, with parallel limbs for UKLR 14, 15, 16 and 22.
It requires sustainability-related financial disclosures in accordance with UK SRS S1, excluding the climate disclosures covered by the S2 limb in (7A).
Where the company has identified risks or opportunities of the kind in S1 ¶3 but not disclosed on them, it must state which ones, the reasons, and any steps it is taking or plans to take.
That is the structural difference from S2: the S2 explanation summarises unmet disclosure requirements, while the S1 explanation names undisclosed risks and opportunities.
UKLR 6.6.6A G reminds a company making climate disclosures to apply S1 insofar as it relates to climate, listing parts that may be relevant, including ¶¶10–24, ¶¶31, 49, 50, 52 and 53 and ¶¶60–71; it is guidance, not a rule.
The FCA’s draft Technical Note 803.1 proposes that an explanation can be short and proportionate but should not omit material information, and that no timeframe is required; it is out for comment until 28 October 2026.
An explanation is not a statement of compliance: a company that explains cannot make an explicit and unreserved statement of compliance with UK SRS S1, the draft says, and the FCA rules page follows the drafting in full.
Name the S1 ¶3 risks or opportunities identified but not disclosed on.
Give the reasons for not making those disclosures.
Describe any steps being taken or planned to make them in future.
Say so: (7B)(c) requires a statement where no S1 risks or opportunities were identified.
Dates
Voluntary for any entity; no effective date.
UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026.
Comply or explain across UK SRS for five listing categories.
Proposed guidance on explanations, consulted on in PMB 66.
Periods beginning on or after this date; climate-first relief available with a statement.
In the annual financial report, within four months of year end.
Every S1 risk and opportunity on comply or explain.
Sources: PS26/19 ¶¶3.12, 3.14, 3.24 and UKLR TP 16 · PMB 66.
A company with a period beginning before 1 January 2027 may keep the TCFD-aligned rules or adopt UK SRS early with the same reliefs, under UKLR TP 16.3R; the switch is covered on the TCFD to UK SRS migration page.
Checks
No rule requires assurance over UK SRS S1 disclosures.
UKLR 6.6.6R(8)(d) requires a statement of whether third-party assurance was obtained and, if so, the provider, what was assured, the level, the standards used and where the report is.
The FCA said it is not requiring explanations where assurance was not sought, and that it will keep the case for mandating assurance under review; the options are on the sustainability assurance page.
The FCA says it will monitor and enforce its UK SRS rules along with the FRC, and will publish its supervisory approach in the second half of 2027.
A breach of the listing rules can lead to a penalty on the issuer, a penalty on a director knowingly concerned, or a public censure, under section 91 of the Financial Services and Markets Act 2000.
Myths
It does not require every listed paragraph to be disclosed: immaterial information may be left out (¶B25).
It does not require a percentage materiality threshold, a double materiality assessment or interim reporting.
It does not let commercial sensitivity cover a risk: the exemption in ¶B34 is for opportunities only, and ¶B37 forbids its use for a risk or for broad non-disclosure.
It does not require a transition plan; the FCA asks only whether one is published and where, as the transition plan reporting requirements page explains.
“UK SRS S1 is mandatory for listed companies from 2027” — the final rules are comply or explain.
“The climate-first relief lasts two years under the standard” — the standard has no time limit; two years is the FCA’s rule for listed companies.
“UK SRS S1 is effective from 1 January 2024” — that is IFRS S1; UK SRS S1 has no effective date.
Other regimes
The Companies Act non-financial and sustainability information statement under section 414CB continues to apply, and UK SRS S2 is a national reporting framework for its climate limb.
SECR energy and carbon reporting is unchanged and separate, as the SECR reporting requirements page sets out.
The Modernising corporate reporting consultation, open until 30 November 2026, says the government will consider how UK SRS should be reflected in the Companies Act; that is a consideration, not a proposal, per ¶¶154–155 of the document.
