UK SRS reporting guidance — the practical question of what disclosures go in the annual report, where in the annual report they sit, and in what form — is set by UK SRS S1 paragraphs 60 to 63 together with the four-pillar disclosure framework inherited from the Task Force on Climate-related Financial Disclosures.

This page covers the reporting mechanics in detail, with paragraph-level citations to the published UK SRS S1 and S2 standards and to the FCA's Consultation Paper CP26/5.

For the entity-level question of who must report and when, see the UK SRS timeline and who must comply with UK SRS.

For the wider compliance programme — gap analysis, governance, data systems — see UK SRS compliance.

This page covers the report content itself.

The four-pillar disclosure framework

UK SRS S1 and UK SRS S2 both organise sustainability-related financial disclosures around four pillars carried over from the TCFD Recommendations: governance, strategy, risk management, and metrics and targets.

The pillar structure applies to both climate disclosures (under UK SRS S2) and broader sustainability disclosures (under UK SRS S1).

Governance. Disclose the governance body or bodies (which can include a board, committee, or equivalent) responsible for oversight of sustainability-related risks and opportunities, and management's role in the governance processes used to monitor and manage those risks and opportunities. UK SRS S2 paragraph 6 sets out the climate-specific governance requirements; UK SRS S1 paragraphs 26 to 28 set out the equivalent requirements for the wider sustainability landscape.

Strategy. Disclose the sustainability-related risks and opportunities that could reasonably be expected to affect the entity's prospects, the current and anticipated effects on the business model and value chain, the effects on the entity's strategy and decision-making, and the resilience of the entity's strategy to those risks. UK SRS S2 paragraphs 8 to 22 set out the climate-specific strategy requirements, including the scenario analysis required at paragraph 22 — see climate scenario analysis under UK SRS for the substantive content of that requirement.

Risk management. Disclose the processes used to identify, assess, prioritise, and monitor sustainability-related risks, and whether and how those processes are integrated into the entity's overall risk management process. UK SRS S2 paragraph 25 sets out the climate-specific requirement; UK SRS S1 paragraphs 43 to 47 cover the wider sustainability framework.

Metrics and targets. Disclose the information used to measure and monitor performance against the sustainability-related risks and opportunities identified, including the cross-industry climate metrics required by UK SRS S2 paragraph 29 (greenhouse gas emissions, climate-related transition risks, climate-related physical risks, climate-related opportunities, capital deployment, internal carbon prices, and remuneration linked to climate considerations).

Materiality: which risks and opportunities need disclosure

Both standards apply a financial materiality threshold.

The test in UK SRS S1 paragraph 3 is whether information about a sustainability-related risk or opportunity could reasonably be expected to affect the entity's "cash flows, its access to finance or cost of capital over the short, medium or long term."

This is the financially-material threshold familiar from the ISSB standards and is narrower than the EU's double-materiality approach under ESRS.

The materiality assessment must consider three time horizons explicitly identified in UK SRS S1 paragraph 31: short-term, medium-term, and long-term. The entity defines these horizons in a way that reflects the useful life of its assets, the planning horizon used internally, and the time horizon over which the risks and opportunities may crystallise. The horizons used must be disclosed.

UK SRS S1 does not prescribe a fixed list of sustainability topics. Entities identify the topics material to their business through their own risk identification processes. Where they need guidance on which topics to consider, UK SRS S1 paragraph 55 and Appendix C permit reference to:

• The Sustainability Accounting Standards Board (SASB) Standards (the IFRS Foundation now maintains these following the SASB-VRF-IFRS Foundation merger)
• The CDSB Application Guidance for Water- and Biodiversity-related Disclosures
• The most recent pronouncements of other standard-setting bodies whose requirements are designed to meet the information needs of users of sustainability-related financial disclosures
• The Global Reporting Initiative (GRI) Standards
• The European Sustainability Reporting Standards (ESRS)

A UK-specific modification matters here: where IFRS S1 requires entities to "refer to and consider" SASB Standards, UK SRS S1 makes this optional through "may refer to and consider." UK entities are not required to apply SASB disclosure topics or industry-based metrics. The same UK modification applies to the industry-based guidance under UK SRS S2.

Where the disclosures go in the annual report

UK SRS S1 paragraph 60 is unambiguous: sustainability-related financial disclosures must be provided "as part of [the entity's] general purpose financial reports." For UK listed companies, this means the annual financial report.

Paragraph 61 sets out the locations within the annual financial report where the disclosures may sit. These include the management commentary, management's discussion and analysis, operating and financial review, integrated report, and the strategic report — the standard recognises that different jurisdictions and entities use different names for the narrative reporting section, and any of these locations is acceptable provided the report forms part of the entity's general purpose financial reports.

