UK SRS thresholds · the size tests, to the provision
UK SRS thresholds: there is no size test
UK SRS thresholds do not exist in the sense most people mean: neither UK SRS S1 nor UK SRS S2 contains a turnover, balance sheet or headcount test.
The one reporting duty made so far is the FCA’s, and its final rules in PS26/19 draw scope by listing category, on a comply-or-explain basis from 2027.
The size tests a reader keeps meeting belong to other regimes — SECR, ESOS and the Companies Act — and each is set out below with its paragraph.
The standards
Why UK SRS has no threshold
The Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026, and its UK SRS guidance says they are available for voluntary use by any entity that chooses to do so.
The standards set no effective date and no scope test of their own.
UK SRS S1 ¶E5 is written in the conditional: where an entity is required to apply the standard under UK law or regulations, that requirement comes from the Companies Act, the FCA or another UK regulator.
UK SRS S2 carries the same clause at ¶C6, so the climate standard has no threshold either.
The FCA has now used that route: the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026 was made on 24 September 2026 and comes into force on 1 January 2027.
Its test is where a company’s securities are listed, which is why a small listed company can be in scope while a very large private one is not.
The UK SRS S1 and S2 page explains the two standards themselves.
Not your turnover, balance sheet or headcount.
Whether your securities sit in one of five UK Listing Rules categories — and, for everyone else, whether you choose to use the standards voluntarily.
Source: FCA PS26/19 ¶3.6
FCA PS26/19
The listing categories, in and out
PS26/19 names five categories of the UK Listing Rules sourcebook that report against UK SRS, and six that do not.
Every company in the five reports on the same comply-or-explain basis.
| UK Listing Rules category | Under PS26/19 | Paragraph |
|---|---|---|
| UKLR 6 — equity shares (commercial companies) | In · comply or explain | ¶3.6 |
| UKLR 14 — equity shares (international commercial companies, secondary listing) | In · comply or explain | ¶3.6; ¶1.7 |
| UKLR 15 — certificates representing certain securities (depositary receipts) | In · comply or explain | ¶3.6; ¶1.7 |
| UKLR 16 — non-equity shares and non-voting equity shares | In · comply or explain | ¶3.6 |
| UKLR 22 — equity shares (transition) | In · comply or explain | ¶3.6 |
| UKLR 11 closed-ended investment funds · UKLR 12 open-ended investment companies | Out | ¶3.7 |
| UKLR 13 shell companies | Out | ¶3.7 |
| UKLR 17 debt and debt-like securities · UKLR 18 securitised derivatives · UKLR 19 warrants, options and other miscellaneous securities | Out | ¶3.7 |
How many companies
PS26/19 publishes no total.
CP26/5 Annex 2 ¶43 estimated that around 600 listed companies would be affected — the consultation’s estimate, not a count in the final rules.
PS26/19 ¶4.35 adds that the 89 secondary-listing and depositary-receipt issuers are now subject to the same requirements as domestic listed issuers.
When it bites
For accounting periods beginning on or after 1 January 2027, with first reporting in 2028 (PS26/19 ¶3.12).
The dated sequence, including the two reliefs, is on the UK SRS S1 and S2 timeline, and who is in scope works through the categories one by one.
The FCA’s reasons
Why the final rules refused a size test
A threshold was asked for: PS26/19 ¶2.15 records that some listed companies suggested a threshold-based approach that would let smaller issuers fall out of scope.
The FCA declined, and its reason is the answer to anyone looking for a UK SRS size test.
In its response it says the impact climate risks have on a company depends on the company’s business model and industry-specific climate vulnerabilities, not its size, and gives energy and transport companies as examples likely to be highly affected regardless of size.
Proportionality was handled another way: the FCA said that, given feedback that full UK SRS disclosure is not yet feasible for some smaller issuers, a mandatory approach might be disproportionately burdensome for small companies.
So every company in the five categories reports on the same basis, and a smaller issuer that cannot yet disclose explains.
