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.
2019 vs 2027
SECR active since 2019 for large companies; UK SRS proposed mandatory from 2027 for listed companies
Large companies and LLPs, plus all quoted companies
UK SRS
Proposed from 2027
Full sustainability reporting
515 listed companies in full scope
Key Differences
TCFD to UK SRS S2 Transition
Interactive comparison of requirements across the four-pillar framework
TCFD (Current)
Board oversight (voluntary)
Principles-based recommendations for board oversight of climate-related risks and opportunities
Voluntary principles
Requirements
Describe board oversight of climate risks/opportunities
Describe management's role in assessing climate risks/opportunities
General governance arrangements disclosure
UK SRS S2 (proposed from 2027)
Mandatory governance disclosures
Detailed requirements for governance body identification, skills assessment, and decision-making processes
Mandatory detailed
Requirements
Identity and responsibility of oversight body (S2 para 5)
Skills and competencies assessment (S2 para 6)
Information flow and reporting processes (S2 para 7)
Strategic integration and trade-offs (S2 para 8)
Target oversight and performance monitoring
Based on TCFD Final Report (June 2017) and UK SRS S2, published by the Department for Business and Trade on 25 February 2026. Application to listed companies is proposed in FCA CP26/5 and subject to the FCA Policy Statement, unpublished as of 27 July 2026.
SECR (Current Requirements)
SECR focuses on:
Energy consumption reporting across UK operations
Carbon emissions disclosure (Scope 1 and 2)
Energy efficiency measures narrative
Deadline: filed as part of the directors' report with the annual report and accounts (LLPs prepare a standalone Energy and Carbon Report)
SECR applies to:
Large companies exceeding at least two of: turnover above £36m, balance sheet total above £18m, more than 250 employees
Quoted companies (in scope regardless of size)
Large LLPs meeting the same size test
UK SRS (Proposed Requirements)
UK SRS will cover:
Climate-related disclosures (UK SRS S2 basis)
General sustainability requirements (UK SRS S1 basis)
Broader ESG metrics and governance frameworks
Deadline: Aligned with annual report publication
UK SRS applies to:
515 listed companies proposed to be in full scope, out of around 600 affected by the FCA's proposals in total
The full reporting obligation falls on commercial companies (UKLR 6), non-equity and non-voting equity shares (UKLR 16) and the transition category (UKLR 22)
Secondary listings (UKLR 14) and depositary receipts (UKLR 15) would instead give a signposting statement about the requirements applying in their primary listing location
Future extension to large private companies is under consideration only, with no proposed threshold or date
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)
2019: SECR becomes mandatory for large companies and LLPs meeting size thresholds 2026: UK SRS S1 and S2 published by DBT (25 February) 2026: DESNZ post-implementation review of SECR recommends retaining SECR with amendments (26 May) 2027: UK SRS S2 proposed mandatory for listed companies (1 January) 2029: UK SRS S1 proposed comply-or-explain for listed companies (1 January)
Does UK SRS Replace SECR?
No. SECR and UK SRS are separate obligations and both continue.
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 are to be explored through a planned 2026 consultation on streamlining energy and emissions reporting, which has not yet launched.
On the interaction between the two regimes, the DBT government response of 25 February 2026 commits only to consider: DESNZ "will consider how energy and emissions data reported by an entity using UK SRS interacts with the SECR requirements, with a view to reducing unnecessary duplication where possible."
SECR was the existing requirement most commonly cited by respondents to the UK SRS exposure-draft consultation, which received 209 responses.
Nothing published to date phases SECR out, and no date has been set for any change. See regulatory updates for the current status.
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.
If You're Already SECR-Compliant
Your SECR reporting provides a foundation for UK SRS compliance:
Energy data collected for SECR supports climate disclosures under UK SRS S2
Carbon emissions reporting overlaps with UK SRS emissions requirements
Governance processes can be extended for broader sustainability oversight
Preparing for UK SRS
Early Preparation Advantage
Start building sustainability data collection now, even if UK SRS doesn't apply until 2027.
Early preparation reduces compliance costs and improves data quality for mandatory reporting.
Which Framework Applies to You?
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 a one-year Scope 3 relief and a two-year S1 relief; when each expires 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.