Scope Assessment · Who Must Comply
Who must comply with UK SRS
Who must comply with UK SRS is now settled for listed companies: the FCA’s final rules (PS26/19, 30 September 2026) put companies listed in UKLR 6, 14, 15, 16 and 22 on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
They finalise CP26/5, which had proposed mandatory UK SRS S2 for fewer categories; for every other UK entity the standards remain voluntary.
The Modernising Corporate Reporting consultation of 7 September 2026 makes no proposal for private companies.
The short answer
Listed companies, on comply or explain
Who must comply with UK SRS has a short answer: listed companies in five UK Listing Rules categories, on a comply-or-explain basis, from accounting periods beginning on or after 1 January 2027.
The FCA’s final rules (PS26/19, 30 September 2026) set that scope, with first reporting in 2028.
Comply or explain applies across the UK SRS, S2 included: the consultation had proposed making UK SRS S2 mandatory, and the final rules do not.
Any other UK entity may choose to report against UK SRS S1 or UK SRS S2, in whole or in part, and none is required to.
For companies outside the listing regime, the Government has said only that it will consider how UK SRS should be reflected in the Companies Act 2006, as part of the Modernising Corporate Reporting programme.
The UK SRS standards those categories are being brought into are set out in full on our primary reference site.
UK SRS S1 and S2 were published for voluntary use.
The FCA’s final rules apply them to listed companies in scope on a comply-or-explain basis — report, or explain why not.
Decision path
Where does your company fall?
Start with one question — is the company on the FCA’s Official List, and in which UK Listing Rules category? — and the rest follows.
UK SRS, comply or explain, from 1 January 2027
Commercial companies, non-equity and non-voting equity shares, and the transition category.
UK SRS S1 and S2 on a comply-or-explain basis, with a one-year Scope 3 relief and a two-year S1 non-climate relief.
UK SRS, comply or explain, from 1 January 2027
Secondary listings and depositary receipts.
In scope of the final rules on the same basis; the consultation had proposed only a statement of home-jurisdiction requirements.
Excluded by name
Closed-ended investment funds, open-ended investment companies, shell companies, debt and debt-like securities, securitised derivatives, and warrants, options and other miscellaneous securities.
Voluntary — no proposal
Any UK entity outside the listed perimeter may adopt UK SRS voluntarily, in whole or in part.
No government document proposes a threshold or a date for private companies.
Now
The current position: voluntary, available to all
The Department for Business and Trade published the final UK SRS S1 and UK SRS S2 on 25 February 2026.
Both standards are available for immediate voluntary use by any UK entity.
The DBT consultation response confirms that an entity may apply UK SRS “in whole or in part, as they see fit” — there is no minimum scope of application for voluntary reporters.
The standards do, however, require an entity claiming compliance to apply UK SRS S1 and UK SRS S2 together where both are relevant.
The respondent profile explains why voluntary adoption is concentrated among entities already carrying climate-related reporting obligations.
GOV.UK tracks the standards’ development on its UK SRS guidance hub.
Who answered the DBT consultation
Listed companies
UK SRS scope from 1 January 2027: the FCA’s final rules
The FCA published CP26/5 on 30 January 2026, and the consultation closed on 20 March 2026.
Its final rules, PS26/19, followed on 30 September 2026 — and changed both the basis and the scope the consultation had proposed.
| UKLR category | Who it covers | Final treatment (PS26/19) |
|---|---|---|
| Commercial companies (UKLR 6) | The largest category — commercial issuers with equity shares admitted to the Official List | UK SRS, comply or explain |
| Non-equity and non-voting equity shares (UKLR 16) | Issuers of non-equity instruments admitted under chapter 16 | UK SRS, comply or explain |
| Transition category (UKLR 22) | Companies placed there after the 2024 listing regime overhaul — broadly the former standard listing segment | UK SRS, comply or explain |
| International commercial companies secondary listing (UKLR 14) | Issuers with a primary listing outside the UK and a secondary UK listing | UK SRS, comply or explain (CP26/5 had proposed a signposting statement only) |
| Depositary receipts (UKLR 15) | Depositary receipts representing equity shares of issuers based outside the UK | UK SRS, comply or explain (CP26/5 had proposed a signposting statement only) |
All five categories report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
That basis covers every category of disclosure, UK SRS S2 included, with a one-year Scope 3 relief and a two-year UK SRS S1 non-climate relief.
