UK SRS
Material if it could reasonably be expected to influence primary users’ decisions (S1 ¶18).
Single (financial) materiality.UK SRS · ESRS · a gap analysis from the UK side
UK SRS vs ESRS: what a UK SRS reporter adds for the ESRS
UK SRS vs ESRS is, for most UK groups, a practical question: we already report, or will report, under UK SRS — how much of that gets us to the ESRS an EU subsidiary must use?
On climate, most of it: the joint ESRS–ISSB interoperability guidance says almost all ISSB climate disclosures are included in the ESRS.
Beyond climate, and on impacts, very little — because UK SRS S1 applies financial materiality and the ESRS apply double materiality.
The quick answer
Two regimes, one shared ancestor
UK SRS S1 and S2 are the UK’s endorsement of the ISSB’s IFRS S1 and IFRS S2, published by the Department for Business and Trade on 25 February 2026.
The ESRS are the European Sustainability Reporting Standards that the Corporate Sustainability Reporting Directive requires, first adopted by the Commission on 31 July 2023.
UK SRS asks what matters to investors; the ESRS ask that, and also what the company does to people and the environment.
For a UK group with EU operations, the question is rarely “which one” but “how do we satisfy both from one body of work”.
Whether you need the ESRS at all is a scoping question, answered on CSRD in the UK; this page assumes you do, or might.
An entity’s own figures can be read against the EU test on the CSRD thresholds, which are 1,000 employees and €450 million, both exceeded, from financial year 2027.
| UK SRS | ESRS | |
|---|---|---|
| Basis | UK endorsement of ISSB IFRS S1 and S2, with UK amendments | EU standards under the CSRD, drafted by EFRAG |
| Materiality | Single (financial) | Double (impact and financial) |
| Coverage | General (S1) and climate (S2) | Twelve standards across E, S and G |
| Who applies it | Anyone voluntarily; listed companies on comply or explain from 2027 | EU undertakings above €450m and 1,000 employees; non-EU groups via Art 40a |
| Where reported | The annual financial report | The EU management report |
The disclosure map
What a UK SRS report already gives you
Area by area, starting from UK SRS and asking what the ESRS add.
The ESRS column is the revised set in Delegated Regulation (EU) 2026/1563, applying from financial year 2027.
| Area | UK SRS S1 and S2 | ESRS (revised) | For the ESRS |
|---|---|---|---|
| Materiality | Financial only: could the information influence primary users’ decisions (S1 ¶18), by reference to cash flows, access to finance or cost of capital (¶3) | Financial or impact, or both; the financial definition is aligned with IFRS S1 | Gap: the impact assessment — net new work |
| Structure | Four content areas: governance, strategy, risk management, metrics and targets (S1 ¶25) | ESRS 2 general disclosures, and GDR-P, GDR-A, GDR-M and GDR-T for each material topic | Mostly carries; re-cut to ESRS 2’s disclosure requirements |
| Climate governance and strategy | UK SRS S2 | ESRS 2 and E1 | Largely carries: “almost all” ISSB climate disclosures are in the ESRS |
| Transition plan | Information about any plan the entity has; the FCA asks listed companies to say whether one exists and where | The plan; if none, say so and indicate whether and when one is expected | Small gap: the “if none” statement |
| Scope 1 | Required | Required where climate is material, gross | Carries |
| Scope 2 | Location-based required; market-based permitted | Both location-based and market-based | Gap if you report only location-based |
| Scope 3 | Required; one-year relief under the FCA’s rules | Where material | Carries |
| GHG boundary | The GHG Protocol approach the entity chooses | Financial control or operational control approach | Check your approach is one of the two |
| Targets | Targets as set, with any planned use of carbon credits | Gross: no removals, credits or avoided emissions counted | Restate net targets gross |
| Other topics | S1 reaches any sustainability risk or opportunity that meets its test | E2–E5, S1–S4 and G1 wherever material | Gap: topical standards with no UK counterpart |
| Immaterial information | Omitted | “Shall not” be disclosed (ESRS 1 ¶24) | Remove, don’t pad |
| Assurance | Not required; state whether obtained | Limited assurance, including the materiality process | Gap: an assurance engagement |
Read down the last column and a pattern appears: the climate rows mostly carry, the materiality and topic rows do not.
