Who Must Comply with UK SRS

UK Sustainability Reporting Standards are voluntary today.

Any UK entity may choose to report against UK SRS S1 or UK SRS S2 in whole or in part.

Mandatory reporting is coming in two waves:
the FCA proposes to require UK SRS S2 for in-scope listed companies for accounting periods beginning on or after 1 January 2027;
the Government will separately consult on extending UK SRS to economically significant private entities through the Companies Act 2006
as part of the Modernising Corporate Reporting programme.

This page sets out which categories of company fall where,
the transitional reliefs, and the rules that apply to entities outside the FCA's primary listed perimeter.

The UK SRS standards that those categories are being brought into are set out in full on our primary reference site.

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,
although the standards do require an entity claiming compliance to apply UK SRS S1 and UK SRS S2 together where both are relevant.

The DBT received 209 responses to the consultation.

Financial and insurance services made up the largest single sector at 25% of respondents,
with 45% of respondents already reporting under SECR and 35% under TCFD-aligned Companies Act rules
— context that explains why voluntary adoption is concentrated among entities already carrying climate-related reporting obligations.

In scope from 1 January 2027: the FCA's proposals

The FCA published CP26/5 on 30 January 2026.

The consultation closed on 20 March 2026;
a final Policy Statement is expected in autumn 2026 with rules taking effect from 1 January 2027.

As at 27 July 2026 that Policy Statement had not been published, so everything below is a proposal rather than a settled requirement.

The FCA's cost benefit analysis puts 515 listed companies in full scope — those in the commercial companies, non-equity shares and non-voting equity shares, and transition categories — out of around 600 affected in total once the transparency-only categories are counted.

Approximately 90 of the 515 are incorporated outside the UK (Annex 2, paragraphs 43 and 45).

Paragraph 3.4 of CP26/5 names five UK Listing Rule categories that would fall within the new regime:

• Commercial companies (UKLR 6) — the largest category, covering standard commercial issuers with equity shares admitted to the Official List.
• Secondary listing category (UKLR 14) — issuers with a primary listing outside the UK and a secondary UK listing.
• Depositary receipts category (UKLR 15) — depositary receipts representing equity shares of issuers based outside the UK.
• Non-equity shares and non-voting equity shares (UKLR 16) — issuers of non-equity instruments admitted to listing under Chapter 16.
• Transition category (UKLR 22) — companies placed in the transition category following the 2024 listing regime overhaul, broadly the former standard listing segment.

These five categories are not treated identically.

Only UKLR 6, UKLR 16 and UKLR 22 carry the UK SRS reporting obligation.

Companies in these categories would be required to move to mandatory reporting against UK SRS S2
for accounting periods beginning on or after 1 January 2027,
excluding Scope 3 emissions.

Scope 3 and UK SRS S1 non-climate disclosures apply on a comply-or-explain basis instead,
each with an elective transitional relief available for a limited period (see the transitional reliefs below).

Companies in UKLR 14 (secondary listings) and UKLR 15 (depositary receipts)
— those with a primary listing outside the UK — would not report under UK SRS directly.

The FCA instead proposes a transparency-focused regime
under which these issuers disclose the climate and sustainability reporting standards that apply in their home jurisdiction,
including any transition plan requirements, and signpost where those disclosures can be found —
or state that no such requirements apply and no such standards are voluntarily followed.

The FCA is expressly not proposing UK SRS-aligned disclosures for these categories, transition plans included.

The rationale is that primary-listed jurisdictions are the appropriate locus of reporting obligations;
the UK does not seek to duplicate or override them.

The transitional reliefs

Two reliefs are built into UK SRS itself and would apply through the FCA's rules.

Both are elective: a company chooses whether to use them.

Electing a relief requires only a statement in the annual financial report that the disclosures have not been made — no further explanation, because the FCA confirms at paragraph 8.6 that "use of the UK SRS transitional reliefs does not engage our proposed 'explain' provisions".

A company already disclosing Scope 3 may simply carry on doing so; the rules "would not prevent this" (paragraph 8.13).

• Scope 3 emissions: elective one-year relief.
  Under CP26/5 paragraphs 3.9 and 8.6, an in-scope listed company may opt not to disclose Scope 3 emissions under UK SRS S2
  for one year from the date of initial application.
  From accounting periods beginning on or after 1 January 2028 that relief has expired and Scope 3 sits on a comply-or-explain basis:
  the company either discloses Scope 3 in accordance with UK SRS S2 paragraph 29(a),
  or identifies the specific paragraphs not disclosed, the reasons, and the steps being taken to disclose in future.
  The draft instrument carries no sunset on that comply-or-explain basis, so Scope 3 does not become fully mandatory in 2028 or later.
  For more detail on Scope 3 see scope 3 under UK SRS.

• UK SRS S1 non-climate disclosures: elective two-year relief.
  An in-scope listed company may opt not to report against UK SRS S1 for non-climate sustainability matters for up to two years,
  so the relief is available for periods beginning on or after 1 January 2027 and again for periods beginning on or after 1 January 2028.
  From accounting periods beginning on or after 1 January 2029 all the transitional reliefs have expired.
  UK SRS S1 non-climate reporting then operates on a comply-or-explain basis, again with no sunset:
  where a company has identified non-climate sustainability risks or opportunities that could reasonably be expected to affect its prospects,
  it must either disclose them or explain why it has not.

A separate transitional provision applies to listed companies whose accounting period begins before 1 January 2027.

