UK SRSThe UK Sustainability Reporting Standards, ESOS, SECR and TCFD, read against the published text.HUBYOU ARE HEREUK SRS GuideAn independent reference guide to UK SRS, ESG, TCFD, SECR, ESOS and the global standards.Global Reporting StandardsSustainability reporting standards worldwide: ISSB, the EU CSRD after Omnibus I, California SB 253 and SB 261, and UK SRS.UK SRS StandardsUK SRS S1 and S2 at the provision: reliefs, comply or explain, and the FCA statements.ESOS QuestESOS Phase 4 in depth: qualification, the audit, sign-off, action plans and penalties, read against the Regulations.SRS EngineeringThe data build behind a UK SRS report: metrics, owners, controls and timing.SRS ReportWhat a UK SRS report contains, how it is assembled, and how to read one.UK SRS ReportAnalysis and commentary: CDP, the DESNZ emission factors, SECR and ESOS, with every figure cited.UK SRS NewsThe cluster's news publication, and what a UK SRS report contains.UK SRS DeliveryTemplates, costs, ESOS delivery guides and readiness assessment.UK SRS FinanceFinanced emissions, PCAF and IFRS S1/S2 for banks, insurers and asset managers.SECRStreamlined Energy and Carbon Reporting: deadlines, thresholds, eligibility and guidance.Carbon CreditsCarbon credit ratings, risk analysis, valuation and market structure.Environmental RegimesThe eight UK environmental reporting regimes, their thresholds, deadlines and regulators.UK SRS ServicesThe services arm: ESOS, SECR, net zero and sustainability consultancy.

UK SRS scope · FCA PS26/19 ¶¶3.6–3.7

UK SRS: who is in scope?

Start with the securities’ listing category. The five categories are in scope on comply or explain; company size is a separate question.

For listed issuers in scope, the rules apply to periods beginning on or after 1 January 2027. PS26/19 sets the route and transitional reliefs.

UK SRS who is in scope diagram: scope, records and publication
A preparation sequence, not a compliance finding

In scope

The five categories the rules reach

Each category has its own annual-report rule; the UK SRS limb in each reads the same way as UKLR 6.6.6R(7A).

Equity shares of commercial companies. International commercial companies with a secondary listing.

Read the paragraph-level reference
Sources: PS26/19 ¶3.6 and Appendix 1, Annex B (ESG 2.2.6R cross-references) · UK Listing Rules. All five report on comply or explain, with the same reliefs.
CategorySecuritiesWhere the UK SRS limb sitsTransition-plan statement
UKLR 6Equity shares (commercial companies)UKLR 6.6.6R(7A), (7B), (8)Yes
UKLR 14Equity shares (international commercial companies secondary listing)UKLR 14.3.24R(4)No
UKLR 15Certificates representing certain securities (depositary receipts)Through UKLR 15.3No
UKLR 16Non-equity shares and non-voting equity sharesUKLR 16.3.23R(4)Yes
UKLR 22Equity shares (transition)UKLR 22.2.24R(4)Yes

The rules sit in amended UKLR 6.6, 14.3, 15.3, 16.3 and 22.2, with transitional provisions in UKLR TP 16 (PS26/19 ¶¶3.9–3.10).

For a commercial company, UKLR 6.6.6R(7A) asks for climate disclosures under UK SRS S2 or an explanation, and (7B) does the same for UK SRS S1 beyond climate; the FCA and UK SRS takes each limb in turn.

What the report must then contain is on UK SRS reporting, and the climate standard itself on UK SRS S2.

Premium and standard listing no longer exist; the UK Listing Rules replaced them on 29 July 2024, so the category, not the old segment, is the test.

Five listing categoriesExplore

Five listing categories

UKLR 6

Equity shares of commercial companies.

The decision

The scope question in four steps

Check the listing category, reporting entity and separate statutory duties before deciding your reporting route.

Read the full provisions and conditions

1 · Are any of your securities on the UK Official List?

