UK SRS S2 — Climate-related Disclosures
UK SRS S2 is the UK’s endorsed version of the ISSB’s IFRS S2. It asks for Scope 1, 2 and 3 emissions, climate scenario analysis and the transition plan you already have — across governance, strategy, risk management, and metrics and targets.
What UK SRS S2 asks for — climate only, but climate in full
UK SRS S2 is the UK Sustainability Reporting Standard covering climate-related risks and opportunities. It is the UK’s endorsed version of IFRS S2, the ISSB’s global climate standard, and it was published alongside UK SRS S1 on 25 February 2026.
Everything on the climate topic sits in S2. Every other sustainability topic — nature, water, workforce, human rights, governance beyond climate — sits in UK SRS S1. That division is the first thing to get right, because the two standards have different proposed start dates and different compliance mechanics.
Within climate, though, S2 is not a light touch. It asks four things of you, and the fourth is the one that takes longest to build:
If you have reported under TCFD, that structure will look familiar — deliberately so. What is different is the specificity: S2 names the measurement standard, requires the full 15-category value chain, and requires an annual assessment of climate resilience rather than a narrative about it. The gap between a good TCFD report and a compliant S2 disclosure is mostly in those three places.
Photo: Unsplash / Alexander AberoWhere the standard comes from — one chain, three links
S2 did not appear from nowhere. It is the third link in a chain that starts with a voluntary framework and ends with a proposed listing rule.
The publishing department was the Department for Business and Trade (DBT) at the point of publication. On 21 July 2026 it was renamed the Department for Business, Innovation, Science and Trade — so contemporaneous documents carry the older name.
Is UK SRS S2 mandatory yet? Not today — and the date is still a proposal
This is the single most misreported fact about the standard, so here it is precisely, with the date this page last checked it.
11 Aug 2026
UK SRS S2 is not mandatory for anyone. It is published and available for voluntary use. The Financial Conduct Authority consulted in CP26/5 on making it mandatory for in-scope listed companies for accounting periods beginning on or after 1 January 2027. That consultation closed on 20 March 2026. As at the date of this check the FCA had not published its Policy Statement; its stated aim remains “autumn 2026”, and no more precise date exists.
Why this matters more than it sounds: the reliefs in the FCA’s proposals are defined relative to the first in-scope period, not to fixed calendar years. If the Policy Statement slips, the commencement date and every relief date below move together. Anyone who has hard-coded “2028” into a project plan rather than “year two” will be rebuilding that plan.
Two other routes could reach you, and neither is settled. The Government’s Modernising Corporate Reporting programme is the vehicle by which UK SRS could be extended to large private companies; that consultation had not been published as at August 2026, and the term “economically significant” has no definition or threshold attached to it yet. Separately, the Department for Energy Security and Net Zero consulted on climate-related transition plan requirements between June and September 2025; that page still read “we are analysing your feedback” in August 2026. No outcome has been published.
So the honest position for a preparer in 2026 is: voluntary adoption is available now and is the low-risk way to find your data gaps; mandatory application is likely but not yet law; and the sequence below is a plan, not a rulebook.
UK SRS S2 in six dates — two settled, four proposed
The rail below separates what has actually happened from what is still a consultation proposal. Only the first two rows are facts about the past.
Photo: Unsplash / Nicholas Doherty
Who must comply with UK SRS S2
About 515 companies, in three listing categories — and a different, lighter obligation for two more.
The FCA’s cost benefit analysis in CP26/5 examined around 600 listed companies. Of those, roughly 515 would be required to report under UK SRS S2. The distinction between the two numbers is not decoration — it is the difference between a full reporting obligation and a signposting statement, and several published summaries get it wrong.
| Listing category | What CP26/5 proposes | Effect |
|---|---|---|
| UKLR 6 — commercial companies | Full UK SRS S2 reporting obligation | In the ~515 |
| UKLR 16 — non-equity shares and non-voting equity shares | Full UK SRS S2 reporting obligation | In the ~515 |
| UKLR 22 — transition category | Full UK SRS S2 reporting obligation | In the ~515 |
| UKLR 14 — secondary listing | A transparency statement about the sustainability standards applied in the primary listing venue | Not in the ~515 |
| UKLR 15 — depositary receipts | A transparency statement about the sustainability standards applied in the primary listing venue | Not in the ~515 |
Source: FCA CP26/5, 30 January 2026 — proposals, not made rules. Note also that the “premium” and “standard” listing segments were replaced by the UKLR categories in July 2024, so any summary still describing “515 premium listed companies” is describing a regime that no longer exists.
If you are not listed, nothing in CP26/5 reaches you. You may still adopt UK SRS S2 voluntarily — and many large private groups will, because their customers, lenders and insurers are in scope and will ask. Whether the obligation is ever extended to large private companies is a question for the Modernising Corporate Reporting programme, which had not consulted as at August 2026. Our UK SRS thresholds page tracks that question.
The four pillars — and which two cost real money
Inherited from TCFD, kept by IFRS S2, carried into UK SRS S2 unchanged. Every disclosure the standard asks for hangs off one of these four.
Governance
The body or individual responsible for oversight of climate-related risks and opportunities, the competencies of that body, how it is informed, and how climate considerations are integrated into strategy and decision-making.
Strategy
How climate risks and opportunities affect the business model, value chain, strategy and financial position across short, medium and long-term horizons — including the resilience of the strategy under different climate scenarios.
Risk management
How climate-related risks are identified, assessed, prioritised and monitored, and how those processes integrate with enterprise risk management. Includes the value-chain scope used and the assumptions and methodologies applied.
Metrics and targets
Greenhouse gas emissions under the GHG Protocol — Scope 1, Scope 2 (gross, location-based) and Scope 3 across fifteen categories — plus industry-based metrics, targets, methodologies, base years and progress.
