Last reviewed · 8 May 2026 · Independent UK SRS Reference

UK SRS Regulatory Updates

Sustainability Reporting Standards · Regulatory chronology

The UK SRS regulatory timeline, by actor

Four parallel tracks of activity from the UK Technical Advisory Committee's first recommendation to the proposed in-force date. Reading by row shows what each regulator did and when; reading by column shows the cluster of activity in early 2026.

Last verified 12 May 2026 · Footnotes link to primary sources

202420262027202820292025
DBT
Standards publisher · private companies
12 May 2026
25 Jun 2025Consultation opens[1]
17 Sep 2025Closes · 209 responses[2]
25 Feb 2026UK SRS S1, S2 published[3]
FCA
Listed-company regulator · CP26/5
12 May 2026
30 Jan 2026CP26/5 published[4]
20 Mar 2026Consultation closes[5]
Autumn 2026Policy Statement[6]
FRC
Assurance · TAC and PIC secretariat
12 May 2026
Dec 2024TAC initial advice[7]
12 Nov 2025ISSA (UK) 5000 issued[8]
26 Jan 2026TAC final letter to DBT[9]
15 Dec 2026ISSA (UK) 5000 effective[8]
Effect
Proposed mandatory application
12 May 2026
1 Jan 2027UK SRS S2 in force[10]
1 Jan 2028Scope 3 relief ends[10]
1 Jan 2029S1 deferral ends[10]
DBT events
FCA events
FRC events
Mandatory effect (proposed)
Future / proposed (hollow marker)
Reading guide. The horizontal "now" line shows the date the page was last verified. Hollow markers and italic labels indicate future events that are proposed but not yet legally binding — they depend on the FCA's autumn 2026 Policy Statement or on separate DBT regulation. The clustering of events around February 2026 is genuine: in a five-week window the FCA opened CP26/5 (30 Jan), the TAC sent its final letter to DBT (26 Jan), and DBT published the final standards (25 Feb).
Primary sources
[1]DBT, "Consultation on Exposure Drafts of UK Sustainability Reporting Standards" — published 25 June 2025, closed 17 September 2025. gov.uk consultation page
[2]DBT Government Response, paragraph 1.6 — 209 responses (170 online survey, 39 by email; 199 organisations, 10 individuals). Government Response · web version
[3]DBT publication of final UK SRS S1 and S2 — 25 February 2026. Standards available for voluntary use immediately; no effective date clauses. DBT publication page
[4]FCA Consultation Paper CP26/5 — "Aligning listed issuers' sustainability disclosures with international standards", published 30 January 2026. FCA CP26/5 landing page
[5]FCA CP26/5 consultation closed — 20 March 2026. Substantive submissions from Norges Bank Investment Management, the Quoted Companies Alliance, the Investment Association and Big Four assurance firms. Norges Bank IM response
[6]FCA Policy Statement — expected autumn 2026, per CP26/5 timetable. Final rules subject to Policy Statement; could adopt, modify, or delay the proposals.
[7]UK Sustainability Disclosure Technical Advisory Committee (TAC) — initial endorsement recommendations to DBT, December 2024. Hosted by the FRC. FRC · TAC page
[8]FRC, ISSA (UK) 5000 — sustainability assurance standard published 12 November 2025, effective for engagements covering periods beginning on or after 15 December 2026. FRC · ISSA (UK) 5000
[9]TAC supplementary written recommendations to the Secretary of State for Business and Trade — 26 January 2026. Addressed financed emissions and incorporation of ISSB December 2025 amendments to IFRS S2. FRC · TAC endorsement project
[10]FCA CP26/5, Chapter 8 (Implementation and transitional arrangements) — proposed in-force date 1 January 2027 for UK SRS S2 (UKLR 6, 16, 22); one-year optional Scope 3 deferral; two-year optional S1 deferral. All dates subject to Policy Statement. CP26/5 full text (PDF)
Autumn 2026
Expected FCA final policy statement on mandatory UK SRS S2 reporting rules following CP26/5 consultation

This page tracks regulatory developments from GOV.UK, FCA.org.uk, FRC.org.uk, and other official sources relating to the UK Sustainability Reporting Standards.

Key dates to watch: FCA final rules expected Autumn 2026, the FRC interim assurance register targeted to be operational by mid-2026, and the private companies consultation expected later in 2026.

For the full implementation schedule, see the UK SRS mandatory timeline.

Key Upcoming Milestones

Mid-2026 (target): FRC interim register of sustainability assurance practitioners — targeted, with no launch announcement as at 22 August 2026
Autumn 2026: FCA final policy statement on mandatory UK SRS S2 reporting rules
15 December 2026: ISSA (UK) 5000 assurance standard effective
1 January 2027: UK SRS S2 proposed mandatory for listed companies in scope
Later in 2026: Modernising Corporate Reporting consultation, which DBT has said will consider the need for Companies Act requirements for private entities to report against UK SRS — no scope, threshold or date has been proposed
2026: DESNZ consultation on streamlining energy and emissions reporting, announced in the SECR post-implementation review and not yet launched

Developments Since February 2026

26 May 2026: DESNZ Publishes the Statutory Post-Implementation Review of SECR

DESNZ published the statutory post-implementation review of the SECR regulations on 26 May 2026, with the formal departmental recommendation to amend rather than remove.
"The overarching recommendation is to retain the SECR requirements with amendments… Removing SECR would risk reversing gains in transparency and board level accountability."

