UK SRS — who is in scope?
UK SRS who is in scope is decided by company type, not by employee count. The FCA’s CP26/5 proposal targets UKLR categories 6, 16 and 22— around 515 of the ~600 UK-listed companies the proposals affect — from accounting periods beginning on or after 1 January 2027. The other 89, listed only under UKLR 14 or 15, owe a statement about their primary venue and no UK SRS obligation. AIM, private and most non-listed UK companies are out of scope today. DBT has signalled a broader “Modernisation of Corporate Reporting” consultation that may cover private-company application, but it had not launched as of August 2026, with no date or mechanism proposed.
UK SRS — who is in scope today
UK SRS who is in scope is decided by company type, not size. The FCA proposal under CP26/5 anchors the mandatory regime to three UK Listing Rules categories — commercial equity, non-equity and non-voting equity shares, and the transition category.
UK SRS who is in scope: under the FCA’s 1 CP26/5 consultation, the proposed mandatory regime captures around 515 UK-listed companies through three named UK Listing Rules categories.
The test is binary — a company is in the listed category or it is not — rather than the multi-criteria employee/turnover/balance-sheet test used for SECR 2.
The three named categories are UKLR 6 (equity shares, commercial companies), UKLR 16 (non-equity and non-voting equity shares) and UKLR 22 (equity shares, transition) 3.
For the numerical tests that might apply if DBT extends UK SRS S1 to large private companies, see UK SRS thresholds.
Who is out of scope under the FCA proposal
Knowing UK SRS who is in scope is half the answer — the other half is who is explicitly not. AIM, private companies, and UK companies listed only abroad are outside the proposed mandatory regime.
- AIM-listed companiesOut of scope (mandatory)
- AIM is a separate growth market regulated by the London Stock Exchange, not by the FCA under UKLR. AIM companies are not captured by CP26/5's mandatory scope. Many large AIM issuers nonetheless adopt UK SRS voluntarily to satisfy institutional investor demand.
- Private UK companiesOut of scope (today)
- Privately-owned UK companies (Ltd, plc not on a UK regulated market, LLPs without listed debt) are outside CP26/5. They remain subject to SECR if they meet the large-company size test. DBT has signalled a broader ‘Modernisation of Corporate Reporting’ consultation that may cover private-company application of UK SRS S1, but that consultation had not launched as of August 2026 and no date or mechanism has been proposed.
- UK companies listed only abroadOut of scope (mandatory)
- A UK-incorporated company whose only listing is on a non-UK exchange (NYSE, Nasdaq, Euronext) is not within the proposed UK SRS mandatory scope, because UKLR 6 / 16 / 22 only catch UK regulated-market listings. They may still be caught by the EU CSRD via Article 40a — see /csrd-vs-uk-srs.
- Subsidiaries of in-scope parentsReported through parent
- A UK subsidiary of an in-scope listed parent is covered through the parent's consolidated sustainability statement. The subsidiary itself does not file separately under UK SRS but must support the parent's data and controls. See /uk-srs-thresholds for consolidation rules.
- Limited Liability Partnerships (LLPs)Out of scope unless listed
- LLPs are outside UK SRS mandatory scope unless they have listed debt securities falling under UKLR. They remain subject to the LLP Energy and Carbon Report Regulations 2018 (SECR for LLPs).
The three UKLR categories in plain English
What UKLR 6, 16 and 22 actually mean — the FCA's chosen listing categories for in-scope companies under the proposed UK SRS regime.
UK SRS who is in scope — the population required to comply
UKLR 6 captures the bulk of the population — most of the FTSE 350 commercial companies.
UKLR 16 adds listed non-equity and non-voting share classes.
UKLR 22 adds the transition category.
Of roughly 600 UK-listed companies the proposals affect, the FCA counts around 515 required to comply with UK SRS S2 from accounting periods beginning on or after 1 January 2027.
The remaining 89 — listed only under UKLR 14 or 15 — disclose what their primary listing venue requires instead, and carry no UK SRS obligation.
UK SRS S1 and S2 were published on 25 February 2026 4.
The FCA’s mandatory implementation vehicle is the UK Listing Rules 3, which is why the scope test is defined by listing category rather than company size.
The UK SRS standards themselves adapt the ISSB’s IFRS S1 and IFRS S2 5 for UK conditions.
UK SRS who is in scope — edge cases by company type
Most scope questions come from the edges: dual-listed groups, foreign listings, AIM crossover, secondary listings, debt-only listings, recently-delisted companies.
- Dual-listed (UK + US)Edge case
- In scope through the UK listing. A FTSE 100 company also ADR-listed in New York is captured under UKLR 6 regardless of US filing obligations.
- Standard listing (pre-UKLR transition)Edge case
- Standard-listing equity shares migrated into UKLR categories during the 2024 UK Listing Rules reform. Most former standard-listing equity sits inside UKLR 6 today, and is therefore in scope.
- Debt-only listingEdge case
- A UK company with only debt securities on the UK Main Market (no equity listing) is NOT captured by UKLR 6 / 16 / 22 mandatory scope. The FCA may revisit debt-issuer scope in future policy work.
- AIM company with a Main Market intentionEdge case
- Out of scope until the day of admission to the Main Market. Companies preparing to move from AIM to Main Market should treat UK SRS readiness as part of their listing-prospectus preparation.
- Recently delistedEdge case
- A company that delists during the reporting period is not in scope for that period under the FCA proposal, but must comply for any complete accounting period during which it was listed.
- Newly-listed company (IPO)Edge case
- In scope from the first complete accounting period after admission. The prospectus year and partial periods are handled under specific transitional rules in the final Policy Statement.
