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Disclose in accordance with UK SRS S2 or explain, from periods beginning on or after 1 January 2027.
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UK SRS S2 · Reporting requirements
The UK SRS S2 reporting requirements are the UK’s climate disclosure duties: a voluntary standard published by the Department for Business and Trade on 25 February 2026 and built on IFRS S2 as amended in December 2025.
The FCA’s final rules, PS26/19, apply it on a comply-or-explain basis to companies listed in UKLR 6, 14, 15, 16 and 22 for accounting periods beginning on or after 1 January 2027.
Below is every disclosure requirement with its paragraph, the reliefs, and how the S2 explanation works.
In brief
UK SRS S2 asks for information about climate-related risks and opportunities that could reasonably be expected to affect an entity’s cash flows, access to finance or cost of capital, judged by its usefulness to investors, lenders and other creditors.
It is applied with UK SRS S1 so far as S1 relates to climate, under ¶C2, which brings in S1’s materiality, location, timing and compliance-statement rules.
The standard is available for voluntary use, and only the FCA’s listing rules currently oblige anyone to report against it, on comply or explain.
The UK SRS S2 guide reads the standard paragraph by paragraph and drafts an explanation; this page is the list of duties.
In one table
| Area | Requirement | Paragraph |
|---|---|---|
| Governance | The body or individual overseeing climate risks and opportunities: terms of reference, skills, how and how often informed, trade-offs, target oversight, remuneration link | ¶6(a) |
| Governance | Management’s role: delegation, and the controls and procedures supporting oversight | ¶6(b) |
| Strategy | Climate risks and opportunities, physical or transition, time horizons and how they are defined | ¶10 |
| Strategy | Effects on the business model and value chain, and where they are concentrated | ¶13 |
| Strategy | Strategy and decision-making, including any transition plan the entity has and how targets will be met | ¶14 |
| Strategy | Current and anticipated financial effects on position, performance and cash flows | ¶¶15–21 |
| Strategy | Climate resilience, assessed using scenario analysis | ¶22, ¶¶B1–B18 |
| Risk management | Processes to identify, assess, prioritise and monitor climate risks and opportunities, and their integration | ¶25 |
| Metrics | Absolute gross Scope 1, 2 and 3 emissions in tonnes of CO2 equivalent, measured under the GHG Protocol | ¶29(a) |
| Metrics | Assets or activities vulnerable to transition and physical risks; aligned with opportunities; capital deployed | ¶29(b)–(e) |
| Metrics | Internal carbon prices, and climate-linked executive remuneration | ¶29(f)–(g) |
| Metrics | Industry-based metrics | ¶32 |
| Targets | Each climate target, its validation, review and performance; for emissions targets, gases, scopes, gross or net, and carbon credits | ¶¶33–36 |
| Financial institutions | Financed emissions; if impracticable for the same period, why, how estimated and the plan | ¶29(a)(vi)(2), ¶B59A |
The general requirements S2 relies on are on the UK SRS S1 reporting requirements page.
Who reports
The FCA’s scope test is the listing category, set in PS26/19 ¶3.6: commercial companies, international secondary listings, depositary receipts, non-equity and non-voting equity shares, and the transition category.
International companies with a secondary listing were brought in on the same comply-or-explain basis as domestic issuers, and may rely on home-jurisdiction reporting where it meets UK SRS, explaining any gap.
Closed-ended funds, open-ended investment companies and shell companies are outside the rules.
The government has confirmed that UK SRS S2 is a national reporting framework for section 414CB(6) of the Companies Act 2006, so a company within the climate-related financial disclosure duty can report against S2 without duplicating its disclosures.
That Companies Act duty has its own scope test, set out on the CFD reporting requirements page.
Disclose in accordance with UK SRS S2 or explain, from periods beginning on or after 1 January 2027.
UKLR 6.6.6R(7A) and parallelsMay use UK SRS S2 as a national reporting framework to meet s.414CB, without duplicating disclosures.
DBT response, Chapter 3Voluntary use, with the Scope 3 relief available without a time limit.
FRC FAQsGovernance and risk
UK SRS S2 ¶6(a) asks for the body or individual responsible for oversight of climate-related risks and opportunities, how that is reflected in terms of reference, how skills are assured, how and how often it is informed, how it weighs trade-offs, and how it oversees targets, including any link to remuneration.
Paragraph 6(b) covers management’s role: whether it is delegated to a management-level position or committee, and the controls and procedures that support oversight.