The FCA’s cost-benefit analysis models the difference: its per-company estimates distinguish large issuers from SME issuers, putting SME costs at 75% of the large-issuer figures.
Those are the FCA’s modelled averages of the extra cost over TCFD-aligned reporting, based on its standard cost model, and not quotes or market prices.
In aggregate the FCA estimates a net present value for the final rules of £174.10 million over ten years (¶4.4).
| A large domestic issuer | One-off | Each year |
|---|---|---|
| Comply with all of UK SRS | £127,900 | £194,700 |
| S2 without Scope 3, explain the rest | £55,600 | £67,600 |
| Explain against all of UK SRS | £22,200 | £8,900 |
Lookup
The size tests people mistake for UK SRS
Every figure below is a statutory size test for a regime that is not UK SRS.
Each is stated as its instrument states it, including whether the limb reads “not more than”, “at least” or “in excess of”.
| Test | Limbs | Status changes | Provision |
|---|---|---|---|
| UK SRS (FCA rules) | Listing category: UKLR 6, 14, 15, 16, 22 | No size limb at all | PS26/19 ¶3.6 |
| SECR — unquoted company | Exempt if two or more of: turnover not more than £36m; balance sheet not more than £18m; not more than 250 employees | Two consecutive years after the first | Sch 7 ¶20B |
| SECR — parent company | Group: £36m net (£43.2m gross); £18m net (£21.6m gross); 250 employees | Two consecutive years after the first | Sch 7 ¶20C |
| SECR — quoted company | Any size | — | Sch 7 Part 7 |
| SECR — LLP | The same three limbs, in modified s.415A(2) | Two consecutive years after the first | SI 2008/1911 reg 12B |
| Companies Act — small | Two or more of: turnover not more than £15m; balance sheet not more than £7.5m; not more than 50 employees | Two consecutive years after the first | CA 2006 s.382(3) |
| Companies Act — medium | Two or more of: turnover not more than £54m; balance sheet not more than £27m; not more than 250 employees | Two consecutive years after the first | CA 2006 s.465(3) |
| Companies Act — medium group | £54m net (£64m gross); £27m net (£32m gross); 250 employees | Two consecutive years after the first | CA 2006 s.466(4) |
| Climate disclosures (CFD) | More than 500 employees, and traded, a bank, insurer or AIM company, or turnover over £500m | Each financial year | CA 2006 s.414CA |
| ESOS | At least 250 employees, or turnover over £44m and balance sheet over £38m | A snapshot on the qualification date | SI 2014/1643 Sch 1 |
SECR
SECR’s test is an exemption, not a threshold
Streamlined Energy and Carbon Reporting reaches a large unquoted company because paragraph 20B exempts every company that meets two or more of its “not more than” conditions, and a large company is one that fails to.
So a company at exactly £36 million turnover meets that condition.
After the first financial year the status is sticky: under ¶20B(1) an exempt company that goes over the limits for one year stays exempt, and comes into scope only in the second consecutive year.
The measurement rules in ¶20B(3) matter at the margin: turnover is pro-rated for a short or long year, the balance sheet total is gross assets, and employees are the monthly average of persons employed.
A parent tests its group under paragraph 20C, net or gross, and a quoted company reports at any size.
The SECR requirements page covers what an in-scope company discloses, and the SECR reporting guide the report itself.
The government’s 2026 post-implementation review recommended keeping SECR with amendments; UK SRS does not replace it.
| Limb | ¶20B(2) wording |
|---|---|
| Turnover | Not more than £36 million |
| Balance sheet total | Not more than £18 million |
| Number of employees | Not more than 250 |
The 2025 uplift
The Companies Act moved. SECR did not.
SI 2024/1303 raised the Companies Act money limbs for financial years beginning on or after 6 April 2025.
The medium-sized test in section 465(3) now reads turnover not more than £54 million and balance sheet total not more than £27 million, with the employee limb unchanged at 250.
The small-company test in section 382(3) now reads £15 million and £7.5 million, with 50 employees.
The same instrument amended Schedule 7 of SI 2008/410 only in Parts 3 and 4, so SECR’s Part 7A table was left at £36 million and £18 million.