The joint guidance says an entity starting from ISSB standards can meet ESRS E1 by following its Section 4, which lists the E1 disclosures with no ISSB equivalent; it maps the 2023 ESRS paragraph numbers, so check it against the revised text.
The guidance’s limits, including that it calls itself educational material, are set out on the 2024 joint guidance.
The UK-specific amendments in Annex A of the government’s consultation response are mapped paragraph by paragraph there, with no count; none of them adds an impact lens.
The Scope 2 row is the one most often missed: UK SRS S2 is satisfied by a single location-based figure, and the ESRS are not.
Show only
Showing 12 of 12
| Area | What a UK SRS report gives you | What the ESRS add |
|---|---|---|
| Materiality | Financial only: could the information influence primary users’ decisions (S1 ¶18), by reference to cash flows, access to finance or cost of capital (¶3) | Financial or impact, or both; the financial definition is aligned with IFRS S1 — Gap: the impact assessment — net new work |
| Structure | Four content areas: governance, strategy, risk management, metrics and targets (S1 ¶25) | ESRS 2 general disclosures, and GDR-P, GDR-A, GDR-M and GDR-T for each material topic — Mostly carries; re-cut to ESRS 2’s disclosure requirements |
| Climate governance and strategy | UK SRS S2 | ESRS 2 and E1 — Largely carries: “almost all” ISSB climate disclosures are in the ESRS |
| Transition plan | Information about any plan the entity has; the FCA asks listed companies to say whether one exists and where | The plan; if none, say so and indicate whether and when one is expected — Small gap: the “if none” statement |
| Scope 1 | Required | Required where climate is material, gross — Carries |
| Scope 2 | Location-based required; market-based permitted | Both location-based and market-based — Gap if you report only location-based |
| Scope 3 | Required; one-year relief under the FCA’s rules | Where material — Carries |
| GHG boundary | The GHG Protocol approach the entity chooses | Financial control or operational control approach — Check your approach is one of the two |
| Targets | Targets as set, with any planned use of carbon credits | Gross: no removals, credits or avoided emissions counted — Restate net targets gross |
| Other topics | S1 reaches any sustainability risk or opportunity that meets its test | E2–E5, S1–S4 and G1 wherever material — Gap: topical standards with no UK counterpart |
| Immaterial information | Omitted | “Shall not” be disclosed (ESRS 1 ¶24) — Remove, don’t pad |
| Assurance | Not required; state whether obtained | Limited assurance, including the materiality process — Gap: an assurance engagement |
The same mapping as the table above, sorted by how much of the UK work transfers.
Nothing you choose is stored or sent.
The additions
Four things a UK SRS reporter has to add
The map reduces to four additions, and the first is by far the largest.
The impact assessment is net new work, because nothing in UK SRS asks what the company does to people and the environment for its own sake.
Read the additions in detail
The nine topical standards beyond climate apply only where the assessment finds them material, and immaterial information “shall not” be disclosed.
The own-workforce standard is the one most often found material, and it is set out on ESRS S1 in full.
The climate standard’s eleven disclosure requirements, including both Scope 2 methods, are on the revised ESRS E1.
The assurance opinion and who may give it are on assurance under the CSRD.
What the ESRS addExplore
What the ESRS add
Impact lens
Impacts can be material “irrespective of whether they are financially material”.
What the ESRS add
Assurance
A limited assurance opinion on the statement and the process.