The Policy Statement gives no total count of companies; CP26/5, the consultation, estimated that around 600 listed companies would be affected.
UKLR 14 and 15: now in scope
CP26/5 had proposed that companies with a primary listing outside the UK would not report under UK SRS directly.
It would have had them disclose the climate and sustainability reporting standards that apply in their home jurisdiction and signpost where those disclosures can be found.
The final rules did not adopt that: secondary listings and depositary receipts report against UK SRS on a comply-or-explain basis too.
For how this falls on companies incorporated abroad, see UK SRS for overseas companies.
Reliefs
The transitional reliefs
Two reliefs are built into UK SRS itself — the climate-first relief in UK SRS S1 paragraph E3 and the Scope 3 relief in UK SRS S2 paragraph C4 — and neither carries a time limit in the final standards.
The one-year and two-year windows are set by the FCA’s final rules (PS26/19 ¶3.14), which fix how long an in-scope company may use each relief.
Both are optional: a company chooses whether to use them.
A company using a relief must state that it is doing so, and “no further explanation” is required during the relief period (¶3.20).
A company already disclosing Scope 3 may carry on; the consultation said its rules “would not prevent this” (CP26/5 paragraph 8.13).
Scope 3 emissions: one-year relief
An in-scope company may use one year’s non-disclosure of Scope 3 under UK SRS S2.
After that year, Scope 3 is on the same comply-or-explain basis as every other UK SRS disclosure: disclose it in accordance with UK SRS S2 paragraph 29(a), or explain why not.
Scope 3 does not become mandatory at any point under the final rules.
See scope 3 under UK SRS.
UK SRS S1 non-climate disclosures: two-year relief
An in-scope company may use two years’ non-disclosure of UK SRS S1 non-climate matters.
After the relief, non-climate reporting runs on the same comply-or-explain basis as everything else.
Where a company has identified non-climate sustainability risks or opportunities that could reasonably be expected to affect its prospects, it must then disclose them or explain why not.
The scope, the comply-or-explain basis and the relief periods above are the FCA’s final rules.
Plan to that timetable: the first accounting periods begin on 1 January 2027.
The reliefs in the final rules
- 30 Sep 2026FCA final rules published
PS26/19: comply or explain across the UK SRS.
- 1 Jan 2027Comply or explain begins
Accounting periods starting on or after; both reliefs available.
- 1 yearScope 3 relief
Non-disclosure of Scope 3 under UK SRS S2, stated as used.
- 2 yearsS1 non-climate relief
Non-disclosure of UK SRS S1 non-climate matters, stated as used.
Source: FCA PS26/19 ¶3.12, ¶3.14, ¶3.20
Often misreported
Transition plans and assurance: what the FCA is not requiring
Both often appear in commentary as though they were already in scope.
Transition plans
The FCA’s position in CP26/5 was that mandating climate-related transition plans is a matter for Government policy.
Under the final rules, in-scope companies disclose in the annual report whether they have a climate-related transition plan and, if so, where it can be found (PS26/19 ¶2.37).
Companies that produce one may wish to refer to the IFRS Foundation’s educational material on transition plan disclosure.
Assurance
The FCA’s final rules do not require third-party assurance over UK SRS disclosures; where it is obtained, the company names the provider, which disclosures were assured and which assurance standards were used (PS26/19 ¶2.45).
The FRC published ISSA (UK) 5000 on 12 November 2025 as the UK assurance standard for sustainability disclosures, but its use is voluntary unless mandated separately.
The Modernising Corporate Reporting consultation (paragraph 178) says the Government “does not have any plans to introduce new requirements for reporting companies to obtain assurance over future UK SRS reporting at this stage”.
A statement on whether there is one, and where it can be found.
If obtained, name the provider, the disclosures assured and the standards used.
Private companies
Private companies: the MCR programme
UK SRS does not apply to private companies, and no requirement has been proposed.
The DBT consultation response, paragraph 1.16, says the Modernising Corporate Reporting (MCR) programme “will include consideration of the need for requirements within the Companies Act for private entities to report against UK SRS” — consideration, not commitment.
The MCR consultation was published on 7 September 2026 by the Department for Business, Innovation, Science and Trade (the renamed DBT), and closes at 11:59pm on 30 November 2026.
