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Climate Analysis · UK SRS S2 Paragraph 22

Climate scenario analysis under UK SRS

UK SRS S2 paragraph 22 requires climate-related scenario analysis to support the resilience disclosure, carrying over the IFRS S2 scenario analysis requirements unchanged.

The approach must be commensurate with the entity’s circumstances — from qualitative narratives to quantitative modelling.

The requirement

What paragraph 22 requires

Climate scenario analysis under UK SRS is one of the more demanding requirements in UK SRS S2.

Paragraph 22 requires every entity applying the standard to disclose information that lets users of its general purpose financial reports understand the resilience of its strategy and business model to climate-related changes, developments and uncertainties.

It also requires the entity to use climate-related scenario analysis to assess that resilience.

This page sets out what the standard requires, how the FCA’s final Listing Rules apply it from 1 January 2027, which scenarios are commonly used, and where the standard accommodates entities with less mature analytical capability.

UK SRS S2 paragraph 22 — core requirements

An entity shall disclose information that enables users of general purpose financial reports to understand:

  • its assessment of its climate resilience as at the reporting date, including its capacity to adjust or adapt to climate-related changes (¶22(a)); and
  • how and when it carried out its climate-related scenario analysis, including the scenarios used, the time horizons considered and the key assumptions made (¶22(b)).
¶22
The provision in UK SRS S2 that requires scenario analysis to support a resilience disclosure

Origin

IFRS S2 scenario analysis requirements, as carried into UK SRS S2

UK SRS S2 was published by the Department for Business and Trade on 25 February 2026, alongside UK SRS S1.

Both standards are currently available for voluntary use.

The FCA consulted on making UK SRS S2 mandatory for in-scope listed issuers; its final rules (PS26/19, 30 September 2026) instead require them to report against it on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

The IFRS S2 scenario analysis requirements — paragraph 22 and application guidance paragraphs B1 to B18 of IFRS S2 (December 2025 text) — pass into UK SRS S2 with the same paragraph numbers and the same wording.

None of the UK amendments recorded in Annex A of the Government’s consultation response touches them.

The structure of the requirement matters: an entity does not freely choose its method.

The method is determined by the entity’s circumstances, and those circumstances must be reassessed each time the analysis is carried out.

Application guidance ¶¶B1–B18

Source: UK SRS S2 ¶¶B1–B18
ParagraphsWhat they cover
B2–B7How an entity assesses its circumstances
B8–B15How an entity determines an appropriate approach
B16–B18Additional factors over time

Proportionality

The proportionality principle

The defining feature of UK SRS S2 scenario analysis is that the approach must be “commensurate with the entity’s circumstances”.

This is not a get-out clause; it is a calibration rule.

An entity must consider two factors when determining its approach:

  • its exposure to climate-related risks and opportunities; and
  • the skills, capabilities and resources available to it, both internal and external, to carry out the analysis.

The combination of these factors determines whether a simpler or more advanced approach is appropriate.

The IFRS Foundation factsheet published in March 2026, which applies equally to UK SRS S2 because the two standards are aligned, describes this as a matrix.

An entity with high exposure and high analytical capability is expected to apply a more advanced, quantitative approach.

An entity with low exposure or limited capability may use a simpler approach, such as qualitative scenario narratives.

High exposure · high capability

Advanced quantitative

Required under ¶B17 to apply a more advanced quantitative approach.

High exposure · limited capability

Simpler first, then build

May start simpler but “would build its capabilities through experience” (¶B17).

Low exposure · high capability

Simpler approach

A simpler approach may be commensurate with circumstances.

Low exposure · limited capability

Qualitative narratives

Scenario narratives can provide a reasonable and supportable basis (¶B15).

After the IFRS Foundation factsheet (March 2026), Figure 2 · UK SRS S2 ¶¶B15, B17

Scenario analysis is not optional

An entity with limited skills or resources may use a qualitative narrative — but it must still carry out the analysis, disclose what scenarios it considered, and explain what it concluded.

Capacity is not a reason to omit the disclosure.

Frequency

Two calibration mechanisms, one asymmetry

Under paragraph B15, qualitative information — including scenario narratives, alone or combined with quantitative data — can provide a reasonable and supportable basis for the resilience assessment.

