Critical Countdown: S2 Climate Reporting

1 January 2027 is the proposed start date for UK SRS S2 climate reporting under FCA CP26/5. The FCA puts 515 listed companies in full scope, out of around 600 affected in total. 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
• Assurance is not required; companies must state whether they have obtained it
• Scope 3 transitional relief may be elected 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, excluding Scope 3, for UKLR 6 (commercial companies), UKLR 16 (non-equity shares) and UKLR 22 (transition category) companies. UKLR 14 (secondary listing) and UKLR 15 (depositary receipts) issuers are also affected, but receive a transparency and signposting statement rather than a UK SRS reporting obligation.

• Scope 1 and 2 emissions reporting required
• Scope 3 sits on a comply-or-explain basis, with an elective one-year transitional relief in year 1
• Climate scenario analysis mandatory
• A statement of whether a transition plan has been published, and where to find it — publishing a plan is not itself 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
• Assurance remains voluntary; where obtained, the provider, scope, level and standards used must be disclosed

1 January 2028 📈 SCOPE 3

Scope 3 transitional relief expires

The elective one-year transitional relief for Scope 3 emissions is no longer available. Scope 3 then sits on a comply-or-explain basis: a company either discloses Scope 3 in accordance with UK SRS S2, or identifies the paragraphs it has not applied, the reasons, and the steps it is taking to disclose in future. The draft instrument places no sunset on that comply-or-explain basis, so Scope 3 does not become fully mandatory in 2028.

• Material 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 (Scope 3 relief expires)

• Map complete value chain and suppliers
• Assess which GHG Protocol Scope 3 categories are material
• Engage suppliers on emissions data collection
• Implement data collection and verification systems
• Decide whether to obtain voluntary assurance, and prepare the assurance statement either way

Interactive Implementation Tools

Start Your Compliance Journey

With under six months until the proposed UK SRS S2 start date of 1 January 2027 under CP26/5 — and the FCA Policy Statement that would confirm it still unpublished as at 27 July 2026 — early preparation is critical.

Use our compliance guide and scope assessment tool to develop your implementation plan.