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.
250+ employees
Expected threshold for private company UK SRS requirements based on SECR precedent and EU CSRD alignment
No confirmed timeline for private company UK SRS requirements. Government review of non-financial reporting is considering private company scope as part of the broader Modernising Corporate Reporting programme.
UK SRS for Private Companies: Current Status
Private company UK SRS requirements remain under active government review as part of the broader Modernising Corporate Reporting programme.
While listed companies face proposed mandatory UK SRS S1 and S2 from 1 January 2027 under FCA proposals, large private companies are expected to face similar requirements through future legislation.
Understanding potential private company UK SRS scope helps large private companies, advisors, and stakeholders prepare for expected reporting requirements.
Government consultation on modernising corporate reporting addresses private company reporting obligations.
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 12 May 2026 · Subject to FCA Policy Statement on CP26/5
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 mandatory UK SRS S2 climate disclosures and comply-or-explain UK SRS S1 disclosures from accounting periods beginning on or after 1 January 2027. Subject to FCA Policy Statement (autumn 2026). Scope 3 one-year deferral; S1 two-year optional deferral.
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 but the Modernising Corporate Reporting consultation may extend mandatory application to economically significant private companies — likely earliest 2028 reporting periods.
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.
Large private companies meeting size thresholds (250+ employees or £36m+ turnover) are most likely candidates for UK SRS requirements.
Current SECR regulations already apply these thresholds, providing precedent for private company sustainability requirements.
Companies Likely to be Affected
Private equity-backed companies with significant operations and institutional investor requirements
Large family businesses above size thresholds seeking stakeholder engagement benefits
Subsidiaries of listed companies through group reporting obligations and parent company alignment
Professional services firms are already advising on preparatory measures for companies anticipating future UK SRS obligations.
Legislative Framework
Private company UK SRS requirements would likely be implemented through amendments to the Companies Act 2006,
extending strategic report requirements to capture sustainability disclosures. This approach maintains consistency with listed company requirements while addressing private company characteristics.
International Precedents
Framework
Scope
Threshold
Status
EU CSRD
Large private companies
250+ employees, €50m+ revenue
Active 2024+
UK SRS (proposed)
Large private companies
250+ employees, £36m+ turnover
Under review
SECR (current)
Large companies
250+ employees
Established 2019
EU Corporate Sustainability Reporting Directive (CSRD) applies to large private companies, providing international precedent for private company sustainability requirements.
EU CSRD scope includes companies with 250+ employees, €50m+ revenue, or €25m+ assets.
UK private company requirements may adopt similar thresholds while reflecting UK market characteristics and regulatory preferences.
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.
Early Preparation Advantage
Large private companies should begin sustainability data collection and governance preparation regardless of timeline uncertainty.
Early preparation enables smoother transition when requirements become mandatory.
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 expected UK SRS requirements using gap analysis
Engage professional advisers for implementation support and readiness assessment
Benefits of Early Preparation
Smoother transition when requirements become mandatory, 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