If not — AIM, private, LLP, overseas-only — the FCA’s UK SRS rules do not reach you.

Go to step 4.

2 · Which category are they in?

UKLR 6, 14, 15, 16 or 22: in scope.

UKLR 11, 12, 13, 17, 18 or 19: out.

A company with listings in more than one category is in if any one of them is in scope.

3 · When does your accounting period begin?

Periods beginning on or after 1 January 2027 report against UK SRS or explain; earlier periods stay on the TCFD rule unless you adopt early.

4 · Which other duties apply?

SECR, ESOS and the Companies Act climate duty have their own size tests, whatever the answer above.

Steps 1 and 2 are the whole UK SRS scope test; there is no third limb of size, sector or headcount.

Step 3 tells you when; the first period for every month of year-start is set out on the UK SRS deadline.

The interactive version is the UK SRS scope checker, which walks a company through steps 1 to 3 and names the provisions.

  1. 1

    Official List

    Check whether the securities are on the UK Official List.

  2. 2

    Listing category

    Identify whether UKLR 6, 14, 15, 16 or 22 applies.

  3. 3

    Reporting entity

    Use the same reporting entity as the related financial statements.

  4. 4

    Other duties

    Check separate regimes even if the FCA UK SRS route does not apply.

Find your kind of entity

Fourteen kinds of entity, and where each one lands

Filter to the entities in scope, those out, or those caught by other duties instead, or search for your own kind of company.

Filter by outcome

Showing 14 of 14

EntityCategoryOutcome under the FCA’s rules
UK company with shares listed as a commercial companyUKLR 6In — comply or explain, with transition-plan statement
Overseas company with a secondary listing in LondonUKLR 14In — may rely on aligned home reporting; no transition-plan statement
Issuer of depositary receiptsUKLR 15In — as UKLR 14
Issuer of listed preference or non-voting sharesUKLR 16In — with transition-plan statement
Company in the transition categoryUKLR 22In — with transition-plan statement
Investment trust or other closed-ended fundUKLR 11Out — reached through the asset manager
Open-ended investment companyUKLR 12Out
Shell company (a SPAC, for example)UKLR 13Out
Issuer of listed bonds onlyUKLR 17Out
Issuer of securitised derivatives, warrants or optionsUKLR 18, 19Out
AIM company with more than 500 employeesNot a UKLR categoryOut of UK SRS rules; in the Companies Act climate duty
Large private company or LLPNo listingOut of UK SRS rules; SECR and CFD by size
UK subsidiary of a listed groupIts parent’s categoryNo duty of its own; feeds the group report
UK group listed only overseasNo UK listingOut of UK SRS rules; EU or home rules may apply

Sources: FCA PS26/19 ¶¶1.7, 3.6–3.7 and the responses after ¶¶2.44 and 2.67; CA 2006 s 414CA; LSE AIM Rules.

Nothing you choose is stored or sent.

Excluded

Six categories out, and the FCA’s reasons

PS26/19 ¶3.7 excludes funds because “the best way to introduce requirements for investment vehicles is through obligations on the asset manager, rather than the listed funds”.

Asset managers have their own climate reporting under the FCA’s ESG sourcebook, which is why a listed investment trust is out while its manager may not be.

Read the paragraph-level reference

Shell companies are out because their purpose is an acquisition or merger and they have no substantial operations to report on.

For debt, securitised derivatives and warrants the FCA says it does “not consider it to be proportionate or effective to extend requirements to these issuers” — without the “at this time” its consultation had used.

The category, not the label, decides: a property company admitted as a commercial company in UKLR 6 is in scope, while a fund admitted under UKLR 11 is not.

