Standards Comparison · International Alignment
IFRS S2 paragraph 6, and UK SRS vs IFRS S1 and S2
UK SRS are the UK’s domestic version of the International Sustainability Standards Board’s IFRS S1 and IFRS S2.
The small number of targeted differences, reflecting UK regulatory context and market characteristics, are mapped in Annex A of the government’s response.
Alignment
Substantial baseline alignment
UK SRS S1 and S2 are the UK’s domestic sustainability reporting standards, published by the Department for Business and Trade on 25 February 2026.
They are based on the ISSB’s IFRS S1 and IFRS S2, with a small number of UK-specific differences mapped in Annex A of the government’s consultation response.
Understanding UK SRS vs IFRS S1 and S2 — where they match and where they part — is critical for multinational companies managing cross-border reporting, UK companies reading the international landscape, and advisers supporting implementation across jurisdictions.
UK entities reporting under UK SRS will be substantially comparable with entities in other jurisdictions reporting under IFRS S1 and S2.
The FRC’s FAQ describes the content of each UK standard as “largely the same” as its IFRS counterpart.
What both UK SRS standards adopt unchanged
| Element | What it means |
|---|---|
| Four-pillar structure | Governance, strategy, risk management, and metrics and targets — the framework originally developed by the TCFD |
| Core disclosure requirements | “Connected information” with financial reporting at the same time and for the same period (UK SRS S1 ¶¶21–24), cross-industry metrics and industry-based guidance |
| Technical methodology | Measurement approaches, including the GHG Protocol Corporate Standard as the default basis for greenhouse gas emissions (S2 ¶29(a)(ii)) |
| Conceptual foundation | Matters that could reasonably be expected to affect cash flows, access to finance or cost of capital — not impact materiality |
IFRS S2 para 6 · Governance
IFRS S2 paragraph 6 (para 6): governance, adopted unchanged in the UK
IFRS S2 paragraph 6, commonly cited as IFRS S2 para 6, is the governance disclosure requirement, and the UK adopted it without amendment.
The paragraph can be read in full in the IFRS Foundation’s free HTML text of IFRS S2; Annex A of the Government’s consultation response lists every UK change to IFRS S2, and paragraph 6 is not among them.
UK SRS S2 is set out in paragraphs 1–37 and retains IFRS S2’s paragraph numbering, so a reference to para 6 identifies the same requirement in either standard.
Paragraph 6 is the governance disclosure requirement, and it is not among the UK-specific differences set out below — the UK adopted it unchanged.
The structure around it is easy to misread, so it is worth stating plainly.
Paragraph 5 states the governance objective, paragraph 6 carries the entire disclosure requirement, and paragraph 7 requires an entity to avoid unnecessary duplication with UK SRS S1.
Governance is therefore one paragraph, not four.
Paragraph 6(a) requires disclosure about the governance body(s) — which can include a board, committee or equivalent body — or individual(s) responsible for oversight, specifically covering:
- 6(a)(i) — how responsibilities are reflected in terms of reference, mandates, role descriptions and related policies
- 6(a)(ii) — how the body determines whether appropriate skills and competencies are available or will be developed
- 6(a)(iii) — how and how often the body is informed about climate-related risks and opportunities
- 6(a)(iv) — how the body takes those risks and opportunities into account when overseeing strategy, major transactions and risk management, including whether it considered the trade-offs involved
- 6(a)(v) — how the body oversees target-setting and monitors progress, including whether related performance metrics are included in remuneration policies
Paragraph 6(b) requires disclosure about management’s role, including whether it is delegated to a specific management-level position or committee, and whether management uses controls and procedures to support oversight.
For a group reporting under both regimes, this pillar needs no reconciliation.
A governance disclosure prepared to satisfy IFRS S2 paragraph 6 satisfies UK SRS S2 paragraph 6, because they are the same requirement.
The governance block in IFRS S2 and UK SRS S2
| Paragraph | Role |
|---|---|
| 5 | The governance objective |
| 6 | The entire disclosure requirement — 6(a)(i)–(v) and 6(b) |
| 7 | Avoid unnecessary duplication with UK SRS S1 |
Paragraph 6 does not appear in Annex A: the same text applies under both standards.