Paragraph 62 permits an entity to include UK SRS disclosures in the same location as information disclosed for other purposes (for example, information required by other regulators). The sustainability-related disclosures must be clearly identifiable and not obscured by that additional information, applying the requirements in paragraph B27.

Paragraph 63 permits cross-referencing to another report published by the entity, provided the requirements in paragraphs B45 to B47 are followed. The cross-referenced information must be available on the same terms and at the same time as the sustainability-related financial disclosures, and the authorising body responsible for the annual financial report bears responsibility for the cross-referenced content.

The FCA's CP26/5 paragraph 4.13 reinforces this position for listed companies: climate-related disclosures and any explanations on Scope 3 emissions must be made in companies' annual financial reports, with cross-referencing permitted in the circumstances set out in UK SRS S1 paragraphs B45 to B47. The FCA does not propose to specify in which section of the annual financial report the disclosures should appear, leaving entities to decide based on their existing reporting structure and any interoperability requirements they face.

One UK-specific position matters: the IFRS S1 transitional relief permitting sustainability reports to be published at a later date than the annual report has been removed for UK SRS. Under the UK version, sustainability disclosures must be published in or at the same time as the annual report. The Government's consultation response concluded that later publication would damage the connectivity between financial statements and narrative reporting.

Connectivity with the financial statements

UK SRS S1 establishes connectivity as a core principle: sustainability-related financial disclosures must be presented in a way that allows users to relate them to the entity's financial statements. This is one of the most significant departures from the previous TCFD-aligned approach, which encouraged but did not mandate financial linkage.

Connectivity in practice means disclosing how sustainability-related risks and opportunities relate to information in the financial statements, including the carrying amounts of assets and liabilities, the recognition and measurement of provisions, and the assumptions used in forward-looking estimates. UK SRS S1 paragraphs 60 to 71 set out the general requirements, and the connectivity expectation applies across all sustainability disclosures, not only climate.

For climate-related disclosures specifically, UK SRS S2 paragraph 21 requires disclosure of the effects of climate-related risks and opportunities on the entity's financial position, financial performance, and cash flows for the reporting period — the financial-statements link is built into the substantive standard.

Comply-or-explain mechanics

Both UK SRS S1 and UK SRS S2 contain disclosure requirements. The FCA's CP26/5 proposes that some of those requirements be applied on a mandatory basis and others on a "comply or explain" basis. The position varies by topic:

CP26/5 paragraph 4.6 and 5.6 set out the "comply or explain" approach for Scope 3 and S1 non-climate respectively. Where an entity chooses to "explain" rather than comply, CP26/5 paragraphs 4.8 and 5.8 require the entity's annual financial report to set out:

• The specific paragraphs of UK SRS S2 for which it has not produced Scope 3 disclosures, or the specific sustainability-related risks or opportunities under S1 for which it has not produced disclosures
• The reasons for not making those disclosures
• Any steps the entity is taking or plans to take to make those disclosures in the future, and the timeframe within which it expects to be able to make them

The "comply or explain" approach is not a permission to be silent. Under CP26/5 paragraph 5.11, if an entity has not identified any sustainability-related risks and opportunities that could reasonably be expected to affect its prospects, this must be disclosed in its annual financial report.

A UK-specific subtlety affects the statement of compliance: an entity using the comply-or-explain provisions on Scope 3 or S1 non-climate cannot also assert full compliance with UK SRS. The Government's published consultation response confirmed this position.

The two-year "climate-first" provision

UK SRS S1 contains a UK-specific extension of the IFRS S1 transitional relief that permits climate-only reporting. Under IFRS S1, an entity may apply UK SRS S2 (climate) in the first annual reporting period without also applying UK SRS S1 (broader sustainability), with the entity required to disclose the use of the provision. This is a one-year relief in IFRS S1.

UK SRS S1 extends this to two years for UK entities, recognising the FCA's comply-or-explain timetable for UK SRS S1 non-climate disclosures. An entity may report only against UK SRS S2 (climate) for its first two reporting periods, then bring in the wider UK SRS S1 disclosures in the third reporting period.

The trade-off: an entity using the climate-first provision is not permitted to assert compliance with UK SRS S1. The entity must instead disclose that it has used the provision and is reporting on climate only. This is a UK-specific modification — IFRS S1 permits a compliance statement when using the equivalent relief; UK SRS S1 does not.

Scope 1, 2, and 3 emissions: what to disclose

UK SRS S2 paragraph 29 sets out the greenhouse gas emissions disclosure requirements. In summary:

Scope 1 emissions. Direct greenhouse gas emissions from sources owned or controlled by the entity. Disclosed in metric tonnes of CO2-equivalent, calculated using the GHG Protocol Corporate Standard methodology (or, during the one-year additional GHG method relief in CP26/5 paragraph 8.7, a method the entity was already using).