The pillars are not equally expensive. Governance and risk management are largely a documentation exercise for a company that already runs a risk framework. Strategy is where scenario analysis lands. Metrics and targets is where Scope 3 lands. Those last two are the whole of the cost, and they are also the two with the longest lead time.
Photo: Unsplash / Paula PrekopovaGovernance — and the remuneration question nobody mentions
There is a requirement in the governance pillar that almost no summary of the standard mentions, and it is the one most likely to require a conversation with your remuneration committee.
UK SRS S2 requires you to disclose how climate-related considerations are factored into executive remuneration, and whether and how climate-related performance metrics are included in remuneration policies. For most companies the honest answer in year one will be “they are not” — which is a permitted answer, but a visible one, sitting in the annual report next to the remuneration report itself.
The other governance disclosures are more procedural, and they are more demanding than TCFD was:
Name the body or individual with oversight — board, committee or named executive. “The board has oversight” without saying which body holds it, and how often it meets on climate, is the most common thin disclosure.
How the body determines whether appropriate skills and competencies are available to it. This is a genuine change of register from TCFD: it invites a statement about board capability.
How and how often the body is informed about climate matters, and how it oversees the setting of targets and monitors progress against them.
How climate considerations are integrated into strategy, major transactions and risk management processes — and how trade-offs are handled.
The practical test: if a reader cannot tell from your governance section who would be answerable if a climate risk crystallised, the disclosure is not doing its job.
UK SRS S2 greenhouse gas emissions — three scopes, one methodology
S2 does not let you choose a measurement basis. It names the GHG Protocol Corporate Standard and requires gross emissions in tonnes of CO2 equivalent.
Direct emissions
Everything from sources you own or control — gas burned on site, company vehicles, process emissions, refrigerant leakage. Usually the smallest number and the easiest to defend, because the data is on your own meters and invoices.
Purchased energy
Emissions from the electricity, steam, heat and cooling you buy. S2 requires the location-based figure; market-based information may be disclosed alongside it where you have contractual instruments. Both methods are defined in the GHG Protocol Scope 2 Guidance.
The value chain
Fifteen categories, upstream and downstream, measured under the Corporate Value Chain (Scope 3) Standard. For most companies this is 70–90% of the total footprint and effectively all of the work.
Two details that catch preparers out. First, emissions must be disclosed gross, before any deduction for purchased carbon credits — credits are disclosed separately, and are their own requirement. Second, you must disclose the measurement approach, inputs and assumptions, not just the answer. A number without its method is not a compliant disclosure, and it is the first thing an assurance provider will ask to see.
UK preparers converting activity data into emissions will generally use the UK Government greenhouse gas conversion factors, republished annually — the 2026 set was published on 11 June 2026. Our carbon accounting guide for UK SRS walks through the conversion itself, and Scope 1, 2 and 3 explained covers the boundary rules.
Photo: Unsplash / Nikola Jovanovic
The fifteen Scope 3 categories under UK SRS S2
Tap the ones you could measure today. The count underneath is your honest starting position.
Not every category applies to every business, and S2 does not ask you to report emissions from categories that are not applicable. It asks you to consider all fifteen, report those that are material, and be transparent about which you have excluded and why. “Not material” is a judgement you have to be able to defend; “we did not get to it” is not the same thing and should not be dressed as the first.
One category deserves separate mention because it changes the shape of the problem entirely. Category 15, financed emissions, is where a bank’s, insurer’s or asset manager’s footprint actually lives — frequently hundreds of times its operational emissions. UK SRS S2 includes a specific provision requiring an explanation where measuring financed emissions is impracticable, which is a UK-added accommodation for exactly how hard this category is. Our Scope 3 under UK SRS page takes each category in turn.
How to measure Scope 3 — and what to disclose about the method
The standard cares about your method almost as much as your number. Here is the hierarchy preparers actually work down, and what has to be said about each step.
A rough, spend-based estimate across every category, before you refine anything. This is what tells you which three categories carry 80% of the footprint — and stops you spending a quarter perfecting business travel while Category 1 sits unmeasured.
Financial spend multiplied by an emissions factor per pound. Fast, defensible as a starting point, and explicitly contemplated by the GHG Protocol — but it moves with prices rather than with your actual emissions, so it cannot show reduction.
Physical quantities multiplied by industry-average factors — tonnes of steel, litres of fuel, passenger-kilometres. Better than spend, and usually achievable from data you already hold in procurement and logistics systems.
Primary data from the suppliers inside your material categories. This is the only method that lets you show a reduction you actually caused, and it is the one with the longest lead time — typically two reporting cycles before coverage is meaningful.
Which categories used which method, the proportion of each based on primary versus estimated data, the significant assumptions, and the degree of uncertainty. This is a requirement, not good practice.
Improving your method usually increases your reported Scope 3 number, because better data finds emissions that estimates missed. If your first restated year shows a rise, the disclosure must explain that it reflects better measurement rather than worse performance — and your governance disclosure should show that the board understood this before the number moved.
Photo: Unsplash / Zac Wolff
Climate scenario analysis under UK SRS S2
Resilience assessment is mandatory. The scenarios are not prescribed. That combination is what makes this the most-asked, least-explained part of the standard.
UK SRS S2 requires you to assess the resilience of your strategy and business model to climate-related changes, developments and uncertainties — using climate-related scenario analysis, and doing it every reporting period. What it does not do is tell you which scenarios to use.
The Government itself flagged this as the difficult area. In the exposure draft consultation it specifically asked the market what further guidance was needed on scenario analysis, and respondents said what you would expect: worked examples, and help with proportionality. That gap is still largely unfilled, which is why so much published commentary on S2 simply omits this section.
