Last reviewed · 8 May 2026 · Independent UK SRS Reference
Last reviewed · 8 May 2026 · Independent UK SRS Reference

UK SRS stands for UK Sustainability Reporting Standards — the UK's domestically endorsed sustainability disclosure framework, based on the global baseline standards issued by the International Sustainability Standards Board (ISSB). UK SRS consists of two standards:

  • UK SRS S1General Requirements for Disclosure of Sustainability-related Financial Information (the overarching framework)
  • UK SRS S2Climate-related Disclosures (climate-specific requirements)

The standards were published by the Department for Business and Trade (DBT) on 25 February 2026 and are currently available for voluntary use by any UK entity that chooses to adopt them. Mandatory application for in-scope listed issuers is proposed under FCA Consultation Paper CP26/5 from accounting periods beginning on or after 1 January 2027, subject to the FCA's final policy statement expected in autumn 2026.

≈500 companies
UK-listed companies proposed in scope of mandatory UK SRS S2 from 1 January 2027
Sustainability Reporting Standards · Scope decision aid

Am I in scope of UK SRS?

A practical decision tree walking through the rules in CP26/5, the Companies Act, and the proposed mandatory framework. UK SRS itself is available for voluntary adoption by any UK entity — the question of mandatory application is jurisdiction-specific.

Last verified 12 May 2026 · Subject to FCA Policy Statement on CP26/5

Question 1
Is the entity listed on the UK Main Market?
i.e. admitted to one of the categories under the UK Listing Rules
No, AIM-listed or unlisted
Yes, Main Market
Question 2
Which UKLR category?
The category determines the rules under FCA CP26/5
UKLR 6, 16, 22
Proposed mandatory UK SRS S2 from 1 Jan 2027
For Commercial (UKLR 6), Non-equity (UKLR 16), and Transition (UKLR 22) listed companies, FCA CP26/5 proposes mandatory UK SRS S2 climate disclosures and comply-or-explain UK SRS S1 disclosures from accounting periods beginning on or after 1 January 2027. Subject to FCA Policy Statement (autumn 2026). Scope 3 one-year deferral; S1 two-year optional deferral.
UKLR 14, 15
Flexible — disclose home-jurisdiction requirements
For Secondary listing (UKLR 14) and Depositary Receipts (UKLR 15), the FCA proposes a flexible approach. Companies would not apply UK SRS in full but would disclose the climate and sustainability reporting requirements applicable in their primary listing location, plus any voluntary standards adopted.
If not Main Market listed
Is the entity listed on AIM?
AIM is an LSE-operated market governed by AIM Rules, not the UKLR
Yes, AIM-listed
Out of CP26/5
Not in scope of FCA's proposed mandatory rules
AIM is operated by the London Stock Exchange under the AIM Rules for Companies — it is not a UKLR category. AIM companies are out of scope of CP26/5. AIM Rules may impose their own sustainability disclosure requirements; AIM companies may also voluntarily adopt UK SRS at any time.
No, unlisted
Question 3
Public Interest Entity under Companies Act?
Banks, insurers, large entities of public significance
PIE — Yes
s414CB(1)–(5) climate disclosures apply
PIEs must include a non-financial and sustainability information statement in the Strategic Report. Under s414CB(2A), the Government has designated UK SRS S2 as a national reporting framework — using UK SRS S2 satisfies the climate-related disclosure requirements. Voluntary adoption strongly recommended.
PIE — No · SECR-obligated
Voluntary adoption available · monitor MCR consultation
Large unlisted companies meeting the SECR two-of-three test (£36m turnover, £18m balance sheet, 250 employees) continue under SECR. UK SRS is voluntary today but the Modernising Corporate Reporting consultation may extend mandatory application to economically significant private companies — likely earliest 2028 reporting periods.
No PIE · No SECR
Voluntary adoption available
UK SRS is available for voluntary use by any UK entity — including small businesses, charities, LLPs and partnerships. Voluntary adoption is all-or-nothing for the standard adopted (S1 or S2) and reliefs can be used indefinitely until any future mandatory rules apply.

Outcome categories

Proposed mandatory under CP26/5
Flexible (disclose-home-jurisdiction)
Watch for further consultation
Voluntary adoption only
Out of CP26/5 scope

Origins and development

UK SRS originates from the International Sustainability Standards Board (ISSB), established at COP26 in Glasgow in November 2021 by the IFRS Foundation as a global standard-setter for sustainability-related financial disclosures. The ISSB published its inaugural two standards — IFRS S1 and IFRS S2 — in June 2023, and revised IFRS S2 in December 2025.

