UK SRS FAQ: essential questions answered

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 for voluntary use, UK SRS S1 covers general sustainability-related financial disclosures while UK SRS S2 covers climate-related disclosures.

Both incorporate UK-specific differences and are designed to be reported alongside the financial statements — in the UK, typically within the Strategic Report.

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 a small number of UK-specific differences, so companies reporting under UK SRS will be substantially aligned with the global ISSB framework.

One exception matters: UK SRS S1 ¶73A means an entity using the climate-first relief cannot assert compliance with UK SRS S1.

The differences are mapped in Annex A of the government’s consultation response, which states that where a requirement is not in its table there is no difference.

The government consulted on six proposed amendments in June 2025, but two did not survive to publication (one withdrawn, one replaced) and further provisions were added afterwards, so the final position is mapped in Annex A rather than by a count.

The final differences are:

• no effective date;
• no first-year delayed-reporting relief;
• the climate-first (UK SRS S1 ¶E3) and Scope 3 (UK SRS S2 ¶C4) reliefs left untimed, with availability set by UK law or FCA rules (S1 ¶E5, S2 ¶C6);
• SASB references softened from “shall” to “may”;
• new S1 ¶¶73A–73B on compliance statements and UK-law override;
• S2 ¶B59A, requiring an explanation where financed emissions cannot be estimated for the reporting period.

The removal of the GICS requirement for financed emissions was the ISSB’s own December 2025 amendment to IFRS S2, not a UK amendment.

There have been three consultations, and they are often conflated.

The Department for Business and Trade consulted on the exposure drafts of UK SRS S1 and S2 from 25 June to 17 September 2025, received 209 responses, and published its response with the final standards on 25 February 2026.

The FCA consulted in CP26/5 from 30 January to 20 March 2026 on making UK SRS S2 mandatory for in-scope listed companies.

Its final rules, PS26/19, published on 30 September 2026, instead require listed companies in scope to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

The Modernising corporate reporting consultation, published 7 September 2026 and closing 30 November 2026, says the government “will consider how UK SRS should be reflected in the Companies Act 2006”.

Listed companies in scope of the FCA’s final rules report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027; no other UK entity is required to use it.

Scope is five listing categories (PS26/19 ¶3.6): commercial companies (UKLR Chapter 6), international commercial companies secondary listing (UKLR Chapter 14), depositary receipts (UKLR Chapter 15), non-equity shares and non-voting equity shares (UKLR Chapter 16), and the transition category (UKLR Chapter 22), as the UK Listing Rules application table names them.

Closed-ended investment funds, open-ended investment companies, shell companies, and debt, securitised derivative and miscellaneous securities are excluded (¶3.7).

The Policy Statement gives no total count; CP26/5, the consultation, estimated that around 600 listed companies would be affected.

The premium and standard listing segments referenced in older commentary were abolished on 29 July 2024 and have no bearing on current UKLR scope.

FCA CP26/5 Chapter 3 set out the scope definitions as consulted on.

Yes, if they are listed in a category in scope.

Under the FCA’s final rules, companies with a secondary listing (UKLR 14) or a depositary receipts listing (UKLR 15) report against UK SRS on a comply-or-explain basis, as do the commercial companies, non-equity shares and transition categories — regardless of domicile.

The consultation had proposed only that they state which overseas climate and sustainability standards they apply and signpost where those disclosures can be found; the final rules did not adopt that.

More on overseas companies and UK SRS.

Not today, and nothing is proposed.

The government’s February 2026 response said the Modernising Corporate Reporting programme would consider whether the Companies Act should require private entities to report against UK SRS.

The Modernising corporate reporting consultation, published 7 September 2026, says only that the government “will consider how UK SRS should be reflected in the Companies Act 2006”.

No government document proposes any threshold or date for private companies.

See private companies and UK SRS.

It is required by the Standard.

UK SRS S2 ¶22 requires an entity to use climate-related scenario analysis to assess its climate resilience — a significant strengthening from the TCFD regime, where it was recommended but not required.

The entity must disclose how the analysis was done, including the scenarios, inputs and key assumptions used, with an approach commensurate with its circumstances.

UK SRS S2 does not require a company to have a transition plan.

Where it has one, UK SRS S2 ¶14(a)(iv) requires disclosure of information about it, including the key assumptions used in developing it and the dependencies it relies on.

Separately, the FCA’s final rules require in-scope listed companies to disclose in the annual report whether they have a climate-related transition plan and, if so, where it can be found (PS26/19 ¶2.37) — not a duty to have a plan, as FCA CP26/5 had also proposed.

UK SRS S2 paragraph 29(a) requires disclosure of absolute gross Scope 3 greenhouse gas emissions, the Scope 3 categories included in the measure, and the measurement approach, inputs and assumptions used.

Emissions are measured under the GHG Protocol Corporate Standard unless a jurisdictional authority or exchange requires another method (¶29(a)(ii)), and the categories are those of the GHG Protocol Scope 3 Standard.

Under the FCA’s final rules Scope 3 is on a comply-or-explain basis, like every other UK SRS disclosure.

A company may use one year’s non-disclosure of Scope 3, stating that it is doing so; after that, it discloses Scope 3 or explains why not.

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.

DBT confirmed this in its February 2026 response, and the wider UK SRS legislation position is set out separately.

Section 463 limits directors’ liability to the company 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.

The TCFD was created by the Financial Stability Board in 2015 and disbanded in October 2023, with monitoring of climate-disclosure progress passing to the IFRS Foundation.

Under the FCA’s final rules, listed companies in scope report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027; CP26/5 had proposed that this replace the TCFD-aligned Listing Rules.

It keeps the same four-pillar structure while making climate-related scenario analysis a requirement, adding a formal statement of compliance and extending the metrics and targets requirements.

The basis is uniform: comply or explain across all categories of disclosure, where the consultation had proposed a mandatory UK SRS S2 core.