The ESRS, briefly
Twelve standards, and a revision on a clock
The first set, Delegated Regulation (EU) 2023/2772, has two cross-cutting standards, ESRS 1 and ESRS 2, and ten topical ones; EFRAG describes the sector-agnostic Set 1 on its site.
The revision kept all twelve, cut the mandatory datapoints by over 60% on the Commission’s figure, and prohibits disclosing immaterial information.
For financial year 2026 a company chooses between the 2023 standards, the revised set early, or the 2023 standards with eight reliefs, and must say which.
Two instruments did two different jobs: Omnibus I narrowed who reports, and the revised ESRS simplified what they report.
Read who writes the ESRS and their tools
The ESRS page goes through the standards and the revision in full, and EFRAG’s sustainability reporting hub carries the texts.
EFRAG advises and the Commission adopts, so the ESRS arrive as EU law; what EFRAG is and does has no UK counterpart.
EFRAG’s draft datapoint note adds that the revised ESRS have no datapoints reported irrespective of materiality, and the datapoint count explains what each figure measures.
Adopted is not in force, and in force is not applied
The revised ESRS were adopted on 3 July 2026 and published in the Official Journal on 21 September 2026 as Delegated Regulation (EU) 2026/1563.
Article 3 puts entry into force at 10 November 2026 and application at financial years beginning on or after 1 January 2027; every date is in the CSRD timeline.
Source: DR (EU) 2026/1563 Art 3
The calendar
The UK and EU dates side by side
For a calendar-year group, the first UK SRS report under the FCA’s rules and the first revised-ESRS statement cover the same year; this chronology is as at 11 October 2026.
- 31 July 202301
- 25 February 202602
- 18 March 202603
Omnibus I in force
The CSRD narrowed to 1,000 employees and €450m from FY2027. - 21 September 202604
- 30 September 202605
- 1 January 202706
Both apply
UK accounting periods and EU financial years beginning on or after this date. - 1 January 202907
UK reliefs expired
Scope 3 and climate-first reliefs have both ended; comply or explain continues.
UK SRS, as the rules now stand
Voluntary standards, comply or explain for listed companies
UK SRS S1 sets the general requirements and UK SRS S2 the climate disclosures, following the four content areas TCFD made familiar: governance, strategy, risk management, and metrics and targets.
The FCA’s final rules, PS26/19 of 30 September 2026, ask listed companies in UKLR 6, 14, 15, 16 and 22 to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
Read the rule detail
They finalise CP26/5, which had proposed making UK SRS S2 mandatory; the final rules adopt comply or explain across all of UK SRS instead.
Two reliefs apply: one year’s non-disclosure of Scope 3, and two years’ non-disclosure of S1 matters beyond climate, with the relief stated and no further explanation needed.
UK SRS S2 builds on IFRS S2, and the ISSB’s climate standard is the text the interoperability guidance maps against ESRS E1.
UK SRS todayExplore
UK SRS today
Reliefs
One year without Scope 3; two years without S1 matters beyond climate.
UK SRS today
Consultation
CP26/5 had proposed a mandatory S2; the final rules did not adopt it.
The difference that drives the rest
Single against double materiality
UK SRS applies single, financial materiality, judged by influence on the decisions of primary users of general purpose financial reports, by reference to cash flows, access to finance or cost of capital.
The ESRS add impact materiality: a matter is reportable if it is material from either perspective.
The joint guidance says the financial definitions are aligned, so the financially material subset of an ESRS assessment is a sound starting point for UK SRS S1, not the other way round.
Read the materiality detail
The concept and its legal source are on double materiality.
The UK test in its own words is on UK SRS materiality, and the two lenses compared on single and double materiality side by side.
The impact side’s own test, with severity and likelihood, is on impact materiality.
One sustainability matter
ESRS
Material on the impact test, the financial test or both (revised ESRS 1 ¶35).
Double materiality.The new work
How a UK SRS reporter builds the impact assessment
The impact assessment is the one piece of ESRS work a UK SRS report gives no head start on.
