UK SRS thresholds — company qualification criteria
Determine whether your company is in scope for UK Sustainability Reporting Standards. Listed companies face immediate application regardless of size; large private companies are captured by the proposed 500-employee · £36m turnover · £18m balance-sheet two-of-three test, phased in through 2028.
Who UK SRS applies to
Public Interest Entities (PIEs) based on specific size and listing criteria. Listed companies have no size exemption; large private companies meet the two-of-three test.
The UK Sustainability Reporting Standards (UK SRS) apply to Public Interest Entities (PIEs) based on specific size and listing criteria. Understanding these thresholds is essential for determining your compliance obligations and implementation timeline. For the complete UKSRS reference — UK Sustainability Reporting Standards — covering S1, S2, deadlines and who must comply.
All UK-listed companies are in
LSE Main Market (premium and standard), AIM with additional criteria, specialist segments meeting the PIE definition, and dual-listed entities where UK is primary.
Listed Company Qualification
UK-listed companies automatically qualify for UK SRS reporting regardless of their size. This includes all companies with equity securities admitted to trading on a UK regulated market, specifically:
Listed companies in scope
Estimated number of UK-listed companies that will be immediately subject to UK SRS requirements, with no size-based exemptions available.
Listed companies must begin UK SRS reporting for financial years starting on or after 1 January 2026, beginning with enhanced climate disclosures under UK SRS S2. Full sustainability disclosures under UK SRS S1 follow in 2027.
The two-of-three test
More than 500 employees · more than £36m net turnover · more than £18m gross assets — meet two for two consecutive financial years.
Large Private Company Thresholds
Large private companies qualify for UK SRS when they meet at least two of the following three criteria for two consecutive financial years: 2
Qualification Criteria (Two of Three Required)
More than 500 employees (average during financial year, full-time equivalent basis)
More than £36 million net turnover (annual revenue after deductions)
More than £18 million gross assets (total balance sheet value)
How to count and measure
Employee FTE, net turnover after VAT and returns, gross balance-sheet assets, group consolidation, two-year test. Aligned with Companies Act 2006 definitions.
Threshold Calculation Methodology
Employee Count Calculation
The 500-employee threshold uses specific calculation rules aligned with Companies Act 2006 definitions: 2
Financial Threshold Measurement
Turnover and balance sheet thresholds follow established company law definitions:
Combined turnover threshold impact
Estimated aggregate turnover of private companies potentially qualifying under the £36m threshold, representing significant economic scope.
Group-level assessment principles
Ultimate UK parent reports for the group. Subsidiary exemptions where coverage is explicit. Joint ventures on proportionate consolidation. Complex structures need specialist advice.
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:
UK SRS vs EU CSRD thresholds
Alignment with EU CSRD criteria lets multinational groups reuse the same threshold assessment and data collection — though disclosure requirements still diverge.
UK SRS thresholds align closely with international frameworks, particularly the EU Corporate Sustainability Reporting Directive (CSRD). This alignment facilitates compliance for multinational groups: 3
The alignment with EU CSRD criteria enables companies operating in both jurisdictions to leverage similar threshold assessments and data collection processes. However, disclosure requirements and assurance standards may differ between frameworks. See our detailed comparison guide for comprehensive analysis.
Three-phase implementation schedule
Phase 1 Jan 2026 large listed climate-only · Phase 2 Jan 2027 full UK SRS S1+S2 for large listed · Phase 3 Jan 2028 large private companies (subject to consultation).
Implementation Phases & Timeline
UK SRS implementation follows a phased approach to allow companies adequate preparation time: 5
Three-Phase Implementation Schedule
Large listed companies: Climate disclosures only (UK SRS S2). Enhanced TCFD framework with mandatory risk and opportunity reporting.
Large listed companies: Full sustainability disclosures (UK SRS S1 + S2). Complete environmental, social, and governance reporting.
Large private companies: Subject to consultation outcomes. May include phased disclosure requirements or modified thresholds.
Preparation Timeline Recommendations
Companies should begin preparation well before their applicable phase:
If you just crossed the threshold
What to do when your company first qualifies for UK SRS — assessment, governance, data systems, professional support.
First-Time Application Guidance
Companies qualifying for UK SRS for the first time receive specific accommodation and guidance to support initial implementation:
Initial Year Accommodations
Preparation Recommendations
First-time applicants should prioritise these preparation activities:
Months preparation time
Recommended preparation period for first-time UK SRS implementation, including system setup, data collection, and staff training requirements.
Where thresholds may shift
Consultation outcomes still in play. Watch for changes to the £36m/£18m financial criteria, employee count, and the timing of large-private-company phase-in.
Future Threshold Changes & Consultations
The government maintains flexibility to adjust thresholds based on implementation experience and international developments:
Ongoing Consultation Areas
Monitoring and Review Schedule
The Department for Business and Trade has committed to regular review of threshold effectiveness:
UK SRS thresholds — frequently asked
Listed company automatic qualification, two-of-three test mechanics, group aggregation, exemptions, and how to confirm scope each year.
Frequently Asked Questions
Does my listed company automatically qualify for UK SRS?
Yes, all UK-listed companies with equity securities on a regulated market fall within the UK SRS scope immediately. This includes Main Market listings and does not depend on size thresholds. 1 The requirements apply regardless of your company's employee count or financial metrics.
However, implementation phases still apply. Listed companies must begin reporting for financial years starting on or after 1 January 2026 for climate disclosures (S2), with general sustainability disclosures (S1) following in later phases.
How do I calculate the 500-employee threshold for large private companies?
The 500-employee threshold uses the average number of employees during the financial year, calculated on a full-time equivalent basis. This includes:
For group companies, you must aggregate employees across all subsidiaries within your consolidation scope. 2 The threshold is tested over two consecutive years - you qualify if you exceed 500 employees in both years.
What are the turnover and balance sheet thresholds for large companies?
Large private companies must meet at least two of these three criteria for two consecutive years:
These thresholds align with the EU Corporate Sustainability Reporting Directive (CSRD) criteria. 3 Note that the final thresholds for large private companies remain subject to government consultation and may be adjusted before implementation.
How do subsidiary and group company considerations work?
UK SRS applies group-level assessment principles consistent with financial reporting consolidation:
Companies must assess thresholds at the highest UK entity level that prepares consolidated accounts. This prevents artificial fragmentation to avoid reporting requirements.
When do the different implementation phases apply?
UK SRS implementation follows a three-phase approach to allow companies time to prepare:
Your first reporting year determines when you must comply. For example, if your financial year ends in December, your 2026 year-end accounts (filed in 2027) would include the first UK SRS disclosures. 4
What if my company becomes subject to UK SRS for the first time?
First-time applicants receive specific guidance and potential reliefs:
Companies crossing thresholds should begin preparation immediately, as data collection and systems setup typically require 12-18 months before first reporting. Consider engaging with sustainability assurance providers early in the process.
UK Sustainability Reporting Standards
Related guides & references
UK Sustainability Reporting Hub
Complete overview of UK sustainability reporting requirements and frameworks
UK SRS Compliance Guide
Step-by-step implementation roadmap with practical checklists and timelines
UK SRS S1 — General Requirements
Non-climate sustainability disclosure requirements and materiality framework
UK SRS S2 — Climate-Related Disclosures
Enhanced TCFD framework with mandatory climate risk and opportunity reporting
CSRD vs UK SRS Comparison
Detailed comparison of European and UK sustainability reporting requirements
SECR Reporting Guide
Streamlined Energy and Carbon Reporting requirements still in effect