Under paragraph B18, the entity is not required to refresh the underlying scenario analysis annually; it may align it with its strategic planning cycle, which the standard gives as “for example, every three to five years”.

However, the entity must assess its resilience annually to reflect updated insight, and must at a minimum update its scenario analysis in line with its strategic planning cycle.

This creates an update asymmetry.

The resilience output disclosed under paragraph 22(a) is refreshed every reporting period.

The scenario methodology disclosed under paragraph 22(b) may remain unchanged across several periods if no new scenario analysis was carried out.

Source: UK SRS S2 ¶¶B15, B18.
DisclosureHow often it is refreshed
¶22(a) resilience assessmentEvery reporting period
¶22(b) scenario methodologyMay stay unchanged across periods if no new analysis was carried out
Underlying scenario analysisAt a minimum in line with the strategic planning cycle — “for example, every three to five years” (¶B18)

Scenario sets

Which scenarios

UK SRS S2 does not mandate a specific scenario or scenario provider.

Paragraphs B12 and B13 require a “reasonable and supportable” basis for the scenarios selected, with inputs relevant to the entity’s activities and their geographical location, and B12 suggests scenarios “that are publicly and freely available from authoritative sources”.

Three scenario families dominate UK practice

01 · Financial sector

NGFS scenarios

The Network for Greening the Financial System publishes reference scenarios designed for financial sector use.

The current long-term set is version 5, published in November 2024, in four families: Orderly, Disorderly, Hot house world, and Too little, too late.

The NGFS also published an updated Guide on Climate Scenario Analysis on 13 November 2025, whose main addition is short-term scenarios for near-term risk assessment.

They are the de facto reference for UK financial services firms and are routinely cited in Bank of England supervisory exercises.

02 · Energy pathway

IEA Net Zero Emissions by 2050

The IEA’s NZE Scenario, updated in November 2025 as part of World Energy Outlook 2025, translates the Paris Agreement’s 1.5°C goal into a global pathway for the energy sector.

In the 2025 update, warming exceeds 1.5°C around 2030 and peaks at around 1.65°C about 2050, before falling back below 1.5°C by 2100.

A company using it as its 1.5°C-aligned pathway should reflect that change rather than the original 2021 framing, and name the edition used.

03 · Physical risk

IPCC scenarios

The IPCC’s Shared Socio-economic Pathways — SSP1-1.9, SSP1-2.6, SSP2-4.5, SSP3-7.0, SSP5-8.5 — are widely used for physical climate risk modelling.

They underpin the climate science in the NGFS scenarios.

Because the NGFS re-issues its scenarios periodically, a disclosure that relies on them should name the version used.

UK SRS S2 does not mandate a minimum number of scenarios or a required temperature pathway.

What it requires is disclosure of which scenarios were used, including whether one consistent with the latest international agreement on climate change was among them — not that one must be.

Common practice, not a requirement

Many entities combine one scenario consistent with the latest international agreement on climate change — typically a 1.5°C or well-below-2°C pathway — with at least one higher-physical-risk scenario.

FCA rules

What the FCA proposed in CP26/5, and decided

The FCA published Consultation Paper CP26/5 on 30 January 2026.

The consultation closed on 20 March 2026; it proposed that in-scope listed companies — commercial companies (UKLR 6), non-equity shares and non-voting equity shares (UKLR 16), and the transition category (UKLR 22) — report against UK SRS S2 on a mandatory basis, with an exception for Scope 3 emissions.

The FCA’s final rules (PS26/19, 30 September 2026) went a different way: listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis across all categories of disclosure, for accounting periods starting on or after 1 January 2027.

The scenario analysis requirements in paragraph 22 therefore apply to them as a disclosure to make, or to explain.

Scope 3 carries a one-year relief under the final rules; see Scope 3 under UK SRS.

CP26/5 did not propose to amend or soften the scenario analysis requirements themselves, and the Standard’s proportionality mechanism is preserved.

