Scope · Private companies
Private companies and UK SRS
There is no government proposal bringing private companies into UK SRS scope.
The Government has committed only to consider the question, and no more than that.
The Modernising Corporate Reporting consultation of 7 September 2026 says only that it “will consider how UK SRS should be reflected in the Companies Act 2006”.
The answer
Does UK SRS apply to private companies?
Not today: private companies are not in scope of any UK SRS reporting requirement, and none has been proposed.
Listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis from accounting periods beginning on or after 1 January 2027, under the FCA’s final rules of 30 September 2026, which finalised FCA CP26/5.
Those rules are listing rules: they reach listed companies only.
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.
Source: DBT consultation response
Any threshold or start date for private companies circulating in commentary is not drawn from a government source.
September 2026
What the MCR consultation actually says
The MCR consultation was published on 7 September 2026 by the Department for Business, Innovation, Science and Trade (the renamed DBT), having been trailed as “later in 2026” in the Regulation Action Plan progress report of July 2026.
It closes at 11:59pm on 30 November 2026, and on UK SRS it makes no proposal.
“Looking ahead, the government will consider how UK SRS should be reflected in the Companies Act 2006, taking into consideration feedback to this consultation, the CFD PIR and related processes.”
Asks whether a new “very large” company category should be created for certain non-financial reporting obligations, says the government “has an open mind on how to proceed”, and attaches no figures.
The government “does not have any plans to introduce new requirements for reporting companies to obtain assurance over future UK SRS reporting at this stage”.
Caution
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.
| Circulating figure | Where it actually comes from | A UK SRS proposal? |
|---|---|---|
| 250+ employees, >£54m turnover, >£27m balance sheet | The Companies Act 2006 large-company test as uprated from 6 April 2025, lifted and reapplied by a third party | No |
| 1 January 2028 | The date CP26/5 proposed for listed-company Scope 3 comply-or-explain, conflated | No |
| >500 employees and >£500m turnover | The existing climate-related financial disclosure test, landed on by other commentators speculating on the same question | No |
That different commentators have landed on different tests is itself evidence that nothing is settled.
Who might be caught
Expected scope for private companies under UK SRS
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 for that phrase to be defined, and the government response records the request without answering it.
The MCR consultation asks how a “very large” company threshold should be defined and which requirements should attach to it, but proposes nothing — so any statement about which private companies would be caught, and from when, is still unsourced.
Companies most exposed to the question
Private equity-backed companies
Significant operations and institutional investor requirements.
Large family businesses
Lenders, insurers and customers already ask sustainability questions.
Subsidiaries of listed companies
Already supplying data into a parent’s group reporting.
The Written Ministerial Statement of 21 October 2025 (HCWS973) announced exemptions for medium-sized private companies from the Strategic Report requirement and removal of the Directors’ Report requirement.
The September 2026 consultation says it will “test the merits of non-financial reporting requirements for private companies”.
The vehicle
The 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.
For how listed companies are treated, see who must comply with UK SRS.
Comparison
Regimes that do apply to private companies
| Framework | Applies to private companies? | Test | Status |
|---|---|---|---|
| EU CSRD | Yes, for the largest undertakings | More than 1,000 employees and more than €450m net turnover (both), from financial years beginning on or after 1 January 2027 | Amended by Omnibus I (Directive (EU) 2026/470) |
| UK SRS | No | No threshold proposed | Consideration only, via MCR |
| SECR (current) | Yes | Exempt only if two or more of: turnover not more than £36m, balance sheet total not more than £18m, not more than 250 employees | In force for financial years beginning on or after 1 April 2019 |
The EU precedent
The EU Corporate Sustainability Reporting Directive does extend sustainability reporting to large private undertakings, and is frequently cited as a precedent.
Its scope has since narrowed: the consolidated Accounting Directive as amended by Omnibus I applies the requirement to undertakings that exceed both 1,000 employees and €450m net turnover, from financial years beginning on or after 1 January 2027.