The governing principle is commensurability. The standard requires an approach commensurate with your circumstances — your exposure to climate risk, and the skills, capabilities and resources available to you. A mid-cap distributor is not expected to run the modelling a global insurer runs. What both are expected to do is explain the approach they took and why it fits.
Choosing your scenarios
Three families of published pathway do almost all the work in practice. You are not obliged to use any of them, and you may use more than one — most preparers use two or three, chosen to bracket the range of plausible futures rather than to describe a single expected one.
Network for Greening the Financial System
Built for financial supervisors, and the default in UK financial services. Frames futures as orderly, disorderly and hot-house world, with both long-term pathways and, since 2025, short-term scenarios. Comes with variables you can actually model against.
Best where transition risk is financial ↗World Energy Outlook scenarios
Energy-system pathways — Stated Policies, Announced Pledges and Net Zero by 2050. The natural choice where your exposure is to energy prices, fuel demand or the pace of electrification, and the most intuitive family for industrial and energy-intensive businesses.
Best for energy and industry ↗AR6 pathways and SSPs
The underlying physical science. Where your material risk is physical — flood, heat, drought, storm damage to sites or supply chains — the IPCC’s shared socio-economic pathways and the regional atlas are the right basis, and S2 asks you to use the latest assessment reports where possible.
Best for physical risk ↗What you actually have to disclose
The scenarios are an input. The disclosure is about the analysis and what it told you. Four things must appear:
Which scenarios you used and why they are relevant, whether they are aligned with the latest international agreements, the source of the scenarios, and the time horizons applied.
The assumptions you made about the transition — policy, technology, energy prices — and about physical changes, plus how they relate to the assumptions used elsewhere in your financial reporting.
Where the analysis is weakest. Saying so is a compliance requirement, not an admission — and a disclosure with no stated uncertainty reads as one that has not been done properly.
Your ability to adapt strategy and business model over time in response to what the analysis found: the availability and flexibility of resources, and where the plan would have to change.
In March 2026 the IFRS Foundation published a webcast and factsheet on the climate resilience and scenario analysis requirements, explaining the proportionality mechanisms built into the standard. It is educational material rather than a change in requirement, and it is currently the most useful free guidance available on this specific problem.
advice
Do not start by buying a model. Start by writing down the two or three ways climate could actually break your business, then choose scenarios that stress those specific things. A qualitative analysis that identifies the right risks and says honestly where it is uncertain is a better first-year disclosure than a quantitative one that models the wrong thing to three decimal places.
Photo: Unsplash / Ricardo Gomez AngelUK SRS S2 and transition plans — disclose, don’t (yet) mandate
S2 does not require you to have a climate transition plan. It requires you to disclose the one you have — and that distinction is doing a lot of work.
If you have published a transition plan, S2 requires information about it: the targets, the key assumptions it rests on, the dependencies it relies on (policy, technology, third parties), and how it will be resourced. If you have not, the standard does not manufacture an obligation to write one.
Two things sit alongside that. First, the FCA’s CP26/5 proposes a listing-rule layer: in-scope companies would state whether and where they have published a transition plan, or explain why not. That is a disclose-or-explain statement, not a requirement to produce a plan. Second, the Department for Energy Security and Net Zero consulted on climate-related transition plan requirements between June and September 2025 — and as at August 2026 no outcome had been published. Anyone telling you mandatory transition plans are coming on a particular date is ahead of the evidence.
For the substance of a plan, the practical reference is the Transition Plan Taskforce material. The TPT’s disclosure-specific outputs are now hosted by the IFRS Foundation on its knowledge hub, and in June 2025 the Foundation published its own guidance on disclosing information about an entity’s climate-related transition in accordance with IFRS S2 — which is the bridge between the TPT framework and what S2 actually asks for. Our UK SRS transition plans page covers the drafting itself.
Carbon credits under UK SRS S2
A short section, because the requirement is short — and almost universally omitted from summaries of the standard.
If your emissions targets rely on carbon credits, S2 requires you to disclose the extent to which, and how, you plan to use them to achieve those targets. That includes which third-party scheme will verify or certify the credits, the type of credit — whether the underlying offset is nature-based or technology-based, and whether it is achieved through removal or emission avoidance — and any other significant factors necessary for users to understand the credibility and integrity of the credits you intend to rely on.
Two consequences follow. First, because reported emissions are gross, credits never reduce the headline number — they appear as a statement about how you intend to close the gap between that number and your target. Second, the requirement is about planned use, which several professional bodies argued in consultation should have extended to actual use, quality and holdings. It did not. If you want your credit strategy to be credible to a reader, disclosing more than the minimum here is one of the cheapest ways to do it.
Connectivity with the financial statements
The disclosures are not a standalone sustainability report bolted to the back of the annual report. They are supposed to reconcile with the accounts.
S2 requires disclosure of the current and anticipated financial effects of climate-related risks and opportunities — on financial position, financial performance and cash flows over the short, medium and long term. In practice that means the assumptions in your climate disclosure should be recognisably the same assumptions used in impairment testing, asset useful lives, provisions and going-concern assessment. Where they differ, the difference should be explicable.
This is where sustainability reporting stops being a communications exercise. A climate disclosure that describes a material transition risk to a product line, sitting in the same document as an impairment review that assumes that line continues indefinitely, is an inconsistency an auditor will find and a reader will notice.
The UK endorsement clarified connectivity for the UK’s Strategic Report framework specifically, and UK SRS S2 has been designated in a way that lets companies satisfy the climate-related elements of the non-financial and sustainability information statement under the Companies Act without duplicating them. That relief is one of the more valuable practical features of the UK version, and it is why placement within the annual report matters.
The transitional reliefs — and what using them costs you
There are transitional reliefs. Some of them are free; one of them stops you claiming full compliance. That is a distinction worth knowing before you rely on it.
