UK sustainability reporting: the complete guide

UK SRS comprises two standards published by the Department for Business and Trade on 25 February 2026 1.

UK SRS S1 sets the general requirements for disclosing sustainability-related financial information across governance, strategy, risk management, and metrics and targets, and applies to any sustainability matter that could reasonably affect a company's cash flows, access to finance, or cost of capital 3.

UK SRS S2 applies that framework specifically to climate, requiring disclosure of greenhouse gas emissions across Scopes 1, 2 and 3, plus climate scenario analysis and resilience information 4.

Both standards are based on ISSB IFRS S1 and S2 — UK SRS S2 on IFRS S2 as amended by the ISSB in December 2025, so the GWP and GHG-Protocol-methodology changes are the ISSB’s, not the UK’s. The widely-quoted “six UK-specific amendments” is DBT’s count of what it proposed in June 2025: the GICS amendment was withdrawn once the ISSB made that change globally, the two-year climate-first extension was replaced by removing the time limit altogether, and ¶73A, ¶73B, ¶B59A and ¶E5 were added after the consultation closed. Annex A of the government’s consultation response maps the final differences paragraph by paragraph and carries no count — and it scopes itself: “Where requirements in the standards are not included in the table, there are no differences between the two.” 2

Three separate provisions do work that is often welded into one. UK SRS S1 ¶20 requires the disclosures to be “for the same reporting entity as the related financial statements”. ¶¶21–24, under the standard’s own heading Connected information (elaborated at ¶¶B39–B44), require information to be presented so users can understand the connections — and say nothing about timing. Timing is ¶64: disclosures must be reported “at the same time as” the related financial statements and cover “the same reporting period”. 28

The standards apply single (financial) materiality — the outside-in effect on the company — not the “double materiality” used by the EU. UK SRS S1 ¶3 states the test as risks and opportunities that could reasonably be expected to affect an entity’s “cash flows, its access to finance or cost of capital”; the phrase “enterprise value” appears nowhere in either standard. 9

The Department for Business and Trade publishes the standards, but it does not compel anyone to use them — they are voluntary 1.

Whether listed companies must report against them is the FCA's decision, set out in Consultation Paper CP26/5, on aligning listed issuers’ sustainability disclosures, published on 30 January 2026 5.

CP26/5 proposes mandatory UK SRS S2 climate reporting for in-scope listed companies for accounting periods beginning on or after 1 January 2027, replacing the FCA’s existing TCFD-aligned listing rule, UKLR 6.6.6R(8) 22.

Scope 3 emissions and the wider UK SRS S1 disclosures would instead be "comply or explain" 6.

The consultation closed on 20 March 2026, with a Policy Statement expected in autumn 2026 5.

Roughly 515 listed issuers fall within scope, across UKLR categories 6, 16 and 22 — of ~600 affected across five categories defined by the Financial Conduct Authority 725.

Greenhouse gas emissions sit at the heart of UK SRS S2, which requires measurement using the GHG Protocol Corporate Standard and reporting in tonnes of CO₂ equivalent across all three scopes 416.

UK companies convert activity data using the UK Government's GHG Conversion Factors, published by the Department for Energy Security and Net Zero (DESNZ) 16.

Scope 3 — value-chain emissions — is the most challenging component, covering all 15 categories defined by the GHG Protocol Scope 3 Standard, which is why the FCA proposes to treat it as comply-or-explain rather than strictly mandatory 6.

UK SRS does not arrive into a vacuum.

Streamlined Energy and Carbon Reporting (SECR), inserted into Schedule 7 Part 7A of SI 2008/410 with effect from 1 April 2019 by SI 2018/1155, already requires large companies and LLPs to disclose energy use and Scope 1 and 2 emissions in their annual reports 10.

SECR’s test is drafted as an exemption, not a size test: SI 2008/410 Sch 7 ¶20B(2) exempts an unquoted company that meets two or more of — turnover not more than £36m, balance sheet total not more than £18m, not more than 250 employees. DESNZ’s independent evaluation of January 2026 measured 19,900 organisations in scope, 76% above the 2018 impact assessment’s forecast of 11,300. 10

SECR is enforced by the FRC and remains in place; its thresholds were left unchanged even as wider company-size limits rose for periods beginning on or after 6 April 2025 1011.

The Government has said it will consider how SECR and UK SRS interact to reduce duplication 23.

The Task Force on Climate-related Financial Disclosures (TCFD) — the framework underpinning the FCA's current listing rules — was formally disbanded in 2023 and absorbed into the ISSB, and UK SRS S2 is its direct successor 1222.

Companies familiar with TCFD reporting will recognise the four-pillar structure in UK SRS S2 4.

Two areas are moving fast.

Nature is next: the ISSB announced in November 2025 that it will develop nature-related disclosure standards drawing on the TNFD framework, with an exposure draft targeted for October 2026 14 — though any resulting standard would need UK endorsement by the Department for Business and Trade before entering UK SRS 15.

Transition plans are the other live question: UK SRS S2 already requires a company to disclose its transition plan where one exists 20, while the Department for Energy Security and Net Zero has consulted on whether to make transition plans mandatory and has so far kept its options open 18.

Both areas are covered in depth in the dedicated implementation guides.

UK SRS is deliberately aligned with the global ISSB baseline so UK disclosures stay internationally comparable, following the Government's commitment to international consistency 2.

This approach contrasts sharply with the EU's Corporate Sustainability Reporting Directive (CSRD), which applies double materiality — reporting both a company's impact on the world and the world's financial impact on the company — whereas UK SRS uses financial materiality only 926.

Notably, the UK chose disclosure standards over a classification system: in July 2025 HM Treasury decided not to proceed with a UK Green Taxonomy — “work to develop a UK Taxonomy should therefore not proceed” — prioritising UK SRS, assurance of sustainability reporting, and transition plans instead 17.

This positions the UK as following the global ISSB model rather than the more prescriptive EU approach, maintaining focus on investor-relevant financial information while avoiding the complexity of impact materiality assessments 26.