UK SRS timeline — S1 + S2 roadmap

The UK SRS timeline is the calendar that governs UK adoption of the Sustainability Reporting Standards. It starts with the exposure-draft consultation that ran 25 June to 17 September 2025, which drew 209 responses from preparers, investors and professional bodies. Anchor one: 25 February 2026, 1 DBT publishes the final UK SRS S1 and S2 as the UK endorsement of IFRS S1 and S2 with six UK-specific amendments — available for voluntary adoption immediately. Anchor two: 20 March 2026, the 4 FCA CP26/5 consultation closes. Anchor three: autumn 2026, the expected FCA Policy Statement confirming the mandatory regime. Anchor four: 1 January 2027, proposed mandatory start for UK SRS S2 for the roughly 515 in-scope listed companies under UKLR 6, 14, 15, 16 and 22. Anchor five: 1 January 2029, proposed broader UK SRS S1 comply-or-explain extension per 2 DBT guidance, alongside a separate Modernising Corporate Reporting consultation expected during 2026 on extending scope to large private companies.

For the single-date question see UK SRS deadline; for who the timeline catches see UK SRS who is in scope; for the regulatory mechanics see UK SRS regulations; for how this compares with the EU regime see UK SRS vs CSRD/ESRS.

UK SRS timeline — 25 Jun–17 Sep 2025Exposure-draft consultation

DBT's exposure draft of UK SRS S1 and S2 was open for consultation for twelve weeks and received 209 responses from preparers, investors, auditors and professional bodies, shaping the six UK-specific amendments in the final standards.

UK SRS timeline — 25 February 2026DBT publication

Department for Business & Trade publishes final UK SRS S1 and UK SRS S2 as the UK endorsement of IFRS S1 and S2 with six UK-specific amendments. Voluntary early adoption available from this date.

UK SRS timeline — autumn 2026FCA Policy Statement

Expected publication of the FCA Policy Statement on UK SRS, following the CP26/5 consultation that closed 20 March 2026, confirming the final mandatory rule, transitional reliefs, in-scope UKLR categories and the first applicable accounting period.

UK SRS timeline — 1 January 2027Mandatory S2 start

Proposed mandatory start of UK SRS S2 climate disclosure for around 515 UK-listed companies in UKLR 6, 14, 15, 16 and 22 under FCA CP26/5. First reports land in 2028.

UK SRS timeline — 1 January 2029Broader S1 scope

Proposed broader extension of UK SRS S1 on a comply-or-explain basis. Subject to further DBT consultation; would eventually inform any extension to large private UK companies through the Modernising Corporate Reporting programme.

UK SRS S1 and UK SRS S2 represent the foundational framework for sustainability disclosure in the UK capital market. The 1 Department for Business and Trade published both standards on 25 February 2026 as the UK endorsement of the ISSB’s 2 IFRS S1 and S2 baseline.

The standards build directly on the 2 ISSB international baseline with six UK-specific amendments reflecting domestic regulatory priorities. The UK government’s stated preference was to preserve international interoperability: the six amendments are targeted and purposeful, not a wholesale rewrite. Implementation follows a phased approach, with UK SRS S2 climate disclosures proposed mandatory from 1 January 2027 and UK SRS S1 general requirements on a comply-or-explain basis from 1 January 2029.

The phasing reflects the relative maturity of climate data infrastructure. Most large listed companies already collect Scope 1 and 2 emissions data under the FCA’s existing TCFD-aligned Listing Rules. UK SRS S2 builds on that foundation, while UK SRS S1’s broader sustainability topics — biodiversity, water, workforce, supply chain — require more extensive data system development, justifying the later 2029 date confirmed in 3 FCA CP26/5.

UK SRS S1 establishes the overarching architectural requirements for all sustainability-related financial disclosures beyond climate topics, as specified in 1 UK SRS S1 paragraphs 1–15. S1 provides the conceptual framework for materiality assessment, connectivity principles, and disclosure requirements across governance, strategy, risk management, and metrics.