Scope 3 in year one
An elective one-year deferral of Scope 3 disclosure in the first mandatory period. Elective — if you already report Scope 3, you may simply carry on.
Does not block a compliance statementFirst-year GHG methodology
Relief in the first year from the requirement to use the GHG Protocol where you currently measure on a different basis required by a jurisdictional authority or exchange.
Does not block a compliance statementClimate-first reporting
The relief permitting you to report only climate information in the first year, deferring the wider S1 topics. Useful — but while you are using it, you cannot assert full compliance with UK SRS S1.
Blocks an unqualified S1 compliance statementThe mechanics matter because a statement of compliance is a binary thing. Where you use a relief, you must say so — and the UK version added explicit paragraphs clarifying how compliance statements work when reliefs are in play. Used correctly, the Scope 3 and methodology reliefs let you state compliance with UK SRS S2 while still taking the extra year. Used carelessly, an unqualified compliance claim alongside an undisclosed relief is a misstatement.
Comparative information is the other place first-year preparers get caught: you are not required to provide comparatives for the first reporting period, which sounds generous until you realise that year two requires you to restate year one on any improved methodology, and explain the restatement.
How UK SRS S2 differs from IFRS S2
The substantive climate content is the same. What the UK changed is the machinery around it — dates, reliefs, and a few requirements that did not fit the UK reporting framework.
A word of caution before the list. During the June 2025 consultation the Government proposed six amendments to the ISSB baseline, and that number has been widely repeated since — including in earlier versions of this page. The final standards published in February 2026 do not state a total, and the composition changed: one proposed UK amendment, on the mandatory GICS industry classification, became unnecessary when the ISSB itself provided that relief in December 2025, and new UK-specific provisions were added instead. Treat “six” as the exposure-draft figure, not as a description of the standard you would apply today. The authoritative list is the mapping table in Annex A of the Government’s consultation response.
| What changed | Why |
|---|---|
| Effective dates removed | IFRS S2’s own effective date has no meaning in the UK. When UK SRS S2 applies is a matter for UK legislation and FCA rules — which is exactly why the dates on this page are proposals. |
| Relief allowing sustainability reporting later than the accounts removed | The UK expects the information inside the annual report, at the same time as the financial statements. Reporting later is not compatible with the Strategic Report framework. |
| Climate-first and Scope 3 reliefs no longer time-limited in the standard | The standard leaves the timing to UK rule-makers rather than baking in ISSB transition dates, so the reliefs are available whenever the UK sets the start. |
| SASB references softened from “shall” to “may” | The industry-based metrics in the SASB Standards are US-derived and not always a good fit for UK businesses. Consideration became optional rather than required. |
| Financed-emissions impracticability explanation added | A new provision requiring an explanation where measuring financed emissions is not practicable — an accommodation for banks, insurers and asset managers on Category 15. |
| Compliance-statement paragraphs added | New paragraphs clarifying how a statement of compliance works when transitional reliefs are being used — see the reliefs above. |
| First-year GHG methodology relief | Where an entity currently measures on a basis required by a jurisdictional authority or exchange, it need not switch to the GHG Protocol in year one. |
Sources: UK SRS S1 and UK SRS S2 as published, and the Government response to the consultation on UK Sustainability Reporting Standards, both 25 February 2026 — see primary sources. Our UK SRS amendments page annotates each change against the IFRS text.
UK SRS S2 vs UK SRS S1 — side by side
Published together, structured identically, and proposed to arrive two years apart. Confusing the two is the most common error in project planning.
| UK SRS S2 | UK SRS S1 | |
|---|---|---|
| Scope | Climate-related risks and opportunities only | Every other material sustainability topic |
| Proposed mandatory date | Periods beginning on or after 1 January 2027 | Comply-or-explain from 1 January 2029 |
| GHG emissions | Scope 1, 2 and 3 required under the GHG Protocol | Not applicable — emissions live in S2 |
| Scenario analysis | Required, every reporting period | Not required in the same form |
| Transition plan | Disclose the plan if you have one | Not applicable |
| Materiality basis | Financial materiality — effects on enterprise value | Financial materiality — the same basis |
One nuance that trips up the “S1 is deferred, ignore it” reading: S1 carries the conceptual foundations — materiality, the reporting entity, connected information, fair presentation. Those apply from the first year insofar as they relate to the climate disclosures you are making under S2. You cannot apply S2 properly while ignoring S1 entirely; you can defer S1’s additional topic coverage. The full general standard is covered on UK SRS S1, and the pair together on what is UK SRS — S1 and S2 explained.
Photo: Unsplash / Li-An Lim
Moving from TCFD reporting to UK SRS S2
If you already report under the UK’s TCFD-aligned listing rules, you are most of the way there. Here is the delta.
UK TCFD reporting requirements are not a separate destination from UK SRS S2 — they are the previous version of it. The FCA’s proposals in CP26/5 would replace the TCFD-aligned listing rule provisions with UK SRS. The four pillars carry over unchanged. What changes is depth, and it changes in five specific places.
| Requirement | Under TCFD-aligned reporting | Under UK SRS S2 |
|---|---|---|
| Emissions measurement basis | Recommended; methodology at your discretion | GHG Protocol Corporate Standard named in the standard |
| Scope 3 | “If appropriate”, commonly partial | All fifteen categories considered; material ones reported |
| Scenario analysis | Describe resilience; often narrative | Assess resilience using scenario analysis, every period, with inputs, assumptions, uncertainties and adaptive capacity disclosed |
| Financial effects | Qualitative description common | Current and anticipated effects on position, performance and cash flows |
| Remuneration | Optional in practice | Disclose how climate is factored into executive remuneration |
The practical migration path is therefore not a rewrite. It is a gap analysis against those five rows, then a data project on whichever of them you cannot currently evidence — which for almost everyone is Scope 3 and scenario analysis. Our TCFD to UK SRS migration guide takes the mapping requirement by requirement.