Risk management under ¶25 asks for the inputs and parameters used, whether scenario analysis informs risk identification, how likelihood and magnitude are assessed, how climate risk is prioritised, how it is monitored and whether the process has changed.
Where oversight or risk management is run on an integrated basis, ¶7 and ¶26 let the entity give integrated disclosures rather than repeating them for each risk.
Strategy
Paragraph 10 requires each climate risk to be classed as physical or transition, the time horizon over which it could occur, and how short, medium and long term are defined against the entity’s planning horizons.
Paragraph 13 asks where in the business model and value chain the risks and opportunities are concentrated, for example by geography, facility or asset type.
Paragraph 14 covers changes to the business model, direct and indirect mitigation and adaptation, how targets will be met, how the plans are resourced, and progress on plans disclosed before.
Paragraph 14(a)(iv) requires information about any climate-related transition plan the entity has, with its key assumptions and dependencies, which is a disclosure about a plan, not a duty to have one.
The current and anticipated financial effects follow, and ¶19 lets an entity give qualitative information where effects are not separately identifiable or measurement uncertainty is too high, provided it explains why under ¶21.
The government’s transition plan consultation has not produced any rule, and the position is on the transition plan reporting requirements page.
Resilience
UK SRS S2 ¶22 says the entity shall use climate-related scenario analysis to assess its climate resilience using an approach commensurate with its circumstances.
What scales is the depth of the analysis, not the obligation to do one.
An entity with a high degree of exposure and access to the necessary skills, capabilities or resources is required to apply a more advanced quantitative approach, under ¶B17.
The analysis may be refreshed in line with a multi-year planning cycle, for example every three to five years, but the resilience assessment in ¶22(a) is updated at each reporting date.
The application guidance draws on the TCFD’s scenario documents, and the original framework is in the TCFD’s 2017 report.
Exposure to climate risk, and the skills, capabilities and resources available (¶B2).
Qualitative narratives can be enough; high exposure plus resources requires a quantitative approach (¶B17).
Scenarios used, assumptions and the period the analysis was carried out (¶22(b)).
The analysis follows the planning cycle; the ¶22(a) assessment is updated each period (¶B18).
Scope 1, 2 and 3
The emissions limb is the most specific part of the standard, and the part where the UK reliefs sit.
| Requirement | What UK SRS S2 says | Paragraph |
|---|---|---|
| Measure | Absolute gross emissions in tonnes of CO2 equivalent, classified as Scope 1, 2 and 3 | ¶29(a)(i) |
| Method | GHG Protocol Corporate Standard (2004), unless a jurisdictional authority or exchange requires another method | ¶29(a)(ii) |
| Approach | Disclose the measurement approach, inputs and assumptions, and any changes | ¶29(a)(iii) |
| Boundary | Scope 1 and 2 split between the consolidated group and other investees | ¶29(a)(iv) |
| Scope 2 | Location-based, plus contractual-instrument information where it informs users; market-based optional | ¶29(a)(v), ¶¶B30–B31 |
| Scope 3 | The categories included, under the GHG Protocol Scope 3 Standard (2011) | ¶29(a)(vi)(1) |
| Financed emissions | For asset management, commercial banking or insurance; Category 15 may be limited to financed emissions | ¶29(a)(vi)(2), ¶¶29A–29C |
| Emission factors | None prescribed; use factors that best represent the activity | ¶B29 |
Paragraph B30 puts it beyond doubt that Scope 2 must be disclosed on a location-based approach, which differs from the dual reporting in the GHG Protocol Scope 2 Guidance; the methods are compared on the Scope 2 emissions page.
Emissions are gross, so carbon credits are never deducted from the reported figures.
How Scope 3 is measured and when it must be reported across every UK regime is on the Scope 3 reporting requirements page, and the UK SRS detail on UK SRS Scope 3 reporting.
Metrics and targets
Beyond emissions, ¶29(b)–(e) asks for the amount and percentage of assets or activities vulnerable to transition and physical risks or aligned with opportunities, and the capital deployed towards climate risks and opportunities.
Paragraph 29(f) asks whether and how the entity uses an internal carbon price in decision-making, and the price per tonne it uses.
Paragraph 29(g) asks how climate considerations feed executive remuneration and the percentage of executive pay linked to them.
Paragraph 32 requires industry-based metrics, and in the UK text the entity may, rather than shall, refer to the ISSB’s Industry-based Guidance in choosing them.
