UK SRS — who is in scope?

AIM-listed companies

Out 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 companies

Out 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 consulted on extending UK SRS S1 to a broader set of large private companies from 1 January 2029 on a comply-or-explain basis.

UK companies listed only abroad

Out 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 parents

Reported 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).

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 listing

Edge 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 intention

Edge 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 delisted

Edge 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 listing

Edge 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.

The current proposal under FCA CP26/5 keeps the mandatory perimeter at UKLR 6, 16 and 22. The Department for Business & Trade has signalled that broader UK SRS S1 comply-or-explain scope from 1 January 2029 remains under consideration, potentially capturing large private UK companies meeting size tests broadly analogous to the EU CSRD thresholds. Until the FCA Policy Statement (expected autumn 2026) and any further DBT consultation, this remains directional rather than fixed.

Voluntary early adoption ahead of any 2029 expansion is being encouraged by the FRC 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.