UK SRS S1 · Scope and timing
UK SRS S1 scope: who it applies to and when
The UK SRS S1 scope for listed companies is now set: under the FCA’s final rules (PS26/19, 30 September 2026), S1 applies on a comply-or-explain basis to companies listed under UKLR 6, 14, 15, 16 and 22 from 1 January 2027.
Any other entity may apply the standard voluntarily; FCA CP26/5 was the consultation behind the rules.
Scope
Companies in scope
Under the FCA’s final rules, UK SRS S1 applies to the same population as S2 — the listed companies in the five categories the FCA has put in scope.
That population is commercial companies (UKLR 6), international commercial companies secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16), and the transition category (UKLR 22).
CP26/5 had proposed only a transparency and signposting statement for UKLR 14 and 15; the final rules bring them into UK SRS reporting, and the consultation estimated around 600 listed companies would be affected.
Scope may be extended to private companies through future Companies Act amendments, but nothing has been proposed.
The Modernising Corporate Reporting consultation of 7 September 2026 says only (paragraph 155) that the government “will consider how UK SRS should be reflected in the Companies Act 2006”.
See regulatory updates for the latest.
Timing
When does UK SRS S1 apply? The two-year relief
Two different things get called “the S1 relief”, and only one of them has an end date.
| Where it sits | What it allows | How long | |
|---|---|---|---|
| ¶E3 climate-first relief | UK SRS S1 itself | Disclose only climate-related information in the period(s) the entity first applies the Standard | No time limit in the final Standard |
| Non-climate relief | FCA PS26/19 | An in-scope company may choose not to disclose S1 non-climate matters, stating that it is doing so | Two years — the FCA’s final rules |
The time limit was removed from the final Standards — a change DBT announced in its letter to the FCA of 5 January 2026.
Separately, under the FCA’s final rules, UK SRS S1 applies on a comply-or-explain basis from the same date as S2 — accounting periods beginning on or after 1 January 2027 — as FCA CP26/5 had proposed.
The FCA’s rules let a company use two years’ non-disclosure of S1 non-climate matters (PS26/19 ¶3.14).
A company using the relief states that it is doing so, and no further explanation is required during the relief period (¶3.20).
Once the two years are used, the relief is no longer available: the company complies with S1, or explains.
The relief is deliberate: most listed companies have some climate disclosure experience through TCFD, but fewer have mature programmes for biodiversity, water, workforce and supply chain.
See the UK SRS timeline for all key dates.
S1 under the FCA’s final rules
- 25 Feb 2026Voluntary use opens
The ¶E3 relief is available to any adopter, with no time limit.
- 1 Jan 2027Comply-or-explain begins
Non-climate relief available.
- Years 1–2Relief available
Two years’ non-disclosure, stated as used.
- After year 2Relief no longer available
Comply with S1, or explain.
The FCA published its final rules, PS26/19, on 30 September 2026; the comply-or-explain basis and the relief length above come from them.
In practice
What comply-or-explain means in practice
Comply-or-explain is not optional reporting.
As consulted on in CP26/5 paragraphs 5.7–5.8, a listed company would either comply with UK SRS S1 or, where it has identified sustainability-related risks or opportunities that could reasonably be expected to affect its prospects, explain in its annual financial report.
A general statement that the company has decided not to apply S1 is insufficient, and a company that has identified no such risks or opportunities must say so (paragraph 5.11).
The FCA did not, however, propose a requirement-by-requirement account of every S1 paragraph not applied, which it considers would produce lengthy explanations of limited benefit to investors (paragraph 5.9).
In practice, companies choosing the explain path will still need to understand S1 in detail.
They will need to identify their material sustainability-related risks and opportunities, decide whether disclosure is feasible for each, and — where it is not — say why.
The materiality framework under S1 determines which sustainability topics require disclosure.
An explanation must set out
- 01The risks or opportunities
For which disclosures have not been made.
- 02The reasons
Why they have not been made.
- 03The steps and timeframe
Any steps taken or planned to make them in future.
Source: FCA CP26/5 ¶5.7–5.8 — as consulted on; check the final wording in PS26/19
An issuer that explains rather than complies may not be able to state compliance with UK SRS (¶5.12).
Now
What companies should do now
The two-year relief may make S1 look distant, but the data collection and governance it needs take time to build.
Assess data for each topic
Check the availability and quality of data behind each material topic.
Establish oversight beyond climate
Build governance for broader sustainability oversight — see UK SRS for boards.
Test your reporting systems
Evaluate whether current systems can accommodate non-climate sustainability disclosures.
A gap analysis is the recommended starting point.
For the relationship between UK SRS and the global ISSB baseline, see UK SRS vs IFRS S1 and S2.
Companies already reporting under SECR will have some existing data infrastructure to build on.
For the regulator’s own overview of UK sustainability reporting requirements, see the FRC’s Sustainability Reporting Developments FAQ.
The standards themselves are on the DBT publication page, and the reasoning behind the reliefs is in the government response.
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.
- Financial Conduct AuthorityCP26/5: sustainability disclosures — consultation page
The consultation PS26/19 finalises: the proposed scope and the transitional relief.
- 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 (¶3.6), from accounting periods starting on or after 1 January 2027; two years’ S1 non-climate relief (¶3.14), stated as used (¶3.20).
- Financial Conduct AuthorityCP26/5: Aligning listed issuers' sustainability disclosures with international standards (PDF)
¶3.4 scope, ¶3.9 relief, ¶5.7–5.12 the S1 explain provisions as consulted, Annex 2 ¶43 estimate of around 600 affected.
- Department for Business and TradeUK SRS S1 General Requirements — final standard (PDF)
¶E3: the climate-first relief, with no time limit.
- Department for Business and TradeUK SRS S1 and UK SRS S2
The standards as published for voluntary use, 25 February 2026.
- Department for Business and TradeGovernment response to the UK SRS consultation
¶1.17–1.23 and Annex A on the removal of the relief time limits.
- Department for Business and TradeLetter to the FCA on finalising UK SRS, 5 January 2026 (PDF)
Announced the removal of the time limits from the transitional reliefs.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance hub
GOV.UK page tracking the standards.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
7 September 2026, closing 30 November 2026; ¶155 on UK SRS in the Companies Act.
- legislation.gov.ukCompanies Act 2006
The route for any future private-company requirement.
- Financial Reporting CouncilSustainability reporting developments — FAQ
Updated 26 February 2026; the regulator’s own overview of UK requirements.
- IFRS FoundationInternational Sustainability Standards Board
The global baseline UK SRS S1 endorses.
Continue reading
Read next
UK SRS S1 — general requirements
The standard itself: what S1 asks every reporting entity to disclose.
UK SRS S1 materiality
How S1 decides which sustainability topics must be disclosed.
UK SRS S2
The climate standard applied alongside S1 from the 2027 comply-or-explain start.
UK SRS gap analysis
Where to start sizing the work S1 non-climate reporting implies.
UK SRS timeline
Every UK SRS date in sequence.
Who must comply with UK SRS
Scope by listing category.