Financial Services · Sector-Specific Requirements

UK SRS for financial services: banks, insurers and asset managers

What UK SRS asks of banks, insurers and asset managers is the financed emissions disclosure in UK SRS S2 paragraph 29(a)(vi)(2) and Appendix B.

It sits alongside PRA SS5/25 and the FCA’s existing ESG sourcebook rules.

For listed companies it is now final: the FCA’s rules of 30 September 2026, finalising CP26/5, put them on a comply-or-explain basis against UK SRS from 2027.

Financed emissions →UK SRS S2

In one line

What UK SRS means for financial services

UK SRS for financial services means one thing above all: the additional financed emissions disclosures that UK SRS S2 asks of entities whose activities include asset management, commercial banking or insurance.

UK SRS S2 paragraph 29(a)(vi)(2) requires “additional information about the entity’s financed emissions (which are part of Category 15 greenhouse gas emissions), if its activities include asset management, commercial banking or insurance”.

The detail sits in Appendix B paragraphs B59–B63A.

For the finance-team treatment of financed emissions under IFRS S2 and PCAF — attribution factors, data quality scores and the methodology choices this page only sketches — the family’s reference is uksrs.finance.

For listed financial institutions in scope, the FCA’s final rules (PS26/19, 30 September 2026) require these disclosures on a comply-or-explain basis from accounting periods beginning on or after 1 January 2027; closed-ended investment funds and open-ended investment companies are excluded.

Financial activities that trigger additional financed emissions disclosure: asset management, commercial banking, insurance

UK SRS S2 ¶29(a)(vi)(2), ¶B59

Scope 3 Category 15, investments — where financed emissions sit

UK SRS S2 ¶29(a)(vi)(2)

Architecture

Four regulatory relationships, one set of numbers

UK SRS sets entity-level disclosure; it complements, rather than replaces, prudential and conduct requirements.

Relationship	What it does	Status
FCA listing rules (PS26/19, finalising CP26/5)	Require in-scope listed financial institutions (UKLR 6, 14, 15, 16 and 22) to report against UK SRS, or explain why not, from 1 January 2027	Final — published 30 September 2026
PRA SS5/25	Supervisory expectations on climate-related risk management for banks and insurers — prudential safety and soundness, not investor disclosure	In effect since 3 December 2025; sets expectations, creates no reporting duty
FCA conduct rules (PS23/16, ESG sourcebook)	SDR and investment labels; for in-scope asset managers and asset owners, TCFD entity and product reports	Product-level limb proposed for removal in CP26/17
Insurers’ prudential regime	The own risk and solvency assessment is a separate exercise whose climate content should be consistent with UK SRS disclosures	Existing

Information

Consistent architecture

UK SRS disclosures and what is given to prudential and conduct regulators must not contradict each other.

Risk

Aligned risk management

Climate risk processes that satisfy UK SRS disclosure and PRA SS5/25 expectations within one integrated framework.

Governance

Coordinated oversight

Board and committee oversight that addresses UK SRS governance disclosures and supervisory expectations together.

Data

Coherent measurement

Metrics that hold together across regimes while meeting each regime’s own measurement requirements.

Coordination needs compliance, risk and sustainability functions working together rather than siloed responses to each regulator.

Financed emissions

Financed emissions for banks, insurers and asset managers

Financed emissions are the sector-specific element of UK SRS S2, and the one that needs the most measurement infrastructure.

The standard defines them as the portion of an investee’s or counterparty’s gross greenhouse gas emissions attributed to the entity’s loans and investments — part of Scope 3 Category 15 (investments).

Source: UK SRS S2 ¶29(a)(vi)(2), ¶¶B59–B63A.
Activity	Paragraphs	What UK SRS S2 asks for
Asset management	¶B61	Absolute gross financed emissions disaggregated by investees’ Scope 1, 2 and 3; total assets under management included; percentage of total AUM covered, with exclusions explained; methodology and allocation method
Commercial banking	¶¶B62–B62A	Absolute gross financed emissions, disaggregated by Scope 1, 2 and 3, for each industry by asset class; gross exposure for each industry by asset class (loans, project finance, bonds, equity investments, undrawn loan commitments); percentage of gross exposure included, with undrawn commitments disclosed separately; industry classification used
Insurance	¶¶B63–B63A	Absolute gross financed emissions for each industry by asset class; gross exposure for each industry by asset class — the insurer’s investments, not its underwriting book; percentage of gross exposure included; methodology and allocation method

The December 2025 ISSB amendments to IFRS S2, incorporated into UK SRS S2, permit an entity to limit its measurement and disclosure of Category 15 to financed emissions as so defined.

