UK SRS timeline: voluntary now, comply or explain from 2027

No, and the FCA's final rules do not make it mandatory. UK SRS S2 was published on 25 February 2026 and is available for voluntary adoption. The FCA's final rules (PS26/19, 30 September 2026) require listed companies in scope to report against UK SRS, S2 included, on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. The consultation, CP26/5, had proposed making UK SRS S2 mandatory; the final rules do not.

The final rules apply to 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. PS26/19 gives no total count. The FCA's consultation, CP26/5, estimated in its Cost Benefit Analysis (Annex 2 paragraph 43) that around 600 listed companies would be affected.

Six categories are excluded (PS26/19 ¶3.7): closed-ended investment funds (UKLR 11), open-ended investment companies (UKLR 12), shell companies (UKLR 13), debt and debt-like securities (UKLR 17), securitised derivatives (UKLR 18), and warrants, options and other miscellaneous securities (UKLR 19). For UKLR 11 and 12, CP26/5 said reporting should fall on the asset manager rather than the fund; for the others, it considered direct reporting would not be proportionate or effective at that stage.

The final rules apply to accounting periods starting on or after 1 January 2027 (PS26/19 ¶3.12), so a company whose period begins on 1 April 2027 starts with that period. Under CP26/5's proposal (paragraph 8.10), a company whose period began before 1 January 2027 could continue with the TCFD-aligned rules for that period or apply UK SRS early. The reliefs run for one year (Scope 3) and two years (UK SRS S1 non-climate matters).

In-scope listed companies report against UK SRS, on a comply-or-explain basis, for accounting periods starting on or after 1 January 2027; CP26/5 proposed that this replace the TCFD-aligned listing rules. UK SRS S2 keeps the four TCFD pillars and goes further on quantitative scenario analysis, connected information with the financial statements, and cross-industry metrics. The TCFD itself was disbanded on 12 October 2023. SECR, the Companies Act energy and emissions regime, is separate and continues: DESNZ's post-implementation review of 26 May 2026 recommended retaining it with amendments.

It is elective, not automatic. Under the FCA's final rules a company may use one year's non-disclosure of Scope 3 under UK SRS S2 (PS26/19 ¶3.14); a company using it must state that it is doing so, and no further explanation is required during the relief period. After that year Scope 3 is disclosed, or its omission explained, on the same comply-or-explain basis as every other UK SRS disclosure — the final rules do not make it mandatory.

It does not: under the FCA's final rules UK SRS S1, like S2, is comply or explain for listed companies in scope from accounting periods starting on or after 1 January 2027. A company may use two years' non-disclosure of S1 non-climate matters (PS26/19 ¶3.14), stating that it is doing so. The S1 conceptual foundations — materiality, the value chain, connected information — are needed to apply UK SRS S2 at all, because S2 cannot be applied without them.

CP26/5 and the FCA’s final rules cover listed issuers only. The Modernising corporate reporting consultation of 7 September 2026, closing 30 November 2026, makes no proposal on UK SRS for private companies: paragraph 155 says only that the government "will consider how UK SRS should be reflected in the Companies Act 2006". No government or regulator document proposes a threshold or a commencement date.

No. The FCA’s final rules do not require assurance; where a company obtains it, it names the provider, which disclosures were assured and which assurance standards were used. The FRC published ISSA (UK) 5000 on 12 November 2025, effective for periods beginning on or after 15 December 2026, but its use is voluntary.