IFRS S2 · ¶5 to ¶37
IFRS S2 paragraph by paragraph: what each one requires, and what UK SRS S2 changes
Start with IFRS S2 paragraph 6, the governance requirement most readers arrive for, then work through strategy, risk management, and metrics and targets in the order the standard sets them out.
Each row paraphrases or quotes the December 2025 text of IFRS S2 and says whether UK SRS S2 changes it.
The test is Annex A of the government’s consultation response, which says: “Where requirements in the standards are not included in the table, there are no differences between the two.”
Governance — ¶¶5–7
| IFRS S2 paragraph | What IFRS S2 requires | UK SRS S2 |
|---|---|---|
| ¶5 Governance objective | States the objective: to enable users to understand “the governance processes, controls and procedures an entity uses to monitor, manage and oversee climate-related risks and opportunities”. | Unchanged Same wording. |
| ¶6 The governance requirement, in full | IFRS S2 paragraph 6 reads, in full: “To achieve this objective, an entity shall disclose information about: (a) the governance body(s) (which can include a board, committee or equivalent body charged with governance) or individual(s) responsible for oversight of climate-related risks and opportunities. Specifically, the entity shall identify that body(s) or individual(s) and disclose information about: (i) how responsibilities for climate-related risks and opportunities are reflected in the terms of reference, mandates, role descriptions and other related policies applicable to that body(s) or individual(s); (ii) how the body(s) or individual(s) determines whether appropriate skills and competencies are available or will be developed to oversee strategies designed to respond to climate-related risks and opportunities; (iii) how and how often the body(s) or individual(s) is informed about climate-related risks and opportunities; (iv) how the body(s) or individual(s) takes into account climate-related risks and opportunities when overseeing the entity’s strategy, its decisions on major transactions and its risk management processes and related policies, including whether the body(s) or individual(s) has considered trade-offs associated with those risks and opportunities; and (v) how the body(s) or individual(s) oversees the setting of targets related to climate-related risks and opportunities, and monitors progress towards those targets (see paragraphs 33–36), including whether and how related performance metrics are included in remuneration policies (see paragraph 29(g)). (b) management’s role in the governance processes, controls and procedures used to monitor, manage and oversee climate-related risks and opportunities, including information about: (i) whether the role is delegated to a specific management-level position or management-level committee and how oversight is exercised over that position or committee; and (ii) whether management uses controls and procedures to support the oversight of climate-related risks and opportunities and, if so, how these controls and procedures are integrated with other internal functions.” | Unchanged Word for word the same in UK SRS S2 ¶6, and absent from Annex A — so the UK made no change. Read the ¶6 walkthrough. |
| ¶7 Avoid duplication with S1 | In preparing the ¶6 disclosures, avoid unnecessary duplication in accordance with IFRS S1 (¶B42(b)); where oversight of sustainability matters is integrated, give integrated governance disclosures rather than one set per risk. | Cross-reference only Same requirement, pointing to UK SRS S1 ¶B42(b) instead of IFRS S1. |
Strategy — ¶¶8–23
| IFRS S2 paragraph | What IFRS S2 requires | UK SRS S2 |
|---|---|---|
| ¶8 Strategy objective | To enable users to understand “an entity’s strategy for managing climate-related risks and opportunities”. | Unchanged Same wording. |
| ¶9 The five things users must understand | (a) the climate-related risks and opportunities (¶¶10–12); (b) their effects on the business model and value chain (¶13); (c) their effects on strategy and decision-making, including any transition plan (¶14); (d) their current and anticipated financial effects (¶¶15–21); and (e) the climate resilience of the strategy and business model (¶22). | Unchanged Same wording and the same cross-references. |
