Standards · General Requirements
UK SRS S1: General Requirements for Disclosure of Sustainability-related Financial Information
UK SRS S1 establishes how an entity discloses information about all sustainability-related risks and opportunities that could reasonably be expected to affect its cash flows, access to finance or cost of capital.
The Department for Business and Trade issued it on 25 February 2026 as a voluntary standard; the FCA’s final rules apply it to listed companies in scope on a comply-or-explain basis from 2027.
Status
Voluntary standard, comply-or-explain for listed companies
UK SRS S1 was issued by the Secretary of State for Business and Trade, within the Department for Business and Trade, on 25 February 2026.
It is the UK-endorsed version of IFRS S1, with UK-specific differences set out in Annex A of the government’s consultation response, and has been available for voluntary use by any UK entity since publication.
There is no effective date in the Standard itself; any required application is set in separate legislation, in FCA rules or by another UK regulator (UK SRS S1 ¶E5).
The FCA’s final rules (PS26/19, 30 September 2026) set it for listed companies: S1 applies on a comply-or-explain basis for in-scope listed issuers from accounting periods beginning on or after 1 January 2027, as the FCA’s Consultation Paper CP26/5, which closed on 20 March 2026, had proposed.
The final rules add an optional deferral for non-climate matters that the Standard leaves untimed: two years’ non-disclosure, stated as used.
In-scope issuers are those listed under UKLR 6, 14, 15, 16 and 22; first reporting under the rules is in 2028.
Private companies: the Modernising corporate reporting consultation (published 7 September 2026, closes 30 November 2026) says only that the government “will consider how UK SRS should be reflected in the Companies Act 2006” — no threshold or date is proposed.
The complete schedule is on our UK SRS timeline and the editorial UK SRS timeline on our sister publication.
How S1 becomes an obligation
- 30 Jan 2026FCA CP26/5 published
Proposed S1 on a comply-or-explain basis for in-scope listed issuers.
- 25 Feb 2026UK SRS S1 issued
Voluntary use by any UK entity from publication.
- 20 Mar 2026CP26/5 consultation closes
- 30 Sep 2026FCA final rules — PS26/19
Comply or explain across the UK SRS, S1 included.
- 1 Jan 2027Comply-or-explain start
For accounting periods beginning on or after this date.
- Years 1–2Non-climate relief
Two years’ non-disclosure under the FCA’s rules; the Standard itself sets no time limit.
Requirements
UK SRS S1 general requirements: what the standard actually requires
UK SRS S1 covers all sustainability-related risks and opportunities that could reasonably be expected to affect an entity’s cash flows, access to finance or cost of capital over the short, medium or long term.
It is not a climate-specific standard — climate disclosures are covered by UK SRS S2.
The two are designed as a pair: UK SRS S1 ¶E2 requires an entity to apply S1 and UK SRS S2 at the same time, unless it uses the climate-first relief in ¶E3.
S1 covers the full universe of sustainability matters: biodiversity, water and marine resources, workforce, supply chain, governance, and any other factor that meets the materiality threshold.
Its structure follows the same four content pillars used by the IFRS Sustainability Disclosure Standards and the now-disbanded Task Force on Climate-related Financial Disclosures (TCFD).
The full text of UK SRS S1 is set out requirement by requirement on our primary reference site.
Structure
The four content pillars
Each pillar carries specific disclosure requirements, applied together with any other UK Sustainability Reporting Standard that specifically addresses the relevant risk or opportunity.
Governance
The processes, controls and procedures used to monitor, manage and oversee sustainability-related risks and opportunities.
Strategy
How the entity manages those risks and opportunities, including effects on its business model, value chain, financial position and resilience.
Risk management
How risks and opportunities are identified, assessed, prioritised and monitored.
Metrics and targets
Performance against the risks and opportunities, and against any targets set or required by law.
Each pillar is taken apart in the UK SRS four-pillar framework.
Materiality
The single materiality basis
UK SRS S1 applies a single materiality basis.