The consequence is the one to remember: a company with £40 million turnover, £20 million of assets and 200 staff is medium-sized for its accounts and inside SECR.
The written ministerial statement of 21 October 2025 described the uplift as increasing the monetary thresholds by approximately 50%.
| Small (s.382) | Medium (s.465) | |
|---|---|---|
| Turnover | Not more than £15m | Not more than £54m |
| Balance sheet total | Not more than £7.5m | Not more than £27m |
| Employees | Not more than 50 | Not more than 250 |
ESOS and the climate duty
Two more tests with different shapes
ESOS does not use two-of-three.
Schedule 1 of the ESOS Regulations defines a large undertaking as one that employs at least 250 persons, or has turnover in excess of £44 million and a balance sheet total in excess of £38 million.
The employee limb includes 250 itself; the money limbs do not include £44 million or £38 million exactly, and both must be exceeded.
For Phase 4 the test is taken once, on the qualification date of 31 December 2026, according to the Environment Agency’s Phase 4 guidance, and group aggregation applies.
The ESOS guide covers what qualification then requires.
The Companies Act climate-related financial disclosure duty has a third shape: section 414CA applies to traded companies, banks, insurers, AIM companies and companies with turnover over £500 million, and then excludes any with 500 or fewer employees.
UK SRS S2 is a national reporting framework for that duty, so a large company can discharge it with UK SRS S2 disclosures without being in scope of the FCA’s rules.
Checker
Run one year’s figures through every test
The checker applies each test above to a single year’s single-company figures.
It is deliberately literal: it reads the limbs as the instruments write them, so £36 million turnover counts as meeting SECR’s condition and £44 million does not count as exceeding ESOS’s.
Three things it cannot do for you are group aggregation, the two-consecutive-year rules and the ESOS snapshot date.
If you are listed, the only UK SRS answer is your category, and the UK SRS compliance page sets out what comply or explain then requires.
One year’s figures · five tests
No UK SRS duty.
The FCA rules reach listing categories only, and no private-company threshold is proposed.
Voluntary use remains open.
This year’s figures meet fewer than two of the qualifying conditions, so they point to SECR scope.
After the first year, one year over the limits does not bring an exempt company in.
These figures do not meet the large-undertaking test on their own.
Group aggregation can change that.
Medium-sized on this year’s figures (s.465(3)).
Note that this can sit beside SECR scope: the two tests stopped agreeing on 6 April 2025.
At or under the 500-employee floor, which applies to every limb of s.414CA, so this duty does not arise.
Indicative only, for one year’s single-company figures.
Balance sheet total means gross assets, and employees means the monthly average of persons employed, not full-time equivalents.
Groups aggregate, and each test has its own group rule.
Worked through
The two-year rule, year by year
| Year | Unquoted company’s figures against SECR ¶20B(2) | Status that year | Why |
|---|---|---|---|
| Year 1 (first financial year) | Fails two conditions | In scope | The first year is judged on that year alone — ¶20B(1)(a) |
| Year 2 | Meets two conditions | Still in scope | (b)(i) needs the preceding year met too; (b)(ii) needs it to have been exempt |
| Year 3 | Meets two conditions again | Exempt | Met in this year and the preceding year — ¶20B(1)(b)(i) |
| Year 4 | Fails two conditions | Still exempt | Met in the preceding year and exempt then — ¶20B(1)(b)(iii) |
| Year 5 | Fails two conditions again | In scope | None of the three limbs of ¶20B(1)(b) is satisfied |
The two-year rule is why a single year’s figures never settle a size question for an established company.
It works in both directions: a company does not drop out after one good year under the limits, and does not come in after one bad year over them.
Measurement follows ¶20B(3): turnover is pro-rated for a financial year that is not twelve months, the balance sheet total is the aggregate of the assets shown with no deduction for liabilities, and employees are the average of the monthly headcounts.
The Companies Act uses the same persons-not-FTEs headcount at section 382(6).
