Framework overview · Four pillars
The four pillars of sustainability reporting under UK SRS
UK SRS carry the TCFD’s four-pillar structure — governance, strategy, risk management, and metrics and targets.
UK SRS S1 ¶25 asks for more under each pillar, across all material sustainability matters.
Origins
Where the four pillars come from
The four pillars of sustainability reporting — governance, strategy, risk management, and metrics and targets — come from the Task Force on Climate-related Financial Disclosures (TCFD) recommendations of 2017.
UK SRS S1 paragraph 25 adopts them as the core content of every sustainability disclosure.
The TCFD fulfilled its remit and was disbanded on 12 October 2023, with the FSB asking the IFRS Foundation to take over monitoring of companies’ climate-related disclosures; the recommendations site is preserved but no longer maintained.
The Department for Business and Trade published UK SRS on 25 February 2026, extending TCFD’s foundation to all material sustainability matters.
The standards are voluntary; the FCA’s final rules (PS26/19, 30 September 2026) require in-scope listed issuers to report against them on a comply-or-explain basis from 1 January 2027.
Knowing how the framework evolved lets a company build on its existing climate disclosures rather than starting again.
From TCFD to UK SRS
- 2017TCFD recommendations
Four pillars, eleven recommended disclosures.
- 12 Oct 2023TCFD disbanded
The FSB asks the IFRS Foundation to take over monitoring.
- 1 Jan 2024IFRS S1 and S2 effective
The international baseline.
- 25 Feb 2026UK SRS published
S1 ¶25 adopts the four pillars as core content.
- 1 Jan 2027UK SRS applies to listed issuers
Comply or explain — FCA final rules (PS26/19).
The framework
UK SRS governance, strategy, risk management, metrics and targets: how the framework evolved
UK SRS keep the four-pillar structure and add quantitative requirements, a scenario analysis requirement, and reporting at the same time as the financial statements.
| Pillar | UK SRS S1 | UK SRS S2 | What it asks beyond TCFD |
|---|---|---|---|
| Governance | ¶¶26–27 | ¶¶5–7 | How the governance body takes sustainability into account in strategy, major decisions and risk management, and oversees targets |
| Strategy | ¶¶28–42 | ¶¶8–23 | Scenario analysis required (S2 ¶22); quantified financial effects |
| Risk management | ¶¶43–44 | ¶¶24–26 | Inputs and parameters used, and whether scenario analysis informs risk identification |
| Metrics and targets | ¶¶45–53 | ¶¶27–37 | Scope 1, 2 and 3 emissions and six further cross-industry metric categories (S2 ¶29) |
Both UK SRS S1 and UK SRS S2 share the same foundations.
Four-pillar disclosure
Governance, strategy, risk management, and metrics and targets — the framework originally developed by the TCFD.
Connected, material, measured
The “Connected information” requirement with the financial statements (S1 ¶¶21–24); materiality based on cash flows, access to finance or cost of capital (S1 ¶3); cross-industry metrics (S2 ¶29); industry-based metrics (S2 ¶32).
Stated measurement
Measurement approaches, including the GHG Protocol Corporate Standard for emissions (S2 ¶29(a)(ii)), with disclosure of the inputs and assumptions behind them.
Financial, not impact, materiality
A focus on matters that affect cash flows, access to finance or cost of capital — the key difference from the EU’s double materiality under CSRD.
That alignment keeps UK SRS reporting substantially comparable with reporting under IFRS S1 and IFRS S2 in other jurisdictions.
The requirement-by-requirement comparison with TCFD is at TCFD vs UK SRS.
Pillar 1
Governance
The governance pillar requires disclosure of board and management oversight of sustainability-related risks and opportunities.
Companies describe the governance processes, policies and controls used to monitor, manage and oversee sustainability matters, including climate change.
Board oversight disclosure covers sustainability expertise, committee structures and accountability mechanisms.
The final UK SRS require disclosure of how the governance body takes those risks and opportunities into account, and how it oversees targets and performance.
Management’s role spans sustainability strategy, implementation oversight and performance monitoring, and companies disclose the management processes for identifying, assessing and managing sustainability matters across the organisation.
Pillar 2
Strategy
The strategy pillar requires disclosure of the sustainability-related risks and opportunities that could affect the business model, strategy and financial planning over the short, medium and long term.
Companies explain how those factors shape strategic planning and decision-making.
Scenario analysis is a requirement of UK SRS S2 climate strategy disclosure rather than a recommendation, using “an approach that is commensurate with the entity’s circumstances”.
The standard prescribes no particular scenarios; many companies draw on published sets such as the NGFS scenarios and the IEA Net Zero Emissions by 2050 scenario.
Financial quantification of effects is a significant step up from TCFD practice.
UK SRS S2 does not require an entity to have a transition plan; where it has one, the standard requires specific information about it, including the key assumptions used and the dependencies it relies on.
UK SRS S2 ¶22 requires it, “commensurate with the entity’s circumstances” — what scales is the depth, not the obligation.
If an entity has one, it discloses the key assumptions and dependencies (UK SRS S2 ¶14(a)(iv)).
Pillar 3
Risk management
The risk management pillar describes the processes for identifying, assessing, prioritising and monitoring sustainability-related risks.
Companies disclose how those processes integrate with overall enterprise risk management and influence business decisions.
Climate risk assessment covers both physical risks, acute and chronic, and transition risks.