| ¶10 Climate-related risks and opportunities | The entity shall (a) describe the risks and opportunities that could reasonably be expected to affect its prospects; (b) say, for each risk, whether it is a physical or a transition risk; (c) specify the time horizon — short, medium or long term — over which each could affect it; and (d) explain how it defines those three horizons and how they link to its strategic planning horizons. | Unchanged Same four limbs. |
| ¶11 Information to use | Use “all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort”, including past events, current conditions and forecasts. | Unchanged Same wording. |
| ¶12 Industry-based disclosure topics | The entity “shall refer to and consider the applicability of” the industry-based disclosure topics in the Industry-based Guidance on Implementing IFRS S2. | Changed “Shall” becomes “may”: the entity may refer to and consider the Industry-based Guidance (Annex A). |
| ¶13 Business model and value chain | Disclose (a) the current and anticipated effects of climate-related risks and opportunities on the business model and value chain, and (b) where in the business model and value chain they are concentrated — for example, geographical areas, facilities and types of assets. | Unchanged Same wording. |
| ¶14 Strategy, decision-making and transition plans | (a) How the entity has responded, and plans to respond, in its strategy and decision-making, including how it plans to achieve its targets: (i) changes to the business model and resource allocation; (ii) direct mitigation and adaptation; (iii) indirect mitigation and adaptation; (iv) “any climate-related transition plan the entity has, including information about key assumptions used in developing its transition plan, and dependencies on which the entity’s transition plan relies”; and (v) how it plans to achieve targets under ¶¶33–36. (b) How it is resourcing those activities. (c) Quantitative and qualitative progress on plans disclosed in earlier periods. | Unchanged Same wording. ¶14(a)(iv) asks about a transition plan the entity has; neither standard requires one, and the DESNZ consultation on transition plan requirements has published no outcome. |
| ¶¶15–21 Financial position, performance and cash flows | Current and anticipated financial effects (¶15), in quantitative and qualitative terms, including risks with a significant risk of a material adjustment to carrying amounts within the next annual reporting period (¶16); a single amount or a range is allowed (¶17). Quantitative information may be omitted where effects are not separately identifiable, measurement uncertainty is too high or — for anticipated effects only — the skills, capabilities or resources are lacking (¶¶19–20), in which case the entity explains why and gives qualitative information instead (¶21). | Unchanged Same wording. |
| ¶22 Climate resilience and scenario analysis | “The entity shall use climate-related scenario analysis to assess its climate resilience using an approach that is commensurate with the entity’s circumstances.” It discloses (a) its resilience assessment at the reporting date and (b) how and when the analysis was done — the scenarios and their sources, key assumptions and the reporting period in which it was carried out. | Unchanged Same wording. No scenario is prescribed by either standard. |
| ¶23 Metrics that inform ¶¶13–22 | The entity “shall refer to and consider” both the cross-industry metric categories (¶29) and the industry-based metrics in the Industry-based Guidance (¶32). | Changed The cross-industry limb keeps “shall”; the industry-based limb becomes “may” (Annex A). |
Risk management — ¶¶24–26
| IFRS S2 paragraph | What IFRS S2 requires | UK SRS S2 |
|---|---|---|
| ¶¶24–26 Risk management | The objective (¶24), then the processes used to identify, assess, prioritise and monitor climate-related risks — including inputs, any use of scenario analysis, how nature, likelihood and magnitude are assessed, and changes from the previous period — and opportunities, and how far they are integrated into overall risk management (¶25). ¶26 repeats the ¶7 rule on avoiding duplication with IFRS S1. | Cross-reference only ¶¶24–25 are unchanged; ¶26 points to UK SRS S1 instead of IFRS S1. |
Metrics and targets — ¶¶27–37
| IFRS S2 paragraph | What IFRS S2 requires | UK SRS S2 |
|---|---|---|
