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.
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
| Category | Securities | Where the UK SRS limb sits | Transition-plan statement |
|---|---|---|---|
| UKLR 6 | Equity shares (commercial companies) | UKLR 6.6.6R(7A), (7B), (8) | Yes |
| UKLR 14 | Equity shares (international commercial companies secondary listing) | UKLR 14.3.24R(4) | No |
| UKLR 15 | Certificates representing certain securities (depositary receipts) | Through UKLR 15.3 | No |
| UKLR 16 | Non-equity shares and non-voting equity shares | UKLR 16.3.23R(4) | Yes |
| UKLR 22 | Equity 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 categories
UKLR 14
Five listing categories
UKLR 15
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
Official List
Check whether the securities are on the UK Official List.
- 2
Listing category
Identify whether UKLR 6, 14, 15, 16 or 22 applies.
- 3
Reporting entity
Use the same reporting entity as the related financial statements.
- 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
| Entity | Category | Outcome under the FCA’s rules |
|---|---|---|
| UK company with shares listed as a commercial company | UKLR 6 | In — comply or explain, with transition-plan statement |
| Overseas company with a secondary listing in London | UKLR 14 | In — may rely on aligned home reporting; no transition-plan statement |
| Issuer of depositary receipts | UKLR 15 | In — as UKLR 14 |
| Issuer of listed preference or non-voting shares | UKLR 16 | In — with transition-plan statement |
| Company in the transition category | UKLR 22 | In — with transition-plan statement |
| Investment trust or other closed-ended fund | UKLR 11 | Out — reached through the asset manager |
| Open-ended investment company | UKLR 12 | Out |
| Shell company (a SPAC, for example) | UKLR 13 | Out |
| Issuer of listed bonds only | UKLR 17 | Out |
| Issuer of securitised derivatives, warrants or options | UKLR 18, 19 | Out |
| AIM company with more than 500 employees | Not a UKLR category | Out of UK SRS rules; in the Companies Act climate duty |
| Large private company or LLP | No listing | Out of UK SRS rules; SECR and CFD by size |
| UK subsidiary of a listed group | Its parent’s category | No duty of its own; feeds the group report |
| UK group listed only overseas | No UK listing | Out 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.
| Category | Securities | Reason given |
|---|---|---|
| UKLR 11 | Closed-ended investment funds | Reached through the asset manager |
| UKLR 12 | Open-ended investment companies | Reached through the asset manager |
| UKLR 13 | Shell companies | No substantial operations |
| UKLR 17 | Debt and debt-like securities | Not proportionate or effective |
| UKLR 18 | Securitised derivatives | Not proportionate or effective |
| UKLR 19 | Warrants, options and other miscellaneous securities | Not proportionate or effective |
Six excluded categories
UKLR 11 / 12
Six excluded categories
UKLR 18 / 19
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.
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 total
Made rules
Do not invent a total
Consultation
Do not invent a total
Your entity
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 listing
AIM
Check the actual listing
Private / LLP
Check the actual listing
Subsidiary
Check the actual listing
Several categories
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 15
Final approach
UKLR 14 and 15
Existing reporting
UKLR 14 and 15
Statement scope
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.
| Regime | Test | Instrument |
|---|---|---|
| SECR (large unquoted companies) | Exceed at least two of £36m turnover, £18m balance sheet, 250 employees | SI 2008/410 Sch 7 ¶20B |
| Companies Act climate duty | Traded, banking, insurance, AIM or turnover over £500m — and over 500 employees | CA 2006 s 414CA |
| ESOS | 250 or more employees, or turnover over £44m and balance sheet over £38m | SI 2014/1643 Sch 1 |
Separate qualification tests
UK SRS
Separate qualification tests
SECR
Separate qualification tests
ESOS
Separate qualification tests
Companies Act
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?
UK SRS applies to companies above a turnover threshold.
An overseas company with a secondary listing in London reports against UK SRS.
A listed investment trust is in scope of the FCA’s UK SRS rules.
The FCA’s final rules say 515 companies must comply.
An AIM company has no climate reporting duty of any kind.
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?
Current rules
What could change scope?
Consultation
What could change scope?
Future decision
A reading and preparation sequence
UK SRS who is in scope: from the question to the evidence
- Step 101
Confirm the route
Record the entity, listing category and reporting period. - Step 202
Map the requirements
Identify the relevant S1 and S2 disclosures and FCA statements. - Step 303
Gather evidence
Trace inputs, methods and judgements to records and owners. - Step 404
Draft the report
Connect material disclosures to the financial statements. - Step 505
Check the statements
Keep explanations, relief use and compliance assertions consistent. - Step 606
Review and publish
Review the complete annual-report package and its publication timing.
Dates, with their status
The relevant dates, drawn in order
- 25 February 202601
UK SRS published
S1 and S2 are published for voluntary use. The standards themselves do not decide which companies must report. - 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. - 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. - 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. - 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. - 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.
Continue your research
Related reporting guides, one question at a time
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.
- Financial Conduct AuthorityPrimary 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.
- Financial Conduct AuthorityPS26/19 (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.
- Financial Conduct AuthorityPS26/19: 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.
- Financial Conduct AuthorityCP26/5: consultation page
The consultation, whose estimate of around 600 affected companies is the only published figure.
- Financial Conduct AuthorityCP26/5 (PDF), Annex 2 ¶43
“Around 600 listed companies would be affected” — the consultation’s estimate.
- FCA HandbookUK Listing Rules (UKLR)
The listing categories, chapter by chapter.
- FCA HandbookUKLR 6.6 — annual financial report
Where the UK SRS limbs sit for commercial companies from 1 January 2027.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
Voluntary use by any entity since 25 February 2026.
- Department for Business and TradeUK SRS S1 General Requirements (PDF) — ¶20
Sustainability disclosures are for the same reporting entity as the related financial statements.
- legislation.gov.ukCompanies Act 2006, section 414CA
The Companies Act climate duty, which does reach AIM companies above its size floor.
- legislation.gov.ukSECR — SI 2018/1155
The energy and carbon report, a separate duty with its own size test.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Open until 30 November 2026; proposes no UK SRS duty for private companies.
- Financial Reporting CouncilSustainability reporting developments — FAQ
How new or amended ISSB standards reach the UK, and UK SRS S2 as a national reporting framework.
- EUR-LexCorporate Sustainability Reporting Directive, (EU) 2022/2464
The EU regime that may reach UK groups through their EU business, independently of the listing rules.