UK SRS S1 & S2 — What is UK SRS?

The UK Sustainability Reporting Standards comprise two interlocking documents published by theDepartment for Business and Trade on 25 February 2026. UK SRS S1 sets the overarching framework for all sustainability-related financial disclosures — governance, strategy, risk management, and metrics across every material topic. UK SRS S2 applies those principles specifically to climate, adding detailed requirements for greenhouse gas emissions, scenario analysis, and transition planning.

Both standards are the UK’s endorsement of the ISSB baseline — IFRS S1 and IFRS S2 — with six targeted UK amendments. The global structure is preserved so that UK reporters remain interoperable with the international baseline used across more than 30 jurisdictions. Voluntary for all entities from publication date; the FCA’s CP26/5 consultation proposes making S2 mandatory for listed companies from accounting periods beginning on or after 1 January 2027.

UK SRS S1 — General requirementsCross-cutting

Establishes the cross-cutting framework for sustainability-related financial disclosures following the ISSB baseline. Requires entities to disclose information about sustainability-related risks and opportunities that could reasonably affect cash flows, access to finance, or cost of capital over the short, medium, or long term. Applies single (enterprise-value) materiality — the same investor-focused lens as financial reporting. See the dedicated UK SRS S1 reference guide for full requirements.

UK SRS S2 — Climate disclosuresClimate-specific

Climate-specific requirements built on the TCFD four-pillar architecture: Governance, Strategy, Risk Management, and Metrics & Targets. Substantially enhances the TCFD baseline with explicit Scope 1, 2, and 3 emissions disclosure, scenario analysis, and transition planning requirements. The UK SRS S2 standard (PDF) requires absolute gross GHG emissions by scope under paragraph 29(a), measured following the GHG Protocol.

The initial mandatory scope covers approximately 515 primary-listed companies under FCA CP26/5, specifically commercial companies under UKLR 6, non-equity shares under UKLR 16, and transition category companies under UKLR 22. Excluded from the initial scope are closed-ended investment funds, shell companies, debt securities issuers, and securitised derivatives issuers. The DBT guidance confirms any UK entity may adopt the standards voluntarily from 25 February 2026 regardless of listing status.

The six UK amendments to the IFRS baseline are not cosmetic changes — they include the removal of ISSB’s first-year transitional relief, a reworking of the climate-first phasing to match UK dates, and a downgrade of SASB industry metrics from mandatory (“shall”) to optional (“may”). The four TCFD pillars are retained in full within UK SRS S2, providing continuity for companies already reporting under the FCA’s TCFD-aligned Listing Rules.

Scope is determined primarily by listing status. Under the FCA’s CP26/5 proposals, mandatory UK SRS S2 reporting applies to issuers with equity shares or certificates representing equity shares in UKLR 6, non-equity shares in UKLR 16, and transition category issuers in UKLR 22. Commercial companies listed on AIM and other markets not covered by UKLR 6, 16, or 22 are not proposed for mandatory inclusion in the initial phase.

Large private companies are not in scope for mandatory reporting at present. The DBT’s Modernising Corporate Reporting programme is expected to consult during 2026 on extending UK SRS to large private entities, but no implementation date has been confirmed. Any UK entity — listed, private, or public sector — may adopt UK SRS voluntarily with immediate effect, provided it makes a full statement of compliance. Partial or selective adoption does not constitute compliance. Use the UK SRS scope checker to confirm applicability.

The phased implementation timeline reflects the relative maturity of climate data infrastructure versus broader sustainability metrics. Most large listed companies have been collecting Scope 1 and 2 emissions data under the FCA’s existing TCFD-aligned Listing Rules; UK SRS S2 builds on that foundation. The FCA CP26/5 proposals provide a one-year comply-or-explain period for Scope 3 (from 2028) and a two-year lead time for UK SRS S1 general sustainability disclosures (from 2029), acknowledging that biodiversity, water, and workforce data collection requires more extensive system development.

The autumn 2026 Policy Statement is the critical milestone for in-scope companies. The period between Policy Statement publication and the 1 January 2027 mandatory start will be short — companies that have not started data gap analysis and governance uplift by mid-2026 face a compressed preparation window. The DBT guidance encourages all entities to begin voluntary adoption now as a readiness measure. See the complete UK SRS implementation timeline for all key dates and compliance checkpoints.

The UK government’s stated preference is to maintain international consistency and minimise deviations from the ISSB baseline. The DBT government response explicitly states that further UK-specific changes should be sought through ISSB standard-setting rather than unilateral UK amendments. This means UK SRS is highly interoperable with IFRS S1/S2 as adopted in Australia, Canada, Japan, Singapore, and other jurisdictions — material for multinationals and cross-listed companies.

The six amendments are targeted and purposeful rather than a wholesale rewrite. The most significant for preparers is the removal of the IFRS S1 first-year transitional relief, which would have allowed entities to omit comparative information in their first reporting period. The DBT guidance removes this relief, meaning UK SRS reporters face a more demanding first-year disclosure requirement than IFRS S1 reporters in other jurisdictions. The climate-first phasing amendment ensures UK SRS S1 general sustainability disclosures follow the UK’s own 2029 date rather than the ISSB’s effective date references. See the UK SRS S1 guide for the full amendment analysis.

UK effective datesDates

ISSB-specific effective-date references are removed and replaced with the UK proposed comply-or-explain date of 1 January 2029.

First-year relief removedTransitional

The IFRS S1 first-year-only reporting relief is removed in the UK adoption — immediate application required.

Climate-first relief reworkedTransitional

IFRS S1 lets entities report only climate in year one. The UK reworks this to match the UK climate-first phasing (S2 from 2027, S1 from 2029).

SASB "shall" → "may"Methodology

Where IFRS S1 requires entities to apply SASB industry metrics ("shall"), UK SRS S1 makes their use voluntary ("may"). SASB stays as a reference, not a mandate.

GICS classification removedMethodology

IFRS S1 references the Global Industry Classification Standard (GICS) for industry identification. UK SRS S1 removes the mandatory GICS reference.

Connectivity clarifiedUK framework

UK SRS S1 retains the IFRS S1 connectivity principle linking sustainability disclosures to the financial statements, with UK-specific clarifications to align with FRC Strategic Report framework and UK Corporate Governance Code.

Implementation preparation for UK SRS S2 typically begins with a scoping exercise to confirm listing-rule applicability under FCA CP26/5. Once scope is confirmed, a governance uplift is needed: the UK SRS S2 Governance pillar requires evidence that the board actively monitors climate-related risks and opportunities — not merely that climate is on an audit committee agenda, but that oversight is documented and connected to executive accountability. Many companies are already partway there through their existing TCFD-aligned reporting; the gap analysis focuses on where UK SRS S2 goes further.

Data systems are the long-lead item. Building a reliable Scope 3 inventory across all 15 GHG Protocol categories requires supplier engagement, product-level data collection, and systems integration that typically takes 12–18 months to establish. The one-year comply-or-explain relief for Scope 3 under CP26/5 gives listed companies until January 2028 before Scope 3 is hard mandatory, but companies that start in 2026 will be better positioned for the 2028 deadline. See the UK SRS implementation roadmap for a detailed workstream breakdown and resource planning guidance.

The UK SRS S1 and S2 framework touches every aspect of how a company manages, measures, and discloses sustainability-related risks and opportunities. The guides below cover the complete implementation journey: from understanding the standards’ requirements to assurance, scope 3 measurement, transition planning, and tracking the FCA’s CP26/5 rulemaking through to the autumn 2026 Policy Statement. All content is verified against primary sources — the DBT standards publication, the FCA’s CP26/5, and the DBT guidance page.