Scope 2 emissions. Indirect emissions from the generation of purchased electricity, steam, heating, and cooling consumed by the entity. Disclosed on a location-based basis under UK SRS S2 paragraph 29(a)(iii), with market-based information disclosed only if contractual instruments exist that materially affect users' understanding of the entity's Scope 2 emissions.

Scope 3 emissions. Indirect emissions in the entity's value chain, across the 15 GHG Protocol Scope 3 categories. UK SRS S2 paragraph 29(a)(vi) requires disclosure of Scope 3 emissions across all material categories. CP26/5 proposes that this requirement be applied on a comply-or-explain basis, with a one-year transitional relief permitting full omission for the first reporting period. For asset managers, commercial banks, and insurers, additional disclosure of financed emissions is required under paragraph 29(a)(vi)(2) and paragraphs B58 to B63.

Industry-based metrics

UK SRS S2 paragraph 32 requires entities to disclose industry-based metrics where they are material. The IFRS Foundation has published Industry-based Guidance on Implementing IFRS S2, which is derived from the SASB Standards and provides industry-specific climate-related disclosure topics and metrics across 68 SASB Sustainable Industry Classification System (SICS) industries.

A UK-specific modification: where IFRS S2 requires entities to "refer to and consider" the Industry-based Guidance, UK SRS S2 treats this guidance as optional through "may refer to and consider." UK entities are not required to apply industry-based metrics, although doing so will typically improve the quality and comparability of disclosures for sector-specialist investors.

How UK SRS reporting differs from current frameworks

For listed companies that currently report on a TCFD-aligned basis, the UK SRS framework carries over the four-pillar structure but adds substantially to the depth required, particularly on quantification, scenario analysis, and connectivity. The comparison with SECR and existing Companies Act disclosures is more nuanced because those regimes have different objectives.

For the practical interaction between UK SRS S2 and the existing Companies Act climate disclosures, see the FRC Sustainability Reporting Developments FAQ for the FRC's authoritative interpretation, which confirms the section 414CB(2A) designation.

Practical reporting structure: what a UK SRS-aligned annual report looks like

There is no FCA-prescribed structure for UK SRS-aligned reporting. The FCA's CP26/5 paragraph 4.13 explicitly avoids specifying where in the annual report disclosures should appear, citing flexibility for entities to integrate disclosures with their wider reporting and to facilitate interoperability with other reporting requirements they face.

In practice, three structural patterns are emerging for UK SRS reporting:

Pattern 1 — Climate disclosures integrated into the strategic report. Climate-related disclosures under UK SRS S2 appear within the strategic report alongside the existing climate-related financial disclosures under Companies Act section 414CB. This minimises duplication and presents climate information in a single, coherent place. The Non-Financial and Sustainability Information Statement (NFSIS) cross-references the UK SRS S2 disclosures and explicitly confirms the use of UK SRS S2 as the framework satisfying section 414CB(2A).

Pattern 2 — Standalone UK SRS sustainability section. A separate sustainability section within the strategic report or the broader annual report, presenting all UK SRS S1 and S2 disclosures together. This pattern works for entities with more developed sustainability reporting practices who want to present a comprehensive sustainability narrative in one place.

Pattern 3 — Cross-referenced to a separate report. UK SRS S1 paragraph 63 permits cross-referencing to another report published by the entity, provided the requirements in paragraphs B45 to B47 are met. This typically suits entities that publish a standalone sustainability or ESG report and want to incorporate by reference rather than duplicating content. The cross-referenced report must be published at the same time as the annual report, on the same terms, with the same level of authorising responsibility.

Whichever structure is chosen, two requirements apply. First, the location of the UK SRS disclosures must be specified in the annual financial report itself — readers must be able to find them. Second, the entity must include a statement explaining whether or not third-party assurance has been obtained, and if so, the name of the assurance provider, what has been assured, the level of assurance, the assurance standards used, and where the assurance report can be located.

What about assurance

UK SRS does not mandate third-party assurance of sustainability disclosures. The FRC's International Standard on Sustainability Assurance (UK) 5000, published on 12 November 2025 and effective for assurance engagements on periods beginning on or after 15 December 2026, is available for voluntary use. CP26/5 paragraph 7.6 proposes a disclosure requirement on whether voluntary assurance has been obtained, but does not mandate the assurance itself.

The Government has signalled a longer-term intention to legislate for a sustainability assurance provider registration regime through the FRC's successor body, the Audit, Reporting and Governance Authority (ARGA), but no timetable has been published. The FRC will establish an interim regime and related register by mid-2026.

