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UK SRS S1 · Materiality

UK SRS S1 materiality: how it is defined

UK SRS S1 materiality turns on one test in UK SRS S1 paragraph 18: would omitting, misstating or obscuring the information influence the decisions of investors, lenders and other creditors?

It is single, financial materiality, consistent with IFRS S1 — not the double materiality of the EU’s CSRD.

The definition

What UK SRS S1 means by material

UK SRS S1 materiality turns on one test: under UK SRS S1 paragraph 18, information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions primary users make on the basis of general purpose financial reports.

Primary users are defined as existing and potential investors, lenders and other creditors.

The Standard sets no thresholds and does not predetermine what is material in any particular situation (UK SRS S1 paragraph B19).

This is not the same as financial statement materiality.

Sustainability materiality asks about influence on an investor’s assessment of the company’s prospects, not about whether the accounts would change.

This distinction is central to the UK SRS framework.

UK SRS S1 paragraph 18

Sustainability-related financial information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users of general purpose financial reports make on the basis of those reports.

Asks whether information…
Financial statement materiality…would change the numbers in the accounts.
Sustainability materiality (UK SRS)…about sustainability-related risks and opportunities would influence an investor’s assessment of prospects — even before the financial impact appears in the accounts.

Comparison

Single materiality vs double materiality

UK SRS uses a single, financial materiality approach, consistent with IFRS S1 globally.

For the double materiality technical material, see EFRAG, technical adviser on the ESRS.
UK SRS and IFRS S1CSRD and ESRS
Perspective“Outside-in”: how sustainability matters could reasonably be expected to affect the companyOutside-in and “inside-out”: also how the company’s activities affect people and the environment
TestEffect on cash flows, access to finance or cost of capital over the short, medium or long term (UK SRS S1 ¶3)Impacts count regardless of whether they affect cash flows, access to finance or cost of capital
SourceUK SRS S1 ¶¶3, 18ESRS 1 — Commission Delegated Regulation (EU) 2023/2772, Annex I

A company considers sustainability risks and opportunities through their potential effect on its cash flows, access to finance, cost of capital or business model over the short, medium and long term.

That differs fundamentally from the double materiality approach of the EU Corporate Sustainability Reporting Directive, adopted under Directive 2013/34/EU.

For the full comparison with the global baseline, see UK SRS vs IFRS S1 and S2.

Reporting under both

A UK company subject to both UK SRS and CSRD will need to apply both materiality lenses.

Overseas companies listed in several jurisdictions should review these differences carefully.

Process

Materiality assessment under UK SRS in practice

UK SRS does not prescribe a materiality assessment methodology.

It does require companies to disclose the process and judgements they used to identify material sustainability topics.

Paragraph 59 requires them to identify the standards and other sources of guidance they applied.

In practice, a robust assessment builds a long list of topics, assesses each against the definition, engages relevant stakeholders and documents the rationale for every inclusion and exclusion.

A structured gap analysis can show where materiality assessment processes need strengthening.

A typical assessment

  1. 01
    Build a long list

    Potential sustainability topics relevant to the industry and value chain.

  2. 02
    Assess each topic

    Against the paragraph 18 definition.

  3. 03
    Engage stakeholders

    Those relevant to the topics on the list.

  4. 04
    Document the rationale

    For including or excluding each topic — the judgement must be evidenced.

Starting point

Using the SASB Standards as a starting point

The SASB Standards provide industry-specific lists of sustainability topics likely to be material.

They are not mandatory in the UK, but offer a practical starting point for a company building its materiality assessment for the first time.

The ISSB maintains them alongside its global disclosure framework.

Permissive in the UK

UK SRS S1 ¶¶55(a) and 58(a): an entity “may refer to and consider” the SASB Standards.

IFRS S1 says “shall”.

Recorded in Annex A of the DBT consultation response

Stakes

Why this matters

The materiality definition determines the boundary of a company’s UK SRS disclosures.

A well-conducted assessment protects the company from both under-disclosure — which, under the FCA’s final listing rules that followed CP26/5, risks regulatory challenge where it is not explained — and over-disclosure.

It is also the foundation for the statement of compliance.

Boards should be able to understand and evidence the materiality judgements made.

For the disclosure requirements structured around the four-pillar framework, see our dedicated guide.

Review the S1 scope and timing requirements and the UK SRS timeline too.

For the primary texts, see the FCA’s CP26/5 consultation paper, the published UK SRS S1 and S2, and the GOV.UK UK SRS guidance, which confirms the standards are available for voluntary use by any entity.

Under-disclosure

Under the FCA’s comply-or-explain listing rules from 2027, under-disclosure without an explanation risks regulatory challenge.

Over-disclosure

Creates reporting burden without corresponding value to investors.

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 12 sources fromDepartment for Business and TradeIFRS FoundationFinancial Conduct AuthorityEUR-LexEFRAG
  1. Department for Business and Trade
    UK SRS S1 General Requirements — final standard (PDF)

    Published 25 February 2026. ¶3, ¶¶17–19, ¶B19, ¶¶55(a), 58(a) and 59.

  2. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2

    The publication page for both standards.

  3. Department for Business and Trade
    UK SRS consultation response (PDF)

    Annex A records the "shall" to "may" SASB amendment.

  4. Department for Business and Trade
    UK Sustainability Reporting Standards — GOV.UK guidance

    The standards are available for voluntary use by any entity.

  5. IFRS Foundation
    IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information

    The IFRS S1 materiality definition UK SRS S1 carries.

  6. IFRS Foundation
    International Sustainability Standards Board

    Maintains the SASB Standards alongside the global disclosure framework.

  7. IFRS Foundation
    SASB Standards

    Referenced permissively in UK SRS S1 ¶¶55(a) and 58(a).

  8. Financial Conduct Authority
    CP26/5: Sustainability disclosures

    The consultation on the listing rules that apply UK SRS, finalised by PS26/19.

  9. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    First published 30 September 2026. The final rules: listed companies in scope report against UK SRS on a comply-or-explain basis from accounting periods starting on or after 1 January 2027.

  10. Financial Conduct Authority
    CP26/5: Aligning listed issuers' sustainability disclosures with international standards (PDF)

    The consultation paper itself.

  11. EUR-Lex
    Commission Delegated Regulation (EU) 2023/2772 — Annex I, ESRS 1

    The double materiality requirement, adopted under Directive 2013/34/EU.

  12. EFRAG
    EFRAG sustainability reporting

    Technical adviser on the ESRS, for the double materiality comparison.

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