None of this touches UK SRS, because neither the standards nor the FCA’s rules have a size limb to which a two-year rule could attach.
Industries
Which industries have disclosure thresholds?
Under UK SRS, none: neither the standards nor the FCA’s rules take a company in or out by sector.
Industry enters UK SRS as content, not scope.
UK SRS S2 ¶32 asks for industry-based metrics associated with the business model, and says the entity may refer to the ISSB’s industry-based guidance, which organises companies into the 77 industries of the SICS classification.
In IFRS S2 that reference is “shall”; the UK made it “may”, and the duty to give some industry metrics remained.
The FCA’s refusal of a size threshold was itself an industry argument: energy and transport companies are likely to be highly affected by climate risks whatever their size.
Sector-specific UK regimes do exist, but they sit outside UK SRS: occupational pension schemes have their own climate reporting duty, and the UK ETS covers installations and aviation and maritime operators by activity.
Pension scheme climate reporting, the UK ETS and UK sustainability reporting by sector cover those.
Private companies
No private-company threshold, and none proposed
No government document proposes a UK SRS threshold or date for private or unlisted companies.
The Modernising corporate reporting consultation, published on 7 September 2026 and open until 30 November 2026, says only that the government will consider how UK SRS should be reflected in the Companies Act 2006.
The same document asks whether to create a new “very large” company category for some non-financial reporting, says the government has an open mind on how to define it, and gives no figures (¶¶57–58).
Any employee or turnover figure you see attached to UK SRS for private companies is therefore someone’s guess or a number borrowed from SECR, ESOS or the EU.
The EU’s own test is different again: after the 2026 amendments, Article 19a(1) of the Accounting Directive reads 1,000 employees and €450 million net turnover, and the Corporate Sustainability Reporting Directive is the instrument behind it; our CSRD and UK SRS comparison sets the two side by side.
Voluntary use needs no threshold: any entity can apply the standards now, and the UK SRS readiness assessment is a structured way to test the gap first.
Groups
Groups and subsidiaries
UK SRS settles one group question directly: UK SRS S1 ¶20 requires the sustainability-related financial disclosures to be for the same reporting entity as the related financial statements.
A listed parent reporting group accounts therefore reports UK SRS for the group.
Because the FCA’s duty attaches to the listed company, there is no UK SRS subsidiary exemption to claim: an unlisted subsidiary has no UK SRS duty of its own.
The size-based regimes each carry their own group rule — SECR ¶20C, Companies Act s.466 and ESOS aggregation across the UK group — and they do not agree with one another.
For what the listed report must contain, see UK SRS reporting, UK SRS S2 and UK SRS S1; for the FCA’s part, the FCA and UK SRS.
The regulators’ own explanations are at the FCA and in the FRC’s sustainability reporting FAQs.
What the consultation proposes
Where the next size test might come from
If a new size test ever reaches UK SRS, it will come through the Companies Act, and the Modernising corporate reporting consultation is the document to watch.
It proposes to remove the directors’ report and move SECR disclosures elsewhere in the annual report, without changing who reports under SECR (¶149).
It says it does not include proposals on the Companies Act climate-related financial disclosure requirements, because a post-implementation review of them is under way (¶147).
It asks whether a new category of “very large” companies should be created for some non-financial reporting obligations, and says the government has an open mind on how to define it (¶¶57–58).
And it says the government will consider how UK SRS should be reflected in the Companies Act (¶¶154–155).
It also records that the Department for Energy Security and Net Zero intends to consult on SECR and ESOS later in 2026 (¶150).
None of that is a threshold, and none of it applies to anybody until legislation follows; a “very large” category is the most likely place a figure would first appear.
UK SRS and MCR tracks the consultation, and modernising corporate reporting covers it in full.
Test yourself
Seven threshold claims, true or false
Each statement on the panel is one we see repeated about UK SRS scope, and each answer names the provision that settles it.
The pattern in the false ones is the same: a size figure from another regime attached to UK SRS, or a one-year reading of a two-year rule.
