Critical Countdown: S2 Climate Reporting
1 January 2027 is the proposed deadline for UK SRS S2 climate reporting under FCA CP26/5. UKLR 6 commercial companies and other in-scope entities would need to be ready.
What You Must Do Now
Before January 2027:
- Complete climate risk assessment (physical & transition risks)
- Implement Scope 1 & 2 emissions monitoring systems
- Develop climate scenario analysis capabilities
- Create transition plan with science-based targets
First Reports Due:
- December 2027: March year-end companies
- March 2028: Calendar year-end companies
- Limited assurance required on selected metrics
- Scope 3 carve-out available in year 1 only
Complete Implementation Timeline
February 2026 ✅ COMPLETED
UK SRS S1 & S2 Published by DBT
The Department for Business and Trade (DBT) published final UK SRS standards with six technical modifications to UK SRS S1 and S2.
- Final standards available for voluntary early adoption
- Implementation guidance and examples published
- Educational resources and training materials released
Autumn 2026 📋 UPCOMING
FCA Policy Statement Expected
The FCA is expected to publish its Policy Statement finalising the consultation proposals from CP26/5.
- Final UK SRS implementation rules confirmed
- Detailed guidance on scope and requirements
- Final cost-benefit analysis published
1 January 2027 🚨 PROPOSED
UK SRS S2 (Climate) Proposed Start Date
Climate-related disclosures proposed to become mandatory for UKLR 6 (commercial companies), UKLR 16 (non-equity shares) and UKLR 22 (transition category) companies.
- Scope 1 and 2 emissions reporting required
- Scope 3 transitional relief available in year 1
- Climate scenario analysis mandatory
- Transition plans required
December 2027 / March 2028 📊 DEADLINE
First UK SRS S2 Annual Reports Due
Companies must publish their first UK SRS S2 climate disclosures in annual reports.
- Calendar year companies: Reports due by March 2028
- March year-end companies: Reports due by December 2027
- Limited assurance required on selected metrics
1 January 2028 📈 SCOPE 3
End of Scope 3 Carve-Out Period
UK-specific transitional relief for Scope 3 emissions ends. Full supply chain emissions disclosure required unless impractical.
- All 15 GHG Protocol Scope 3 categories must be assessed
- Materiality assessment required for each category
- Supply chain engagement necessary
1 January 2029 📋 COMPLY-OR-EXPLAIN
UK SRS S1 (General Sustainability) Begins
General sustainability disclosures begin on comply-or-explain basis. Covers all material sustainability topics beyond climate.
- Biodiversity and ecosystem impacts
- Water resources and waste management
- Human capital and workforce matters
- Supply chain and value chain impacts
Compliance Preparation Checklist
For January 2027 (S2 Climate)
- Conduct climate risk assessment (physical & transition)
- Implement Scope 1 & 2 emissions monitoring
- Develop climate scenario analysis capabilities
- Create transition plan and targets
- Establish governance and oversight structures
For January 2028 (Full Scope 3)
- Map complete value chain and suppliers
- Assess all 15 GHG Protocol Scope 3 categories
- Engage suppliers on emissions data collection
- Implement data collection and verification systems
- Plan for external assurance requirements
Interactive Implementation Tools
The UK SRS regulatory timeline
Five-year path from the Technical Advisory Committee's first endorsement recommendation to the proposed comply-or-explain mandate for broader sustainability disclosures. Three regulators, two committees, one set of standards.
Last verified 12 May 2026 · Tap a milestone for sources
How long UK SRS S2 implementation actually takes
Companies waiting for the FCA Policy Statement to begin preparation are already late. Practitioner consensus puts end-to-end implementation at twelve to eighteen months — driven by Scope 3 data, which can't be compressed.
Last verified 12 May 2026 · Click any workstream for detail
From kickoff to first UK SRS S2 report. Driven by Scope 3 supplier engagement and quantitative scenario modelling — neither compressible.
Of Scope 3 data work — from supplier engagement onset through validation. Of the 15 GHG Protocol categories, Category 1 and Category 11 typically account for >70% of total Scope 3 emissions.
Foundation phase before data work meaningfully begins. Materiality assessment and gap analysis are pre-requisites — running data collection without these creates wasted effort.
Start Your Compliance Journey
With approximately 350 days until UK SRS S2 becomes proposed mandatory under CP26/5, early preparation is critical.
Use our compliance guide and scope assessment tool to develop your implementation plan.