Last reviewed · 8 May 2026 · Independent UK SRS Reference
Last reviewed · 8 May 2026 · Independent UK SRS Reference

Critical Countdown: S2 Climate Reporting

days remaining

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

Sustainability Reporting Standards · Reference Guide

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

DBT · publisher
FCA · listed companies
FRC · assurance & committees
ISSB · global baseline
Effect · proposed application
12 May 2026
Tap any milestone above for full citation, regulatory body, and primary-source link.
Sustainability Reporting Standards · Implementation Benchmark

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

Foundation phase
Data infrastructure
Governance & controls
Assurance & output
Critical path workstream
Workstreams
M1
M2
M3
M4
M5
M6
M7
M8
M9
M10
M11
M12
M13
M14
M15
M16
M17
M18
Materiality assessment
Gap analysis & strategy
Governance framework
Training & capability
Scope 1 & 2 data
Scope 3 supplier engagement
Scope 3 data validation
Scenario methodology
Quantitative scenarios
Connectivity mapping
Transition planning
Dry run & rehearsal
Assurance preparation
Report preparation
Click any bar above for workstream detail, typical effort, and dependencies.
Critical path
18 months

From kickoff to first UK SRS S2 report. Driven by Scope 3 supplier engagement and quantitative scenario modelling — neither compressible.

Scope 3 dominance
14 months

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.

Earliest sensible start
3 months

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.