Implementation Guide
UK SRS reporting guidance
Practical UK SRS reporting guidance: what disclosures go in the annual report, where they sit, and how to comply with UK SRS step by step.
The rules are set by UK SRS S1 paragraphs 60 to 63 and the four-pillar disclosure framework.
The rules in one place
What UK SRS reporting guidance covers
UK SRS reporting guidance is the practical question of what goes in the annual report, where in it, and in what form.
This page covers those reporting mechanics, cited to the paragraph in the published UK SRS S1 and S2, the FCA’s final rules and FCA CP26/5.
For who must report and when, see the UK SRS timeline and who must comply with UK SRS.
For the wider programme — gap analysis, governance, data systems — see UK SRS compliance.
How this sits among the wider family of sustainability reporting standards — SECR, ESOS and the frameworks either side of UK SRS — is covered by our sister editorial title.
Where each rule lives
| Question | Provision |
|---|---|
| Which report? | UK SRS S1 ¶60; CP26/5 ¶4.13 |
| Which section of it? | UK SRS S1 ¶61 |
| Alongside other information? | UK SRS S1 ¶62, ¶B27 |
| Cross-reference elsewhere? | UK SRS S1 ¶63, ¶¶B45–B47 |
| Same time as the accounts? | UK SRS S1 ¶64 |
| Linked to the financials? | UK SRS S1 ¶¶21–24 |
Structure
The four-pillar disclosure framework
UK SRS S1 and S2 both organise disclosures around four pillars carried over from the TCFD Recommendations.
The structure applies to climate (UK SRS S2) and to wider sustainability (UK SRS S1) alike.
Governance
The body or bodies overseeing sustainability-related risks and opportunities — board, committee or equivalent — and management’s role in monitoring and managing them.
Strategy
The risks and opportunities that could affect prospects, their effects on business model, value chain, strategy and decisions, and the resilience of the strategy.
Scenario analysis is required at ¶22 — see climate scenario analysis under UK SRS.
Risk management
The processes to identify, assess, prioritise and monitor sustainability-related risks, and whether and how they are integrated into overall risk management.
Metrics and targets
Performance information, including the cross-industry climate metrics: GHG emissions, transition risks, physical risks, opportunities, capital deployment, internal carbon prices, and climate-linked remuneration.
Materiality
Which risks and opportunities need disclosure
Both standards apply a financial materiality threshold.
The test in UK SRS S1 ¶3 is whether information 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.”
That is the ISSB threshold, and it is narrower than the EU’s double-materiality approach under ESRS.
The assessment must consider the short, medium and long term (UK SRS S1 ¶31).
The entity defines those horizons to reflect its asset lives, internal planning horizon and when the risks may crystallise — and must disclose them.
UK SRS S1 prescribes no fixed topic list; entities find material topics through their own risk identification.
One UK modification matters: where IFRS S1 says “refer to and consider” SASB, UK SRS S1 says “may refer to and consider”, so SASB topics and metrics are optional.
Permissive to use is not permissive to stay silent: ¶59 still requires the entity to identify the standards, pronouncements and industry sources it applied, including any SASB topics.
Sources an entity may refer to
| Source | UK SRS S1 |
|---|---|
| SASB Standards, now maintained by the IFRS Foundation | ¶¶55(a), 58(a) |
| CDSB Framework Application Guidance — water and biodiversity | ¶55(b)(i) |
| Other standard-setters' recent pronouncements for general purpose financial report users | ¶55(b)(ii) |
| GRI Standards | Appendix C ¶C2(a) |
| European Sustainability Reporting Standards (ESRS) | Appendix C ¶C2(b) |
Location
Where the disclosures go in the annual report
UK SRS S1 ¶60 is unambiguous: the disclosures must be provided “as part of [the entity’s] general purpose financial reports” — for a UK listed company, the annual financial report.
Paragraph 61 accepts any narrative section of it — management commentary, MD&A, operating and financial review, integrated report or strategic report — because jurisdictions name that section differently.
Paragraph 62 allows the disclosures to share a location with information given for other purposes, provided they are clearly identifiable and not obscured (¶B27).