For each climate target ¶33 asks for the metric, objective, scope, period, base period, milestones, absolute or intensity basis, and how the latest international agreement on climate change informed it.
Paragraph 34 asks whether a third party validated the target, ¶35 for performance and trends, and ¶36 for each emissions target’s gases and scopes, whether it is gross or net, whether a sectoral decarbonisation approach was used, and the planned use of carbon credits.
A net target always carries its gross target, under ¶36(c), and nothing in the standard requires a target to be validated by any particular body.
Reliefs
| Relief | In UK SRS S2 | For listed companies under the FCA rules |
|---|---|---|
| No comparatives in year one | ¶C1 | No comparatives for the first period (UKLR TP 16.6G(2)) |
| Other GHG method in year one | ¶C3: first annual reporting period only, if used in the year before | Unaffected by the FCA rules (TP 16.4R(3)) |
| No Scope 3 (including financed emissions) | ¶C4: no time limit in the standard | Periods beginning before 1 January 2028; state reliance on the TP and ¶C4 |
| Comparatives after a relief | ¶C5: reliefs may continue to apply to comparatives | Scope 3 comparatives needed only from the period after the first disclosed |
For a commercial company the provision is UKLR TP 16.4R(2)(a), and the statement in the annual financial report must name both the transitional provision and UK SRS S2 ¶C4; the other categories have parallel provisions in TP 16.
Using the relief does not engage the explain rules during the relief period, and a company that already discloses Scope 3 may carry on, PS26/19 says.
For voluntary users the relief has no end date, as the FRC’s FAQs confirm.
UK SRS S2 ¶B41 still refers to “paragraph C4(a)”, an IFRS S2 cross-reference; in the UK text the GHG-method relief is ¶C3.
UK versus IFRS
Annex A of the government response is complete: anything not in it is the same as IFRS S2.
| IFRS S2 | UK SRS S2 | Effect |
|---|---|---|
| ¶¶12, 23, 32: “shall” refer to the Industry-based Guidance | “may” | Reference optional; ¶37 and ¶B65(d) keep “shall” |
| None | ¶B59A (new) | Explain why financed emissions cannot be estimated for the same period, the approach used and a plan with a timeline |
| ¶¶C1–C2: effective date | ¶C2: none | Application set by law or FCA rules |
| ¶C4(a): GHG-method relief, first year | ¶C3 | Still limited to the first annual reporting period |
| ¶C4(b): Scope 3 relief, first year | ¶C4 | First-year limit removed |
| None | ¶C6 (new) | Reliefs subject to the Companies Act, FCA rules or another UK authority |
The December 2025 changes to IFRS S2, including the Category 15 limitation and alternatives to GICS for financed emissions, are the ISSB’s amendments, already in the UK text, not UK departures.
Paragraph B59A is the one place the UK is stricter than IFRS S2, and the international standard itself is covered on the IFRS S2 page.
Listed companies
The S2 limb is UKLR 6.6.6R(7A): climate-related financial disclosures prepared in accordance with UK SRS S2, or a statement summarising the S2 disclosure requirements not met, the reasons, and any steps being taken or planned.
It is framed by requirement, where the S1 limb is framed by risk and opportunity.
The FCA’s draft TN 803.1 proposes that a company need not explain each unmet requirement separately and could indicate the headings or paragraphs not disclosed, and that no timeframe is required; it is draft guidance open for comment until 28 October 2026.
Disclosures and explanations sit in the annual financial report, with cross-reference permitted under UK SRS S1 ¶¶B45–B47, and the company says where they can be found under UKLR 6.6.6R(8)(c).
Paragraph (8)(d) requires a statement of whether third-party assurance was obtained, and (8)(e) whether a transition plan has been published and where, or why not.
A company that explains cannot make an unreserved statement of compliance with UK SRS S2, though explanations the standard itself provides for, such as under ¶21, do not break it, the draft says.
The full rule map by listing category is on the UK SRS and the FCA page.
A summary of the UK SRS S2 disclosure requirements that have not been met.
Why those disclosures were not made.
Any steps being taken or planned to make them in future.
Where the disclosures are, whether they were assured, and whether a transition plan is published.
Dates
GHG amendments, effective internationally from 1 January 2027 and built into UK SRS S2.
Voluntary for any entity; no effective date.
Comply or explain across UK SRS for five listing categories.
Proposed guidance on explanations.
Periods beginning on or after this date; Scope 3 relief available with a statement.
Scope 3 disclosed or explained; first annual reports under the rules appear in 2028.