It is not evidence of a UK proposal, and the UK’s chosen materiality basis differs from the EU’s in any event.
SECR already bites
The reporting obligation that already applies to large UK private companies is SECR.
The DESNZ post-implementation review published on 26 May 2026 recommended that SECR be retained with amendments rather than removed or replaced.
The MCR consultation (paragraph 150) records that DESNZ intends to consult on SECR and ESOS later in 2026; it had not launched as at 26 September 2026.
See SECR and UK SRS.
Preparation
Preparing without a date
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.
- Respond to the MCR consultation (open to 30 November 2026) on the “very large” threshold and private-company reporting questions, rather than planning to a date, since no date exists.
Why prepare early
- Readiness if a consultation does lead to a requirement, avoiding rushed implementation.
- Commercial advantages in stakeholder engagement and investor relations.
- A better understanding of sustainability impacts and opportunities across operations.
- A data set lenders and customers already ask for through sustainability-linked financing and Scope 3 requests.
Large private companies can usefully build sustainability data collection and governance capability whether or not a reporting obligation ever arrives.
SECR, lender due diligence and customer Scope 3 requests already demand much of the same data.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- Department for Business and TradeGovernment response on UK Sustainability Reporting Standards
¶1.16: the MCR programme will include consideration of Companies Act requirements for private entities. Consideration, not commitment.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Published 7 September 2026, closes 30 November 2026. ¶155 (UK SRS “will consider”), ¶57–58 (“very large” threshold, no figures), ¶150 (SECR/ESOS), ¶178 (no assurance requirement at this stage).
- Department for Business and TradeRegulation Action Plan progress report, July 2026 (PDF)
Trailed the MCR consultation as “later in 2026”.
- Financial Conduct AuthorityCP26/5: sustainability disclosures — consultation page
The listed-company consultation, finalised by PS26/19 on 30 September 2026.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
First published 30 September 2026. The final rules reach listed companies in UKLR 6, 14, 15, 16 and 22 only — comply or explain from accounting periods starting on or after 1 January 2027.
- UK ParliamentWritten statement HCWS973, 21 October 2025
Official record of the statement on the Regulation Action Plan and Modernisation of Corporate Reporting.
- TheyWorkForYou (Hansard mirror)Written Ministerial Statement, 21 October 2025
The same statement; its first strand reduces rather than extends private-company reporting.
- legislation.gov.ukCompanies Act 2006
The vehicle the Government has named as under consideration for any private-entity requirement.
- EUR-LexDirective (EU) 2022/2464 (CSRD), as adopted
As adopted in December 2022 — not the current scope text.
- EUR-LexDirective 2013/34/EU — consolidated text, 18 March 2026
Article 19a(1) as amended by Directive (EU) 2026/470 (Omnibus I): more than €450m net turnover and 1,000 employees, from financial years beginning on or after 1 January 2027.
- legislation.gov.ukSI 2008/410, Schedule 7
Matters to be dealt with in the directors’ report, including SECR.
- legislation.gov.ukSI 2008/410, Schedule 7, Part 7A — the SECR size exemption
¶20B(2): exempt where two or more of turnover not more than £36m, balance sheet total not more than £18m, not more than 250 employees.
- Department for Energy Security and Net ZeroEnvironmental reporting guidelines, including SECR requirements
The energy and carbon reporting requirements that already apply to large UK private companies.
- Department for Energy Security and Net Zero2026 post-implementation review of the SECR Regulations 2018
Published 26 May 2026; recommends retaining SECR with amendments.
Continue reading
Read next
UK SRS compliance
Implementation guidance for UK SRS reporting.
UK SRS timeline
Key dates, and the FCA’s comply-or-explain timetable for listed companies.
SECR and UK SRS
How current SECR obligations interact with UK SRS.
Who must comply with UK SRS
Scope by listing category, and where private companies sit.
Voluntary UK SRS reporting
Adopting the standards before any requirement exists.
SME sustainability reporting
What smaller UK companies are and are not asked to report.