The materiality approach follows single (enterprise-value) materiality — the same investor-focused lens as financial reporting. This is consistent with the 4 SASB materiality guidance and the 2 IFRS S1 global baseline. UK SRS S1 does not require impact materiality assessment — only where mandated by other UK regulatory requirements.

The scope of UK SRS S1 covers all sustainability-related risks and opportunities that could reasonably affect an entity’s cash flows, access to finance, and cost of capital. This includes biodiversity, water scarcity, workforce conditions, supply chain labour, governance ethics, and human rights. The key conceptual foundations apply immediately when implementing UK SRS S2 climate disclosures, because S2 cannot be applied without S1 architectural elements per 1 UK SRS S2 paragraph 3.

The six UK-specific amendments to the IFRS S1 baseline are targeted rather than a wholesale rewrite. The most significant for preparers is the removal of the ISSB’s first-year transitional relief — UK SRS reporters face a more demanding first-year requirement than IFRS S1 reporters elsewhere. Climate-first phasing is reworked to match the UK’s own 2029 date under 3 CP26/5 para 3.52. See the UK-specific amendments guide for the full annotation of all six changes.

UK SRS S2 provides comprehensive climate-related financial disclosure requirements with proposed mandatory implementation from 1 January 2027 for listed companies under 3 FCA CP26/5 paragraph 3.45. S2 builds on the four-pillar TCFD architecture while incorporating substantially enhanced requirements including prescriptive 7 GHG Protocol emissions measurement, mandatory scenario analysis under paragraph 22, and climate transition planning disclosures.

The four pillars — Governance, Strategy, Risk Management, and Metrics & Targets — follow the architecture established by the 6 TCFD recommendations (2017), now superseded by the 9IFRS S2 baseline that UK SRS S2 adopts. Under the Metrics & Targets pillar, paragraph 29(a) requires absolute gross GHG emissions in metric tonnes of CO₂ equivalent, classified by Scope 1, Scope 2, and Scope 3, measured under the GHG Protocol Corporate Standard (2004).

The Scope 3 disclosure requirement applies on a comply-or-explain basis from 1 January 2028 under the 3 CP26/5 paragraph 3.67. Comprehensive value chain emissions coverage across all 8 15 GHG Protocol Scope 3 categories is required where material. Implementation planning for Scope 3 requires systematic capability development — supplier engagement, product-level data collection, and systems integration typically take 12–18 months. Companies that begin building Scope 3 infrastructure in 2026 will be better positioned for the 2028 deadline. See the Scope 3 reporting guide for the full 15-category value chain methodology.

The UK SRS S2 climate framework also connects to the broader UK sustainability reporting landscape and aligns with FRC assurance requirements, set out in the 5FRC’s sustainability reporting FAQs. No mandatory assurance is proposed in the initial phase, but in-scope companies must disclose whether they have obtained third-party assurance on their UK SRS S2 disclosures.

Scope is determined primarily by listing status. Under the 3 FCA CP26/5 proposals, mandatory UK SRS S2 reporting applies to issuers with equity shares or certificates representing equity shares in UKLR 6, closed and open-ended investment companies in UKLR 14/15 where applicable, non-equity shares in UKLR 16, and transition category issuers in UKLR 22. That is approximately 515 UK-incorporated LSE-listed companies. See the UK SRS thresholds guide for the full breakdown by listing category.

Excluded from the initial mandatory scope are closed-ended investment funds, shell companies, debt securities issuers, and securitised derivatives issuers. Commercial companies listed on AIM and other markets not covered by UKLR 6, 14, 15, 16, or 22 are also not proposed for mandatory inclusion in the initial phase. Large private companies are not in scope for mandatory reporting at present — the 1 DBT’s Modernising Corporate Reporting programme, signalled by the Written Ministerial Statement of 21 October 2025, is expected to consult during 2026 on extending UK SRS to large private entities, with any effect no earlier than periods beginning in 2028. Any UK entity may adopt UK SRS voluntarily with immediate effect, provided it makes a full statement of compliance. Use the UK SRS scope checker to confirm applicability.