Source: PS26/19 ¶3.7
CategorySecuritiesReason given
UKLR 11Closed-ended investment fundsReached through the asset manager
UKLR 12Open-ended investment companiesReached through the asset manager
UKLR 13Shell companiesNo substantial operations
UKLR 17Debt and debt-like securitiesNot proportionate or effective
UKLR 18Securitised derivativesNot proportionate or effective
UKLR 19Warrants, options and other miscellaneous securitiesNot proportionate or effective
Six excluded categoriesExplore

Six excluded categories

UKLR 11 / 12

Closed-ended investment funds and open-ended investment companies.

How many companies

The rules give no company count

PS26/19 contains no total of the companies its rules reach, so this page gives none either.

It does say that the 89 issuers with a secondary listing or depositary receipts, which its consultation had put on a lighter statement route, “are subject to the same requirements as domestic listed issuers” (¶4.35).

Read the paragraph-level reference

The consultation’s cost-benefit analysis estimated around 600 affected companies; any figure quoted as the number that “must comply” is describing a proposal the final rules replaced.

The population also moves: companies join and leave the Official List every month, which is one more reason a fixed count would mislead.

How the consultation’s estimates were built, and what the FCA changed, is on the UK SRS consultation.

The only published figure

CP26/5 estimated that around 600 listed companies would be affected, based on the Official List as of January 2025.

That is the consultation’s estimate, made for a different design of rules.

Source: CP26/5, Annex 2 ¶43

Do not invent a totalExplore

Do not invent a total

Made rules

Scope is defined by category; the final rules give no total company count.

Edge cases

The edges, where most scope questions come from

Outside this listing-rule route; check Companies Act climate duties separately. No FCA UK SRS duty under these listing rules; other duties may apply.

Read the paragraph-level reference

AIM companies

Outside the FCA’s UK SRS rules: AIM is not a UK Listing Rules category.

Possibly inside the Companies Act climate duty, which names AIM companies at s 414CA(1)(e) but bites only above 500 employees.

Private companies and LLPs

No UK SRS duty, and none proposed.

SECR and the Companies Act or LLP climate duties may apply by size; the SECR reporting guide covers the first.

Subsidiaries of listed groups

No UK SRS duty of their own unless separately listed in scope.

The parent reports for the same reporting entity as its consolidated accounts (UK SRS S1 ¶20), so subsidiary data feeds the group report.

International companies listed in London

In scope through UKLR 14 or, for depositary receipts, UKLR 15.

Home-jurisdiction reporting that aligns with UK SRS outcomes may already broadly comply; gaps are explained.

UK companies listed only overseas

Outside the FCA’s rules, which follow admission to the UK Official List.

EU rules may still reach the group through its EU business; see CSRD vs UK SRS and the CSRD itself.

Debt-only issuers and funds

Outside: UKLR 17 debt and UKLR 11 and 12 funds are among the six excluded categories.

A company with both listed equity in UKLR 6 and listed bonds is in scope through its equity.

Admissions and cancellations part-way through a year: the rules attach to the annual financial report each category’s rules require, and PS26/19 contains no special provision for a company that joins or leaves a category mid-year; take advice on your own timing.

A dual-listed company with its UK equity in UKLR 6 is in scope through that listing, whatever it files elsewhere.

Check the actual listingExplore

Check the actual listing

AIM

Outside this listing-rule route; check Companies Act climate duties separately.

Secondary listings

Why secondary listings came into scope

CP26/5 would have asked UKLR 14 and 15 issuers only to state which overseas sustainability requirements applied to them, with signposting.

The FCA changed course after respondents warned that lighter rules for international companies could lead UK companies to move or downgrade their listings to avoid disclosure.

Read the paragraph-level reference

Its response, verbatim: “We are therefore requiring international companies to report against UK SRS on a ‘comply or explain’ basis, which aligns with the current approach to TCFD.”

The same response adds that where home-jurisdiction reporting aligns with the outcomes of UK SRS a company “may already broadly comply”, but where UK SRS requirements are not met in full it “must provide an explanation”.

One requirement stays off them: the transition-plan statement was finalised as consulted, “with the secondary listing and depositary receipts categories remaining out of scope” — see UK SRS transition plans.