The same amendments permit industry classification systems other than GICS.

UK SRS S2 does not require insurance-associated (underwriting) emissions.

UK SRS S2 adds one paragraph IFRS S2 does not have, and it is the one place the UK asks for more: ¶B59A, listed in Annex A of the government’s consultation response.

Where an entity finds it impracticable to reliably estimate financed emissions for the same reporting period as its financial statements, it must disclose why, the measurement approach, inputs and assumptions it used, and its plan, with a timeline, to align the periods.

Methodology

PCAF, attribution and data quality

UK SRS S2 requires disclosure of the methodology and allocation method used, but does not name one.

The PCAF Global GHG Accounting and Reporting Standard is the widely used financial-industry methodology, with Part A (financed emissions) in its third edition of December 2025.

PCAF’s five-point data quality score runs from 1 (highest quality) to 5 (lowest), and disclosing it shows how much of a figure rests on estimation rather than reported data.

Attribution needs clear disclosure: how emissions are attributed to the institution’s exposure, including proportional approaches and shared financing arrangements.

Boundary decisions need the same: what is included and excluded, including derivatives, short positions and multi-asset exposures.

PCAF data quality score

Highest qualityLowest quality

Source: PCAF Standard

Value-chain data from a different period

UK SRS S2 ¶B19 carries forward the ISSB’s permission to use value-chain emissions data from a different reporting period.

Three conditions apply: use the most recent data available without undue cost or effort, the reporting periods must be the same length, and the entity discloses significant events between the value-chain entities’ reporting dates and its own report.

That is an ISSB provision, not a UK-specific one; the UK’s own additions are listed in Annex A of the DBT consultation response.

Prudential

PRA SS5/25: expectations, not disclosure duties

PRA SS5/25 sets supervisory expectations for banks and insurers on climate-related financial risk management; it replaced SS3/19 in its entirety on 3 December 2025 (PS25/25).

It needs coordinating with UK SRS, but it is not a disclosure regime.

Area	PRA SS5/25	UK SRS
Governance	Board-level oversight of climate risk for prudential risk management	Investor-focused disclosure of governance processes
Risk identification	Systematic identification of climate-related financial risks	Disclosure of climate risks and opportunities that could reasonably be expected to affect cash flows, access to finance or cost of capital (UK SRS S1 ¶3)
Scenario analysis	Expectations on scenario analysis for risk management	UK SRS S2 ¶22: assess and disclose climate resilience using scenario analysis, with an approach commensurate with the entity’s circumstances
Data	Robust data for prudential risk assessment	Robust data for investor disclosure — a different measurement focus

A common error

The PRA did not introduce new disclosure requirements in SS5/25.

“The PRA now requires climate disclosure” is wrong.

Scenarios

From CBES to UK SRS scenario analysis

Firms that took part in the Bank of England’s 2021 Climate Biennial Exploratory Scenario have scenario capabilities that provide a foundation for UK SRS S2, but adaptation is required.

UK SRS S2 does not prescribe particular scenarios or temperature pathways; it requires the entity to explain the scenarios it chose and why they are relevant to its exposure, which may point away from the CBES set.

Managing both regimes well means integrated governance, consistent risk assessment, scenario work that uses consistent assumptions where appropriate, and one data architecture — see climate scenario analysis guidance.

	CBES	UK SRS S2
Scenarios	Set by the Bank of England	Chosen by the entity and explained; none prescribed
Horizons	Prudential assessment horizons	Disclosure-focused, investor horizons
Emphasis	Quantitative risk assessment	Quantitative and qualitative, for investor decisions
Audience	Supervisory	Public disclosure

Asset managers

Entity-level disclosure, product-level rules

UK SRS S2 disclosures address the asset manager’s climate-related risks and opportunities as an entity, not fund-specific climate characteristics.

Separate FCA obligations require product-level sustainability disclosures and labelling under PS23/16.

The existing TCFD product reports carry Scope 1, 2 and 3 emissions and carbon footprint metrics.

Every FCA-authorised firm is also bound by the anti-greenwashing rule, which has applied since 31 May 2024: any reference to a product’s or service’s sustainability characteristics must be consistent with them and fair, clear and not misleading.

The rule covers products and services, not claims a firm makes about itself, as the FCA’s guidance on the anti-greenwashing rule explains.

The task is to give entity-level insight into portfolio exposures without conflicting with product-level frameworks — and to tell clients clearly what appears where.

