UK SRS S2: climate-related disclosures

UK SRS S2 is the UK's climate-related disclosure standard, published by the Department for Business and Trade on 25 February 2026. It is the UK endorsement of the ISSB's IFRS S2, with UK-specific amendments. It requires an entity to disclose the climate-related risks and opportunities that could reasonably be expected to affect its cash flows, its access to finance or its cost of capital.

No. UK SRS S2 is a voluntary standard, and the FCA's final rules (PS26/19, 30 September 2026) do not make it mandatory: listed companies in scope report against it on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reporting in 2028. The consultation, CP26/5, had proposed making UK SRS S2 mandatory for those companies, excluding Scope 3; the final rules adopt comply or explain across all categories of disclosure instead.

Under the FCA's final rules, companies listed in the 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 transition (UKLR 22) categories report against UK SRS S2 on a comply-or-explain basis. CP26/5 had proposed only a signposting statement for UKLR 14 and 15 issuers; the final rules bring them in. Closed-ended investment funds, open-ended investment companies, shell companies, and debt, securitised derivative and miscellaneous securities are excluded. CP26/5 estimated that around 600 listed companies would be affected; the Policy Statement gives no total count.

UK SRS S2 requires absolute gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions measured under the GHG Protocol Corporate Standard. Under the FCA's final rules, a listed company may use a one-year relief from disclosing Scope 3, stating that it is 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.

There is no deadline for voluntary use. For listed companies in scope, the FCA's final rules apply to accounting periods starting on or after 1 January 2027, with first reporting in 2028 — for a 31 December year-end, the report on the 2027 financial year.

UK SRS S2 is the UK endorsement of IFRS S2. The UK government consulted on six proposed amendments in June 2025, but two did not survive to publication; the authoritative list of final differences is Annex A of the government's consultation response, which carries no headline count. The most significant: no fixed effective date, removal of the delayed reporting transition relief, a non-climate reporting relief retained but left untimed in the Standard itself (the FCA's final rules separately give listed companies two years' non-disclosure of non-climate matters), softened SASB references, and added paragraphs clarifying how an entity states compliance when using the reliefs. The Global Industry Classification Standard requirement was removed by the ISSB's own December 2025 amendment to IFRS S2, not by a UK-specific change. The disclosure requirements themselves are otherwise the ISSB global baseline.

No. UK SRS S2 does not require an entity to have a climate-related transition plan, or to set climate targets aligned with any particular goal. Where an entity does have a transition plan, the standard requires disclosure of information about it, including the key assumptions used in developing it and the dependencies it relies on. Under the FCA’s final rules an in-scope listed issuer discloses in its annual report whether it has a climate-related transition plan and, if so, where it can be found; it is not required to have one.

No. The FCA’s final rules do not require assurance. Where an in-scope listed company obtains it, it names the provider, which disclosures were assured and which assurance standards were used. ISSA (UK) 5000, issued by the FRC on 12 November 2025 and effective for engagements on periods beginning on or after 15 December 2026 (or as at a date on or after it, with earlier application permitted), is for voluntary use: it governs how an assurance engagement is performed, not whether one must be obtained.