UKLR 14 and 15Explore

UKLR 14 and 15

Final approach

Report against UK SRS on comply or explain, rather than only signposting home-country reporting.

Not a size test

If you are not listed, the size tests are other regimes’

No UK SRS size threshold exists, and none is proposed for private companies.

The size tests you will meet are for three other regimes, each with its own instrument and its own numbers — set out properly on UK SRS thresholds.

Read the paragraph-level reference

The government’s Modernising Corporate Reporting consultation says it will consider how UK SRS should be reflected in the Companies Act 2006, with no threshold, mechanism or date; the earlier exposure-draft consultation on the standards asked for evidence on future requirements but proposed none.

Any entity may use the standards voluntarily now, in whole or in part; they are published on GOV.UK, and the FRC’s FAQ explains how a UK SRS S2 report can also discharge the Companies Act climate duty.

The international standards behind UK SRS are the ISSB’s, via the International Sustainability Standards Board; ESOS obligations are set out on the ESOS Phase 4 guide.

If you are in scope, the readiness self-check is the next step, and UK SRS S1 and S2 explains what you will report against.

Sources: SI 2018/1155 · CA 2006 s 414CA · SI 2014/1643
RegimeTestInstrument
SECR (large unquoted companies)Exceed at least two of £36m turnover, £18m balance sheet, 250 employeesSI 2008/410 Sch 7 ¶20B
Companies Act climate dutyTraded, banking, insurance, AIM or turnover over £500m — and over 500 employeesCA 2006 s 414CA
ESOS250 or more employees, or turnover over £44m and balance sheet over £38mSI 2014/1643 Sch 1
Separate qualification testsExplore

Separate qualification tests

UK SRS

FCA scope starts with listing category; there is no company-size threshold.

Could it widen?

When scope could change, and what would have to happen

The FCA route is settled: the instrument was made on 24 September 2026 and names five categories.

Widening it within listed companies would need new FCA rules after a new consultation; nothing proposes that.

Read the paragraph-level reference

Reaching unlisted companies would need the Companies Act route, and the government’s September 2026 consultation says only that it will consider how UK SRS should be reflected in the Act.

The FCA says it does not expect a formal post-implementation review of the rules, and what it said it would keep under review is the case for mandatory assurance, not wider scope.

A group with business in the EU may meet European rules sooner than any UK widening; that is a separate test, on CSRD vs UK SRS.

The quiz beside this section checks the six scope claims most often got wrong; nothing you choose is stored or sent.

Who is in scope: true or false?

  1. UK SRS applies to companies above a turnover threshold.

  2. An overseas company with a secondary listing in London reports against UK SRS.

  3. A listed investment trust is in scope of the FCA’s UK SRS rules.

  4. The FCA’s final rules say 515 companies must comply.

  5. An AIM company has no climate reporting duty of any kind.

  6. A UK subsidiary of a listed group must publish its own UK SRS report.

0 of 6 answered.

Nothing you choose is stored or sent.

What could change scope?Explore

What could change scope?

Current rules

The five categories govern the listed-company route.

A reading and preparation sequence

UK SRS who is in scope: from the question to the evidence

A suggested sequence for using this guide. These steps are not an eligibility finding, a statutory timetable or a guarantee of compliance.
  1. Step 101

    Confirm the route

    Record the entity, listing category and reporting period.

    UK SRS reporting route · FCA PS26/19

  2. Step 202

    Map the requirements

    Identify the relevant S1 and S2 disclosures and FCA statements.

    UK SRS reporting route · FCA PS26/19

  3. Step 303

    Gather evidence

    Trace inputs, methods and judgements to records and owners.

    UK SRS reporting route · FCA PS26/19

  4. Step 404

    Draft the report

    Connect material disclosures to the financial statements.

    UK SRS reporting route · FCA PS26/19

  5. Step 505

    Check the statements

    Keep explanations, relief use and compliance assertions consistent.