| ¶¶27–28 Metrics and targets objective | The objective (¶27), then three limbs (¶28): cross-industry metrics (¶¶29–31), industry-based metrics (¶32) and targets (¶¶33–37). | Unchanged Same wording. |
| ¶29 Cross-industry metrics, including GHG emissions | Seven categories: (a) greenhouse gases — absolute gross Scope 1, 2 and 3 emissions in tonnes of CO₂e, measured under the Greenhouse Gas Protocol Corporate Standard (2004) unless a jurisdictional authority or exchange requires otherwise, with location-based Scope 2, the Scope 3 categories included, and financed emissions for asset management, commercial banking or insurance; (b) transition risks; (c) physical risks; (d) opportunities; (e) capital deployment; (f) internal carbon prices; and (g) remuneration. | Unchanged Same wording, including the ISSB’s December 2025 amendments to ¶29(a)(ii) and ¶29(a)(vi)(2). The one UK addition is in Appendix B: ¶B59A, on financed emissions reported for a different period (see below). |
| ¶¶29A–29C Category 15 limited to financed emissions | Added by the ISSB in December 2025: an entity may limit Scope 3 Category 15 to its financed emissions and may exclude derivatives, explaining what it treated as a derivative and what it excluded; if it includes Category 15, it gives the total and the financed-emissions subtotal. In IFRS S2 these December 2025 amendments are effective for periods beginning on or after 1 January 2027. | Unchanged Included in UK SRS S2 as issued. They are the ISSB’s amendments, not UK ones, and UK SRS S2 carries no effective date. |
| ¶32 Industry-based metrics | The entity “shall disclose industry-based metrics” and “shall refer to and consider” those in the Industry-based Guidance on Implementing IFRS S2. | Changed The duty to disclose industry-based metrics stays; referring to the Industry-based Guidance becomes “may” (Annex A). |
| ¶33 Climate-related targets | For each target the entity has set, and any it must meet by law or regulation: (a) the metric; (b) the objective; (c) the part of the entity it covers; (d) the period; (e) the base period; (f) milestones and interim targets; (g) absolute or intensity; and (h) how the latest international agreement on climate change informed it. | Unchanged Same eight items. |
| ¶34 Setting and reviewing targets | (a) Whether the target and its methodology were validated by a third party; (b) the review process; (c) the metrics used to monitor progress; and (d) any revisions, with reasons. | Unchanged Same wording. |
| ¶35 Performance against targets | Performance against each climate-related target, with an analysis of trends or changes. | Unchanged Same wording. |
| ¶36 Greenhouse gas emissions targets | For each GHG target: (a) the gases covered; (b) the Scopes covered; (c) gross or net — a net target needs its gross target disclosed separately; (d) whether a sectoral decarbonisation approach was used; and (e) planned use of carbon credits, including reliance on them, the verifying scheme, the type of credit and factors bearing on credibility and integrity. | Unchanged Same wording. |
| ¶37 Metrics used for targets | The entity “shall refer to and consider” cross-industry and industry-based metrics, including those in an applicable IFRS Sustainability Disclosure Standard. | Cross-reference only Keeps “shall”; the references become UK Sustainability Reporting Standards and UK SRS S1. |
Three body paragraphs change in substance, and each one softens a reference to the Industry-based Guidance: ¶12, ¶23 and ¶32.
Three more — ¶7, ¶26 and ¶37 — change only because they point to UK SRS instead of IFRS.
Everything else in ¶¶5–37 reads the same, which is why a disclosure drafted to IFRS S2 transfers to UK SRS S2 almost line for line.
The differences that matter more sit in the appendices: the effective date, the reliefs and ¶B59A, set out next.
Annex A
How UK SRS differs from IFRS S1 and S2
The government’s 2025 consultation proposed six categories of amendment to the ISSB baseline.
Two were not carried through unchanged — the GICS proposal was withdrawn because the ISSB removed GICS itself, and the climate-first relief proposal was replaced by removing its time limit altogether — and further provisions were added afterwards.
The authoritative map is Annex A of the UK government’s consultation response, published 25 February 2026, not a fixed count.