Portfolio measurement

Look-through — assessing climate risk through holdings to the underlying assets and economic activities.
Coverage — emissions data for every material holding, across equity, fixed income, alternatives and other asset classes.
Active and passive — disclosure differs with the manager’s influence over investee climate strategy.
Change over the period — methods that accommodate portfolio turnover, manager transitions and evolving client mandates.

Watch CP26/17

In-scope asset managers and asset owners already publish TCFD product reports under the ESG sourcebook, with an exemption below £5bn of assets under management or administration, measured as a three-year rolling average.

CP26/17 proposes to remove the product-level TCFD reports; it closed on 13 July 2026 and its Policy Statement had not been published as at 26 September 2026.

Banks

Commercial banks: the lending book

For banks, financed emissions sit alongside the climate risk management and disclosure the rest of UK SRS S2 already asks for.

UK SRS S2 paragraph B62 requires financed emissions for each industry by asset class, which shows the bank’s exposure to carbon-intensive sectors and transition risk.

Credit risk

Banks will be describing how climate factors enter credit assessment, how sector-level climate credit risk is managed, how scenario analysis bears on portfolio credit quality, and their approach to transition finance.

Operations and physical risk

Physical risk reaches branch networks, data centres, third-party providers and — for retail banks — mortgage portfolios through property-level exposure.

What ¶¶B62–B62A ask

01
By industry and asset class
Absolute gross financed emissions.
02
Gross exposure
Loans, bonds, equity investments and undrawn loan commitments.
03
Attribution method
How the bank’s share relates to the size of its gross exposure.
04
Undrawn commitments
The percentage included, disclosed separately.

Insurers

Insurers: investments, not underwriting

An insurer’s UK SRS S2 financed emissions obligation (paragraphs B63–B63A) covers its investment portfolio: financed emissions for each industry by asset class, with the gross exposure and percentage included.

Underwriting is addressed through the standard’s general climate risk, strategy and metrics requirements rather than through financed emissions.

Where material, how climate is integrated into underwriting criteria and pricing falls under the strategy and risk management disclosures.

UK SRS climate disclosures should be consistent with the climate content of the insurer’s own risk and solvency assessment and with SS5/25 expectations.

Asset-liability matching, long-term liability adequacy, physical risk pricing, catastrophe modelling and climate-related coverage exclusions are the areas where that consistency is tested.

Not required by UK SRS S2

Insurance-associated (underwriting) emissions.

Insurers that choose to disclose them can use PCAF Part C, whose second edition was published in December 2025.

Where underwriting risk does go

Climate-related risks and opportunities, strategy and resilience, and the amount and percentage of assets or business activities vulnerable to climate-related risks (¶29(b)–(c)).

Targets

Voluntary commitments become disclosed targets

Many UK financial institutions have made voluntary net zero or interim commitments, individually or through industry alliances, several of which have changed shape since 2024.

For an entity reporting under UK SRS, the targets requirements in UK SRS S2 paragraphs 33–37 turn any such commitment into a disclosed target with a baseline, milestones and progress — under the FCA’s comply-or-explain rules for listed institutions from 2027, and voluntarily for everyone else.

Every target

Quantitative and qualitative

Targets the entity has set and any it must meet by law or regulation: the metric, objective, scope, period and base period.

Net zero

With its interim targets

A net zero commitment is disclosed with the interim targets leading to it, how it was set, and whether a third party validated it.

Greenhouse gas

Gases, Scopes, credits

Which gases and Scopes are covered, whether the target is gross or net, and how far it relies on carbon credits.

Progress

Every period

Performance against each target, with revisions and the reasons for them explained.

Commitments adopted through alliances are disclosed like any other target the entity has set.

Voluntary assurance over target progress is worth considering where credibility matters to investors.

Delivery

Our indicative implementation path

Financed emissions are the sector-specific element of UK SRS S2 and the one that needs the most measurement and methodology work.

Asset managers must keep entity-level UK SRS disclosures consistent with FCA product-level obligations, without duplication, while CP26/17 is decided.

The gap between the FCA’s final rules (30 September 2026) and the first accounting period (1 January 2027) is three months, which argues for preparing now.

Assurance remains voluntary, but the complexity of the sector makes it worth evaluating early.

For more, see our Scope 3 emissions guide, UK SRS compliance framework and climate scenario analysis guidance.

2026
Foundation
Gap analysis against UK SRS; financed emissions methodology (likely PCAF-based); data infrastructure across portfolios and lending books; governance.
2027
Systems and process
Financed emissions calculation across business lines with data quality controls; regulatory coordination; scenario capability; internal controls and voluntary ISSA (UK) 5000 assurance readiness.
2028+
Disclosure and improvement
First disclosures; stakeholder feedback; methodology refinement; assurance as the market matures.