    UK SRS reporting route · FCA PS26/19

  6. Step 606

    Review and publish

    Review the complete annual-report package and its publication timing.

    UK SRS reporting route · FCA PS26/19

Dates, with their status

The relevant dates, drawn in order

  1. 25 February 202601

    UK SRS published

    S1 and S2 are published for voluntary use. The standards themselves do not decide which companies must report.

    DBT: published standards

  2. 30 September 202602

    FCA final rules

    PS26/19 sets a comply-or-explain reporting obligation for the five in-scope listing categories. It replaces the consultation proposals.

    FCA: PS26/19

  3. 28 October 202603

    Draft guidance comments close

    Technical Note 803.1 is proposed guidance on the explanations and compliance statements. Keep its draft status clear.

    FCA: Primary Market Bulletin 66

  4. Periods from 1 January 202704

    New listed-company regime

    The first eligible accounting periods begin. Optional reliefs cover Scope 3 for one year and wider S1 sustainability information for two years.

    PS26/19: implementation and UKLR TP 16

  5. 2028 reporting season05

    First annual reports

    The FCA identifies 2028 as the first reporting year. An issuer’s actual publication deadline follows its annual financial report rules and year end.

    FCA: first reporting

  6. Periods from 1 January 202906

    Transitional reliefs end

    The Scope 3 and climate-first transitional reliefs have expired. The comply-or-explain reporting obligation continues.

    PS26/19: UKLR TP 16

Frequently asked

Questions people ask

Who is in scope of UK SRS?

Under the FCA’s final rules, PS26/19, companies with securities listed in five UK Listing Rules categories: equity shares of commercial companies (UKLR 6), equity shares of international commercial companies with a secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16), and equity shares in the transition category (UKLR 22).

They report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

No other entity is required to use UK SRS.

How many companies are in scope of UK SRS?

The FCA’s final rules give no total.

Its consultation, CP26/5, estimated that around 600 listed companies would be affected; that is the consultation’s estimate, not a count in the rules.

PS26/19 says the 89 issuers with a secondary listing or depositary receipts that CP26/5 identified are now subject to the same requirements as domestic listed issuers.

Is an AIM company in scope of UK SRS?

Not of the FCA’s UK SRS rules: AIM is not one of the UK Listing Rules categories.

An AIM company may be inside a different duty, the Companies Act climate-related financial disclosure requirement in section 414CA, which names AIM companies but applies only where the company has more than 500 employees and is not small or medium-sized. It may use UK SRS voluntarily.

Does UK SRS apply to private companies?

No. No government document proposes a UK SRS threshold or date for private or unlisted companies.

The Modernising Corporate Reporting consultation, open until 30 November 2026, says the government will consider how UK SRS should be reflected in the Companies Act 2006; that is a consultation, not a proposal to require it.

Private companies may use UK SRS voluntarily.

Which listed companies are excluded?

Six categories: closed-ended investment funds (UKLR 11), open-ended investment companies (UKLR 12), shell companies (UKLR 13), debt and debt-like securities (UKLR 17), securitised derivatives (UKLR 18), and warrants, options and other miscellaneous securities (UKLR 19).

The FCA’s reasons are that investment vehicles are better reached through the asset manager, shells have no substantial operations, and it does not consider extending the rules to the others proportionate or effective.

Does a UK subsidiary of a listed group report under UK SRS?

Not in its own right, unless it is itself listed in one of the five categories.

The listed parent reports, and UK SRS S1 paragraph 20 requires sustainability disclosures to be for the same reporting entity as the related financial statements — for a group, the consolidated group.

The subsidiary’s data feeds the parent’s report.

Are companies with a secondary listing in London in scope?

Yes, under the final rules.

CP26/5 had proposed only a signposting statement for UKLR 14 and 15 issuers; PS26/19 requires them to report against UK SRS on a comply-or-explain basis.

Where their home-jurisdiction reporting aligns with the outcomes of UK SRS they may already broadly comply and may rely on it, explaining where UK SRS is not met in full.