| Feature | IFRS S1/S2 | UK SRS S1/S2 |
|---|---|---|
| Effective date | 1 January 2024 | No fixed date in the Standard — any requirement would come from legislation or FCA rules |
| Delayed reporting (IFRS S1 ¶E4) | Permitted in the first annual period | Removed — must align with financial statements |
| Climate-first relief (IFRS S1 ¶E5 → UK SRS S1 ¶E3) | First annual period only | No time limit in the Standard |
| Scope 3 relief (IFRS S2 ¶C4(b) → UK SRS S2 ¶C4) | First annual period only | No time limit in the Standard |
| GHG Protocol methodology relief (IFRS S2 ¶C4(a) → UK SRS S2 ¶C3) | First annual period only | First annual period only — unchanged |
| SASB Standards and Industry-based Guidance (S1 ¶¶55(a), 58(a); S2 ¶¶12, 23, 32) | "Shall refer to" | "May refer to" |
| GICS reference (S2) | Removed by the ISSB, December 2025 | Not present — inherited from the amended IFRS S2 baseline |
| Financed emissions period mismatch (UK SRS S2 ¶B59A) | No equivalent | Must explain why, the approach used, and a plan with a timeline |
| Compliance statement (UK SRS S1 ¶¶73A–73B) | No equivalent | Climate-only reporters cannot assert S1 compliance; reliefs subject to UK law and FCA rules |
No fixed effective date
IFRS: Effective for annual reporting periods beginning on or after 1 January 2024.
UK SRS: No fixed effective date in the standards themselves.
Any required application is set through separate UK legislation or regulation.
The FCA’s final rules set comply-or-explain application for in-scope listed companies from 1 January 2027 — a timeline set by FCA rules, not by the standards; FCA CP26/5 had proposed mandatory application.
Delayed reporting relief removed
IFRS: Paragraph E4 of IFRS S1 permitted delayed publication of sustainability disclosures relative to the financial statements during a transition period.
UK SRS: The relief has been removed; sustainability disclosures are published at the same time as the related financial statements.
The removed wording is at IFRS S1 ¶E4.
That reflects the UK’s emphasis on integrated reporting, giving sustainability information equal prominence and timing with financial reporting.
Climate-first relief — time limit removed
IFRS: In its first annual reporting period, an entity may disclose only climate-related information while it builds non-climate data.
UK SRS: UK SRS S1 ¶E3 retains the relief but removes the time limit entirely — no “first annual reporting period”, and no “two years”.
The 2025 consultation had proposed extending the relief to two years; the published Standard went further.
Any future limit will be set by legislation or FCA rules, not by the Standard.
An entity using the relief cannot assert compliance with UK SRS S1 while doing so (¶73A), though it can still assert compliance with UK SRS S2.
SASB Standards reference softened
IFRS: Entities “shall refer to and consider” the SASB Standards when identifying sustainability-related risks and opportunities.
UK SRS: “May refer to and consider” — SASB application is permissive rather than required.
UK entities gain flexibility in choosing industry-based guidance while SASB remains a recognised resource.
The same softening applies to the Industry-based Guidance references in UK SRS S2 ¶¶12, 23 and 32; ¶37 keeps “shall”.
Annex A, continued
GICS, untimed reliefs, B59A and compliance statements
GICS — an ISSB change, not a UK one
IFRS: The ISSB removed the Global Industry Classification Standard reference from IFRS S2 itself in December 2025.
UK SRS: The UK’s proposed removal was withdrawn as no longer necessary; “GICS” appears nowhere in the final UK SRS S2.
This is not a UK-specific difference from the current IFRS S2 baseline; both standards now share it.
The ISSB’s December 2025 amendments permit classification systems other than GICS for financed emissions.
Some reliefs untimed, one still timed
IFRS: Each of these reliefs applies in the first annual reporting period only.
UK SRS: S1’s climate-first relief (¶E3) and S2’s Scope 3 relief (¶C4) carry no time limit; S2’s GHG Protocol methodology relief (¶C3) keeps “in the first annual reporting period”.
The consultation response confirms the asymmetry was deliberate.
For listed companies the FCA’s final rules now set the limits: one year for Scope 3 and two years for S1 non-climate matters; any other limit would come from legislation.
Paragraph B59A — the one place the UK asks for more
IFRS: No equivalent paragraph.
UK SRS: Where financed emissions cannot reliably be estimated for the same period as the financial statements, disclose why, the approach, inputs and assumptions used, and a plan with a timeline to align the periods.
Every other difference is a relaxation.
A group reporting under both regimes has one UK-only disclosure duty to add for asset management, commercial banking or insurance activities.
Compliance statements — ¶¶73A and 73B
IFRS: No equivalent paragraphs.