The Quoted Companies Alliance’s response to CP26/5 (paragraph 1.7) asked the FCA to clarify that smaller issuers are not expected to undertake externally validated or quantitatively modelled scenario analysis, and that qualitative assessments of climate resilience will be sufficient.

Whatever the answer on that framing, the final rules’ comply-or-explain basis means an issuer that does not meet paragraph 22 in full explains why.

Where the listed-company obligation comes from

  1. 30 Jan 2026
    CP26/5 published

    Proposed mandatory UK SRS S2 for UKLR 6, 16 and 22 issuers.

  2. 20 Mar 2026
    Consultation closed
  3. 30 Sep 2026
    Final rules — PS26/19

    Comply or explain across the UK SRS, for UKLR 6, 14, 15, 16 and 22.

  4. 1 Jan 2027
    Rules apply

    Accounting periods starting on or after this date.

Depth

Quantitative versus qualitative

The standard does not require quantification.

It permits it, expects it where capability and exposure warrant it, and pushes entities toward more quantitative approaches over time.

Three levels of analytical depth in common use — market practice, not categories defined by the Standard.
Level of depthWhat it involvesCommonly appropriate for
Qualitative scenario narrativesHow strategy and business model would respond to scenario conditions, referenced to external scenario sources but without parametric modelling of financial impacts.Smaller entities with limited climate exposure
Hybrid analysisNarratives supplemented by directional or order-of-magnitude quantification of selected impacts — for example, fixed-asset exposure to physical risk by location, or the estimated cost of carbon under a transition scenario.Entities building capability
Quantitative modellingFull financial modelling of scenario outcomes through revenue, cost, capital expenditure and balance sheet line items, with explicit assumptions about climate policy, energy prices, demand patterns and physical risk.Larger financial institutions and high-exposure industrials

Paragraph B17 states that an entity with high exposure and access to the necessary skills, capabilities or resources “is required to apply a more advanced quantitative approach to climate-related scenario analysis”.

The same paragraph says an entity with high exposure but without those skills might initially use a simpler approach, but “would build its capabilities through experience” and apply a more advanced quantitative approach over time.

Paragraph B16 adds that the approach need not be the same from one reporting period or strategic planning cycle to the next.

The FCA’s cost-benefit analysis in CP26/5 assumes issuers will adapt their existing TCFD processes to UK SRS’s more quantitative metrics and improve their reporting over time.

Nothing in the consultation or the final rules’ comply-or-explain basis requires uniform quantification of scenario analysis at the point of first application.

The output

What the resilience disclosure must contain

Paragraph 22(a) requires the entity to disclose its assessment of climate resilience itself.

This is not a summary of the scenario analysis methodology; it is a statement about the entity’s strategy and business model.

Where the entity has published a climate-related transition plan, paragraph 22 is interconnected with the transition plan disclosures and with the FCA’s final rules, which require disclosure of whether the company has a climate-related transition plan and, if so, where it can be found.

See transition plans under UK SRS.

For entities operating across several jurisdictions, the analytical choices must be transparent enough that a user can judge whether the inputs are reasonable in light of the entity’s circumstances.

ParagraphDiscloses
¶22(a)The assessment of climate resilience itself: implications for strategy and business model, including existing assets, planned investments, financing requirements and access to capital; how and when the entity expects to respond, including planned transition activity.
¶22(b)The analysis: scenarios used, time horizons, scope of operations covered, and key assumptions — climate policy, macroeconomic trends, national or regional variables, energy usage and technology.

Wider framework

How this fits with the wider framework

UK SRS S2 sits within a broader UK regulatory framework.

The Government has confirmed that UK SRS S2 is a national reporting framework for the purposes of section 414CB(6) of the Companies Act 2006.

A company reporting in accordance with UK SRS S2 therefore does not need to duplicate its disclosures to meet the climate-related financial disclosure obligations in section 414CB(2A).

The Government has also said it will consider the future of the section 414CB(2A) obligations when it considers the merits of reporting requirements against UK SRS.

For listed companies, the existing TCFD-aligned Listing Rule disclosures remain the rule until the FCA’s final rules apply, from accounting periods beginning on or after 1 January 2027.

Existing TCFD scenario work — much of it built on the TCFD’s 2017 Technical Supplement on scenario analysis — should transfer substantially.

