UK SRS vs ESRS: starting from a UK SRS report

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.

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, eleven 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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.