UK SRS: ¶73A: an entity using the E3 relief may not assert UK SRS S1 compliance and must disclose its use of the relief, but may assert UK SRS S2 compliance if it discloses the reliefs used.
¶73B makes the compliance-statement provisions (¶¶72–73A) subject to any Companies Act, FCA or other UK rules that later require the Standards to be applied — the same override ¶¶E5 and C6 apply to the reliefs.
Groups
Implications for multinational groups
For multinational groups, the substantial baseline alignment between UK SRS and IFRS S1/S2 should enable broadly consistent reporting approaches.
The adjustments cluster around dates, reliefs, SASB and one added financed emissions duty — not around the disclosure pillars themselves.
Because ISSA (UK) 5000 adopts the IAASB text, assurance methodologies should be directly comparable across jurisdictions.
| Area | Consideration |
|---|---|
| Data infrastructure | The same data systems should support both regimes, adjusted for the Annex A differences. |
| Governance processes | The four-pillar structure is consistent, so the same oversight, risk management and target-setting frameworks apply. |
| Industry guidance | UK entities have more latitude on SASB, but may use it for consistency with international subsidiaries. |
| Assurance approach | ISSA (UK) 5000, issued for voluntary use, adopts the text of the IAASB’s ISSA 5000. |
| Timeline coordination | The FCA’s 2027 comply-or-explain start against IFRS S1/S2’s 2024 effective date; voluntary use allows early alignment. |
EU
EU comparison and double materiality
UK SRS stay close to IFRS S1/S2, but differ significantly from the EU’s Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS).
| Aspect | UK SRS and ISSB | CSRD and ESRS |
|---|---|---|
| Materiality | Single (financial) materiality, judged by influence on the decisions of primary users (UK SRS S1 ¶18), by reference to cash flows, access to finance or cost of capital (¶3) | Double materiality: financial materiality plus impact materiality — the entity’s effects on people and the environment |
| Audience | Primary users of financial statements — investors, lenders and other creditors | A wider stakeholder audience, including workers, communities and civil society |
| Sector requirements | SASB Standards referenced on a permissive basis | No sector-specific ESRS: Directive (EU) 2026/470 deleted the Commission’s power to adopt them |
For UK entities with EU subsidiaries subject to CSRD, this creates a genuine dual reporting challenge that goes well beyond the relatively minor differences between UK SRS and IFRS S1/S2.
Adoption
Regional adoption patterns
The IFRS Foundation tracks adoption of IFRS S1 and S2 across major economies.
Its own count, at June 2026, is that over 40 jurisdictions have decided to use or are taking steps to introduce the ISSB Standards, with requirements already in effect in 19 of them by February 2026 — though the mechanism, scope and start date differ in each.
The UK is not among the jurisdictions in which the standards are already in effect.
The Foundation listed the UK as a snapshot — a jurisdiction whose approach is still in progress — rather than as a finalised profile, before the FCA’s final rules.
UK SRS S1 and S2 are available for voluntary use, and the FCA’s final rules of 30 September 2026 require listed issuers in scope to report against them on a comply-or-explain basis from 2027, settling the CP26/5 consultation.
Several other jurisdictions are evaluating IFRS S1/S2 as part of their disclosure frameworks.
UK entities operating globally will increasingly meet IFRS S1/S2 as the international baseline, which makes the alignment a strategic advantage.
Planning
Implementation planning
For UK entities preparing for the FCA’s comply-or-explain rules, the relationship with IFRS S1/S2 creates several planning opportunities.
- Early voluntary adoption — begin reporting under UK SRS using the IFRS S1/S2 guidance already available, adapting for the Annex A differences.
- International practice — learn from jurisdictions where IFRS S1/S2 are already mandatory, while recognising the UK modifications.
- Technology — platforms that support IFRS S1/S2 should need relatively minor adjustment for UK SRS.
- Advisers — firms with IFRS S1/S2 experience should be well placed to support UK SRS implementation.
- Assurance readiness — an engagement under ISSA (UK) 5000 is performed to the same requirements as one under ISSA 5000.