Under paragraph 8.10 of CP26/5, such companies may either:
continue to apply the existing TCFD-aligned rules and guidance for that reporting period,
or voluntarily apply the new UK SRS-aligned requirements early.

Transition plans and assurance: what the FCA is not requiring

Two areas where the FCA has explicitly stopped short of mandating something are worth noting because they often appear in commentary as if they were already in scope:

• Transition plans are not mandated. The FCA's position in CP26/5 is that mandating the production of climate-related transition plans is a matter for Government policy. The FCA's proposal is more limited: in-scope companies must include a statement in their annual report confirming whether they have published a climate-related transition plan and where it can be found, or the reasons why no plan has been published. Companies that produce transition plans may wish to refer to the IFRS Foundation's educational material on transition plan disclosure.

• Assurance is not mandated. The FCA does not propose to require third-party assurance over UK SRS disclosures at this stage. Where companies obtain assurance voluntarily, they would be required to disclose the assurance level obtained, the assurance standard used, and the identity of the assurance provider. The FRC published ISSA (UK) 5000 as the UK assurance standard for sustainability disclosures, but its use is voluntary unless mandated separately.

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 states that the Modernising Corporate Reporting (MCR) programme, announced in October 2025,
"will include consideration of the need for requirements within the Companies Act for private entities to report against UK SRS".

That is consideration, not commitment.

The MCR consultation had not been published as at 27 July 2026; the latest stated timing is "later in 2026", with no firm date.

The MCR programme has two complementary strands.

The first, set out in a Written Ministerial Statement on 21 October 2025, is a set of immediate legislative changes intended to remove reporting obligations from up to 51,000 companies — exempting medium-sized private companies from the Strategic Report requirement, exempting wholly-owned subsidiaries where their disclosure is included in a UK parent's annual report, and removing the Directors' Report requirement.

The Government estimates these reforms will save UK businesses around £230 million per year in administrative costs.

The second strand, which is the relevant one for UK SRS scope, is a broader consultation on corporate reporting framework alignment.

Within that consultation, the Government will consider whether to extend UK SRS reporting requirements to "economically significant private entities" through amendments to the Companies Act 2006.

The DBT consultation response notes several issues that the MCR consultation will need to resolve:

• Defining "economically significant." Paragraph 1.61 of the DBT response records that "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 at present.
• Subsidiaries of reporting parents. Paragraph 1.67 records strong respondent support for an exemption where a parent company already reports against UK SRS or an equivalent international standard (such as the European Sustainability Reporting Standards). The consultation will determine whether such an exemption is granted.
• Proportionality and phasing. Paragraph 1.68 records that "proportionality is the priority for consultation respondents" and that a phased approach with a longer preparation period is expected for private entities not currently in scope of similar requirements.

What this means in practice: there is no private company UK SRS proposal to plan to.

No government or regulator document proposes a threshold or a commencement date, the MCR consultation had not been published as at 27 July 2026, 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.

See UK SRS for private companies.

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).

However, the FRC has confirmed in its FAQ updated 26 February 2026 that the Government has designated UK SRS S2 as a national reporting framework under section 414CB(2A) of the Companies Act 2006.

The practical effect: an entity using UK SRS S2 does not need to separately satisfy the climate-related financial disclosure requirements in section 414CB(1)-(5), provided the use of UK SRS S2 is clearly referenced in the NFSIS.

This applies whether UK SRS S2 is applied on a mandatory or voluntary basis.

SECR continues to operate alongside UK SRS.

The Government has indicated it will consider how energy and emissions data reported under UK SRS interacts with SECR, with a view to reducing unnecessary duplication, but the SECR Regulations remain in force.

DESNZ published its statutory post-implementation review of SECR on 26 May 2026, recommending that the requirements be retained with amendments rather than removed — so UK SRS does not replace SECR.

For the relationship with ESOS and SECR see ESOS and UK SRS.

Quick reference: who falls where

What to do this year

For listed companies in UKLR 6, 16 or 22:

• Treat 2026 as a transition year. Map your 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 greater quantification of financial impacts and tighter linkage between scenario analysis and the resilience disclosure required by 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 give a comparability advantage with investors who prefer integrated reporting.
• Brief the audit committee. UK SRS reporting sits within the Strategic Report and is subject to the same governance, oversight and (where applicable) assurance arrangements as financial reporting.

For private companies likely to be in scope of MCR proposals:

• Watch for the MCR consultation, still expected "later in 2026". Until it is published there is no threshold, no date and nothing to plan to.
• Begin internal preparation now. Whether or not a private company requirement ever arrives, the data collection, governance and Scope 1/2 emissions measurement work is substantial and is a leading indicator of investor and lender expectations regardless of any formal threshold.
• Consider whether voluntary application now is commercially useful. Some private equity owners and lenders are already asking portfolio companies for UK SRS-aligned disclosure; early voluntary reporting can satisfy that demand while building capability ahead of any mandatory regime.

Sources and References

• FCA CP26/5 — FCA consultation published 30 January 2026 with scope and timetable proposals
• DBT consultation response — Government response covering MCR linkage and private company scope
• UK SRS publication — Government publication of final standards on 25 February 2026
• UK SRS guidance hub — GOV.UK guidance page tracking development
• MCR Written Ministerial Statement — Hansard record setting out MCR programme
• FRC FAQ — FRC FAQ on UK SRS integration with Companies Act
• Companies Act 2006, section 414CA — Statutory basis for NFSIS integration