The UK endorsement process was led by the Department for Business and Trade (DBT) with two specialist committees:

  • The UK Sustainability Disclosure Technical Advisory Committee (TAC) — convened to assess the technical aspects of the IFRS standards for UK endorsement. The TAC issued its initial recommendations in December 2024, recommending that IFRS S1 and IFRS S2 be endorsed for UK use with some minor amendments. The TAC met again in January 2026 to assess the ISSB's December 2025 amendments.
  • The UK Sustainability Disclosure Policy and Implementation Committee (PIC) — convened to consider implementation matters and stakeholder views.

DBT consulted on the exposure drafts of UK SRS S1 and UK SRS S2 from 25 June 2025 to 17 September 2025, alongside a parallel consultation on the development of an oversight regime for sustainability assurance. The consultation received 209 responses.

Timeline Summary

From ISSB establishment at COP26 (November 2021) to UK SRS publication (February 2026) took just over four years, with the UK endorsement process itself taking approximately 18 months from first TAC meeting to final publication.

The six UK-specific amendments to IFRS S1 and S2

UK SRS preserves the substance of the ISSB standards but contains six UK-specific amendments developed through the endorsement process:

Amendment 1 — Removal of delayed reporting relief (S1). IFRS S1 permitted entities to publish sustainability-related disclosures up to nine months after the financial statements in the first year of application. UK SRS S1 removes this relief, requiring sustainability disclosures to be published at the same time as the financial statements. This ensures connectivity between financial and non-financial reporting.

Amendment 2 — Extended "climate-first" relief (S1). IFRS S1 permitted a one-year transition relief allowing entities to focus on climate-related disclosures in their first year of application. UK SRS S1 extends this relief to two years, giving entities additional time to develop disclosures on wider non-climate sustainability topics.

Amendment 3 — Alternative industry classification (S2). IFRS S2 originally required commercial banking entities reporting Scope 3 financed emissions to use the Global Industry Classification Standard (GICS). The ISSB amended this in December 2025 to permit any "internationally recognised industry classification" — and UK SRS S2 incorporates this amendment.

Amendment 4 — Removal of effective date clauses. IFRS S1 and S2 each include statements specifying their effective dates. UK SRS S1 and S2 remove these effective date clauses entirely; effective dates will instead be set by the FCA (via Listing Rules) or UK government (via Companies Act regulation) when mandatory reporting is introduced.

Amendment 5 — SASB "shall" changed to "may". IFRS S1 and S2 contain a requirement that entities "shall refer to and consider the applicability of" the Sustainability Accounting Standards Board (SASB) industry-based metrics. UK SRS S1 and S2 change "shall" to "may" — providing greater flexibility and recognising that SASB materials may not be relevant to all UK entities.

Amendment 6 — Transition reliefs tied to mandatory use. Transition reliefs in IFRS S1 and S2 have been amended in UK SRS to be explicitly linked to mandatory (rather than voluntary) reporting periods. The reliefs will be available in the first year an entity is required to comply, and any time limits or conditions will be set by the relevant UK regulator or legislation.

The four-pillar disclosure framework

UK SRS follows the four-pillar disclosure framework that originated with the Task Force on Climate-related Financial Disclosures (TCFD) and was adopted by the ISSB for IFRS S1 and S2. Both UK SRS standards require entities to provide information across:

Governance. Disclosures about the governance processes, controls, and procedures the entity uses to monitor, manage, and oversee sustainability-related (S1) or climate-related (S2) risks and opportunities. This includes board-level oversight, management's role, and the integration of sustainability oversight into existing governance structures.

Strategy. Disclosures about the sustainability-related (S1) or climate-related (S2) risks and opportunities that could reasonably be expected to affect the entity's prospects, including its business model, value chain, financial position, financial performance, cash flows, and access to finance over the short, medium, and long term. UK SRS S2 also requires scenario analysis to assess climate resilience under different plausible future states.

Risk management. Disclosures about the processes the entity uses to identify, assess, prioritise, and monitor sustainability-related (S1) or climate-related (S2) risks and opportunities, including how these processes are integrated into the entity's overall risk management framework.

Metrics and targets. Disclosures of the metrics used to measure and manage sustainability-related (S1) or climate-related (S2) performance, including any targets set by the entity. UK SRS S2 requires disclosure of Scope 1, 2, and 3 greenhouse gas emissions; cross-industry metrics covering transition risks, physical risks, opportunities, capital deployment, internal carbon prices, and remuneration; and industry-based metrics where available.

