UK SRS thresholds — who must report, and who doesn't yet

The UK Sustainability Reporting Standards (UK SRS S1 and UK SRS S2) were published in final form by the Department for Business and Trade on 25 February 2026 and are available for voluntary use now. According to 1, mandatory application is delivered separately — through changes to the UK Listing Rules proposed in FCA CP26/5 — rather than through a size-based threshold in the standards themselves. Understanding which mechanism applies to you is essential before you plan a compliance timeline.

Listed companies do not qualify for mandatory UK SRS by size — they qualify by which UK Listing Rules (UKLR) chapter their securities sit under. FCA CP26/5 proposes mandatory UK SRS S2 for issuers within 2:

Companies in scope must begin mandatory reporting under UK SRS S2 for financial years starting on or after 1 January 2027, with Scope 3 emissions disclosure on a comply-or-explain basis from 2028. The broader UK SRS S1 standard follows on a comply-or-explain basis from 1 January 2029 — a two-year relief window built into the FCA's proposal.

Private companies are not in mandatory UK SRS scope today, and the government has not published a private-company threshold. What exists instead is a policy signal: the Modernising Corporate Reporting (MCR) programme, confirmed via a Written Ministerial Statement on 21 October 2025, which proposes extending UK SRS to economically significant private companies. A consultation on scope, thresholds and timing is expected during 2026, with the earliest realistic effective date being periods beginning in 2028 or later.

Until DBT consults, treat every private-company figure on this page — and elsewhere — as commentary. Companies already covered by SECR or in scope for ESOS should keep meeting those existing obligations regardless of how the MCR consultation lands.

No official UK SRS calculation methodology has been published for private companies, because no threshold exists yet. Based on how the Companies Act 2006 and EU CSRD define equivalent size tests, a plausible (but unconfirmed) methodology would likely include:

Full-time equivalent (FTE)Likely basis

Part-time employees counted proportionally, averaged across the financial year — the standard approach used in Companies Act 2006 size tests.

Net turnoverLikely basis

Revenue after VAT, returns and trade discounts, consistent with existing UK company-law definitions.

Gross assetsLikely basis

Total balance-sheet value before depreciation and provisions — again, the existing Companies Act convention rather than a confirmed UK SRS rule.

Two-consecutive-year testEU CSRD

The EU CSRD requires a threshold to be met (or ceased to be met) for two consecutive financial years before status changes — a mechanism UK SRS may or may not mirror.

Companies should not build compliance systems around these assumptions. The MCR consultation, expected during 2026, is where DBT will set out the actual test — see the UK SRS S1 and S2 timeline for how this fits alongside the confirmed listed-company dates.

Group Company & Subsidiary Considerations

UK SRS applies group-level assessment principles to prevent artificial fragmentation and ensure comprehensive reporting:

Parent Company Obligations

Subsidiary Exemptions

Qualifying subsidiaries may claim exemption from separate UK SRS reporting where:

Multinational groups often assume UK SRS and EU CSRD scope will line up, because both regimes originate from the same sustainability-reporting push. In fact the mechanisms differ fundamentally: UK SRS mandatory scope today is a listing-category test, while EU CSRD uses employee, turnover and balance-sheet thresholds that already apply to large private companies. 5

Groups reporting under both regimes should not assume one compliance programme automatically satisfies the other — materiality basis, assurance expectations and disclosure granularity all diverge. See our detailed CSRD vs UK SRS comparison for the full analysis.

Unlike the private-company picture, the listed-company timeline is concrete — proposed by the FCA in 2 and expected to be confirmed once the Policy Statement is published in autumn 2026:

For private companies, there is no equivalent table yet — see the full UK SRS S1 and S2 timeline for how the MCR consultation is expected to slot in from 2028 onward.

Preparation Timeline Recommendations

Companies should begin preparation well before their applicable date:

Companies newly confirmed within UKLR 6, 14, 15, 16 or 22 should expect the FCA's Policy Statement to carry standard first-time accommodations, consistent with how comparable regimes (including CSRD) have phased in new reporters:

First-time applicants should prioritise: engaging stakeholders for a materiality assessment, mapping available sustainability data against UK SRS S2 and UK SRS S1 requirements, and establishing governance and reporting ownership early. Consider engaging sustainability consultants and assurance providers well ahead of the 1 January 2027 deadline.

Two separate uncertainties remain, and it is worth keeping them distinct:

FCA Policy Statement (autumn 2026)Listed companies

Will confirm — or adjust — the CP26/5 proposals: the ~515-company scope, the 1 January 2027 S2 start date, and the Scope 3 and S1 comply-or-explain dates.

MCR consultation (expected 2026)Private companies

Will set out, for the first time, whether and how private companies get a UK SRS threshold — expect employee, turnover and balance-sheet criteria to be proposed and consulted on, not simply announced.

Comply-or-explainTransition mechanism

A relief mechanism where companies must disclose against a standard or explain why they have not — used for UK SRS S1 (2029) and Scope 3 emissions (2028) rather than immediate hard mandates.

UK Sustainability Reporting Standards