UK SRS by the numbers

Basic UK SRS Framework

What are the UK Sustainability Reporting Standards?

The UK Sustainability Reporting Standards (UK SRS) are the UK Government's endorsed versions of the ISSB's global baseline sustainability disclosure standards — IFRS S1 and IFRS S2. Published by DBT on 25 February 2026, UK SRS S1 covers general sustainability-related financial disclosures while UK SRS S2 covers climate-related disclosures. Both incorporate UK-specific amendments and are designed to sit within the existing Strategic Report framework under the Companies Act 2006.

How do UK SRS relate to IFRS S1 and IFRS S2?

UK SRS S1 and S2 are the UK's national adoptions of IFRS S1 and IFRS S2 respectively. They follow the ISSB global baseline with minor UK-specific amendments, meaning companies reporting under UK SRS will be substantially aligned with the global ISSB framework. The amendments address proportionality, Strategic Report placement, jurisdictional relief provisions, and alignment with existing UK reporting legislation.

What are the UK-specific amendments to the ISSB standards?

The UK has made targeted amendments to the global ISSB standards to fit the UK regulatory context. These include modifications for proportionality considerations, specific placement requirements within the Strategic Report, transitional relief provisions for certain disclosure requirements, and technical amendments to align with existing UK corporate reporting legislation.

Timeline and Mandatory Dates

When does UK SRS become mandatory?

UK SRS S2 is proposed mandatory from January 2027. FCA CP26/5 paragraph 3.1 confirms this applies to approximately 500 companies. UK SRS S1 follows on a comply-or-explain basis from 1 January 2029.

What is the Scope 3 transition timeline?

Scope 3 emissions disclosure under UK SRS S2 benefits from a one-year transitional relief period. From 1 January 2028, Scope 3 disclosure moves to a comply-or-explain basis for all in-scope companies. This relief recognises the complexity of value chain emissions measurement and reporting.

Can companies adopt UK SRS voluntarily before mandatory dates?

Yes. Both UK SRS S1 and S2 are available for voluntary use immediately following their publication on 25 February 2026. However, voluntary adoption requires full compliance with the applicable standard — companies cannot cherry-pick individual disclosure requirements.

Scope and Application

Which companies must comply with UK SRS?

The initial scope covers approximately 500 UK primary-listed companies. This includes commercial companies with equity shares admitted to the premium listing segment (UKLR Chapter 6), companies with non-equity shares in the premium listing segment (UKLR Chapter 16), and companies in the transition category (UKLR Chapter 22). FCA CP26/5 Chapter 3 contains the detailed scope definitions.

Do overseas companies listed in the UK need to comply?

Overseas companies with secondary listings and depositary receipt categories are not required to comply with UK SRS directly. Instead, they must disclose their home jurisdiction sustainability reporting requirements. Companies with a primary listing in the UK are in scope regardless of domicile.

Will UK SRS apply to private companies?

The Government has indicated its intention to extend UK SRS to economically significant private companies and LLPs through Companies Act amendments. However, the specific thresholds and timeline have not yet been confirmed. Private companies should monitor regulatory developments for future obligations.

S1 and S2 Standards

What is the difference between UK SRS S1 and S2?

UK SRS S2 deals exclusively with climate-related financial disclosures and includes greenhouse gas emissions, climate risks and opportunities, and transition planning. UK SRS S1 covers general sustainability-related financial disclosures beyond climate, including biodiversity, water resources, social factors, and human capital. S2 is proposed mandatory from January 2027, while S1 follows on a comply-or-explain basis from January 2029.

What is the materiality definition under UK SRS?

UK SRS adopts the ISSB's enterprise value approach to materiality. Sustainability information is material if omitting, misstating, or obscuring it could reasonably be expected to influence decisions that primary users make on the basis of financial reports. This focuses on financially material sustainability risks and opportunities rather than impact materiality.

What is the four-pillar framework?

UK SRS uses a four-pillar disclosure framework inherited from TCFD but significantly expanded: Governance (oversight and governance processes), Strategy (actual and potential impacts on strategy and business model), Risk Management (processes to identify, assess, and manage sustainability risks), and Metrics and Targets (metrics and targets used to assess and manage sustainability-related risks and opportunities).

Climate and Scope 3

Is climate scenario analysis mandatory under UK SRS?

Yes. Climate scenario analysis is mandatory under UK SRS S2, representing a significant strengthening from the TCFD regime where it was recommended but not required. Companies must disclose scenario analysis assumptions, methodologies, and results as part of their strategy disclosures.

What must companies disclose about transition plans?

Under UK SRS S2, companies must disclose their climate transition plan or explain why they have not published one. Where a transition plan exists, disclosures must cover emissions reduction targets, actions to achieve those targets, capital allocation committed to transition activities, and progress against previous commitments.

What are the Scope 3 disclosure requirements?

UK SRS S2 requires disclosure of Scope 3 greenhouse gas emissions in absolute terms and intensity metrics where appropriate. From 1 January 2028, this moves to a comply-or-explain basis recognising the measurement challenges. Companies must also disclose their approach to Scope 3 estimation, significant assumptions, and data limitations.

Assurance

Is assurance required for UK SRS disclosures?

UK SRS assurance is voluntary. FCA CP26/5 paragraph 7.5 states unambiguously that the FCA is not proposing mandatory assurance requirements. However, companies must disclose whether they have obtained third-party assurance and, if so, provide specific details about the assurance provider, scope, level, and standards used.

What is ISSA (UK) 5000?

ISSA (UK) 5000 is the UK sustainability assurance standard issued by the FRC. Effective for assurance engagements on sustainability information reported for periods beginning on or after 15 December 2026, it provides general requirements for both limited and reasonable assurance engagements. The standard is profession-agnostic and applies to all sustainability information except that required in financial statements.

Legal Framework and Liability

What liability protections exist for UK SRS disclosures?

UK SRS disclosures made within the Strategic Report attract the same section 463 safe-harbour protection as other Strategic Report disclosures under the Companies Act 2006. This limits directors' civil liability to circumstances where the director knew the statement was untrue or misleading, was reckless, or involved dishonest concealment. Voluntary third-party assurance does not change this protection.

How does UK SRS replace TCFD?

The TCFD was formally disbanded in October 2023. UK SRS S2 is proposed to replace the TCFD-aligned Listing Rules from January 2027, significantly expanding disclosure requirements including mandatory scenario analysis, formal compliance statements, and the four-pillar framework with enhanced metrics and targets requirements. The transition represents a move from 'recommended' to 'comply-or-explain' for most requirements.

Implementation and Compliance

How should companies prepare for UK SRS compliance?

Companies should conduct a gap analysis of current TCFD reporting against UK SRS S2 requirements, assess Scope 3 data collection capabilities, review governance structures for sustainability oversight, evaluate systems and controls for connectivity between sustainability and financial reporting, consider voluntary assurance arrangements, and brief the board on disclosure obligations and resource requirements. Professional guidance is available from major accounting and consulting firms.

Where in the annual report do UK SRS disclosures go?

UK SRS disclosures are made within the Strategic Report under section 414CB(2A) of the Companies Act 2006. Companies have flexibility in exactly where within the Strategic Report the disclosures appear, but they must be clearly identified as UK SRS disclosures and include a formal statement of compliance with the applicable standards.