What UK SRS S1 covers (the general framework)

UK SRS S1 establishes the overarching framework for sustainability-related financial disclosures. Key elements:

  • Single materiality (or "investor materiality"). Disclosures focus on sustainability-related risks and opportunities that could reasonably be expected to affect the entity's prospects — its financial position, financial performance, cash flows, access to finance, or cost of capital. This differs from the "double materiality" approach used in some other frameworks (notably the EU Corporate Sustainability Reporting Directive).
  • Connectivity with financial statements. UK SRS disclosures must be provided at the same time and for the same period as the financial statements; the reporting entity must be the same as for consolidated financial statements; and the sustainability disclosures must be connected to the financial statements.
  • General-purpose financial reporting. UK SRS disclosures form part of the entity's general-purpose financial reports, alongside the financial statements.
  • Forward-looking information. Disclosures must include forward-looking information about sustainability-related risks and opportunities that could reasonably be expected to affect the entity's prospects.
  • Industry-based information. Entities may (not shall, under UK SRS) refer to SASB industry-based metrics where relevant.

What UK SRS S2 covers (the climate standard)

UK SRS S2 sets out the climate-specific disclosure requirements. Key elements:

  • Mandatory scenario analysis using scenarios appropriate to the entity's circumstances. Many UK-listed companies are expected to use scenarios derived from the Network for Greening the Financial System (NGFS) or the International Energy Agency (IEA).
  • Scope 1, 2, and 3 GHG emissions disclosure using the GHG Protocol Corporate Standard. Scope 2 location-based emissions are mandatory; market-based emissions may also be disclosed.
  • Cross-industry metrics covering: transition risks; physical risks; climate-related opportunities; capital deployment toward climate-related risks and opportunities; internal carbon prices; and remuneration linkage to climate-related considerations.
  • Industry-based metrics where available — UK SRS S2 references SASB industry standards as a permissive resource (not mandatory).
  • Financed emissions for entities in asset management, commercial banking, and insurance activities.
  • Carbon credits disclosure where the entity uses carbon credits to meet net emissions targets.
  • Transition reliefs including: no requirement for comparative information in the first year; alternative GHG measurement method in the first year; and Scope 3 emissions deferral in the first year.

Who must comply with UK SRS

UK SRS is currently available for voluntary use by any UK entity. There is no current mandatory application.

Proposed mandatory scope (FCA CP26/5). The FCA's Consultation Paper CP26/5, published 30 January 2026 and closed 20 March 2026, proposes that UK SRS S2 climate disclosures become mandatory for in-scope listed issuers from accounting periods beginning on or after 1 January 2027. The proposed scope covers approximately 500 companies across five UK Listing Rules (UKLR) categories:

  • UKLR 6 — Commercial companies (the largest category)
  • UKLR 14 — Secondary listings
  • UKLR 15 — Depositary receipts
  • UKLR 16 — Non-equity shares
  • UKLR 22 — Transition category

UKLR 11 (closed-ended investment funds) and UKLR 12 (open-ended investment companies) are out of scope of CP26/5.

Under CP26/5 proposals:

  • UK SRS S2 climate disclosures: mandatory from accounting periods beginning 1 January 2027
  • Scope 3 emissions within S2: comply-or-explain with an optional one-year deferral
  • UK SRS S1 wider sustainability disclosures: comply-or-explain from 1 January 2027 with an optional two-year deferral (so latest mandatory application from 1 January 2029)
  • Transition plan disclosure: must state whether and where a transition plan has been published
  • Assurance disclosure: must state whether voluntary assurance has been obtained (no mandatory assurance proposed at this stage)

The FCA's final Policy Statement is expected in autumn 2026.

Private companies and beyond. The UK government's Modernising Corporate Reporting (MCR) programme, announced in October 2025, is considering extending UK SRS requirements to economically significant private companies and limited liability partnerships via Companies Act 2006 amendments. A consultation on the MCR programme is expected later in 2026.

Implementation timeline

DateMilestone
November 2021ISSB established at COP26 in Glasgow
June 2023ISSB publishes IFRS S1 and IFRS S2
December 2024UK Sustainability Disclosure TAC issues initial recommendations
25 June 2025DBT publishes exposure drafts of UK SRS S1 and S2 for consultation
17 September 2025UK SRS consultation closes (209 responses received)
12 November 2025FRC publishes ISSA (UK) 5000 — UK sustainability assurance standard
December 2025ISSB publishes Amendments to clarify IFRS S2
30 January 2026FCA publishes CP26/5 — proposed mandatory UK SRS for listed companies
25 February 2026DBT publishes final UK SRS S1 and UK SRS S2 — available for voluntary use
20 March 2026FCA CP26/5 consultation closes
Autumn 2026FCA Policy Statement expected (confirming mandatory scope and timeline)
15 December 2026ISSA (UK) 5000 becomes effective for periods beginning on or after this date
1 January 2027Proposed mandatory application of UK SRS S2 for in-scope listed issuers
Spring 2028First mandatory UK SRS S2 reports published (for December 2027 year-ends)