It makes no proposal on UK SRS for private companies: paragraph 155 says “the government will consider how UK SRS should be reflected in the Companies Act 2006, taking into consideration feedback to this consultation, the CFD PIR and related processes”.
Immediate legislative changes
Set out in a Written Ministerial Statement on 21 October 2025 (HCWS973), these remove reporting obligations from up to 51,000 companies.
Medium-sized private companies exempted from the Strategic Report; wholly-owned subsidiaries exempted where a UK parent’s annual report covers them; the Directors’ Report requirement removed.
The September 2026 consultation
The strand relevant to UK SRS scope.
It tests “the merits of non-financial reporting requirements for private companies” and asks (paragraphs 57–58) whether to create a new “very large” company category — with no figures attached and “an open mind on how to proceed”.
Three issues the consultation leaves open
Defining “economically significant”
DBT response ¶1.61: “a notable number of respondents asked that the phrase ‘economically-significant private entities’ (or companies) be clearly defined, with several caveating their answer in the absence of this definition.” There is no published definition.
Subsidiaries of reporting parents
¶1.67 records strong support for an exemption where a parent already reports against UK SRS or an equivalent standard such as the European Sustainability Reporting Standards. Whether it is granted is undecided.
Proportionality and phasing
¶1.68: “proportionality is the priority for consultation respondents”, and a phased approach with a longer preparation period is expected for private entities not already in similar regimes.
No government or regulator document proposes a threshold or a commencement date, and the Government has committed only to consider the question.
Thresholds and start dates circulating in commentary — including “250 or more employees” and “1 January 2028” — are not drawn from any government source.
Existing regimes
Existing reporting carries over
UK SRS does not replace the existing climate-related reporting regime under section 414CA of the Companies Act 2006 — the non-financial and sustainability information statement (NFSIS).
But the FRC’s FAQ, updated 26 February 2026, confirms the Government has confirmed UK SRS S2 as a national reporting framework for the purposes of section 414CB(6) of the Companies Act 2006.
In DBT’s words, companies reporting in accordance with UK SRS S2 “do not need to duplicate their disclosures” to meet the section 414CB(2A) obligations, provided the use of UK SRS S2 is clearly referenced in the NFSIS.
This applies whether UK SRS S2 is applied under the FCA’s comply-or-explain rules or voluntarily.
The section 414CB climate disclosures are outside the September 2026 MCR consultation, under a separate post-implementation review due to complete by spring 2027 (MCR paragraphs 147–148).
SECR continues to operate alongside UK SRS, and the SECR Regulations remain in force.
DESNZ published its statutory post-implementation review of SECR on 26 May 2026, recommending the requirements be retained with amendments rather than removed; MCR paragraph 150 records that DESNZ intends to consult on SECR and ESOS later in 2026.
For the relationship with ESOS and SECR, see ESOS and UK SRS.
What continues alongside UK SRS
| Regime | Status |
|---|---|
| Non-financial and sustainability information statement (s.414CA) | Continues |
| Climate-related financial disclosures (s.414CB(2A)) | Can be met by reporting under UK SRS S2 (s.414CB(6)); under separate review to spring 2027 |
| SECR | Continues; PIR recommends retention with amendments |
Quick reference
Who falls where
| Entity type | UK SRS obligation | Date | Notes |
|---|---|---|---|
| UKLR 6 commercial company | UK SRS S1 and S2, comply or explain | 1 Jan 2027 | One-year Scope 3 relief; two-year S1 non-climate relief; first reports in 2028 |
| UKLR 16 non-equity issuer | UK SRS S1 and S2, comply or explain | 1 Jan 2027 | Same reliefs as UKLR 6 |
| UKLR 22 transition category | UK SRS S1 and S2, comply or explain | 1 Jan 2027 | Same reliefs as UKLR 6 |
| UKLR 14 secondary listing | UK SRS S1 and S2, comply or explain | 1 Jan 2027 | CP26/5 had proposed a transparency statement only; the final rules did not adopt it |
| UKLR 15 depositary receipts | UK SRS S1 and S2, comply or explain | 1 Jan 2027 | CP26/5 had proposed a transparency statement only; the final rules did not adopt it |
| Large private company | No proposal; under consideration via MCR | Undetermined | No threshold and no commencement date proposed; the 7 September 2026 consultation makes no proposal |
| SME or medium-sized private company | No proposal | n/a | The MCR programme is reducing reporting obligations for this cohort |
| Voluntary adopter | Voluntary | Now | Available immediately for any entity |
For every date in sequence, see the UK SRS timeline.