Transition plan disclosures

UK SRS S2 paragraph 14 requires entities that have published a climate-related transition plan to disclose information about it, but does not require entities to have a transition plan. CP26/5 paragraph 6.9 supplements this with a disclosure rule for listed companies: an entity must state in its annual financial report whether it has published a climate-related transition plan, and if it has, where the plan can be found, including a hyperlink where appropriate. If the entity has not published a transition plan, it must state why not.

The IFRS Foundation published Educational Material on disclosing information about an entity's climate-related transition in June 2025, building on the work of the Transition Plan Taskforce. CP26/5 paragraph 6.10 introduces FCA Handbook Guidance stating that listed companies producing a transition plan may wish to use this material. The guidance is optional.

DESNZ ran a separate consultation on climate-related transition plans between June and September 2025. The Government has stated that this consultation will inform its future approach to transition plan requirements; no decisions have yet been published.

Frequently asked questions

Where in the annual report should UK SRS disclosures sit?

UK SRS S1 paragraph 60 requires the disclosures to be part of the entity's general purpose financial reports. Paragraph 61 sets out the acceptable locations within the annual financial report, including the strategic report, management commentary, OFR, MD&A, or integrated report. The FCA does not prescribe a specific section. The location must be specified in the annual financial report so that readers can find the disclosures.

Can UK SRS disclosures be in a separate sustainability report?

Under UK SRS S1 paragraph 63, information can be included by cross-reference to another report published by the entity, provided the requirements in paragraphs B45 to B47 are met. The cross-referenced report must be published at the same time as the annual report, on the same terms, with the same level of authorising responsibility. The IFRS S1 relief permitting later publication of sustainability reports has been removed for UK SRS.

What does "comply or explain" mean in practice?

If an entity chooses to "explain" rather than comply with a UK SRS S1 non-climate disclosure or a UK SRS S2 Scope 3 disclosure, CP26/5 paragraphs 4.8 and 5.8 require the entity to identify the specific paragraphs of the standard where it has not produced disclosures, the reasons for not making the disclosures, and the steps it is taking to be able to make them in the future together with the timeframe. An entity using comply-or-explain cannot also assert full compliance with UK SRS.

Is climate-only reporting allowed under UK SRS?

Yes, for the first two reporting periods, under the UK-specific extension of the climate-first relief in UK SRS S1. An entity may report against UK SRS S2 (climate) without applying UK SRS S1 (broader sustainability) for two years, then bring in the wider disclosures in the third year. The entity must disclose use of the provision and cannot assert full compliance with UK SRS S1 during the relief period.

Do I need to disclose Scope 3 emissions in the first year?

Under CP26/5 paragraph 8.6, in-scope listed companies can omit Scope 3 disclosures entirely for the first reporting period. The relief expires for accounting periods beginning on or after 1 January 2028, after which Scope 3 reporting is on a comply-or-explain basis.

Do I have to apply SASB Standards under UK SRS?

No. UK SRS S1 paragraph 55 makes reference to SASB Standards optional through "may refer to and consider." This is a UK-specific modification of IFRS S1, which uses the mandatory "shall refer to and consider." The same modification applies to the industry-based guidance under UK SRS S2. Applying SASB and industry-based guidance will typically improve disclosure quality and comparability, but it is not required.

How does UK SRS reporting interact with the Companies Act 2006?

Section 414CB of the Companies Act 2006 requires UK companies with more than 500 employees and turnover above £500m (or banks and insurance companies with more than 500 employees) to make climate-related financial disclosures in the Non-Financial and Sustainability Information Statement. The FRC has confirmed that UK SRS S2 is designated as a national reporting framework under section 414CB(2A): an entity applying UK SRS S2 — voluntarily or mandatorily — does not need to separately satisfy section 414CB(1) to (5), provided UK SRS S2 use is clearly referenced in the NFSIS.

Is comparative information required in the first year?

No. CP26/5 paragraph 8.15 provides that comparative information is not required for any disclosures made for the first time under UK SRS. This aligns with the IFRS S1 transitional provisions. Comparative information becomes a requirement from the second reporting period onwards.

What if I voluntarily adopt UK SRS now?

Voluntary adoption is open today. The full UK SRS S1 and UK SRS S2 apply — voluntary adopters do not receive the FCA's transitional reliefs because those reliefs apply to the FCA's mandatory rules from 1 January 2027, not to the standards themselves. A voluntary adopter must therefore apply UK SRS S2 in full, including Scope 3, and either also apply UK SRS S1 in full or use the two-year UK SRS S1 climate-first provision and forgo the compliance statement.