Every UK regime is mapped side by side on the sustainability reporting requirements hub.
Check yourself
Each answer names the provision it turns on.
The standard itself is on GOV.UK, and the rules that apply it to listed companies are in PS26/19.
For both standards side by side, read UK SRS S1 and S2.
True or false?
A listed company using the climate-first relief can describe its report as complying with UK SRS S1.
UK SRS S1 sets no percentage threshold for materiality.
UK SRS S1 disclosures may be published a few months after the financial statements.
Under the FCA rules the S1 explanation is framed around the risks and opportunities not disclosed on.
The FCA rules require listed companies to obtain assurance over their UK SRS disclosures.
UK SRS S1 has an effective date of 1 January 2024.
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Frequently asked
UK SRS S1 requires an entity to disclose material information about the sustainability-related risks and opportunities that could reasonably be expected to affect its prospects, covering governance, strategy, risk management, and metrics and targets (¶25).
The disclosures form part of the general purpose financial reports (¶60), are published at the same time and for the same period as the financial statements (¶64), carry comparatives for the preceding period (¶70) and support an explicit and unreserved statement of compliance only when every requirement is met (¶72).
No. UK SRS S1 was published by the Department for Business and Trade on 25 February 2026 as a voluntary standard.
The FCA’s final rules in PS26/19 put companies listed in UKLR 6, 14, 15, 16 and 22 on a comply-or-explain basis across UK SRS for accounting periods beginning on or after 1 January 2027.
That is a duty to disclose or explain, not a duty to disclose in full.
From accounting periods beginning on or after 1 January 2027, companies with listings in the commercial companies (UKLR 6), international secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16) and transition (UKLR 22) categories must report against UK SRS S1 or explain.
Everyone else may use it voluntarily.
No Companies Act requirement to report against UK SRS has been made.
The FCA rules apply to accounting periods beginning on or after 1 January 2027, with first reports in 2028.
A listed company may rely on the climate-first relief in UK SRS S1 ¶E3 for periods beginning before 1 January 2029, provided it states that it is doing so.
From periods beginning on or after 1 January 2029 every S1 risk and opportunity is on comply or explain.
Paragraph 25 lists four areas.
Governance (¶¶26–27): the body or individual overseeing sustainability-related risks and opportunities and management’s role.
Strategy (¶¶28–42): the risks and opportunities, their effects on the business model, value chain, strategy, financial position and cash flows, and resilience.
Risk management (¶¶43–44): the processes used to identify, assess, prioritise and monitor them.
Metrics and targets (¶¶45–53): performance, including progress towards targets.
Information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users of general purpose financial reports make on the basis of those reports (¶18).
Primary users are existing and potential investors, lenders and other creditors.
The standard sets no materiality thresholds (¶B19), information that is not material need not be disclosed even if listed as a minimum requirement (¶B25), and judgements are reassessed at each reporting date (¶B28).
UK SRS S1 ¶60 requires the disclosures to be provided as part of the general purpose financial reports, and ¶61 names the strategic report among the places they can sit.
Information may be included by cross-reference to another report under ¶63 and ¶¶B45–B47, provided it is available on the same terms and at the same time.
The FCA rules keep the disclosures and any explanation in the annual financial report, with cross-reference permitted on those terms.
No. UK SRS S1 ¶64 requires the sustainability-related financial disclosures to be reported at the same time as the related financial statements and for the same reporting period.
IFRS S1 ¶E4 allowed later publication in the first year, and the UK removed that relief from UK SRS S1.
UK SRS S1 ¶E3 permits an entity to disclose only climate-related risks and opportunities, applying S1 only insofar as it relates to climate.
The standard sets no time limit; for listed companies the FCA rules make it available for periods beginning before 1 January 2029 (UKLR TP 16), and the company must state that it is relying on it.