Paragraph 63 permits cross-referencing to another report the entity publishes, under ¶¶B45–B47.
The cross-referenced information must be available on the same terms and at the same time, and the body authorising the annual financial report is responsible for it.
FCA CP26/5 ¶4.13 reinforces this for listed companies: climate disclosures and any Scope 3 explanations go in the annual financial report, with cross-referencing as S1 ¶¶B45–B47 allow.
The FCA did not propose to specify which section, leaving entities to decide from their existing structure and interoperability needs.
The IFRS S1 relief allowing sustainability reports to be published after the annual report (IFRS S1 ¶E4) has been removed for UK SRS.
Disclosures must be reported at the same time as, and for the same period as, the related financial statements (UK SRS S1 ¶64).
The Government’s consultation response records the removal in its Annex A table, where the E4 row reads “Not applicable”.
Connected information
Linking to the financial statements
UK SRS S1 makes Connected information a core principle (¶¶21–24): users must be able to relate the disclosures to the financial statements.
It is one of the biggest departures from TCFD, which encouraged but did not mandate the financial linkage.
In practice it means showing how sustainability risks and opportunities relate to carrying amounts of assets and liabilities, provisions, and the assumptions behind forward-looking estimates.
The general requirements run from UK SRS S1 ¶54 to ¶71, and the expectation applies to all sustainability disclosures, not only climate.
For climate, UK SRS S2 ¶¶15–21 require the current and anticipated effects on financial position, performance and cash flows — the link is built into the substantive standard.
The word “connectivity” appears nowhere in UK SRS S1.
The Standard’s own term is “Connected information”.
Compliance basis
Comply-or-explain mechanics
The FCA’s final rules (PS26/19, 30 September 2026) apply comply or explain across the UK SRS; FCA CP26/5 had proposed a mandatory basis for UK SRS S2 other than Scope 3.
| Requirement | Compliance basis (PS26/19) | Application | What CP26/5 had proposed |
|---|---|---|---|
| UK SRS S2 climate disclosures (excluding Scope 3) | Comply or explain | Accounting periods beginning on or after 1 January 2027 | Mandatory |
| UK SRS S2 Scope 3 emissions | Comply or explain | From 1 January 2027, with one year’s relief from disclosure | Comply or explain after a one-year relief |
| UK SRS S1 non-climate sustainability disclosures | Comply or explain | From 1 January 2027, with two years’ relief from disclosure | Comply or explain after a two-year relief |
CP26/5 ¶¶4.6 and 5.6 set out the comply-or-explain approach it proposed for Scope 3 and for S1 non-climate respectively.
Where an entity explained, CP26/5 ¶¶4.8 and 5.8 proposed that the annual financial report set out:
- the paragraphs of UK SRS S2 not disclosed for Scope 3, or the S1 risks or opportunities not disclosed
- the reasons
- the steps being taken to disclose in future, and the expected timeframe
If an entity has identified no sustainability-related risks or opportunities that could affect its prospects, it must say so in the annual financial report (CP26/5 ¶5.11).
An entity that explains on Scope 3 or S1 non-climate may not be able to assert compliance with UK SRS, because UK SRS S1 ¶72 allows an unreserved compliance statement only where every requirement is met.
The FCA said as much at CP26/5 ¶5.12, and promised more detail in its Policy Statement (¶5.13) — now published as PS26/19.
Reliefs
The climate-first provision: untimed, not “two years”
UK SRS S1 appendix E ¶E3 lets an entity disclose only climate information (applying UK SRS S2) while it builds the data for wider sustainability disclosures.
The government’s 2025 consultation proposed extending the relief from IFRS S1’s one year to two years for UK entities.
The final Standard did not adopt two years — it removed the time limit entirely.
There is accordingly no fixed number of periods after which a climate-first reporter must bring in UK SRS S1’s wider disclosures.
Any future limit would be set by legislation or FCA rules, not by the Standard.
The trade-off stands regardless: while using the provision an entity cannot assert compliance with UK SRS S1 (¶73A), and must disclose that it is reporting on climate only — though it can still assert compliance with UK SRS S2.