Worth knowing for context: the TCFD itself was disbanded in October 2023, its monitoring responsibilities passing to the IFRS Foundation. Reporting “in line with TCFD” is now reporting in line with a framework that no longer has a maintainer. That is the strategic argument for moving early rather than waiting for the rule to compel you.
Photo: Unsplash / Nick FewingsUK SRS S2 and SECR — two regimes, one dataset
SECR does not go away when UK SRS arrives. For now both run in parallel, and the overlap is a data opportunity rather than a duplication problem.
Streamlined Energy and Carbon Reporting has been in force since 1 April 2019 and requires large UK companies and LLPs to report energy use, greenhouse gas emissions, at least one intensity ratio and the energy-efficiency actions taken, inside the directors’ report. It is a UK statutory regime with a much wider population than the FCA’s listed-company proposals.
Two developments matter for how you plan. The Government confirmed, in correspondence with the FCA in January 2026, that SECR continues alongside UK SRS while the interaction between them is reviewed. And in May 2026 the Department for Energy Security and Net Zero published its statutory post-implementation review of the SECR regulations, which recommended retaining SECR with amendments rather than repealing it — while noting scope to simplify the framework and to consider how SECR fits within the wider corporate reporting landscape.
Earlier versions of this page carried a count of the large UK entities inside SECR. That figure derived from the 2018 impact assessment forecast, and the 2026 post-implementation review found the measured population to be materially larger. We have removed the number rather than repeat a stale one, and will restate it when we can quote the review directly.
Practically: your SECR Scope 1 and Scope 2 dataset is the foundation of your S2 metrics disclosure. Same activity data, same conversion factors, different presentation and a much wider surrounding narrative. Any company treating UK SRS S2 as a greenfield project when it already files SECR is about to pay twice for the same numbers. Our SECR guide covers the statutory requirement itself.
Getting the disclosures assured
Assurance is not yet mandatory for UK SRS. It is coming into shape around the standard, and the direction of travel is clear enough to plan for.
Three moving parts. First, the standard itself: the FRC issued ISSA (UK) 5000, the UK assurance standard for sustainability information, in November 2025 — effective for engagements on sustainability information reported for periods beginning on or after 15 December 2026, which is to say the first proposed mandatory UK SRS year. Second, the oversight regime: the Government responded to its consultation on assurance of sustainability reporting in January 2026, backing a voluntary registration regime for assurance providers, which the FRC has been tasked with standing up. As at late July 2026 that register had not yet launched. Third, the FCA’s proposals would require in-scope companies to state whether their disclosures have been assured, and by whom.
What that means for a preparer is simple enough: nobody will force you to obtain assurance in year one, but you will be asked to say whether you did. Building an audit trail that could be assured is therefore worth doing from the first voluntary report, because retrofitting provenance onto two years of spreadsheets is materially more expensive than capturing it as you go.
The things an assurance provider will ask for first are unglamorous: the source document behind each activity figure, the version of the conversion factors applied, the rationale for each materiality judgement, and evidence that someone independent of the preparer reviewed the result. Our sustainability assurance guide covers limited versus reasonable assurance and what each involves.
What a first-year UK SRS S2 disclosure actually looks like
Respondents to the Government’s consultation asked repeatedly for worked examples and illustrative disclosures, and few have appeared. This is one — an illustration written for this page, not a real company’s filing.
For the year ended 31 December 2027 the Group’s gross Scope 1 emissions were 14,200 tonnes CO2e and gross Scope 2 emissions, measured on a location-based method, were 9,700 tonnes CO2e. Emissions are measured in accordance with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard, applying the UK Government greenhouse gas conversion factors for the reporting year. Scope 2 market-based emissions were 3,100 tonnes CO2e, reflecting renewable electricity contracts covering 68% of purchased electricity.
The Group has applied the transitional relief permitting deferral of Scope 3 disclosure in the first reporting period. Preparatory work has been completed on a category screening exercise across all fifteen categories of the Corporate Value Chain (Scope 3) Standard, which identified categories 1 (purchased goods and services), 4 (upstream transportation) and 11 (use of sold products) as expected to be material. Scope 3 disclosure will be made from the year ending 31 December 2028.
Scope 1 emissions are calculated from metered fuel consumption and fleet fuel cards; the Directors consider the uncertainty in this figure to be low. Scope 2 is calculated from supplier invoices for 97% of sites by floor area, with the remaining 3% estimated on a floor-area basis. Refrigerant losses are estimated from service records rather than measured, and represent the largest single area of estimation uncertainty within Scope 1.
The Group has committed to a 42% reduction in gross Scope 1 and 2 emissions against a 2025 base year by 2030. The Group does not currently plan to use carbon credits to achieve this target. Any future use would be disclosed, including the scheme verifying the credits and whether the underlying offset is achieved through removal or avoidance.
Illustrative only. Figures are invented for the purpose of showing structure and are not derived from any company’s reporting. Nothing on this page is advice.
Preparing for UK SRS S2 — the order of work
Sequence matters more than speed here, because two of these have lead times you cannot compress by spending money.
UK SRS S2 by sector — which requirement will hurt
The standard is the same for everyone. The expensive part is not.
Category 15 is the whole problem
Financed emissions dwarf operational emissions, often by orders of magnitude. The UK added a specific impracticability explanation for exactly this. Expect the methodology discussion to be longer than the number.
Category 11 and product-level data
Use of sold products usually dominates, and it depends on assumptions about customer behaviour you cannot observe. Scenario analysis on energy prices and the IEA pathways will be the natural fit.