For UK-specific implementation guidance, see the UK SRS compliance guide, the editorial UK SRS timeline, and the individual guides to UK SRS S1 and UK SRS S2.
For multinational groups, consider a group-wide sustainability disclosure policy built on the IFRS S1/S2 foundation, with jurisdiction-specific annexes for local amendments such as those in UK SRS.
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.
- IFRS FoundationIFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information
The international baseline for general sustainability-related financial disclosures. Effective 1 January 2024.
- IFRS FoundationIFRS S1 — full text, paragraphs 1–86 and Appendices A–E (free HTML)
The IFRS S1 wording UK SRS S1 departs from, including ¶E4 (delayed reporting).
- IFRS FoundationIFRS S2 Climate-related Disclosures
The international baseline for climate-related disclosures. Effective 1 January 2024.
- IFRS FoundationIFRS S2 Climate-related Disclosures — December 2025 text (free HTML)
The paragraph-numbered ISSB text, ¶¶1–37, read side by side with UK SRS S2 for the paragraph-by-paragraph guide.
- IFRS FoundationISSB issues targeted amendments to IFRS S2 (11 December 2025)
The Category 15 limitation and the removal of the GICS requirement; effective in IFRS S2 for periods beginning on or after 1 January 2027.
- Department for Business and TradeUK SRS S1 General Requirements — final standard (PDF)
Published 25 February 2026. ¶¶E3, 73A, 73B.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — final standard (PDF)
Published 25 February 2026. ¶¶5–37, B59A, C3, C4, compared paragraph by paragraph with IFRS S2.
- Department for Business and TradeUK SRS consultation response (PDF), Annex A
Annex A maps every UK difference from IFRS S1 and S2; where a requirement is not in its table, there is no difference.
- Department for Business and TradeUK Sustainability Reporting Standards — GOV.UK guidance
The standards are available for voluntary use by any entity that chooses to do so.
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
Updated 26 February 2026. Describes each UK standard as "largely the same" as its IFRS counterpart, and the untimed reliefs as usable indefinitely by voluntary reporters.
- Financial Reporting CouncilAssurance standards — including ISSA (UK) 5000
ISSA (UK) 5000, issued 12 November 2025 for voluntary use; it adopts the text of the IAASB’s ISSA 5000.
- 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 for UKLR 6, 14, 15, 16 and 22, from accounting periods starting on or after 1 January 2027; one-year Scope 3 and two-year S1 non-climate reliefs (¶3.14).
- Financial Conduct AuthorityCP26/5: Sustainability disclosures
The consultation PS26/19 finalises; it proposed UK SRS reporting for UKLR 6, 16 and 22 issuers from 1 January 2027.
- GHG ProtocolA Corporate Accounting and Reporting Standard
The 2004 standard IFRS S2 ¶29(a)(ii) and UK SRS S2 ¶29(a)(ii) both require greenhouse gas emissions to be measured under.
- Department for Energy Security and Net ZeroClimate-related transition plan requirements — consultation
Ran 25 June to 17 September 2025; no outcome published as at 26 September 2026.
- IFRS FoundationUse of IFRS Sustainability Disclosure Standards by jurisdiction
Jurisdictional profiles and snapshots; the UK is listed as a snapshot, not a profile.
- IFRS FoundationISSB update to the joint CMAC–GPF meeting, 18 June 2026 (Agenda paper 1b)
“Over 40 jurisdictions have already decided to use or are taking steps to introduce ISSB Standards.”
- IFRS FoundationJurisdictional Readiness Assessment Guide and tool (news, February 2026)
“Requirements in 19 jurisdictions have already come into effect.”
- EUR-LexDirective (EU) 2026/470 (Omnibus I), Art 2(6)(a)
Deletes the Commission’s empowerment to adopt sector-specific ESRS.
Continue reading
Read next
What is UK SRS?
The UK Sustainability Reporting Standards and their origins.
UK SRS S1 — general requirements
The general sustainability disclosure requirements and the climate-first relief.
UK SRS S2 — climate-related disclosures
The climate standard, including the governance requirement in paragraph 6.
UK SRS compliance guide
The compliance programme for UK-specific requirements.