All of UK SRS on comply or explain.
Sources: IFRS Foundation, 11 December 2025 · PS26/19 ¶¶3.12, 3.14, 3.23, 3.24 · DTR 4.1.3R.
Checks
No rule requires UK SRS S2 disclosures, including emissions, to be assured; the FCA asks only for a statement of whether assurance was obtained and its details.
The FCA says it will monitor and enforce compliance with its UK SRS rules along with the FRC, and will publish information on 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 FSMA 2000 section 91.
Assurance options are compared on the sustainability assurance page.
Myths
It does not require dual Scope 2 reporting, a transition plan, a particular target-setting scheme, or assurance.
It does not require every listed paragraph regardless of materiality: UK SRS S1 ¶B25, which S2 applies, lets immaterial information be omitted.
It does not allow offsets to reduce reported emissions, because the emissions figures are gross.
“UK SRS S2 is mandatory for listed companies from 2027” — that was the consultation proposal; the final rules are comply or explain.
“The Scope 3 relief in UK SRS S2 lasts one year” — the standard has no limit; one year is the FCA rule for listed companies.
“Removing GICS was a UK amendment” — the ISSB made that change in December 2025.
“Scenario analysis is optional for smaller companies” — it is required; the approach scales.
Other regimes
For listed companies, UK SRS S2 replaces the TCFD-aligned listing rules from periods beginning on or after 1 January 2027, and the move is covered on the TCFD reporting requirements page.
The Companies Act climate-related financial disclosures remain law, and the FRC says companies need not duplicate them where use of UK SRS S2 is clearly referenced.
SECR continues alongside, with its own energy and emissions figures, as set out on the GHG reporting requirements page.
The sustainability reporting requirements hub maps every UK regime, and the international standard is on the ISSB reporting requirements page.
Check yourself
Each answer names the paragraph or rule it turns on.
The standard is on GOV.UK and the listed-company rules are in PS26/19.
The two standards together are compared on UK SRS S1 and S2.
True or false?
UK SRS S2 requires both location-based and market-based Scope 2.
The Scope 3 relief in UK SRS S2 itself has no time limit.
A smaller company may skip scenario analysis under UK SRS S2.
A net emissions target must be accompanied by its gross target.
The FCA rules require listed companies to publish a transition plan.
The GHG-method relief in UK SRS S2 is limited to the first annual reporting period.
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Frequently asked
UK SRS S2 requires climate-related disclosures in four areas: governance (¶¶5–7), strategy including scenario analysis (¶¶8–23), risk management (¶¶24–26), and metrics and targets (¶¶27–37), which include absolute gross Scope 1, 2 and 3 greenhouse gas emissions, six further cross-industry metric categories, industry-based metrics and climate targets.
It is applied together with UK SRS S1 so far as S1 relates to climate.
No. UK SRS S2 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 require companies listed in UKLR 6, 14, 15, 16 and 22 to disclose in accordance with UK SRS S2 or explain, for accounting periods beginning on or after 1 January 2027.
The FCA had consulted on making S2 compulsory and moved to comply or explain in the final rules.
For listed companies in the five categories, the FCA rules apply to accounting periods beginning on or after 1 January 2027, with first reports in 2028.
A company with a period beginning before then may keep the TCFD-aligned rules or adopt UK SRS early with the same reliefs.
Any other entity can use UK SRS S2 voluntarily now.
Paragraph 29(a)(i) requires absolute gross Scope 3 emissions, and ¶C4 relieves an entity from disclosing them with no time limit in the standard.
Under the FCA rules a listed company may use the relief for periods beginning before 1 January 2028 if it states it is relying on the transitional provision and ¶C4.
After that, Scope 3 is on comply or explain.
No. UK SRS S2 ¶29(a)(v) and ¶B30 require location-based Scope 2 and information about contractual instruments where they exist and inform users’ understanding.
Market-based Scope 2 is permitted but not required, which differs from the dual reporting in the GHG Protocol Scope 2 Guidance.
Yes.
Paragraph 22 requires climate-related scenario analysis to assess climate resilience, using an approach commensurate with the entity’s circumstances.
A simpler qualitative approach can be appropriate, but an entity with high exposure and the necessary skills or resources is required to use a more advanced quantitative approach (¶B17).
The analysis can follow the strategic planning cycle, but the resilience assessment is updated each year (¶B18).
No. Paragraph 14(a)(iv) requires information about any climate-related transition plan the entity has, including key assumptions and dependencies.