The two principal upgrades are greater quantification of financial impacts, and tighter linkage between scenario outputs and the ¶22(a) resilience disclosure; see TCFD vs UK SRS.

Using UK SRS S2 under section 414CB(6)

The FRC adds two conditions:

  • use of UK SRS S2 must be clearly referenced in the Non-Financial and Sustainability Information Statement; and
  • the existing requirements of section 414CB(1)–(5) must still be met.

This applies whether UK SRS S2 is applied under the FCA’s comply-or-explain rules or voluntarily.

FRC sustainability reporting FAQ, updated 26 February 2026

Next steps

What to do this year

Companies in scope of the FCA’s final rules should treat 2026 as a transition year.

01 · Map

Map TCFD work to ¶22

Most TCFD-aligned scenario analysis will satisfy the ¶22(b) methodology disclosure with limited modification; the ¶22(a) resilience disclosure is more likely to need new work.

02 · Choose

Anchor the scenario set

For most non-financial entities, one 1.5°C-aligned pathway (IEA NZE or NGFS Orderly) and one higher physical risk scenario (NGFS Hot house world or an SSP3/5 pathway) is the minimum credible set.

03 · Document

Place the entity on the matrix

The “commensurate with circumstances” calibration is a defensible judgement, but it must be a documented one.

04 · Align

Match the planning cycle

There is no requirement to repeat the full scenario analysis annually, but the resilience assessment must be refreshed each reporting period.

05 · Govern

Engage the audit committee early

Scenario outputs feed the strategy resilience disclosure, which sits within the Strategic Report and carries the same governance as financial reporting.

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 fromDepartment for Business and TradeIFRS FoundationFinancial Conduct AuthorityNetwork for Greening the Financial SystemInternational Energy AgencyIntergovernmental Panel on Climate Change
  1. Department for Business and Trade
    UK SRS S2 Climate-related Disclosures — final standard (PDF)

    Published 25 February 2026. Paragraph 22 and application guidance ¶¶B1–B18.

  2. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2

    The publication page for both standards, available for voluntary use.

  3. IFRS Foundation
    IFRS S2 Climate-related Disclosures — December 2025 text

    The ISSB text whose ¶22 and ¶¶B1–B18 UK SRS S2 carries unchanged.

  4. Financial Conduct Authority
    CP26/5: Aligning listed issuers' sustainability disclosures with international standards

    Published 30 January 2026, closed 20 March 2026 — the consultation PS26/19 finalises. It proposed mandatory UK SRS S2 for UKLR 6, 16 and 22 issuers.

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

    First published 30 September 2026. The final rules: comply or explain across the UK SRS (¶1.2, ¶1.7) for UKLR 6, 14, 15, 16 and 22, from accounting periods starting on or after 1 January 2027.

  6. IFRS Foundation
    Climate resilience and scenario analysis factsheet (PDF)

    March 2026 implementation factsheet setting out the proportionality matrix.

  7. Network for Greening the Financial System
    NGFS Scenarios Portal

    Long-term scenarios, version 5, November 2024.

  8. Network for Greening the Financial System
    NGFS publishes updated Guide on Climate Scenario Analysis

    Published 13 November 2025.

  9. International Energy Agency
    Net Zero Emissions by 2050 Scenario — World Energy Outlook 2025

    Updated NZE Scenario, November 2025.

  10. Intergovernmental Panel on Climate Change
    Sixth Assessment Report, Working Group I

    The physical science basis behind the SSP scenarios.

  11. Task Force on Climate-related Financial Disclosures
    Technical Supplement: The Use of Scenario Analysis (PDF)

    June 2017 — the basis of most existing TCFD scenario work.

  12. Bank of England
    Climate change

    Supervisory climate scenario analysis and stress testing.

  13. Financial Reporting Council
    Sustainability reporting developments — frequently asked questions

    Updated 26 February 2026. The conditions on using UK SRS S2 as a national reporting framework.

  14. legislation.gov.uk
    Companies Act 2006, section 414CB

    Non-financial and sustainability information statement; subsection (6) national reporting frameworks.

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