The pattern in the true ones is that scope follows the listing, not the company’s size, and that a company outside the FCA’s rules can still be inside a different regime.
AIM is the clearest case: AIM securities are not admitted to the Official List, so the listing categories do not reach them, but the Companies Act climate duty names AIM companies with more than 500 employees, as the government’s climate disclosure guidance explains.
UK SRS thresholds: true or false?
A listed commercial company with £20 million turnover is outside the FCA’s UK SRS rules because it is small.
The FCA considered a size threshold and rejected it.
Since 6 April 2025, SECR applies only to unquoted companies above £54 million turnover.
A company that crosses SECR’s limits for one year comes into scope that year.
Part-time employees count as fractions in the SECR and Companies Act headcount tests.
The government has proposed a UK SRS threshold for large private companies.
An AIM company can have a climate reporting duty even though the FCA’s UK SRS rules do not reach it.
0 of 7 answered.
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The rest of the picture
Where the thresholds question leads next
The year’s events that set these rules are logged, with dates, on UK SRS in 2026, and the consultation history on the UK SRS consultation page.
Assurance is not a scope question, but it is the next one most listed companies ask; the sustainability assurance guide explains what the FCA’s statement requires.
For every UK reporting regime in one place, start at sustainability reporting.
Frequently asked
UK SRS thresholds, answered
Is there a UK SRS threshold?
No. UK SRS S1 and S2 contain no size threshold and no effective date.
The only reporting duty made so far is the FCA’s, in PS26/19, and it applies by listing category: companies listed in UKLR 6, 14, 15, 16 or 22 report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, whatever their size.
Who must report under UK SRS?
Companies with securities in five UK Listing Rules categories: UKLR 6 commercial companies, UKLR 14 secondary listings, UKLR 15 depositary receipts, UKLR 16 non-equity and non-voting equity shares, and UKLR 22 transition.
They report against UK SRS or explain, for accounting periods beginning on or after 1 January 2027.
No other UK entity has a UK SRS duty.
How many companies are in scope of UK SRS?
The FCA’s Policy Statement gives no total.
Its consultation, CP26/5, estimated that around 600 listed companies would be affected; that is the consultation’s estimate.
PS26/19 does say that the 89 secondary-listing and depositary-receipt issuers are now subject to the same requirements as domestic listed issuers.
Does UK SRS apply to private companies?
Not as a requirement, and no threshold for private companies has been proposed.
The government’s Modernising corporate reporting consultation, open until 30 November 2026, says the government will consider how UK SRS should be reflected in the Companies Act 2006. It proposes no mechanism, figure or date.
Is the SECR threshold the same as the Companies Act large-company test?
No, not since 6 April 2025.
SECR’s own table in SI 2008/410 Schedule 7 paragraph 20B still uses turnover not more than £36 million, balance sheet total not more than £18 million and not more than 250 employees.
The Companies Act medium-sized limits rose to £54 million and £27 million.
A company can be medium-sized for its accounts and still inside SECR on the same figures.
Do the size tests count part-time employees as fractions?
No. SECR paragraph 20B(3)(c) and Companies Act sections 382(6) and 465(6) count the monthly average number of persons employed under contracts of service.
A part-time employee counts as one person.
UK SRS itself has no employee test.
Is a company on AIM in scope of UK SRS?
Not through the FCA’s rules, which name UK Listing Rules categories and AIM is not one of them.
An AIM company can still be inside the Companies Act climate disclosure duty in section 414CA, which names AIM expressly, if it also has more than 500 employees.
Which industries have disclosure thresholds under UK SRS?
None.
Neither UK SRS nor the FCA’s rules take a company in or out by industry.
Industry enters UK SRS as content: UK SRS S2 paragraph 32 asks for industry-based metrics, and the entity may refer to the ISSB’s industry-based guidance.
The FCA rejected a size threshold partly because energy and transport companies are likely to be highly affected by climate risk whatever their size.
Why did the FCA not set a size threshold for UK SRS?
Some listed companies asked for one.
PS26/19 says the impact of climate risks depends on a company’s business model and industry-specific vulnerabilities, not its size.