The revised ESRS 1 says that, in general, the starting point is the assessment of impacts, with risks and opportunities assessed after.
Read how to build it
The revised ESRS require no materiality matrix and no stakeholder survey, and they set no universal numeric threshold.
The steps, with the paragraph behind each, are on running a double materiality assessment, and a working register on the double materiality template.
EFRAG’s IG 1 on materiality is non-authoritative and was written for the 2023 ESRS, as EFRAG’s guidance status sets out.
The impact assessmentExplore
The impact assessment
Impacts first
“In general, the starting point is the assessment of impacts.”
The impact assessment
Severity
Scale, scope and irremediable character; likelihood for potential impacts.
The impact assessment
Engagement
Engagement within due diligence is a key input; no survey is required.
The impact assessment
Disclosure
IRO-1 describes the process; IRO-2 lists what was found material.
Structure, area by area
The four UK SRS content areas, mapped to ESRS 2
UK SRS S1 organises disclosure into four content areas: governance, strategy, risk management, and metrics and targets.
The revised ESRS name four reporting areas that track them closely — governance, strategy including financial effects, the management of impacts, risks and opportunities, and metrics and targets — and deliver them through ESRS 2.
Governance carries best: a UK board’s description of who oversees climate and how it is informed maps onto GOV-1, with GOV-4’s internal-controls disclosure as the addition.
Strategy carries in part: SBM-3’s financial effects resemble the UK’s, but SBM-1 asks for the business model and value chain in more detail and SBM-2 for stakeholders’ views.
Risk management carries least, because IRO-1 describes a process that assesses impacts as well as risks.
Metrics and targets carry for climate, and the ESRS then add the metrics of every other material topic.
ESRS 2’s disclosures are, in the standard’s words, “likely to result in material information for all undertakings”, which is why the re-cut starts there.
The UK structure is set out on UK SRS S1, and the ESRS 2 disclosures one by one on the UK guide to CSRD.
| UK SRS content area | Where it lands in the ESRS |
|---|---|
| Governance | ESRS 2 GOV-1 to GOV-4, including internal controls over sustainability reporting |
| Strategy | ESRS 2 SBM-1 to SBM-3, including current and anticipated financial effects |
| Risk management | ESRS 2 IRO-1, which describes the process for impacts as well as risks |
| Metrics and targets | GDR-M and GDR-T, and the metrics in each material topical standard |
Transition plans
Two different questions about the same plan
Neither regime requires a company to have a transition plan, and both ask about it.
Under the FCA’s final rules, a listed company in UKLR 6, 16 or 22 states in its annual financial report whether it has published a climate-related transition plan and, if so, where it can be found; if it has not, it says why not.
The FCA put it plainly in PS26/19: it is not requiring listed companies to produce transition plans.
ESRS E1 asks for the plan’s key features where there is one, and where there is none, for a statement of that fact and an indication of whether and, if so, when one is expected.
Read how to draft both
So a UK company without a plan writes a “why not” for the FCA and a “whether and when” for the ESRS — two sentences that are worth drafting together.
Where a plan exists, E1-1 asks for more of its content in the statement itself, including investment and funding and compatibility with limiting warming to 1.5°C.
The UK SRS transition plan disclosures page covers the UK side, and climate transition plans covers what a plan contains.
Transition plansExplore
Transition plans
FCA statement
UKLR 6, 16 and 22: whether a plan is published, where, or why not.
Transition plans
No UK duty
The FCA is not requiring listed companies to produce transition plans.
Transition plans
ESRS E1
Key features, or a statement that there is none and whether and when one is expected.
Transition plans
E1-1 content
Investment and funding, and compatibility with 1.5°C, where a plan exists.
Where UK SRS sits at home
UK SRS beside SECR, ESOS and the old TCFD rules
UK SRS is not the only UK reporting duty, and comparing it with the ESRS only makes sense once the rest of the UK stack is in view.
