Sustainability Reporting Standards · Where it stands
Where the FCA process currently stands
UK SRS S2 is not yet mandatory for any company. The Financial Conduct Authority's CP26/5 process moves through five sequential stages — three are complete, two remain. Until the Policy Statement is issued, mandatory dates are FCA proposals, not law.
Last verified 12 May 2026
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Consultation Paper published
30 Jan 2026Completed
The FCA published CP26/5: Aligning listed issuers' sustainability disclosures with international standards, proposing to replace the existing TCFD-aligned Listing Rules with rules requiring in-scope listed companies to apply UK SRS S2 from 1 January 2027 and UK SRS S1 on a comply-or-explain basis.
The seven-week consultation drew responses from listed companies, institutional investors, accounting and assurance bodies, and trade associations. Material substantive submissions arrived from large asset managers and pension funds — several with positions notably stronger than the FCA proposals.
The FCA is reviewing consultation responses and preparing its final Policy Statement. Three outcomes are possible: adopt the proposals as drafted; modify them in light of consultation feedback (most likely on Scope 3 treatment, S1 sunset date, secondary-listing scope, or assurance requirements); or delay the timeline. The FCA has stated the Policy Statement is expected in autumn 2026 — typically September through November.
If the Policy Statement adopts the proposed timeline, the new UKLR rules would apply to accounting periods beginning on or after 1 January 2027 for in-scope listed companies (UKLR 6, 16, and 22 in full; UKLR 14 and 15 with a flexible disclose-home-jurisdiction-requirements approach). The existing TCFD-aligned rules would be deleted.
The 1 January 2027 date is when the rules would come into force — applied to accounting periods beginning on or after that date. The first mandatory UK SRS S2 reports would appear in the annual reports published around six months after each in-scope company's year-end. A December year-end company would publish in spring 2028; an April year-end would publish in mid-2028.
Sequence inferred from FCA CP26/5 implementation provisions in Chapter 8
All future-dated stages are subject to the FCA's final Policy Statement and to any further regulatory developments. Mandatory dates are FCA proposals, not law, until the Policy Statement is issued and the rules made.
Undetermined
No government or regulator document proposes a threshold or a commencement date for private company UK SRS reporting
There is no government proposal bringing private companies into UK SRS scope. The Government has committed only to consider the question — no more than that — through the Modernising Corporate Reporting programme. Any specific threshold or start date circulating in commentary is speculation.
UK SRS for Private Companies: Current Status
Private companies are not in scope of any UK SRS reporting requirement today, and none has been proposed.
Listed companies in UKLR 6, 16 and 22 face proposed mandatory UK SRS S2 climate reporting from accounting periods beginning on or after 1 January 2027 under FCA proposals that are themselves not yet final — the FCA Policy Statement is expected in autumn 2026 and had not been published as at 27 July 2026.
Private companies sit entirely outside that perimeter.
The only commitment on record is one to consider the question.
The DBT government response of 25 February 2026 states that the Modernising Corporate Reporting programme "will include consideration of the need for requirements within the Companies Act for private entities to report against UK SRS".
That is consideration, not commitment.
The MCR consultation has not been published as at 27 July 2026; the latest stated timing is "later in 2026", with no firm date given in the Regulation Action Plan progress report of July 2026.
Beware circulating thresholds
Figures such as "250 or more employees", "more than £54m turnover" and "more than £27m balance sheet", and start dates such as 1 January 2028, appear widely in secondary commentary on private company UK SRS. None of them comes from a government or regulator document. The thresholds are the Companies Act 2006 large-company test as uprated from 6 April 2025, lifted and reapplied by a third party; the 2028 date is the FCA's listed-company Scope 3 date, conflated. Other commentators speculating on the same question have landed on more than 500 employees and more than £500m turnover — an order of magnitude apart, which is itself evidence that nothing is settled.
Expected Scope
Sustainability Reporting Standards · Scope decision aid
Am I in scope of UK SRS?
A practical decision tree walking through the rules in CP26/5, the Companies Act, and the proposed mandatory framework. UK SRS itself is available for voluntary adoption by any UK entity — the question of mandatory application is jurisdiction-specific.
Last verified 27 July 2026 · Subject to FCA Policy Statement on CP26/5, unpublished as of that date
Question 1
Is the entity listed on the UK Main Market?
i.e. admitted to one of the categories under the UK Listing Rules
No, AIM-listed or unlisted
Yes, Main Market
Question 2
Which UKLR category?
The category determines the rules under FCA CP26/5
UKLR 6, 16, 22
Proposed mandatory UK SRS S2 from 1 Jan 2027
For Commercial (UKLR 6), Non-equity (UKLR 16), and Transition (UKLR 22) listed companies, FCA CP26/5 proposes UK SRS S2 climate disclosures — excluding Scope 3 — and comply-or-explain UK SRS S1 disclosures from accounting periods beginning on or after 1 January 2027. 515 listed companies are in full scope, of around 600 affected. Subject to the FCA Policy Statement (autumn 2026, not yet published). A company may elect transitional relief for Scope 3 and for S1. The FCA has not confirmed the relief periods, and the Standards themselves set none; when relief ends the topic falls to comply-or-explain, which is drafted without a sunset.