Category 1, across thousands of suppliers
Purchased goods and services across a long, fragmented supply chain. Spend-based estimation first, supplier engagement on the top decile, and a clear disclosure about the mix of methods.
Physical risk is the live one
Flood, heat and subsidence exposure across a fixed asset base, plus downstream leased assets in Category 13. IPCC pathways and the regional atlas do more work here than transition scenarios.
Everything, at once
Material Scope 1, material Scope 3, acute transition risk and an existing disclosure history. Generally the best-prepared sector and the one with the most to explain.
Small footprint, real scrutiny
Modest Scope 1 and 2, with Categories 1, 6 and 7 carrying the total. The risk here is under-investing because the numbers look small, then failing the method and uncertainty disclosures.
Physical risk and transition risk — the two halves
S2 asks about both, and they behave completely differently — different time horizons, different data, different scenarios, and usually different owners inside the business.
| Physical risk | Transition risk | |
|---|---|---|
| What it is | Damage and disruption from the changing climate itself — acute events like flood, storm and wildfire; chronic shifts like heat, drought and sea level | Cost and disruption from the shift to a lower-carbon economy — policy, carbon pricing, technology, market preference, litigation and reputation |
| When it bites | Grows across decades; acute events can arrive at any time | Front-loaded — the faster the transition, the sooner the cost |
| The perverse relationship | Worse in a slow-transition world | Worse in a fast-transition world |
| Where the data is | Asset locations, hazard maps, IPCC regional projections, insurer models | Product and revenue mix, carbon intensity, capital plans, policy pipelines |
| Typical scenario source | IPCC pathways and the regional atlas | NGFS and IEA scenarios |
| Who owns it | Operations, property, insurance, supply chain | Strategy, finance, product, regulatory affairs |
The inverse relationship in row three is the single most useful thing to understand about climate scenario work, and it is why one scenario is never enough. A business that models only an orderly transition sees its transition costs and misses its physical exposure; a business that models only a hot-house world sees the opposite. Running at least one of each is what makes the resilience statement meaningful rather than decorative.
S2 also asks you to consider opportunities, not only risks — new products, new markets, resource efficiency, resilience as a competitive advantage. In practice opportunity disclosure is the thinnest part of most reports, because it requires commercial specificity that companies are reluctant to publish. A disclosure that lists three detailed risks and one vague opportunity is telling the reader something about how seriously the opportunity side has been examined.
Photo: Unsplash / Noah BuscherMateriality — the judgement everything else rests on
S2 uses a single, financial materiality test — and getting that test right is what decides how large the whole exercise becomes.
Information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions that primary users of general purpose financial reports make on the basis of those reports. Primary users means existing and potential investors, lenders and other creditors. That is the same conceptual test used in financial reporting, applied to sustainability information.
Two things follow that people find counter-intuitive. First, materiality is not the same as size. A small emissions category attached to a product line facing a regulatory ban may be far more decision-useful than a large one that is stable and cheap to abate. Second, materiality is entity-specific. There is no threshold percentage in the standard, and any consultant offering you one is offering you their convention, not a rule.
This is also where UK SRS S2 diverges most visibly from the European regime. The European Sustainability Reporting Standards use double materiality — requiring disclosure both of how sustainability matters affect the company and of how the company affects people and the environment, whether or not that has financial consequences. UK SRS S2 requires only the first of those. A group reporting under both will find its UK disclosure is a subset of its European one, not a different document. Our UK SRS versus ESRS comparison covers the practical consequences of running both.
the judgement
Whatever you conclude, write down why at the time you conclude it. Materiality assessments are the first thing an assurance provider tests and the first thing that looks arbitrary in hindsight. A one-page record of what you considered, what you excluded and on what basis is worth more at year-two than any amount of retrospective reconstruction.
Industry-based metrics — and what the UK changed
IFRS S2 tells you to consider industry-specific metrics drawn from the SASB Standards. The UK version softened that from an instruction to an option.
Under IFRS S2 as issued, an entity shall refer to and consider the applicability of the industry-based metrics in the accompanying guidance — a body of metrics derived from the SASB Standards, which cover 77 industries and specify things like greenhouse gas intensity per unit of production, water withdrawn in stressed regions, or exposure to assets in flood zones.
In UK SRS S2 that requirement was softened to may. The reasoning is straightforward: the SASB metrics are US-derived, and their industry definitions and units do not always map cleanly onto UK businesses or UK regulatory categories. Making consideration mandatory would have imposed a translation cost for limited benefit.
The practical consequence is worth thinking about rather than celebrating. Industry metrics are what make one company’s disclosure comparable with another’s — and comparability is most of what investors want from this regime. Choosing not to use them is permitted; choosing not to use them and not offering any sector-relevant metric in their place produces a disclosure that cannot be benchmarked against anything. Where a SASB metric fits your business, using it remains the path of least resistance for both you and your readers.
One live watch item: in March 2026 the ISSB published an exposure draft proposing amendments to the SASB Standards and the IFRS S2 industry-based guidance, with the comment period closing in July 2026. Any resulting change would need to pass through the UK endorsement process before it affected UK SRS S2 — which is a reminder that the UK standard is a snapshot of a moving international baseline, not a permanent text.
Seven ways a climate disclosure fails
Drawn from what regulators and assurance providers have consistently criticised in TCFD-era reporting — because the same failures will carry straight into S2.
Boilerplate governance
“The Board has oversight of climate-related matters.” Which body, meeting how often, informed by what, competent on what basis? Naming nothing is the most common thin disclosure and the easiest to fix.
Scenario analysis with no consequence
Three scenarios described in a table, and no statement of what the analysis changed. If the resilience assessment did not alter a single view, say so and say why — but a silent table is not an assessment.