Paragraph E3 contains no reference to “the first annual reporting period” and none to “two years”.
The only nearby time limit, in ¶E4(b), governs comparative information once an entity stops relying on the relief — it is not the relief’s own expiry.
Metrics
Scope 1, 2 and 3 emissions, and industry-based metrics
UK SRS S2 ¶29 sets out the greenhouse gas emissions disclosure requirements.
Scope 1
Direct emissions from sources the entity owns or controls, in tonnes of CO2-equivalent.
Measured under the GHG Protocol Corporate Standard — or, in the first annual period under the UK SRS S2 ¶C3 relief (carried into the FCA’s draft rules by CP26/5 ¶8.7), a method the entity was already using.
Scope 2
Indirect emissions from purchased electricity, steam, heating and cooling, disclosed on a location-based basis.
Information about contractual instruments is disclosed where it informs users’ understanding.
Scope 3
Value chain emissions across the 15 GHG Protocol categories, for all material categories.
The FCA’s final rules put it on comply-or-explain, with one year’s relief permitting full omission; the Standard’s own ¶C4 relief carries no time limit for voluntary reporters.
Asset managers, commercial banks and insurers also disclose financed emissions under ¶29(a)(vi)(2) and ¶¶B58–B63A.
The UK-specific ¶B59A requires an explanation where financed emissions cannot be estimated for the same period as the financial statements.
For the 15 categories and the data-collection challenges, see Scope 3 under UK SRS.
Industry-based metrics
UK SRS S2 ¶32 requires industry-based metrics associated with the business model, activities or other common features.
The IFRS Foundation’s Industry-based Guidance on Implementing IFRS S2 derives from the SASB Standards and organises topics and metrics by the SASB Sustainable Industry Classification System.
Where IFRS S2 says “refer to and consider” that guidance, UK SRS S2 says “may” (¶¶12, 23 and 32).
The duty to disclose industry-based metrics remains; what is optional is drawing them from the ISSB guidance — though doing so will typically improve quality and comparability for sector-specialist investors.
Other frameworks
How UK SRS reporting differs from current frameworks
For a TCFD-aligned reporter, UK SRS keeps the four pillars but adds depth — quantification, scenario analysis and Connected information.
The comparison with SECR and the Companies Act is more nuanced, because those regimes have different objectives.
| Framework | Status under UK SRS | Key difference |
|---|---|---|
| TCFD-aligned Listing Rules (current) | CP26/5 ¶4.4 proposed replacing them for in-scope listed companies; the FCA’s final rules put those companies on comply or explain against UK SRS from periods beginning 1 January 2027; the TCFD rule stays in the Handbook until the FCA changes it | UK SRS S2 requires quantitative metrics, Connected information and industry-based metrics that TCFD only encouraged |
| Companies Act 2006 section 414CB | UK SRS S2 confirmed by the Government as a national reporting framework for s414CB(6) | An entity applying UK SRS S2 need not duplicate its s414CB(2A) disclosures, provided UK SRS S2 use is clearly referenced |
| SECR | Continues in parallel | Statutory under the Companies Act; UK SRS S2 covers similar emissions ground in a different reporting structure |
| ESOS | Continues in parallel | A four-yearly assessment, not annual financial reporting — different cadence and audience |
| EU CSRD / ESRS | Separate regime for entities in CSRD scope | Double materiality, broader topics and sector standards; interoperability guidance from EFRAG and the IFRS Foundation |
| TPT Disclosure Framework | Not referenced in UK SRS S2; ¶14(a)(iv) requires disclosure about any transition plan the entity has | The TPT concluded in 2024 and the IFRS Foundation hosts its materials; the Foundation's June 2025 guidance on transition disclosures draws on TPT work |
For the FRC’s authoritative reading of the s414CB(6) position, see its Sustainability Reporting Developments FAQ.
Putting it together
How to comply with UK SRS step by step: what a UK SRS-aligned annual report looks like
There is no FCA-prescribed structure.
CP26/5 ¶4.13 deliberately leaves the location open so entities can integrate with wider reporting and other regimes — and three patterns are emerging.