They do not make the separate transition-plan statement.

Is every FTSE 100 or FTSE 250 company in scope of UK SRS?

Not as such.

Index membership is not the test; the listing category is.

A FTSE company whose shares are listed as a commercial company in UKLR 6 is in scope, while an investment trust in the same index, listed as a closed-ended investment fund under UKLR 11, is excluded.

Are investment trusts in scope of UK SRS?

No. Closed-ended investment funds (UKLR 11) and open-ended investment companies (UKLR 12) are among the six excluded categories.

The FCA said requirements for investment vehicles are best introduced through obligations on the asset manager, whose own climate reporting sits in the ESG sourcebook.

Does UK SRS apply to LLPs?

No. An LLP has no listing and cannot fall into a UK Listing Rules category.

A large LLP may have SECR and climate-related financial disclosure duties under its own regulations, and may use UK SRS voluntarily.

Could UK SRS scope widen in future?

Only through a further decision that has not been taken.

The FCA route is made and covers five categories.

For unlisted companies the government says it will consider how UK SRS should be reflected in the Companies Act 2006, in a consultation open until 30 November 2026 that proposes no requirement, threshold or date.

Is there a size threshold for UK SRS?

No. Scope under the FCA’s rules follows the listing category, not turnover, balance sheet or employees.

Size tests belong to other regimes — SECR, ESOS and the Companies Act climate duty — which are set out on the UK SRS thresholds page.

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 14 sources fromFinancial Conduct AuthorityFCA HandbookDepartment for Business and Tradelegislation.gov.ukDepartment for Business, Innovation, Science and TradeFinancial Reporting Council
  1. Financial Conduct Authority
    Primary Market Bulletin 66 — preparation and draft TN 803.1

    Published 30 September 2026. Technical Note 803.1 remains a consultation draft; comments close 28 October 2026.

  2. Financial Conduct Authority
    PS26/19 (PDF): ¶¶1.7, 3.6, 3.7, 3.9, 4.35 and the responses after ¶¶2.44 and 2.67

    The five categories in scope, the six out and the FCA’s reasons, and the position of secondary listings.

  3. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    “Who this is for”: the commercial companies, transition, non-equity and non-voting equity shares, and secondary listing or depositary receipts categories.

  4. Financial Conduct Authority
    CP26/5: consultation page

    The consultation, whose estimate of around 600 affected companies is the only published figure.

  5. Financial Conduct Authority
    CP26/5 (PDF), Annex 2 ¶43

    “Around 600 listed companies would be affected” — the consultation’s estimate.

  6. FCA Handbook
    UK Listing Rules (UKLR)

    The listing categories, chapter by chapter.

  7. FCA Handbook
    UKLR 6.6 — annual financial report

    Where the UK SRS limbs sit for commercial companies from 1 January 2027.

  8. Department for Business and Trade
    UK SRS S1 and UK SRS S2 — publication page

    Voluntary use by any entity since 25 February 2026.

  9. Department for Business and Trade
    UK SRS S1 General Requirements (PDF) — ¶20

    Sustainability disclosures are for the same reporting entity as the related financial statements.

  10. legislation.gov.uk
    Companies Act 2006, section 414CA

    The Companies Act climate duty, which does reach AIM companies above its size floor.

  11. legislation.gov.uk
    SECR — SI 2018/1155

    The energy and carbon report, a separate duty with its own size test.

  12. Department for Business, Innovation, Science and Trade
    Modernising corporate reporting — consultation

    Open until 30 November 2026; proposes no UK SRS duty for private companies.

  13. Financial Reporting Council
    Sustainability reporting developments — FAQ

    How new or amended ISSB standards reach the UK, and UK SRS S2 as a national reporting framework.

  14. EUR-Lex
    Corporate Sustainability Reporting Directive, (EU) 2022/2464

    The EU regime that may reach UK groups through their EU business, independently of the listing rules.

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