The FCA said in PS26/19 that UK SRS S2 does not require entities to have a transition plan, and its rule asks a listed company only to state whether it has published one and where, or why not.
For each climate-related target, ¶33 asks for the metric, objective, scope, period, base period, milestones, whether it is absolute or intensity, and how the latest international agreement on climate change informed it.
Paragraph 34 covers validation and review, ¶35 performance, and ¶36 the gases and scopes of any emissions target, whether it is gross or net, and the planned use of carbon credits.
A net target needs its gross target disclosed too.
Paragraph 32 requires industry-based metrics associated with the entity’s business models and activities.
In UK SRS S2 the entity may, rather than shall, refer to the Industry-based Guidance on Implementing IFRS S2 when choosing them.
The requirement to disclose industry-based metrics remains.
UKLR 6.6.6R(7A) requires climate-related financial disclosures prepared in accordance with UK SRS S2 or, where they are not made or made only in part, a statement setting out a summary of the UK SRS S2 disclosure requirements not met, the reasons, and any steps being taken or planned.
The FCA’s draft TN 803.1 proposes that an explanation need not address each requirement separately and could indicate the headings or paragraphs not disclosed.
Yes.
UK SRS S1 ¶73A says an entity using the reliefs in UK SRS S2 ¶C3 or ¶C4 is not prevented from asserting compliance with UK SRS S2, provided it discloses its use of them alongside the statement of compliance.
A company that explains unmet requirements under the FCA rules cannot make an unreserved statement of compliance.
Annex A of the government’s consultation response lists the differences: no effective date; “may” rather than “shall” refer to the Industry-based Guidance at ¶¶12, 23 and 32; ¶B59A, which requires financial institutions to explain why financed emissions cannot be estimated for the same period; the Scope 3 relief (¶C4) without a time limit; and ¶C6, which makes the reliefs subject to UK law or FCA rules.
The December 2025 GHG amendments are the ISSB’s and are already in the UK text.
For listed companies, yes: PS26/19 replaces the TCFD-aligned listing rules from periods beginning on or after 1 January 2027.
UK SRS S2 builds on the TCFD’s recommendations.
The Companies Act climate-related financial disclosure duty remains, and UK SRS S2 is a national reporting framework that can be used to meet it.
No. Neither UK SRS S2 nor the FCA rules require assurance.
A listed company must state whether it obtained third-party assurance and, if so, the provider, what was assured, the level, the standards used and where the report is.
No. Paragraph 29(a)(i) requires absolute gross emissions, so carbon credits are not netted off.
Paragraph 36(e) asks only for the planned use of carbon credits to achieve any net emissions target, with the scheme, type and other factors needed to judge their credibility.
An entity with asset management, commercial banking or insurance activities discloses financed emissions as part of Scope 3 Category 15 (¶29(a)(vi)(2) and ¶¶B58–B63A).
Where it is impracticable to estimate them for the same period as the financial statements, UK SRS S2 ¶B59A requires the reason, the measurement approach used, and a plan with a timeline, a UK addition not in IFRS S2.
The GHG Protocol Corporate Standard (2004), unless a jurisdictional authority or exchange requires another method (¶29(a)(ii)).
UK SRS S2 ¶C3 lets an entity keep a different method in its first annual reporting period if it used that method in the period immediately before; unlike the Scope 3 relief, this one stays limited to the first year.
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 S2 paragraph reference on this page.
Materiality, location, timing and the compliance-statement rule S2 relies on.
Published 25 February 2026.
Voluntary use by any entity.
The complete list of UK differences, including ¶B59A and the untimed Scope 3 relief.
UK SRS S2 is a national reporting framework for Companies Act s.414CB(6).
Final rules, 30 September 2026; one-year Scope 3 relief.
The made S2 limb and its transitional provisions.
Continuing obligations for commercial companies.
Consultation on draft TN 803.1, comments by 28 October 2026.
Proposed guidance on explanations; draft until finalised.
The annual financial report within four months of year end.
UK SRS S2 differences; no duplication of s.414CB(2A) disclosures.
The international standard and its history.
The amended text UK SRS S2 is built on.
The GHG amendments the UK absorbed into UK SRS S2.
The measurement basis in ¶29(a)(ii).
The Scope 3 categories in ¶29(a)(vi)(1).
Location-based and market-based methods.
The four-pillar structure UK SRS S2 builds on.
The climate-related financial disclosure duty and the national framework route.
Penalties for breach of the listing rules.
A consultation, not law.
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