Integrated into the strategic report
UK SRS S2 disclosures sit in the strategic report alongside the s414CB climate disclosures, in one coherent place.
The NFSIS cross-refers to them and confirms UK SRS S2 as the s414CB(6) national reporting framework that discharges the s414CB(2A) disclosures.
A standalone UK SRS section
A separate sustainability section presenting all S1 and S2 disclosures together — suited to entities with mature sustainability reporting.
See what belongs in each section for the template-level detail.
Cross-referenced to a separate report
UK SRS S1 ¶63 allows incorporation by reference to a standalone sustainability or ESG report, under ¶¶B45–B47.
That report must be published at the same time, on the same terms, with the same authorising responsibility.
First, specify the location of the UK SRS disclosures in the annual financial report itself, so readers can find them.
Second, state whether third-party assurance was obtained — and if so, the provider, what was assured, the level, the standards used, and where the assurance report is.
Assurance and transition plans
Two things UK SRS does not require
Assurance
The FRC’s ISSA (UK) 5000, published on 12 November 2025 and effective for engagements on periods beginning on or after 15 December 2026, is available for voluntary use.
ISSA (UK) 5000 adopts the IAASB’s ISSA 5000 with UK-specific additions, one of which prohibits internal auditors from providing direct assistance on an engagement under the UK standard.
The Government’s January 2026 response on an oversight regime signalled an intention to legislate for an assurance practitioner register “as and when Parliamentary time allows”, keeping registration voluntary, with no timetable.
The FRC was tasked with an interim, voluntary register targeted for mid-2026; that target has passed with no FRC announcement that it is live, so it should not be described as existing.
Transition plans
UK SRS S2 ¶14 requires an entity with a published transition plan to disclose information about it, but does not require it to have one.
The FCA’s final rules add a listed-company disclosure: state in the annual report whether the company has a climate-related transition plan and, if so, where it can be found (PS26/19 ¶2.37); CP26/5 ¶6.9 had proposed a similar statement.
The IFRS Foundation’s June 2025 guidance on disclosing climate-related transition information builds on the Transition Plan Taskforce, and CP26/5 ¶6.10 proposed Handbook Guidance that listed companies may wish to use it — it is optional.
DESNZ consulted on climate-related transition plan requirements from 25 June to 17 September 2025; as at 26 September 2026 no response has been published and the page still invites readers to “visit this page again soon to download the outcome”.
Not required. Under the FCA’s final rules, where assurance is obtained the company names the provider, the disclosures assured and the standards used (PS26/19 ¶2.45); CP26/5 ¶7.8 had reserved mandatory assurance for a later stage.
Not required. UK SRS S2 requires disclosure about a plan where one exists.
Frequently asked
UK SRS reporting — frequently asked
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?
Under the FCA's final rules (PS26/19, 30 September 2026), comply or explain applies across all UK SRS disclosures for listed companies in scope. On the explanation itself, the consultation, CP26/5, proposed at paragraphs 4.8 and 5.8 that an entity explaining rather than complying on a UK SRS S1 non-climate disclosure or a UK SRS S2 Scope 3 disclosure 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 that "explains" may not be able to assert compliance with UK SRS (CP26/5 paragraph 5.12; UK SRS S1 paragraph 72).
Is climate-only reporting allowed under UK SRS?
Yes, under the climate-first relief in UK SRS S1 appendix E (paragraph E3). An entity may report against UK SRS S2 (climate) without applying UK SRS S1 (broader sustainability). The final Standard carries no fixed number of reporting periods for this relief — the government's 2025 consultation had proposed a two-year limit, but the published Standard removed the time limit on the relief entirely. The entity must disclose use of the provision and cannot assert full compliance with UK SRS S1 while it applies — though it can still assert compliance with UK SRS S2.
Do I need to disclose Scope 3 emissions in the first year?
Under the FCA's final rules (PS26/19, 30 September 2026), in-scope listed companies may use one year's non-disclosure of Scope 3 under UK SRS S2, stating that they are doing so; no further explanation is required during the relief period. After that, Scope 3 is reported, or its omission explained, on the same comply-or-explain basis as every other UK SRS disclosure. CP26/5 paragraph 8.6 had proposed the same one-year relief.