For listed companies, the FCA’s UK SRS rules replace the TCFD-aligned disclosures they made before; the TCFD to UK SRS migration guide shows how the old disclosures move across.
Read the rest of the UK stack
SECR continues to require energy and carbon reporting in the directors’ report for companies that meet its own tests, and energy savings opportunity scheme continues on its own cycle.
The FCA rules reach only the listing categories set out on who is in scope of UK SRS; everyone else may use the standards voluntarily.
What “comply or explain” requires in practice is on UK SRS compliance, and the dates are in the dated UK SRS register.
The ESRS sit outside all of this, and reach a UK group only through the routes on CSRD in the UK.
The UK stackExplore
The UK stack
ESRS
Outside the UK stack; reaches a UK group only through EU entities.
Who the reports are for
What a UK investor gets from each
UK SRS is written for primary users of general purpose financial reports — investors, lenders and other creditors — and asks what could affect the company’s prospects.
The ESRS are written for those users and for others, such as business partners, trade unions and civil society, and add what the company does to people and the environment.
Read the investor view
For a UK investor holding a European company, the ESRS statement therefore contains the investor-relevant information and more, and the financially material subset is defined in terms aligned with IFRS S1.
For a UK investor holding a UK listed company, the UK SRS report under the FCA’s rules is the source, and its explanations matter as much as its disclosures in the first years.
An investor comparing the two should compare the climate sections directly and treat the ESRS impact disclosures as additional, not as a different answer to the same question; ESG reporting in practice covers the voluntary frameworks investors also use.
The wider contrast between the EU regime and the ISSB baseline UK SRS is built on is set out on the CSRD against the ISSB standards.
ReadersExplore
Readers
ESRS readers
Those users, and business partners, trade unions and civil society.
Test yourself
Five claims about UK SRS and the ESRS, checked
Each claim appears in comparisons of the two regimes written for UK readers, and each is settled by the provision named under it.
The second changed on 30 September 2026, when the FCA’s final rules departed from its own consultation.
The third and fourth are the two most useful facts for a group planning to report under both: one is a data gap, the other is the reason the financial work transfers.
UK SRS vs ESRS: true or false?
A UK SRS report satisfies a CSRD obligation.
UK SRS S2 is mandatory for UK listed companies from 2027.
ESRS E1 asks for both location-based and market-based Scope 2.
The financial materiality definitions in ESRS and IFRS S1 are aligned.
CSRD reports must be reasonably assured from 2028.
0 of 5 answered.
Nothing you choose is stored or sent.
EFRAG’s tools
Three EU resources a UK reporter meets for the first time
A UK SRS reporter moving to the ESRS meets EFRAG’s resources, which have no UK SRS counterpart.
The most tempting, the draft datapoint list, is the one EFRAG says “must not be used as a checklist”.
Read the EFRAG resources detail
What the list counts is on ESRS datapoints, and the digital format on the draft XBRL taxonomy, as at 11 October 2026.
A checklist keyed to the rules rather than to datapoints is on the CSRD readiness checklist.
EFRAG’s resourcesExplore
EFRAG’s resources
Knowledge Hub
The delegated-act text, rendered standard by standard.
Dual reporting
Plan once, report twice
Build once
The Scope 1, 2 and 3 inventory, the governance record, the transition plan and the control environment serve both regimes.
Capture market-based Scope 2 from the start.
Assess twice
Run the double materiality assessment for the EU entity, and take its financially material subset as the UK SRS starting point.
Share the data, separate the conclusions.
Assure once, where you must
The EU statement needs limited assurance.
A UK SRS report needs none; if assurance is obtained, the UK report names the provider, what was assured and the standard used.
The order of work that avoids rework: establish the CSRD route and filing entity, build the inventory to the more demanding of the two standards, run the double materiality assessment, then cut the UK SRS report from it.