Market preparation varies significantly across listed companies, with larger entities generally more advanced in TCFD implementation but requiring significant enhancement for full UK SRS S2 compliance. Common readiness gaps include Scope 3 measurement capability, climate scenario assessment sophistication, and the integration of sustainability disclosures with financial statements — a core discipline of the UK SRS framework required by 3 CP26/5 proposed timeline.

Benchmark your organisation’s UK SRS readiness across key capability areas — governance arrangements, data systems, materiality assessment, and disclosure preparation — against the proposed January 2027 mandatory start date. Companies that have not started data gap analysis and governance uplift by mid-2026 face a compressed preparation window. The 1 DBT guidance encourages all entities to begin voluntary adoption now as a readiness measure.

UK SRS S1 and S2 are interconnected standards requiring a coordinated rather than standalone implementation approach. S1 provides the architectural foundation — materiality assessment, connectivity to financial statements, value chain principles — that S2 climate disclosures rely on. Companies cannot apply UK SRS S2 in isolation without understanding UK SRS S1 principles. This relationship is explicit in 1 UK SRS S2 paragraph 3, which states that S2 relies on S1 for its governance and strategy disclosure requirements.

In practice, S2 climate focus provides a practical foundation for broader S1 sustainability topics. Building governance structures, data pipelines, and materiality processes for UK SRS S2 creates infrastructure that can be extended for UK SRS S1 topics from 2029. Implementation planning through the integrated compliance roadmap should address both standards together — covering governance, data systems, and reporting capabilities in one coordinated programme.

Board oversight arrangements must accommodate both climate-specific governance under S2 and the broader sustainability governance framework under S1, with clear accountability structures and reporting lines. Combined data system architecture should support both climate measurement under S2 — GHG emissions across all three scopes, climate scenario assessment capabilities — and broader sustainability KPI tracking under S1, with integration with financial reporting systems for the connectivity requirements in the 2 ISSB baseline. See the comprehensive capability assessment for a structured gap analysis framework.

Implementation timeline is subject to completion of the 9 FCA regulatory process following the CP26/5 consultation that closed 20 March 2026. Key regulatory milestones include the FCA Policy Statement expected autumn 2026, final rules publication, and transitional guidance development through industry engagement.

The autumn 2026 Policy Statement is the critical milestone for in-scope companies. The period between Policy Statement publication and the 1 January 2027 mandatory start will be short — companies that have not started data gap analysis and governance uplift by mid-2026 face a compressed preparation window. The 1 DBT guidance confirms all entities may begin voluntary adoption now as a readiness measure, before any mandatory rules take effect.

Listed companies should begin comprehensive preparation programmes immediately given the proposed January 2027 S2 effective date. Governance establishment typically requires 6–12 month lead times, and data system implementation for full Scope 1, 2, and 3 capability typically requires 12–18 months. Preparation priorities include board sustainability governance arrangements, emissions measurement capability, climate scenario assessment, value chain mapping and supplier engagement, and integration between sustainability and financial reporting teams. Use the systematic implementation planning guide for a structured workstream breakdown.

Market preparation varies significantly across listed companies. Larger entities are generally more advanced in TCFD implementation, but TCFD compliance does not equal UK SRS S2 compliance — the gap analysis focuses on where UK SRS S2 goes further. The original TCFD recommendations published in 2017 were voluntary and principles-based; UK SRS S2 replaces that principles-based guidance with prescriptive requirements, as confirmed in 1 the final standards published by DBT.

Common readiness gaps identified across the in-scope listed company population include: Scope 3 measurement capability across all 8 15 GHG Protocol categories; climate scenario assessment sophistication beyond qualitative narrative; value chain mapping completeness; and the integration between sustainability and financial reporting processes required for the connectivity disclosures in the 2 ISSB baseline.

Readiness assessment should cover both standards together through the comprehensive evaluation framework, identifying priority areas for development and resource allocation. For companies with existing TCFD reporting, the starting point is a gap analysis against UK SRS S2’s enhanced requirements — particularly scenario analysis under paragraph 22, Scope 3 measurement, and the financial-effects connectivity to the balance sheet and income statement.