A Scope 3 number with no method
One total, no category breakdown, no indication of what is primary and what is estimated, no uncertainty. This is the single most common assurance finding, and it is a compliance failure rather than a presentational one.
Targets without base years
“Net zero by 2040” against what, measured how, covering which scopes? A target without a base year, a boundary and a methodology is not a disclosable target.
Disconnection from the accounts
A material transition risk described in the front half, and no trace of it in impairment, useful lives or provisions in the back half. Readers and auditors both notice.
Silent use of a relief
Taking the Scope 3 deferral or the climate-first relief without stating it, then asserting unqualified compliance. That combination turns a permitted choice into a misstatement.
Stale conversion factors
Applying last year’s emission factors to this year’s activity data. Cheap to get right, embarrassing to get wrong, and the first thing a competent reviewer checks.
The data you need, and where it already lives
Almost every input already exists somewhere in the business. The work is assembling it repeatably, with provenance, on an annual cycle.
| Disclosure | Data required | Usually lives in |
|---|---|---|
| Scope 1 | Fuel and gas consumption, fleet mileage and fuel, refrigerant top-ups, process emissions | Facilities, energy invoices, fleet cards, maintenance records |
| Scope 2 | Purchased electricity, heat, steam and cooling by site; renewable contracts and certificates | Energy supplier invoices, half-hourly meter data, procurement contracts |
| Scope 3 screening | Supplier spend by category, freight volumes, travel bookings, headcount and commuting patterns | Accounts payable, the general ledger, logistics and travel management systems, HR |
| Scope 3 refinement | Supplier-specific emissions factors and product footprints for material categories | Nowhere yet — this is the supplier engagement programme |
| Physical risk | Asset register with locations, hazard exposure, business interruption history | Property and insurance records, risk register |
| Transition risk | Revenue and margin by product and geography, capital plan, carbon-intensive asset base | FP&A, the strategic plan, fixed asset register |
| Financial effects | Impairment assumptions, asset lives, provisions, going-concern inputs | Group finance — and this is the connection most often missed |
The pattern to notice: only one row has no existing home. Everything else is a collection and governance problem rather than a measurement problem — which is why the companies that struggle most are not the ones with the biggest footprints, but the ones with the most fragmented systems and the least clarity about who owns each number.
Whether that assembly happens in a spreadsheet or a platform is a question of scale and audit appetite rather than compliance: nothing in UK SRS S2 requires software. What it effectively requires is an audit trail from source document to disclosed figure, which spreadsheets can provide and frequently do not. Our carbon reporting software comparison assesses the platforms on exactly that criterion, and carbon accounting for UK SRS covers doing it without one.
What happens if the Policy Statement slips
A question no competitor page answers, and the one most likely to matter to anyone building a project plan in 2026.
The FCA has stated an aim of autumn 2026 for its Policy Statement, and had not published it as at 11 August 2026. Consultations slip routinely and for unremarkable reasons. So it is worth being clear about what would and would not move.
The transitional reliefs in CP26/5 are defined relative to the first period in which the requirements apply, not to fixed calendar years. If commencement moves to 2028, the Scope 3 relief moves to 2029 and S1 moves with it. Plans that say “Scope 3 by 2028” break; plans that say “Scope 3 by year two” do not.
UK SRS S2 is published and final. A delayed Policy Statement changes when it is compulsory, not what it says. Voluntary adopters are unaffected.
Supplier engagement and scenario capability take two reporting cycles regardless of the rule. A twelve-month delay converts directly into twelve months of better first-year data for anyone who keeps going — and into nothing at all for anyone who stops.
Consultation responses pressed the FCA on the Scope 3 comply-or-explain limb and on the treatment of secondary listings. A Policy Statement is not a rubber stamp on the consultation, and the final rules may differ from the proposals summarised on this page. We re-verify this page against the FCA and the FRC and will update it when the statement lands.
The standard is published, the dates are proposals, and the two things that take longest — value-chain data and a repeatable scenario process — are the two you can start without waiting for a rule.
The bottom line · Photo: Unsplash / name_gravityUK SRS S2 key facts
Every row on this page in one place, with its status. Anything marked proposed is not law.
UK SRS S2 — frequently asked questions
UK SRS S2 covers climate-related risks and opportunities only — physical risks, transition risks and climate opportunities — disclosed across the four TCFD pillars of governance, strategy, risk management, and metrics and targets. It requires Scope 1, 2 and 3 greenhouse gas emissions measured under the GHG Protocol Corporate Standard, climate scenario analysis, and disclosure of a climate transition plan where the entity has one. Every other sustainability topic sits in UK SRS S1.
Not yet. UK SRS S2 was published on 25 February 2026 for voluntary use by any UK entity. Under FCA CP26/5, mandatory application is proposed for roughly 515 in-scope listed companies for accounting periods beginning on or after 1 January 2027 — subject to the FCA Policy Statement, which the FCA aims to publish in autumn 2026 and which had not been published as at 11 August 2026. Scope 3 emissions get an elective one-year transitional relief, moving to comply-or-explain from 1 January 2028.
Scope 1 (direct) and Scope 2 (purchased energy) emissions are required, measured under the GHG Protocol Corporate Standard. Scope 3 value-chain emissions are required across the 15 categories of the GHG Protocol Corporate Value Chain (Scope 3) Standard where material. Under the FCA’s proposals, an elective relief allows Scope 3 to be deferred in the first mandatory year (2027), and it applies on a comply-or-explain basis from 1 January 2028.
Yes. UK SRS S2 requires entities to use climate-related scenario analysis to assess the resilience of their strategy and business model. No specific scenarios are mandated — entities must use an approach commensurate with their circumstances, and common practice references IEA, NGFS or IPCC pathways, including at least one scenario consistent with limiting warming to a level requiring no significant overshoot. Entities must disclose the inputs, assumptions, significant uncertainties and their capacity to adjust strategy.