Information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions primary users — existing and potential investors, lenders and other creditors — make on the basis of the entity’s general purpose financial reports.
The reference point is the entity’s cash flows, access to finance or cost of capital (UK SRS S1 ¶3): how sustainability matters affect the entity’s prospects, not the entity’s effects on the wider environment or society.
That is a critical difference from the EU Corporate Sustainability Reporting Directive (CSRD) and its European Sustainability Reporting Standards (ESRS), which apply double materiality and require disclosure of impacts on people and the environment regardless of financial effect.
UK SRS S1 keeps the scope deliberately narrower and financially anchored, in line with the IFRS Foundation’s ISSB framework.
For a UK group with EU subsidiaries subject to CSRD, two separate but related regimes apply; they operate independently, so plan for both.
How UK SRS materiality is defined and applied is covered at UK SRS S1 materiality — how sustainability materiality is defined.
| UK SRS S1 | EU CSRD / ESRS | |
|---|---|---|
| Materiality | Single (financial) | Double |
| Question asked | How sustainability matters affect the entity’s prospects | That, plus how the entity’s activities affect people and the environment |
| Primary audience | Investors, lenders and other creditors | Multi-stakeholder |
| Assurance | Not required under the FCA’s final rules | Mandatory |
Differences
How UK SRS S1 differs from IFRS S1
UK SRS were developed by adapting IFRS S1 and IFRS S2 for the UK, on recommendations from the UK Sustainability Disclosure Technical Advisory Committee (TAC).
The government consulted on six proposed amendments in June 2025, but two did not survive to publication and further provisions were added afterwards — the authoritative list is Annex A of the government’s consultation response, which carries no headline count.
| Aspect | IFRS S1 | UK SRS S1 |
|---|---|---|
| Effective date | 1 January 2024 onwards | No fixed date; any requirement would come from the Companies Act 2006, FCA rules or another UK regulator (¶E5) — for listed companies the FCA’s final rules set comply or explain from 1 January 2027, and for others the government “will consider” it |
| Delayed reporting | Permitted under paragraph E4 | Removed — disclosures published at the same time as the related financial statements |
| Climate-first relief (IFRS S1 ¶E5 → UK SRS S1 ¶E3) | First annual reporting period only | Retained, but no fixed period in the Standard; the FCA’s final rules allow it for two years for listed companies |
| SASB Standards | “Shall refer to and consider” (¶¶55(a), 58(a)) | “May refer to and consider” — permissive, not required |
| Industry classification (S2) | GICS originally required for financed emissions | Alternative systems permitted — an ISSB-wide change from December 2025, not a UK-specific amendment |
| Transition reliefs | Time-bound | Time limits removed from the climate-first relief (S1 ¶E3) and the Scope 3 relief (S2 ¶C4); the GHG Protocol methodology relief (S2 ¶C3) keeps its first-year limit |
The SASB wording is at IFRS S1 ¶¶55(a) and 58(a), which require entities to “refer to and consider” the SASB Standards when identifying sustainability-related risks.
The GICS change sits in IFRS S2, not S1: the UK proposed removing the requirement itself, then withdrew that proposal once the ISSB made the same change to IFRS S2 in December 2025, so UK SRS S2 simply inherits it.
For a voluntary reporter, the FRC’s FAQ reads the untimed climate-only relief plainly: it “can be used indefinitely”.
The relief has a price, set by UK SRS S1 ¶73A: an entity using it may not assert compliance with UK SRS S1, though it may still assert compliance with UK SRS S2 if it discloses the reliefs used.
Connected information
The Connected information requirement
One of the most significant requirements in UK SRS S1 is “Connected information” (¶¶21–24, and appendix ¶¶B39–B44) — the Standard’s own heading; “connectivity” does not appear in UK SRS S1.
An entity must present its sustainability-related financial disclosures so that users can understand the connections between sustainability matters and its financial statements.
This is one of the most material differences from the legacy TCFD framework, which encouraged but did not require explicit financial statement linkage.
Under UK SRS S1 the connection must be explicit.