- 01 / Scope01
- 02 / Assess02
- 03 / Collect03
- 04 / Extend04
- 05 / Assure05
- 06 / Report06
Two documents
The ESRS statement in the EU management report; UK SRS in the UK annual report.
The sequence is an illustration, not a timetable either regime prescribes.
To talk a specific group through it, book a free 15-minute call.
Frequently asked
Questions people ask
What is the difference between UK SRS and ESRS?
UK SRS S1 and S2 are the UK’s endorsement of the ISSB’s IFRS S1 and S2: financial materiality, a general standard and a climate standard, written for investors and lenders.
The ESRS are the EU’s standards under the CSRD: double materiality across twelve standards covering environmental, social and governance topics.
On climate the two overlap heavily; beyond climate, and on impacts, the ESRS ask for much more.
Does a UK SRS report satisfy the ESRS?
No. A UK SRS report gives a strong start on climate — the joint ESRS–ISSB guidance says almost all ISSB climate disclosures are included in the ESRS — but the ESRS add the impact lens, nine other topical standards, both Scope 2 methods, gross targets and a statement if there is no transition plan.
Neither regime treats the other as satisfying it.
Is UK SRS mandatory?
No. UK SRS S1 and S2 are voluntary standards.
The FCA’s final rules, PS26/19 of 30 September 2026, require listed companies in UKLR 6, 14, 15, 16 and 22 to report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reports in 2028.
How many ESRS are there?
Twelve: two cross-cutting standards, ESRS 1 General Requirements and ESRS 2 General Disclosures, and ten topical standards, E1 to E5 on the environment, S1 to S4 on social matters and G1 on business conduct.
The 2026 revision kept all twelve.
Do UK companies have to comply with ESRS?
Only if the CSRD reaches them: through an EU subsidiary or EU parent group exceeding €450 million of net turnover and an average of 1,000 employees, an EU regulated-market listing, or, from financial year 2028, Article 40a for non-EU groups with large EU turnover.
Are UK SRS and ESRS converging?
On climate, largely: both build on the same climate architecture and the joint interoperability guidance maps them.
The revised ESRS, applying from 2027, cut datapoints and kept the alignment of the financial-materiality definition with IFRS S1.
The core difference — single against double materiality — remains.
Which Scope 2 figure does each regime want?
UK SRS S2 requires location-based Scope 2 and permits market-based.
ESRS E1 asks for both location-based and market-based figures.
A UK group reporting under both has to produce the market-based number for the ESRS.
Is assurance required under either regime?
Under the CSRD, yes: a limited assurance opinion, with no legislated move to reasonable assurance.
Under the FCA’s rules for UK SRS, no: a listed company states whether it obtained assurance and, if so, the provider, scope and standard.
What is UK SRS?
UK SRS are the UK Sustainability Reporting Standards: UK SRS S1 on general requirements and UK SRS S2 on climate, the UK’s endorsement of the ISSB’s IFRS S1 and S2 with UK amendments.
The Department for Business and Trade published them on 25 February 2026 for voluntary use; the FCA’s rules ask listed companies to report against them on a comply-or-explain basis from 2027.
Is UK SRS the same as IFRS S1 and S2?
Almost.
UK SRS S1 and S2 are based on IFRS S1 and S2, with UK amendments that the government’s consultation response maps paragraph by paragraph in its Annex A. None of the amendments adds an impact lens, so UK SRS keeps the ISSB’s financial materiality.
Does UK SRS cover social topics as the ESRS do?
Only through UK SRS S1, and only where a sustainability-related risk or opportunity could reasonably be expected to affect the company’s prospects.
There is no UK counterpart to the ESRS standards on own workforce, value-chain workers, communities or consumers, and the FCA’s rules give two years’ relief on S1 matters beyond climate.
What does each regime say about transition plans?
Neither requires one.