- Foreign issuer with a UK secondary listingEdge case
- Capture depends on whether the UK listing falls under UKLR 6 / 16 / 22 or a separate overseas-issuer category. Foreign primary listings with UK secondary admission generally are NOT caught, but each case turns on the UKLR category number.
UK SRS scope decision in four steps
A four-step test based on company type, not size. Answer these in order and you will know whether mandatory UK SRS applies to your company.
If · ListingListed under UKLR 6, 16 or 22?
If · SizeLarge under SECR — 2 of 3?
If · EnergyESOS qualification?
When UK SRS who is in scope may broaden
DBT has signalled a broader Modernisation of Corporate Reporting consultation that may test broader S1 scope for large private companies, but as of August 2026 it had not launched. Confirmation depends on that consultation, not the FCA Policy Statement.
The current proposal under FCA CP26/5 1 keeps the mandatory perimeter at UKLR 6, 16 and 22.
The Department for Business & Trade 4 has signalled a broader “Modernisation of Corporate Reporting” consultation that may address private-company application of UK SRS S1, potentially capturing large private UK companies meeting size tests broadly analogous to the EU CSRD thresholds 6— but as of August 2026 that consultation had not launched, and no date or comply-or-explain mechanism has been proposed.
Until DBT’s Modernisation of Corporate Reporting consultation launches and reports, this remains undecided rather than directional.
UK SRS who is in scope is, today, a UKLR test — not a size test. The size test arrives later, if at all.
UK SRS scope analysis — June 2026
Voluntary early adoption ahead of any future scope expansion is being encouraged by the FRC 7 and the institutional investor community.
Companies considering voluntary adoption should sequence preparation around UK SRS readiness assessment and the four UK SRS requirements pillars — governance, strategy, risk management, metrics and targets 4.
UK SRS who is in scope — frequently asked
The questions UK companies ask most often when self-assessing scope: AIM, private, foreign-listed, subsidiaries, future expansion.
Is my AIM-listed company in scope of UK SRS?
Not under the FCA's CP26/5 proposal.
UK SRS S2 mandatory scope, as proposed, applies to UKLR categories 6, 16 and 22 — equity shares in commercial companies, non-equity and non-voting equity shares, and the transition category.
AIM is a separate market regulated by the London Stock Exchange and is not within the FCA's proposed mandatory scope.
AIM companies may adopt UK SRS voluntarily, and many large AIM issuers do so to satisfy investor expectations.
Is a UK private company in scope?
Not under the proposed FCA mandatory regime.
Private UK companies are outside CP26/5 scope, which is anchored to the UK Listing Rules.
The Department for Business & Trade has signalled a broader 'Modernisation of Corporate Reporting' consultation that may cover private-company application of UK SRS S1, but as of August 2026 that consultation had not launched and no date or mechanism has been proposed.
Until then, large private companies remain subject to SECR and may adopt UK SRS voluntarily.
Are foreign-listed companies caught?
Only where they are admitted to trading on a UK regulated market under UKLR 6, 16 or 22.
A UK-incorporated company listed solely on a non-UK exchange (e.g.
NYSE, Euronext) is not within scope of the FCA's proposal.
A dual-listed company with a UK Main Market listing is in scope through the UK listing.
Does my UK subsidiary of an in-scope parent need to report?
Not separately.
UK SRS reporting consolidates at parent level.
A UK subsidiary of an in-scope listed parent is covered through the parent's group sustainability statement — it must supply data and undergo controls testing, but does not file its own UK SRS report.
See /uk-srs-thresholds for the consolidation rules.
When does the scope expand beyond listed companies?
The FCA's autumn 2026 Policy Statement will confirm or amend the proposed UKLR 6, 16 and 22 mandatory regime for listed companies — it does not cover private-company scope, which is a separate DBT strand.
DBT has signalled a broader 'Modernisation of Corporate Reporting' consultation that may address private-company application of UK SRS S1, but as of August 2026 that consultation had not launched, and no date, threshold or mechanism has been proposed.
How is this page different from /uk-srs-thresholds?
This page covers WHO — the named categories of company in scope.
The thresholds page covers HOW — the numerical employee, turnover and balance-sheet tests used to qualify large private companies if and when DBT extends mandatory scope.
Use this page to check whether your company type is caught; use the thresholds page to test the numbers once you've confirmed your type is potentially in scope.
If you confirmed you're in scope
The four follow-on pages cover the numerical thresholds, disclosure requirements, consultation timeline and FCA Policy Statement path.
UK SRS thresholds
Employee, turnover and balance sheet tests for large companies under any future UK SRS scope expansion.
RequirementsUK SRS requirements
The four-pillar disclosure obligations under UK SRS S1 and S2.
ConsultationUK SRS consultation
DBT exposure draft, FCA CP26/5 closure (20 March 2026) and the Policy Statement timeline.
RegulatorUK SRS FCA
FCA approach to mandatory UK SRS S2 climate disclosure for UKLR 6, 16 and 22.
Related guides & references
UK SRS thresholds — employee, turnover and balance sheet tests
The quantitative tests that sit alongside the named categories on this page.
FCA CP26/5 — UK SRS consultation and Policy Statement
The FCA consultation that sets the proposed mandatory scope for UKLR 6, 16 and 22.
UK SRS consultation timeline
DBT exposure draft, FCA CP26/5 closure (20 March 2026) and Policy Statement.
UK SRS requirements — disclosure obligations
Once you confirm you are in scope, the four-pillar disclosure obligations under UK SRS S1 and S2.