UK SRS require disclosure of the inputs and parameters used, whether and how scenario analysis informs risk identification, and how the processes are integrated into overall risk management.
Companies explain their prioritisation approach, risk appetite and management responses to the risks and opportunities identified.
Pillar 4
Metrics and targets
The metrics and targets pillar requires quantitative disclosure of sustainability performance, including greenhouse gas emissions, progress against targets and key performance indicators.
UK SRS S2 ¶29(a) requires absolute gross Scope 1, 2 and 3 emissions, alongside six further cross-industry metric categories in ¶29(b)–(g).
Under the FCA’s final rules every UK SRS disclosure, Scope 3 included, is comply-or-explain from 2027, with a one-year Scope 3 relief — FCA CP26/5 had proposed a mandatory S2 core with Scope 3 outside it.
The GHG Protocol Scope 3 Standard provides the measurement framework across all 15 value chain categories.
Companies disclose the methodologies, data quality and verification approaches behind their metrics.
UK SRS S2 does not require an entity to set climate targets aligned with any particular goal.
Where targets are set — science-based, interim milestones or required by law — companies explain the target-setting methodology, baseline and performance monitoring.
Scope 3 under the FCA’s final rules
- Year 1One-year relief
A company may use one year’s non-disclosure, stating that it is doing so.
- After year 1Comply-or-explain
Disclose Scope 3, or explain why not.
- ThroughoutNever mandatory
The final rules adopt comply or explain across all disclosures.
FCA PS26/19 ¶3.14 · FCA CP26/5
UK law
Where the four pillars already sit in UK law
The closest existing analogue is the climate-related financial disclosure duty in Companies Act 2006 section 414CB, whose eight required items in subsection (2A) follow the same TCFD shape.
| Section 414CB(2A) item | Closest pillar |
|---|---|
| Governance arrangements | Governance |
| How climate risks are identified, assessed and managed | Risk management |
| Integration into overall risk management | Risk management |
| Principal risks and the time periods used | Strategy |
| Impacts on business model and strategy | Strategy |
| Scenario-based resilience | Strategy |
| Targets | Metrics and targets |
| Key performance indicators | Metrics and targets |
The government has confirmed UK SRS S2 is a national reporting framework for section 414CB(6), so a company reporting under UK SRS S2 need not duplicate those disclosures.
The FCA’s final rules apply UK SRS through the listing rules, on a comply-or-explain basis, for UKLR 6, 14, 15, 16 and 22 issuers from 2027; CP26/5 had proposed that UK SRS S2 replace the TCFD-aligned listing rules, which stay in the Handbook until the FCA changes them.
Commentary
Adviser and vendor commentary
Accountancy firms: PwC UK, Deloitte UK and EY UK publish UK SRS briefings and readiness material.
Carbon-accounting software vendors: Zevero, Seedling and Normative market platforms aimed mainly at the metrics and targets pillar.
Law firms: Addleshaw Goddard and Fieldfisher publish client briefings on UK SRS; the UK SRS pages this site previously linked have been removed, so the links point at the firms’ sites.
These are commercial pages from advisers and software vendors, listed for orientation only.
None is a source for any figure, date or requirement on this page, which are cited to the standards and the FCA.
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.
- Task Force on Climate-related Financial DisclosuresTCFD Recommendations (2017)
The original four pillars and eleven recommended disclosures; the site is frozen since the TCFD disbanded in October 2023.
- Department for Business and TradeUK SRS S1 General Requirements — final standard (PDF)
Paragraph 25 sets the four pillars as core content: governance, strategy, risk management, and metrics and targets.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — final standard (PDF)
The climate application: governance ¶¶5–7, strategy ¶¶8–23, risk management ¶¶24–26, metrics and targets ¶¶27–37.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
The final standards, published 25 February 2026.
- IFRS FoundationIFRS S1 General Requirements
The international standard whose core content (paragraph 25) sets the four pillars UK SRS S1 adopts.
- IFRS FoundationIFRS S2 Climate-related Disclosures
Applies the four-pillar structure to climate; adopted by UK SRS S2.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
First published 30 September 2026. The final rules: comply or explain across the UK SRS for listed companies in scope, from accounting periods starting on or after 1 January 2027; one-year Scope 3 relief (¶3.14).
- Financial Conduct AuthorityCP26/5 — full text (PDF)
The consultation PS26/19 finalises; it proposed listing rules applying UK SRS S2 from 1 January 2027.
- legislation.gov.ukCompanies Act 2006, section 414CB
The existing climate-related financial disclosure duty whose eight items follow the four-pillar shape; UK SRS S2 is a subsection (6) national reporting framework.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The fifteen Scope 3 categories referenced under the metrics and targets pillar.
- Network for Greening the Financial SystemNGFS Scenarios Portal
A published scenario set many companies draw on; UK SRS S2 prescribes none.
- International Energy AgencyWorld Energy Outlook 2025 — Net Zero Emissions by 2050 scenario
A published scenario many companies draw on; UK SRS S2 prescribes none.
Continue reading
Read next
TCFD vs UK SRS
Detailed comparison showing how UK SRS enhance TCFD’s four-pillar foundation.
UK SRS S1 — General Requirements
General sustainability requirements applying the four pillars to all material matters.
UK SRS S2 — Climate-related Disclosures
Climate-specific application of the four pillars, with required scenario analysis.
UK SRS S1 and S2
How the two standards apply the pillars together.