Data and assumptions must also be consistent, as far as possible, with those used in the related financial statements (UK SRS S1 ¶23).
If an entity discloses a transition risk to its business model, for example, the related current and anticipated financial effects must be quantified or, where genuine measurement uncertainty exists, explained qualitatively with reasoning.
What must connect
- 01Disclosures on governance, strategy, risk management, and metrics and targets
- 02Narrative and quantitative information
- 03The various sustainability-related risks and opportunities
- 04Data and assumptions in the sustainability disclosures and the related financial statements
UK SRS S1 ¶¶21–24 and B39–B44
Reporting and assurance
When S1 disclosures are published, and who checks them
Reporting
Disclosures must be published with the financial statements, for the same reporting period (UK SRS S1 ¶64).
An entity whose disclosures comply with every requirement makes an explicit and unreserved statement of compliance (¶72), and discloses any reliefs it has used (¶73A).
Voluntary assurance
ISSA (UK) 5000, issued by the FRC on 12 November 2025 for voluntary use, is the UK sustainability assurance standard.
It is effective for engagements on periods beginning on or after 15 December 2026, or as at a specific date on or after it, and early voluntary application is permitted — so it can be applied now.
See UK SRS assurance for the detail.
ISSA (UK) 5000 governs how an assurance engagement is performed; it creates no obligation to obtain assurance.
Under the FCA’s final rules, an in-scope listed company that obtains assurance names the provider, the disclosures assured and the standards used.
From TCFD
How UK SRS S1 builds on TCFD
The TCFD was formally disbanded in October 2023, after publishing its final status report, following the ISSB’s publication of IFRS S1 and S2.
CP26/5 proposed that UK SRS S2 replace the FCA’s TCFD-aligned listing rules for in-scope issuers; the final rules put those issuers on comply or explain against UK SRS from 2027.
| Dimension | TCFD | UK SRS S1 |
|---|---|---|
| Scope | Climate only | All sustainability matters meeting the materiality threshold |
| Connected information | Encouraged, not required | Required |
| Specificity | Principles-based | Detailed disclosure requirements, including quantified current and anticipated financial effects |
| Industry guidance | Supplemental guidance for the financial sector and for selected non-financial groups | SASB Standards as a permissive sector resource |
Listed companies reporting under the TCFD-aligned UK Listing Rules will need to upgrade their data, governance and disclosure infrastructure to meet UK SRS once it applies to them.
Delivery
Where companies typically struggle
Four implementation areas commonly emerge as the hardest.
Materiality that meets the Connected information bar
Materiality assessments must be tied to the financial statements. Historical assessments built on stakeholder consultation or impact frameworks typically need reworking to the financial materiality basis S1 requires.
Scope 3 data along the value chain
Scope 3 is a UK SRS S2 requirement, but the data infrastructure overlaps with S1 value chain disclosure. It is usually the most resource-intensive workstream, because supplier engagement has to run for more than one reporting cycle.
Governance integration
S1 ¶¶26–27 require detailed disclosure of how sustainability oversight is reflected in board mandates, role descriptions, skills assessments and remuneration. Many boards have processes that work but lack the documentation trail ¶27 asks for.
Quantifying financial effects
S1 ¶¶34–40 require quantitative disclosure of current and anticipated financial effects. Qualitative-only disclosure is permitted where measurement uncertainty is genuine, but the bar is high — and any assurance provider engaged will scrutinise the basis.
The four pillars in depth are in the UK SRS four-pillar framework; the compliance pathway is in the UK SRS compliance guide.
Next steps
What to do now if you are in scope
The path depends on whether you are an in-scope listed issuer — comply or explain from 1 January 2027, under the FCA’s final rules — or a large private entity, for which the Modernising corporate reporting consultation proposes no UK SRS threshold or date.
Five steps
- Map existing TCFD-aligned disclosures against UK SRS S2; identify data, governance and disclosure gaps.
- Establish a cross-functional working group spanning finance, sustainability, legal and risk.