Under the FCA’s rules a listed company in UKLR 6, 16 or 22 says whether it has published a transition plan, where, and if not, why not.
ESRS E1 asks for the plan’s key features, or a statement that there is none and whether and when one is expected.
Can one data set serve both UK SRS and the ESRS?
For climate, largely yes: one GHG Protocol inventory, captured with both Scope 2 methods and Scope 3 by significant category, serves UK SRS S2 and ESRS E1.
The materiality conclusions cannot be shared wholesale, because the ESRS add impacts; the financially material subset of an ESRS assessment is the natural UK starting point.
Does a UK SRS reporter need a stakeholder survey for the ESRS?
No. The revised ESRS require no stakeholder survey (ESRS 1 AR 24).
They do say that the results of engagement with affected stakeholders, carried out in the context of ongoing sustainability due diligence, are a key input to the impact materiality assessment (¶42).
The impact assessment is the new work; a survey is one possible way to gather evidence for it, not a requirement.
Does the ESRS require a materiality matrix?
No. The revised ESRS do not mention a materiality matrix; a matrix is an optional presentation choice.
What the statement must describe is the process and its results, under ESRS 2 IRO-1 and IRO-2.
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.
Checked against 15 sources fromDepartment for Business and TradeFinancial Conduct AuthorityEUR-LexCouncil of the EUEFRAGIFRS Foundation / EFRAG
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026 for voluntary use.
- Department for Business and TradeUK SRS S1 General Requirements — ¶3, ¶18, ¶25
Financial materiality; the four content areas.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — ¶29(a)(v), ¶¶B30–B31
Location-based Scope 2 required; market-based permitted.
- Department for Business and TradeExposure drafts of UK SRS: consultation response, Annex A
The paragraph map of UK differences from IFRS S1 and S2; it gives no count.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards
Final rules, 30 September 2026: comply or explain against UK SRS for UKLR 6, 14, 15, 16 and 22.
- Financial Conduct AuthorityPS26/19 (PDF) — ¶¶1.7, 2.37, 2.45, 3.12, 3.14, 3.23–3.24
The reliefs and when they end, the transition-plan statement and the assurance statement.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — the revised ESRS
Applies from financial years beginning on or after 1 January 2027; three options for FY2026.
- Council of the EUC(2026) 5010 final, Annex I — revised ESRS 1 and 2
GDR-P/A/M/T; GOV-4; the GHG boundary choice; ESRS 1 ¶24.
- EFRAGESRS Knowledge Hub — ESRS E1, delegated-act text
E1 wording on transition plans, gross targets and both Scope 2 methods.
- EFRAGESRS Knowledge Hub — revised ESRS 2 General Disclosures (delegated-act text)
GOV, SBM and IRO disclosures that the UK SRS content areas map onto.
- IFRS Foundation / EFRAGESRS–ISSB Standards Interoperability Guidance, 2 May 2024
“almost all the disclosures in ISSB Standards related to climate are included in ESRS”; financial materiality aligned.
- EFRAG2026 Draft List of Datapoints — Explanatory Note, 28 August 2026
“It must not be used as a checklist”; no datapoint reported irrespective of materiality (¶68).
- EFRAGESRS implementation guidance documents
IG 1–3 are non-authoritative and relate to the 2023 ESRS.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Arts 19a, 29a, 34
The CSRD scope test and limited assurance.
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
Narrowed who reports; removed the reasonable-assurance empowerment.
Continue reading
Read next
Scope
CSRD in the UK: four routes in
Whether the CSRD reaches your group, and who files.
Concept
Double materiality
The two lenses and where EU law writes them down.
The UK standards
UK SRS S1 and S2
The two UK standards and how they apply together.
The other direction
ESRS vs UK SRS
The same comparison from an ESRS statement toward UK SRS.
Publication history
Read the revised ESRS publication record
For the adoption and publication sequence, read our EU revised ESRS 2026 source-led news record alongside this comparison.