Refinements will be explored through a planned 2026 consultation on streamlining energy and emissions reporting, which has not yet launched.

UK SRS does not replace or phase out SECR: the government has committed only to consider how energy and emissions data reported under UK SRS interacts with SECR, with a view to reducing unnecessary duplication where possible.

5 June 2026: FCA CP26/17 Proposes Removing Product-Level TCFD Reporting

FCA CP26/17 (Quarterly Consultation No 52), published 5 June 2026, proposes removing product-level TCFD reporting for asset managers, life insurers and FCA-regulated pension providers, replacing it with targeted retail and institutional disclosure rules.
The consultation closed on 13 July 2026 and final rules are expected in autumn 2026. Entity-level TCFD reporting is not changing — see TCFD vs UK SRS.

11 June 2026: DESNZ Publishes the 2026 GHG Conversion Factors

DESNZ published Greenhouse gas reporting: conversion factors 2026 on 11 June 2026, covering UK activities in 2026, with an accompanying methodology paper and major-changes report.

These are the factors used for SECR and for Scope 1, 2 and 3 emissions reporting, and they are distinct from Defra's spend-based emissions multipliers published with the UK and England carbon footprint statistics.

25 June 2026: The Seventh Carbon Budget Is Set

The Carbon Budget Order 2026 (SI 2026/695), made 25 June 2026, sets the seventh carbon budget at 535 MtCO2e for the 2038–2042 period.

Carbon budgets are a duty on the Secretary of State under Climate Change Act 2008 section 4(1) — a national emissions ceiling the government must set and stay under. They create no direct obligation on any company, and are distinct from any UK SRS, SECR or ESOS disclosure duty.

Still outstanding as at 22 August 2026

FCA Policy Statement on CP26/5 — not published; expected autumn 2026
Modernising Corporate Reporting consultation covering private entities — not published; latest stated timing "later in 2026"
Government response to the DESNZ transition plan consultation — the consultation closed 17 September 2025 and GOV.UK still shows "We are analysing your feedback"
DESNZ consultation on streamlining energy and emissions reporting — announced in the SECR post-implementation review, not yet launched

Recent Regulatory Developments

February 2026: UK SRS S1 and S2 Final Standards Published

The Department for Business and Trade published the final UK SRS S1 and UK SRS S2 standards on 25 February 2026.

The standards are available for voluntary adoption immediately, with mandatory application for listed companies proposed from 1 January 2027.

January 2026: FCA CP26/5 Consultation Launch

The FCA launched consultation CP26/5 on sustainability disclosures on 30 January 2026, proposing mandatory UK SRS S2 for 515 listed companies in full scope, out of around 600 affected by the proposals in total (CP26/5 Annex 2, paragraph 43).

The consultation closed on 20 March 2026, with the final policy statement expected Autumn 2026.

November 2025: FRC Issues ISSA (UK) 5000

The FRC issued International Standard on Sustainability Assurance (UK) 5000 on 12 November 2025, effective for assurance engagements on sustainability information reported for periods beginning on or after 15 December 2026, with early application permitted.

The standard is for voluntary use: it governs how an assurance engagement is performed where one is commissioned, and creates no obligation to obtain assurance.

Forthcoming Developments to Watch

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

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.

FCA · CP26/5

Consultation period closes

20 Mar 2026Completed

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.

Public responses include Norges Bank IM · KPMG analysis

3

Policy Statement

Autumn 2026 · expectedCurrently pending

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.

FCA · CP26/5 timetable

4

Rules come into force

1 Jan 2027 · proposedSubject to Policy Statement

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.

FCA · CP26/5 PDF · Chapter 8

5

First mandatory reports published

Spring 2028 · for Dec year-endsProjected

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.

FCA Final Policy Statement

Expected Autumn 2026, the FCA's final policy statement will confirm or modify the mandatory UK SRS S2 requirements for listed companies.

This will establish the definitive scope, timeline, and transitional reliefs for mandatory reporting.

FRC Interim Assurance Register

The government has tasked the FRC with establishing an interim, non-legislative, voluntary public register of sustainability assurance practitioners, targeted to be operational by mid-2026, with statutory underpinning to follow when Parliamentary time allows.

As at 22 August 2026 there is no FRC announcement that the register is live.

Registration will be voluntary and profession-agnostic, covering both audit and non-audit professionals providing sustainability assurance, with an initial focus on firms rather than sole practitioners.

Private Companies Consultation

The Modernising Corporate Reporting programme, announced by DBT in a Written Ministerial Statement of 21 October 2025, "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: no government or regulator document has proposed any threshold or date for private-company UK SRS reporting, and the consultation has not been published.

The latest stated timing is "later in 2026".

Implementation Guidance Updates

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 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.

For background on what the standards require, see our guides on UK SRS S1, UK SRS S2, and the four-pillar framework.

Companies preparing for compliance should start with a gap analysis.

For analysis of the FCA CP26/5 consultation, see KPMG's CP26/5 analysis and BDO's overview of sustainability reporting requirements.

For common questions, visit the UK SRS FAQ.

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