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.
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.
Under the current FCA proposals, companies are not required to produce a climate transition plan. However, they are required to disclose whether they have published one, where it can be found, its key elements, and progress made against it.
If a company has not published a transition plan, it must explain why. This is a disclose-or-explain approach to transition plans, rather than a mandate to produce one.
The requirement sits within the broader UK SRS S2 climate disclosure framework.
Where a transition plan exists, the disclosure must cover the company's emissions reduction targets (including whether they are absolute or intensity-based), the actions being taken to achieve those targets, the capital allocation committed to transition activities, and progress made against previous disclosures.
The plan must be consistent with the company's overall strategy and risk management disclosures under the four-pillar framework.
Transition plan targets should also align with the Scope 3 emissions disclosures required elsewhere in UK SRS S2.
The TPT Framework
The UK Transition Plan Taskforce (TPT) published its framework in October 2023, setting out a gold standard for what a credible transition plan should contain.
While the TPT Framework is not legally mandated under UK SRS, it is the most widely referenced guidance in the UK market and is expected to inform both corporate practice and regulatory expectations.
The framework covers five elements: foundations (company-wide ambition and governance), implementation strategy (actions and policies), engagement strategy (value chain and industry collaboration), metrics and targets, and governance.
Boards should ensure they understand the TPT Framework when overseeing transition plan development.
The Separate Government Consultation
The UK Government is separately consulting on potential mandatory transition plan requirements that would go beyond the current UK SRS S2 disclose-or-explain approach.
This consultation is expected to consider whether certain large companies should be required to produce and publish a transition plan, the minimum content requirements, and the relationship with UK SRS disclosures.
The timeline for this consultation has not been confirmed, but it is expected during 2026. See regulatory updates for the latest developments.
Private companies should also monitor this consultation, as mandatory transition plan requirements could eventually extend beyond listed entities.
As KPMG's analysis of FCA CP26/5 notes, the relationship between UK SRS transition plan disclosures and any future mandatory requirements will be a key design challenge for regulators. Companies should prepare on the assumption that transition plan obligations will only increase over time.
Assurance Considerations
Transition plan disclosures made within the Strategic Report under UK SRS S2 will be subject to the same assurance framework as other UK SRS disclosures. The FRC is establishing an interim register of sustainability assurance practitioners by mid-2026, and ISSA (UK) 5000 provides the assurance standard. While assurance of transition plan disclosures is not yet mandated, audit committees should consider whether voluntary assurance would strengthen the credibility of their transition plan disclosure. See the UK SRS mandatory timeline for all key dates.
Companies in scope should ensure their transition plan disclosures are consistent with their scenario analysis outputs and aligned with the GHG Protocol methodology used for emissions reporting. The transition from TCFD to UK SRS represents an opportunity to strengthen transition plan disclosures. A gap analysis can help identify where existing transition plan documentation falls short of UK SRS expectations. For further professional guidance, see BDO's overview of sustainability reporting requirements.
Sources and References
FCA CP26/5 — CP26/5 transition plan disclosure requirements
Transition Plan Taskforce — Transition Plan Taskforce (TPT) disclosure framework
GFANZ — GFANZ transition plan guidance
SBTi — SBTi corporate net-zero standard
FRC — FRC assurance framework for transition plan disclosures