Next steps
What to do this year
Treat 2026 as a transition year
- Map existing TCFD-aligned reporting against UK SRS S2 paragraph by paragraph and identify the gaps. The four-pillar structure carries over, but UK SRS S2 demands more quantification of financial effects and a tighter link between scenario analysis and the resilience disclosure — see climate scenario analysis under UK SRS.
- Decide whether to take the Scope 3 one-year relief and the S1 two-year relief, or apply early. Voluntary early application of the full standard is permitted and may suit investors who prefer integrated reporting.
- Brief the audit committee. Under the final rules, UK SRS disclosures sit in the annual financial report under the same governance as financial reporting, and any assurance obtained is described — provider, disclosures assured and standards used.
No date, no threshold — but not nothing to do
- Read the MCR consultation (open to 30 November 2026) and respond on the “very large” threshold and private-company non-financial reporting if the answer matters to you.
- Begin internal preparation. Whether or not a requirement ever arrives, data collection, governance and Scope 1 and 2 measurement are substantial pieces of work.
- Consider whether voluntary application is commercially useful. Where owners or lenders ask for UK SRS-aligned disclosure, early voluntary reporting can meet the request while building capability.
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 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 (¶1.2, ¶1.7); scope UKLR 6, 14, 15, 16 and 22 (¶3.6) and exclusions (¶3.7); commencement (¶3.12); reliefs (¶¶3.14, 3.20); transition plans (¶2.37); assurance (¶2.45).
- Financial Conduct AuthorityCP26/5: Aligning listed issuers' sustainability disclosures with international standards
Published 30 January 2026; the consultation PS26/19 finalises. Scope as consulted (¶3.4–3.5), draft reliefs (¶8.6–8.14), the UKLR 14/15 statement it proposed, and its estimate of around 600 affected (Annex 2 ¶43).
- Department for Business and TradeUK SRS S1 and UK SRS S2
Final standards published 25 February 2026.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — final standard (PDF)
The published text, including the ¶C4 Scope 3 relief and ¶29(a).
- Department for Business and TradeGovernment response to the UK SRS consultation
209 responses (¶1.6); respondent profile (¶1.9, Table 2); MCR linkage (¶1.16); private-company feedback (¶1.61, ¶1.67, ¶1.68).
- Department for Business and TradeUK Sustainability Reporting Standards — guidance hub
GOV.UK page tracking the standards’ development.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Published 7 September 2026, closes 30 November 2026. ¶57–58, ¶147–148, ¶150, ¶155 and ¶178.
- UK ParliamentWritten statement HCWS973: Modernisation of Corporate Reporting, 21 October 2025
The official record of the programme announcement.
- TheyWorkForYou (Hansard mirror)Written Ministerial Statement, 21 October 2025
The same statement, as mirrored from Hansard.
- Financial Reporting CouncilSustainability reporting developments — FAQ
Updated 26 February 2026; UK SRS S2 as a national reporting framework.
- Financial Reporting CouncilAssurance standards (including ISSA (UK) 5000)
ISSA (UK) 5000 published 12 November 2025, for voluntary use.
- legislation.gov.ukCompanies Act 2006, section 414CA
The non-financial and sustainability information statement.
- legislation.gov.ukCompanies Act 2006, section 414CB
Climate-related financial disclosures (subsection 2A) and the national reporting framework route (subsection 6).
- Department for Energy Security and Net Zero2026 post-implementation review of the SECR Regulations 2018
Published 26 May 2026; recommends retaining SECR with amendments.
Continue reading
Read next
UK SRS compliance guide
Step-by-step implementation roadmap from materiality assessment to first report.
UK SRS timeline and deadlines
Every date in sequence, from voluntary adoption to the FCA’s final comply-or-explain dates and reliefs.
Scope 3 emissions under UK SRS
Scope 3 measurement, disclosure requirements and the one-year relief in the FCA’s final rules.
UK SRS for private companies
What the MCR consultation does and does not propose, cohort by cohort.
UK SRS for overseas companies
Non-UK incorporated issuers, and secondary listings and depositary receipts under the FCA’s final rules.
ESOS and UK SRS
How the energy audit regime and SECR sit alongside UK SRS.