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.
Most SMEs in the UK are not subject to mandatory sustainability reporting requirements.
However, there are some exceptions and voluntary opportunities:
Current mandatory requirements for SMEs
SECR (large SMEs only): SMEs meeting large company thresholds (£36m+ turnover or £18m+ balance sheet or 250+ employees) must comply with SECR.
Directors' Report disclosure: Large companies must include energy and carbon information in their Directors' Report,
including UK energy consumption and greenhouse gas emissions data.
Supply chain requirements: SMEs may need to provide sustainability data to larger customers who are subject to mandatory reporting,
especially for Scope 3 emissions calculation purposes.
Voluntary adoption opportunities
TCFD-aligned baseline (typical today)
UK SRS S2 target (proposed by 2027)
Dimension
Now
Target
Governance & oversight
3
4
Materiality assessment
2
5
Scope 1 & 2 data
4
5
Scope 3 coverage
1
5
Transition plan
1
4
FS connectivity
1
5
Risk management
3
4
Scenario analysis
2
5
Click any dimension above or on the radar chart for the baseline, target, and citation.
UK SRS voluntary use: Any UK entity can voluntarily adopt UK SRS S1 and S2 from publication date.
Customer requirements: Many SMEs adopt sustainability reporting to meet customer or investor expectations,
particularly when supplying large corporations subject to mandatory disclosure.
Access to finance: Some lenders and investors require ESG information from SME borrowers,
especially for sustainability-linked loans and green financing products.
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.
Proportionality provisions: UK SRS includes comply-or-explain mechanisms that allow smaller entities to provide proportionate disclosures.
Building capability: SMEs can start with basic climate disclosures and build reporting capabilities over time,
beginning with Scope 1 and 2 emissions before expanding to Scope 3 assessment.
Professional support: Consider working with sustainability consultants familiar with SME compliance requirements,
including specialists in small business ESG implementation and cost-effective reporting solutions.
Planning for growth
SMEs planning expansion should consider whether growth might bring them into scope of mandatory reporting requirements.
Early adoption of voluntary standards can help build capability before requirements become mandatory.