Do I have to apply SASB Standards under UK SRS?
No. UK SRS S1 paragraphs 55(a) and 58(a) make 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 reference to the industry-based guidance under UK SRS S2 paragraphs 12, 23 and 32. Applying SASB and industry-based guidance will typically improve disclosure quality and comparability, but it is not required — although paragraph 59 requires you to identify whichever sources you did apply.
How does UK SRS reporting interact with the Companies Act 2006?
Sections 414CA and 414CB of the Companies Act 2006 require traded companies, banking and insurance companies, and other high-turnover companies (turnover above £500m), in each case with more than 500 employees, to make climate-related financial disclosures in the non-financial and sustainability information statement. The Government confirmed in its February 2026 consultation response that UK SRS S2 is a national reporting framework for the purposes of section 414CB(6): an entity applying UK SRS S2 — voluntarily or mandatorily — does not need to duplicate its section 414CB(2A) disclosures, 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 proposed that comparative information is not required for the first accounting period for which disclosures, or partial disclosures, are made under the FCA’s rules. This mirrors UK SRS S1 paragraph E1 and UK SRS S2 paragraph C1. Comparative information becomes a requirement from the accounting period immediately following the first period in which the disclosures were made.
What if I voluntarily adopt UK SRS now?
Voluntary adoption is open today — the standards are available for voluntary use by any entity that chooses to do so. The FCA's one-year and two-year windows are features of its final listing rules (PS26/19), not of the standards, so a voluntary adopter works from the standards' own transition appendices instead. Those appendices are untimed for two of the three reliefs: a voluntary adopter may omit Scope 3 under UK SRS S2 paragraph C4 and report climate-only under UK SRS S1 paragraph E3 for as long as no legislation or FCA rule closes the relief, but must disclose use of the relief and, for climate-only reporting, forgo the UK SRS S1 compliance statement (paragraph 73A). Only the alternative GHG-measurement relief in UK SRS S2 paragraph C3 is limited to the first annual reporting period.
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.
- Department for Business and TradeUK SRS S1 General Requirements — final standard (PDF)
Published 25 February 2026. Paragraphs 60–63 set the location of disclosures; B45–B47 the cross-referencing rules.
- Financial Conduct AuthorityCP26/5: Aligning listed issuers' sustainability disclosures with international standards
Published 30 January 2026 — the consultation PS26/19 finalises. Comply-or-explain mechanics as consulted, the Scope 3 relief and the assurance statement.
- 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 (¶1.2, ¶1.7), from accounting periods starting on or after 1 January 2027 (¶3.12); reliefs (¶¶3.14, 3.20); transition plans (¶2.37); assurance (¶2.45).
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
Confirms UK SRS S2 as a national reporting framework under Companies Act 2006 s414CB(6).
- Department for Business and TradeUK SRS consultation response (PDF, February 2026)
Annex A lists every UK departure from IFRS S1 and S2, including the removed E4 relief.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — final standard (PDF)
Paragraph 29 sets the GHG and cross-industry metrics; Appendix C carries the untimed Scope 3 relief.
- legislation.gov.ukCompanies Act 2006, section 414CB
Climate-related financial disclosures in the NFSIS; subsection (6) on national reporting frameworks.
- GHG ProtocolCorporate Accounting and Reporting Standard
The measurement method UK SRS S2 ¶29(a)(ii) requires unless a jurisdictional authority requires otherwise.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
Issued 12 November 2025; paragraph 15 sets the 15 December 2026 effective date.
Continue reading
Read next
UK SRS S1 — general requirements
The general framework for disclosing sustainability-related financial information, including the materiality test and the four-pillar structure.
UK SRS S2 — climate-related disclosures
The climate standard listed companies report against, or explain, from 1 January 2027, including the scenario analysis requirement at paragraph 22.
UK SRS compliance
The programme view: gap analysis, governance structures, data systems and assurance readiness for in-scope listed companies.
UK SRS reporting templates
What belongs in each section of a UK SRS-aligned report.