- Begin voluntary UK SRS S2 reporting in the 2026 annual report cycle if practical.
- Engage assurance providers early to scope a voluntary approach — the FCA’s final rules do not require assurance.
- Read the FCA’s final rules (PS26/19, 30 September 2026) for the confirmed scope, timeline and reliefs.
Five steps
- Read the UK SRS S1 standard in full to understand the disclosure architecture.
- Track the Modernising corporate reporting consultation (closes 30 November 2026) — it proposes no scope, threshold or timeline for UK SRS.
- Run a materiality assessment on the UK SRS S1 single materiality basis.
- Build Scope 1 and Scope 2 data infrastructure; begin Scope 3 mapping.
- Consider voluntary partial adoption — governance and metrics disclosures — to build capability before any requirement arrives.
Sector-by-sector implementation is in UK SRS reporting guidance; for a readiness assessment, use the UK SRS compliance guide.
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)
Issued 25 February 2026. ¶3 (scope of disclosure), ¶18 (materiality), ¶¶21–24 and B39–B44 (connected information), ¶27 (governance), ¶¶34–40 (financial effects), ¶64 (timing), ¶¶72–73B (compliance), ¶¶E1–E5 (application and transition).
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — final standard (PDF)
The climate standard S1 is applied with; ¶¶C3 and C4 carry the GHG Protocol methodology and Scope 3 reliefs.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — publication page
Published 25 February 2026; the standards are “issued by the UK government”.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
The government’s central UK SRS page: the standards are available for voluntary use by any entity that chooses to do so.
- Department for Business and TradeExposure drafts: UK Sustainability Reporting Standards — consultation
Ran 25 June to 17 September 2025; “the government proposes 6 minor amendments”; 209 responses.
- Department for Business and TradeExposure drafts of UK SRS — consultation response (PDF)
Published 25 February 2026. Annex A compares IFRS S1/S2 with UK SRS S1/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 (¶1.7) for UKLR 6, 14, 15, 16 and 22, from accounting periods starting on or after 1 January 2027; two years’ S1 non-climate relief (¶3.14).
- Financial Conduct AuthorityCP26/5: sustainability disclosures — consultation page
Published 30 January 2026, closed 20 March 2026 — the consultation PS26/19 finalises. It proposed S1 non-climate reporting on a comply-or-explain basis (¶1.6) with a two-year relief (¶3.9).
- IFRS FoundationIFRS S1 General Requirements — standard page
IFRS S1 is effective for annual reporting periods beginning on or after 1 January 2024.
- IFRS FoundationIFRS S1 — full text
The ISSB baseline, including ¶E4 and the SASB references at ¶¶55(a) and 58(a).
- IFRS FoundationInternational Sustainability Standards Board
The standard-setter whose investor-focused materiality UK SRS S1 follows.
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
Updated 26 February 2026: UK SRS S1 is “largely the same” as IFRS S1, and the climate-only relief “can be used indefinitely” by voluntary reporters.
- Financial Reporting CouncilAssurance standards — including ISSA (UK) 5000
ISSA (UK) 5000, issued 12 November 2025 for voluntary use.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Published 7 September 2026, closes 30 November 2026; proposes no UK SRS threshold or date for private companies.
- Financial Stability BoardFSB publishes annual progress report on climate-related disclosures (12 October 2023)
The TCFD’s final status report, and the ISSB asked to monitor climate-related disclosures from 2024.
- EUR-LexDirective (EU) 2022/2464 (CSRD), recital 29
Names the EU’s “double materiality perspective”, the contrast to UK SRS S1’s single materiality.
Continue reading
Read next
UK SRS S2 — Climate-related Disclosures
Climate-specific requirements in-scope listed companies report against, or explain, from 1 January 2027.
UK SRS S1 Materiality
How sustainability materiality is defined and applied under the UK SRS S1 single materiality framework.
UK SRS Four-Pillar Framework
Governance, strategy, risk management, and metrics and targets disclosure requirements under UK SRS.
UK SRS S1 and S2
How the two standards fit together and apply as a pair.