A planning sequence, not a regulatory timetable. The FCA’s rules apply from accounting periods beginning 1 January 2027, with first reports in 2028.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.

Checked against 17 sources fromDepartment for Business and TradeIFRS FoundationPrudential Regulation AuthorityBank of EnglandFinancial Conduct AuthorityPartnership for Carbon Accounting Financials (standard-setter, not a regulator)

Department for Business and Trade
UK SRS S2 Climate-related Disclosures — final standard (PDF)
Financed emissions: ¶29(a)(vi)(2) and Appendix B ¶¶B59–B63A; value-chain data from other periods ¶B19; climate targets ¶¶33–37; resilience and scenario analysis ¶22.
Department for Business and Trade
UK SRS consultation response (PDF), Annex A
Lists every UK difference from IFRS S2, including ¶B59A — the one place UK SRS S2 asks financial institutions for more.
IFRS Foundation
ISSB issues targeted amendments to IFRS S2 (11 December 2025)
Permits limiting Category 15 to financed emissions and using classification systems other than GICS; incorporated into UK SRS S2.
Prudential Regulation Authority
SS5/25 — Enhancing banks' and insurers' approaches to managing climate-related risks (supervisory statement)
The PRA’s expectations on governance, risk management, scenario analysis, data and disclosures; commenced 3 December 2025 (§3.1). Expectations, not rules.
Prudential Regulation Authority
PS25/25 — policy statement on SS5/25
“The final policy replaces SS3/19 in its entirety and takes effect on the date of publication” — 3 December 2025 (¶1.20).
Prudential Regulation Authority
SS3/19 — Enhancing banks’ and insurers’ approaches to managing the financial risks from climate change (superseded)
The April 2019 statement SS5/25 replaced in its entirety; kept for reference only, not current expectations.
Bank of England
Results of the 2021 Climate Biennial Exploratory Scenario (CBES)
The Bank’s exploratory climate scenario exercise for the largest UK banks and insurers, published 24 May 2022.
Financial Conduct Authority
PS26/19: Aligning listed issuers' sustainability disclosures with international standards
First published 30 September 2026. The final rules: listed companies in UKLR 6, 14, 15, 16 and 22, financial institutions included, report against UK SRS on a comply-or-explain basis from accounting periods starting on or after 1 January 2027; closed-ended funds and OEICs are excluded (¶3.7).
Financial Conduct Authority
CP26/5 — Sustainability disclosures
The consultation PS26/19 finalises; it proposed UK SRS-aligned listing rules for in-scope listed companies, financial institutions included.
Financial Conduct Authority
CP26/17 — Quarterly Consultation Paper No. 52
Chapter 2 proposes removing product-level TCFD reporting for asset managers, life insurers and FCA-regulated pension providers; closed 13 July 2026.
Financial Conduct Authority
FCA Handbook, ESG sourcebook — ESG 2.3 Product-level reporting (ESG 2.3.9R)
TCFD product reports must carry Scope 1 and 2, Scope 3, total carbon emissions, total carbon footprint and weighted average carbon intensity.
Financial Conduct Authority
FCA Handbook, ESG sourcebook — ESG 1A.1 Application of ESG 2 (ESG 1A.1.1R–1A.1.2R)
The asset managers and asset owners in scope, and the exemption below £5bn of assets, a three-year rolling average.
Financial Conduct Authority
PS21/24 — Enhancing climate-related disclosures by asset managers, life insurers and FCA-regulated pension providers
The December 2021 policy statement that made the TCFD entity and product rules.
Financial Conduct Authority
PS23/16 — Sustainability Disclosure Requirements (SDR) and investment labels
Final rules of 28 November 2023 on investment labels and product-level sustainability disclosures.
Financial Conduct Authority
FCA Handbook, ESG 4.3.1R — the anti-greenwashing rule
Any reference to a product’s or service’s sustainability characteristics must be consistent with them and fair, clear and not misleading; applies to all FCA-authorised firms from 31 May 2024.
Financial Conduct Authority
FG24/3 — Finalised non-Handbook guidance on the anti-greenwashing rule
The FCA’s guidance on applying ESG 4.3.1R (April 2024); guidance, not a rule.
Partnership for Carbon Accounting Financials (standard-setter, not a regulator)
The Global GHG Accounting and Reporting Standard for the Financial Industry
Part A financed emissions (third edition, December 2025), Part B facilitated emissions, Part C insurance-associated emissions (second edition, December 2025). Not mandated by UK SRS S2 or the FCA Handbook.