No. UK SRS S1 ¶73A says an entity using ¶E3 is not permitted to assert compliance with UK SRS S1 and must disclose its use of the provision instead.
It may still assert compliance with UK SRS S2, provided it discloses use of the relief alongside the statement.
Under UKLR 6.6.6R(7B) a listed company either makes disclosures in accordance with UK SRS S1 (other than the climate disclosures handled under (7A)) or, where it has identified sustainability-related risks or opportunities of the kind described in S1 ¶3 but not disclosed on them, states which risks or opportunities those are, why, and any steps it is taking or plans to take.
If it has identified none, it says so under (7B)(c).
The S1 explanation is organised by risk and opportunity, not by paragraph.
No. UK SRS S1 ¶E1 removes comparatives in the first annual reporting period, and the FCA’s UKLR TP 16.6G(2) says the same for the first period of disclosure under its rules.
An entity that used the climate-first relief need not give non-climate comparatives until the second annual reporting period after it stops using the relief (¶E4(b)).
Annex A of the government’s consultation response is the complete list.
UK SRS S1 has no effective date; the SASB reference is “may” rather than “shall” (¶¶55(a), 58(a)); the first-year later-publication relief (IFRS S1 ¶E4) is removed; the climate-first relief has no time limit in the standard (¶E3); ¶73A restricts the compliance statement for climate-only reporters; and ¶73B and ¶E5 make application subject to UK law or FCA rules.
No. Neither UK SRS S1 nor the FCA rules require assurance.
UKLR 6.6.6R(8)(d) requires a listed company to state whether it obtained third-party assurance over its disclosures and, if so, the provider, scope, level and standards used.
The FCA said in PS26/19 that it is not requiring explanations where assurance was not sought.
Not under the FCA rules.
AIM securities are not admitted to the Official List, and the PS26/19 rules sit in the UK Listing Rules categories 6, 14, 15, 16 and 22.
An AIM company may still use UK SRS S1 voluntarily, and AIM companies with more than 500 employees are within the Companies Act climate-related financial disclosure regime.
No. UK SRS S1 ¶69 says the standard does not mandate which entities provide interim sustainability-related financial disclosures, how often, or how soon after an interim period.
If an entity is required to or chooses to publish interim disclosures, ¶B48 applies.
The made rule asks for the undisclosed risks or opportunities, the reasons and any steps.
The FCA’s draft Technical Note 803.1, open for comment until 28 October 2026, proposes that an explanation can be short and proportionate but should not omit material information, and that no timeframe is required. It is draft guidance until the FCA finalises it.
Sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Every paragraph reference on this page: ¶¶17–18, 25–53, 60–73B, B19, B25, B45–B47 and Appendix E.
The climate standard S1 is applied with (¶C2), and its reliefs ¶¶C3–C4 that ¶73A refers to.
The publication page, 25 February 2026.
The standards are available for voluntary use by any entity.
The complete map of differences between UK SRS S1 and IFRS S1.
Effective dates removed; s.463 protection for disclosure in the strategic report.
Why the relief periods were taken out of the standards.
Comply or explain across UK SRS for periods beginning on or after 1 January 2027.
The made rule text and the transitional provisions.
Where the S1 limb sits for commercial companies.
The consultation on draft TN 803.1 and the FCA’s preparation steps.
Proposed guidance on what an explanation should contain.
The four-month publication deadline that the S1 disclosures travel with.
How UK SRS S1 differs from IFRS S1; reliefs indefinite for voluntary users.
The technical endorsement recommendation behind UK SRS.
The international standard UK SRS S1 is built on, effective internationally from 1 January 2024.
For comparing the IFRS S1 appendix E reliefs with the UK version.
The non-financial and sustainability information statement.
Directors’ liability protection for the strategic report.
The FCA’s penalty power for a breach of the listing rules.
Open until 30 November 2026; the government “will consider” how UK SRS is reflected in the Companies Act.
AIM securities are not admitted to the Official List.