How UK SRS interacts with existing UK reporting

UK SRS does not exist in isolation. Several existing UK reporting regimes overlap with or relate to UK SRS:

TCFD-aligned disclosures. UK-listed companies have been required to make Task Force on Climate-related Financial Disclosures (TCFD)-aligned disclosures under FCA Listing Rules since 2022. UK SRS S2 will replace the current TCFD-aligned regime for in-scope listed issuers from accounting periods beginning 1 January 2027 (subject to the FCA Policy Statement). UK SRS S2 covers the same four pillars as TCFD but adds quantitative cross-industry metrics, mandatory Scope 1/2 emissions, and Scope 3 disclosure requirements.

Companies Act 2006 climate-related disclosures. Certain large UK companies and LLPs are required under section 414CB of the Companies Act 2006 to disclose climate-related financial information within their Strategic Report. The UK government has confirmed that public companies reporting in accordance with UK SRS S2 will be treated as meeting these existing statutory climate disclosure requirements — providing a pathway to streamline reporting rather than maintaining parallel disclosures.

SECR (Streamlined Energy and Carbon Reporting). SECR remains a separate regime under SI 2018/1155, requiring annual energy and carbon disclosure in the Directors' Report. The Department for Energy Security and Net Zero (DESNZ) has committed to "consider how energy and emissions data reported by an entity using UK SRS interacts with the SECR requirements, with a view to reducing unnecessary duplication where possible". No rationalisation has been confirmed; organisations should plan for full compliance with both regimes separately.

Section 463 safe harbour. Where UK SRS disclosures are included in the Strategic Report, the protective provisions of section 463 of the Companies Act 2006 automatically apply, limiting directors' liability for compensation in respect of untrue or misleading statements. The DBT's February 2026 consultation response explicitly confirmed this safe harbour applies to UK SRS disclosures.

How UK SRS differs from the global ISSB baseline

UK SRS preserves the substance of IFRS S1 and IFRS S2 while making six UK-specific amendments (covered above). For UK entities reporting under UK SRS:

  • Disclosures are broadly comparable with disclosures under IFRS S1 and IFRS S2 in other jurisdictions
  • An entity reporting under UK SRS can generally make a statement that its disclosures comply with IFRS S1 and IFRS S2, subject to specific disclosure where the climate-first relief is used
  • More than 40 jurisdictions are adopting ISSB-aligned standards, supporting international comparability and reducing the burden for multinational reporters

Where UK SRS diverges from IFRS S1 and S2 (the six amendments), the divergence is designed to fit UK market conditions and regulatory framework. For multi-jurisdictional reporters, the practical differences are typically manageable through disclosure design.

Preparing for UK SRS

Whether mandatory application arrives in 2027 or later, voluntary adoption now offers clear strategic advantages: longer time to develop data infrastructure, opportunities for capability development, and stakeholder signalling. Practical preparation steps:

1. Map existing TCFD-aligned disclosures against UK SRS S2. For listed companies, the gap is typically in cross-industry metrics, quantitative financial impact, and Scope 3 emissions. Document where existing TCFD disclosures already meet UK SRS S2 requirements.

2. Build Scope 3 emissions data infrastructure. Scope 3 is the longest-lead-time work for most entities. Supplier engagement, data quality, and category prioritisation all take 12-18 months. The CP26/5 one-year transition relief and ongoing comply-or-explain basis provide some flexibility but do not remove the underlying data challenge.

3. Develop or upgrade climate scenario analysis. UK SRS S2 requires scenario analysis. Most entities will use NGFS or IEA scenarios as a starting point. The analysis should reflect the entity's specific business model, geography, and exposure.

4. Strengthen governance and risk management integration. UK SRS requires explicit board-level oversight, management responsibility, and integration into existing risk management processes. Document existing governance structures and identify gaps.

5. Engage assurance providers early. Voluntary assurance under ISSA (UK) 5000 is available from late 2026. Even where assurance is not mandatory, the direction of travel under the FCA's proposals and global ISSB-aligned regimes is towards mandatory assurance over time. Building assurance-ready data infrastructure now is cost-effective.

6. Monitor the FCA Policy Statement and MCR consultation. The FCA's autumn 2026 Policy Statement will confirm or amend the mandatory scope and timeline under CP26/5. The MCR programme consultation later in 2026 will indicate the direction for private companies. Both shape the planning horizon.