For Secondary listing (UKLR 14) and Depositary Receipts (UKLR 15), the FCA proposes a flexible approach. Companies would not apply UK SRS in full but would disclose the climate and sustainability reporting requirements applicable in their primary listing location, plus any voluntary standards adopted.
AIM is an LSE-operated market governed by AIM Rules, not the UKLR
Yes, AIM-listed
Out of CP26/5
Not in scope of FCA's proposed mandatory rules
AIM is operated by the London Stock Exchange under the AIM Rules for Companies — it is not a UKLR category. AIM companies are out of scope of CP26/5. AIM Rules may impose their own sustainability disclosure requirements; AIM companies may also voluntarily adopt UK SRS at any time.
Banks, insurers, large entities of public significance
PIE — Yes
s414CB(1)–(5) climate disclosures apply
PIEs must include a non-financial and sustainability information statement in the Strategic Report. Under s414CB(2A), the Government has designated UK SRS S2 as a national reporting framework — using UK SRS S2 satisfies the climate-related disclosure requirements. Voluntary adoption strongly recommended.
Voluntary adoption available · monitor MCR consultation
Large unlisted companies meeting the SECR two-of-three test (£36m turnover, £18m balance sheet, 250 employees) continue under SECR. UK SRS is voluntary today. The Modernising Corporate Reporting programme will consider whether the Companies Act should require private entities to report against UK SRS, but that consultation has not been published and no scope, threshold or date has been proposed by government.
UK SRS is available for voluntary use by any UK entity — including small businesses, charities, LLPs and partnerships. Voluntary adoption is all-or-nothing for the standard adopted (S1 or S2) and reliefs can be used indefinitely until any future mandatory rules apply.
There is no published definition of the "economically significant private entities" the Government has said it will consider, and no size test has been proposed.
Respondents to the DBT exposure-draft consultation asked specifically for that phrase to be defined, and the government response records the request without answering it.
Until the MCR consultation is published, any statement about which private companies would be caught, and from when, is unsourced.
Companies most exposed to the question
Private equity-backed companies with significant operations and institutional investor requirements
Large family businesses whose lenders, insurers and customers already ask sustainability questions
Subsidiaries of listed companies already supplying data into a parent's group reporting
Professional services firms are already advising on preparatory measures for companies anticipating a future consultation.
Note that the direction of travel in the MCR programme's first strand is reduction, not extension: the Written Ministerial Statement of 21 October 2025 announced exemptions for medium-sized private companies from the Strategic Report requirement and removal of the Directors' Report requirement.
Legislative Framework
If private company UK SRS reporting is ever introduced, the vehicle named by Government is the Companies Act 2006 rather than the FCA's listing rules, because private companies fall outside the FCA's listed perimeter.
The DBT government response frames it as consideration of "the need for requirements within the Companies Act", not as a settled legislative plan.
No draft clauses, regulations or commencement provisions exist.
Comparison: regimes that do apply to private companies
Two of three
SECR catches a company exceeding at least two of: £36m turnover, £18m balance sheet total, 250 employees — quoted companies are in scope regardless of size
Exceeds two or more of £36m turnover, £18m balance sheet, 250 employees
In force since 1 April 2019
The EU Corporate Sustainability Reporting Directive does extend sustainability reporting to large private undertakings, and is frequently cited as a precedent.
It is not evidence of a UK proposal, and the UK's chosen materiality basis differs from the EU's in any event.
The reporting obligation that already bites on large UK private companies is SECR, and the DESNZ post-implementation review published on 26 May 2026 recommended that SECR be retained with amendments rather than removed or replaced.
Refinements are to be explored through a planned 2026 consultation on streamlining energy and emissions reporting, which had not launched as at 27 July 2026.
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 27 July 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.
Early Preparation Advantage
Large private companies can usefully build sustainability data collection and governance capability regardless of whether a reporting obligation ever arrives, because SECR, lender due diligence and customer Scope 3 requests already demand much of the same data.
Immediate Actions
Establish governance frameworks for sustainability oversight and board-level accountability
Begin data collection for baseline sustainability metrics including Scope 1, 2, and 3 emissions
Assess current capabilities against the published UK SRS S1 and S2 text, which is available for voluntary use now
Engage professional advisers for implementation support and readiness assessment
Watch for the MCR consultation rather than planning to a date, since no date exists
Benefits of Early Preparation
Readiness if a consultation does lead to a requirement, avoiding rushed implementation
Commercial advantages in stakeholder engagement and investor relations
Better understanding of sustainability impacts and opportunities across operations
Improved access to sustainability-linked financing and reduced cost of capital