The FCA dealt with proportionality through comply or explain instead: a smaller issuer that cannot yet disclose explains.
Am I required to report my emissions?
Not under UK SRS unless you are a listed company in one of the five categories, and even then on a comply-or-explain basis.
Separately, SECR requires quoted companies and large unquoted companies and LLPs to report energy use and Scope 1 and 2 emissions in their annual reports; an unquoted company is exempt if it meets two or more of turnover not more than £36 million, balance sheet not more than £18 million and not more than 250 employees.
Did the 2025 Companies Act size uplift change UK SRS scope?
No. UK SRS has no size test for the uplift to change.
The uplift raised the Companies Act small and medium money limits from 6 April 2025 and left SECR’s own table at £36 million and £18 million, so it did change the relationship between the accounts regime and SECR, but not UK SRS.
What is a very large company under the Companies Act?
There is no single definition today.
The Modernising corporate reporting consultation, open until 30 November 2026, asks whether to create a new very large category for certain non-financial reporting obligations, says the government has an open mind on the definition, and gives no figures.
When does the FCA’s UK SRS requirement start?
For accounting periods beginning on or after 1 January 2027, with first reports in 2028.
The instrument was made on 24 September 2026 and comes into force on 1 January 2027.
A one-year Scope 3 relief and a two-year relief for UK SRS S1 beyond climate apply from initial application.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
First published 30 September 2026. The final rules: comply or explain across UK SRS for five listing categories.
- Financial Conduct AuthorityPS26/19 (PDF), ¶¶3.6–3.7, 3.12 and 4.35
The five categories in scope, the six excluded, the 1 January 2027 start and the 89 secondary-listing issuers now under the same rules.
- Financial Conduct AuthorityCP26/5 (PDF), Annex 2 ¶43
The consultation’s estimate that around 600 listed companies would be affected. PS26/19 gives no count.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
The standards are available for voluntary use by any entity that chooses to do so.
- Department for Business and TradeUK SRS S1 (PDF), ¶20 and ¶E5
The reporting entity rule, and the conditional clause that leaves any requirement to UK law or regulation.
- legislation.gov.ukSI 2008/410 Schedule 7 paragraph 20B
SECR’s exemption for an unquoted company: two or more of the “not more than” conditions, and the two-year rule in ¶20B(1).
- legislation.gov.ukSI 2008/410 Schedule 7 paragraph 20C
The SECR group test, net or gross.
- legislation.gov.ukCompanies Act 2006, section 382(3)
The small-company conditions as substituted from 6 April 2025: £15 million, £7.5 million, 50 employees.
- legislation.gov.ukCompanies Act 2006, section 465(3)
The medium-sized conditions as substituted from 6 April 2025: £54 million, £27 million, 250 employees.
- legislation.gov.ukCompanies Act 2006, section 466(4)
The group medium-sized test, net and gross.
- legislation.gov.ukSI 2024/1303, regulations 2(2), 5(3), 9 and 10
The 2025 size uplift, which applies to financial years beginning on or after 6 April 2025 and leaves SECR’s Part 7A untouched.
- legislation.gov.ukCompanies Act 2006, section 414CA
The climate-related financial disclosure scope, with its 500-employee floor on every limb.
- legislation.gov.ukESOS Regulations 2014, Schedule 1 paragraphs 1 and 1A
At least 250 employees, or turnover over £44 million and balance sheet over £38 million.
- GOV.UK (Environment Agency)How to comply with ESOS Phase 4
The 31 December 2026 qualification date.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document, ¶¶57–58 and 154–155
Open until 30 November 2026. No figure for any “very large” threshold, and no UK SRS proposal.
- London Stock ExchangeAIM Rules for Companies (PDF)
AIM securities are not admitted to the Official List.
- Department for Business and TradeUK SRS S2 (PDF), ¶32
Industry-based metrics, and the “may” reference to the ISSB’s industry guidance.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026, Article 19a(1)
The EU size test for CSRD reporting after the 2026 amendments, for contrast.