UK SRS S2 does not force an entity to have a transition plan — it requires disclosure of the plan where one exists, and preparers are encouraged to use the ISSB and Transition Plan Taskforce (TPT) materials now hosted by the IFRS Foundation. Separately, FCA CP26/5 proposes that in-scope listed companies disclose whether and where they have published a transition plan, or explain why not. Whether transition plans become mandatory is a decision for Government, which consulted on the question in 2025; no outcome had been published as at August 2026.
UK SRS S2 is the UK’s endorsed version of the ISSB’s IFRS S2. The substantive climate disclosure content is the same; the UK made a small number of amendments to the machinery around it. Effective dates were removed, because when the standard applies is a matter for UK legislation and FCA rules. The relief allowing sustainability information to be reported later than the financial statements was removed. The climate-first and Scope 3 reliefs are no longer time-limited within the standard. References to the SASB industry-based guidance were softened from “shall” to “may”. A financed-emissions impracticability explanation was added, along with paragraphs clarifying how a compliance statement works when reliefs are used, and a first-year relief on GHG measurement methodology. The June 2025 exposure draft proposed six amendments; the final standards do not state a total and the composition changed — the authoritative list is the mapping table in Annex A of the Government’s consultation response.
S2 is the climate-specific standard; S1 is the general standard covering every other material sustainability topic. Under FCA CP26/5, S2 is proposed to become mandatory for in-scope listed issuers from 1 January 2027 (with an elective Scope 3 relief in year one), while S1 follows on comply-or-explain from 1 January 2029. Both were published together on 25 February 2026 and share the four-pillar structure and single (financial) materiality basis. There is a six-row side-by-side comparison on this page, and the general standard is covered in full on UK SRS S1.
For now, both regimes continue in parallel. SECR (Streamlined Energy and Carbon Reporting, in force since 1 April 2019) already requires energy and emissions disclosures from large UK entities, and it is unchanged by UK SRS. The Government has said it will consider the interaction between UK SRS and SECR to reduce duplication, and confirmed in its January 2026 letter to the FCA that SECR continues alongside UK SRS while that review happens. The statutory post-implementation review of SECR, published in May 2026, recommended retaining the regime with amendments.
Nobody, today — it is voluntary. Under the FCA’s CP26/5 proposals, around 515 companies listed in UKLR categories 6 (commercial companies), 16 (non-equity and non-voting equity shares) and 22 (transition) would be required to report under UK SRS S2. Companies in UKLR 14 (secondary listing) and 15 (depositary receipts) would instead make a transparency statement about the sustainability standards applied in their primary listing venue. Extension to large private companies would require the Modernising Corporate Reporting programme, which had not consulted as at August 2026.
No. UK SRS S2 uses a single, financial materiality basis, inherited from IFRS S2: 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. That is a narrower test than the double materiality used by the European Sustainability Reporting Standards, which also require reporting on an entity’s impacts on people and the environment regardless of financial consequence.
Not currently. Assurance of UK SRS disclosures is not mandatory. The FRC issued ISSA (UK) 5000, the UK assurance standard for sustainability information, in November 2025 — effective for engagements on sustainability information reported for periods beginning on or after 15 December 2026. The Government has backed a voluntary registration regime for assurance providers, which the FRC has been tasked with establishing. The FCA’s proposals would require in-scope companies to state whether their disclosures have been assured, and by whom.
Yes, and that is the point of publishing it before any rule requires it. Any UK entity may apply UK SRS S2 voluntarily from 25 February 2026. In practice a voluntary first cycle is the cheapest way to find your data gaps — particularly across the fifteen Scope 3 categories and the scenario analysis process — while the consequences of an incomplete answer are reputational rather than regulatory. If you use transitional reliefs, disclose which ones and be careful about how you word any statement of compliance.
UK SRS S2 — primary sources
Every figure and legal statement on this page carries a citation. These are the primary documents behind them, re-verified on 11 August 2026.
The standards
Regulators and rule-makers
Emissions methodology and scenarios
SECR and UK emissions reporting
Photography throughout: Unsplash (free licence) — Zbynek Burival, Nicholas Doherty, Alexander Abero, Nikola Jovanovic, Zac Wolff, Paula Prekopova, Ricardo Gomez Angel, Li-An Lim, Nick Fewings, Noah Buscher, name_gravity, Quokkabottles.
Go deeper on UK SRS S2
UK SRS S1 — General Sustainability Disclosures
The general standard: every sustainability topic that is not climate.
Scope 3UK SRS Scope 3 Reporting
All fifteen categories, the transitional relief and what assurance requires.
DatesUK SRS Implementation Timeline
The full sequence across both standards, tracked as it changes.
MigrationTCFD to UK SRS Migration
Requirement-by-requirement mapping from TCFD-aligned reporting.
BaselineIFRS S2 Climate Standard
The ISSB standard UK SRS S2 is endorsed from.
ScopeUK SRS Thresholds
Who is caught, and what would have to change to catch private companies.
PlansUK SRS Transition Plans
What a disclosable transition plan contains, and the TPT material behind it.
MethodCarbon Accounting for UK SRS
Activity data, conversion factors and the audit trail.
DetailUK SRS Amendments
The UK-specific changes to the ISSB baseline, annotated.
Start hereWhat is UK SRS? S1 and S2 explained
The overview, if you are new to the standards.
Existing dutySECR Energy & Carbon Reporting
The statutory regime that already applies, and how it feeds S2.
AssuranceSustainability Assurance
Limited versus reasonable assurance, and what ISSA (UK) 5000 requires.
You know what UK SRS S2 asks for. The next question is whether the thresholds reach you — and when.
See whether the thresholds catch you Or start the longest job — Scope 3 under UK SRS, category by category