What is carbon compliance consultancy?

Carbon compliance consultancy involves expert guidance on meeting UK carbon regulations including SECR, TCFD, UK ETS, and upcoming UK SRS requirements. Carbon compliance consultants help businesses navigate complex carbon law, implement emissions reporting systems, and ensure full regulatory compliance.

Who needs carbon compliance consultancy services?

Carbon compliance services are essential for: Premium and Standard listed companies (mandatory TCFD and upcoming UK SRS reporting), large private companies with £500m+ revenue (SECR requirements), financial institutions with £5bn+ assets, and any organisation participating in the UK ETS. From 2026-27, UK SRS will significantly expand mandatory reporting requirements.

What are the penalties for non-compliance with carbon regulations in the UK?

Non-compliance with UK carbon regulations carries significant penalties: SECR violations can result in unlimited fines and director prosecution under the Companies Act 2006. UK ETS non-compliance carries civil penalties up to £50,000 plus £100 per tonne of CO2 equivalent. TCFD and UK SRS breaches may result in FCA enforcement action.

UK SRS Now Official

S1 and S2 published 25 February 2026. FCA CP26/5 published 30 January 2026. Listed companies must prepare for mandatory reporting from 1 January 2027.

UK SRS Implementation: Complete Guide to the New UK Sustainability Reporting Standards

UK SRS S1 and S2 published February 2026. FCA proposing mandatory reporting from January 2027. Complete implementation guide for UK companies.

1 January 2027

FCA proposed mandatory date

1,600+ Companies

UK listed companies affected

2 Standards

S1 General + S2 Climate

What are the UK Sustainability Reporting Standards?

UK SRS = UK Sustainability Reporting Standards, developed by the UK Sustainability Disclosure Technical Advisory Committee (SDTAC) and based on ISSB IFRS S1 (general sustainability) and S2 (climate).

Published: 25 February 2026 by UK government
FCA CP26/5: Published 30 January 2026, proposing mandatory UK SRS from 1 January 2027
Replaces: TCFD listing rules for UK-listed companies
Alignment: Closely aligned with global ISSB standards with UK-specific amendments

UK SRS S1: General Requirements

Sets out general requirements for sustainability-related financial disclosures

• Governance of sustainability risks and opportunities
• Strategy for managing sustainability matters
• Risk management processes
• Metrics and targets across all material topics

UK SRS S2: Climate-related Disclosures

Specific requirements for climate-related risks and opportunities

• Climate scenario analysis
• Scope 1, 2 and 3 GHG emissions
• Climate transition plans
• Cross-industry climate metrics

UK SRS S1 vs S2: What Each Standard Requires

Aspect	S1: General Sustainability	S2: Climate-related
Scope	All material sustainability topics	Climate-specific requirements
Governance	Board oversight of all sustainability matters	Climate governance specifically
Strategy	Business model impacts, value chain	Climate scenario analysis required
Risk Management	Process for all sustainability risks	Climate risk identification & assessment
Metrics	Industry-agnostic and specific metrics	GHG emissions (Scope 1, 2, 3), transition metrics
Compliance Approach	Initially comply-or-explain	Mandatory from start

Who Must Comply with UK SRS and When?

Implementation Timeline

2027

Phase 1: Premium & Standard Listed Companies

• All UK premium listed companies
• Standard listed companies (Main Market)
• Large banks and insurers (£5bn+ assets)
• Asset managers with £50bn+ AUM

2028

Phase 2: Extended Scope (Expected)

• AIM-listed companies
• Large private companies (consultation pending)
• Smaller financial institutions

2029+

Phase 3: Broader Application

• Medium-sized companies
• Supply chain requirements cascade
• Potential SME simplified standards

UK SRS vs TCFD: Key Differences and the Transition

Important: FCA CP26/5 proposes replacing TCFD listing rules with UK SRS requirements from 1 January 2027. Companies currently reporting under TCFD should begin gap analysis against UK SRS S1/S2 immediately.

Key Additional Requirements in UK SRS

New in UK SRS S1:

Broader sustainability topics beyond climate
Value chain assessment requirements
Connected information requirements
Materiality assessment documentation

New in UK SRS S2:

Cross-industry metric requirements
Detailed transition plan disclosures
Scope 3 emissions with specific protocols
Industry-based metrics (SASB aligned)

UK SRS vs ISSB: How the Standards Relate

UK SRS are based on ISSB IFRS S1 and S2 standards with minor UK-specific amendments:

95% aligned: Core requirements remain the same as ISSB
UK context: References to UK law, UK carbon pricing, UK regulators
Interoperability: Companies complying with UK SRS largely comply with ISSB
Global consistency: Enables comparison with international peers

Preparing for UK SRS: Gap Assessment and Readiness Roadmap

Q1 2026: Gap Assessment

• Map current TCFD/SECR reporting against UK SRS requirements
• Identify data gaps, especially for Scope 3 emissions
• Assess governance structure readiness
• Review materiality assessment processes

Q2 2026: System Implementation

• Establish data collection systems for new metrics
• Implement controls and validation processes
• Set up cross-functional reporting teams
• Engage with value chain partners for Scope 3 data

Q3 2026: Dry Run & Testing

• Complete trial UK SRS report
• Internal review and validation
• External assurance readiness assessment
• Board and committee training

Q4 2026: Final Preparation

• Finalise reporting processes and controls
• Complete assurance provider selection
• Prepare first mandatory report structure
• Establish ongoing monitoring systems

UK SRS and Scope 3: The Data Challenge

Critical requirement: UK SRS S2 requires disclosure of Scope 3 emissions across all 15 GHG Protocol categories where material, with specific measurement and estimation protocols.

Downstream Categories

9. Downstream transport
10. Processing sold products
11. Use of sold products
12. End-of-life treatment
13. Downstream leased assets
14. Franchises
15. Investments

Key Challenges

• Supplier engagement
• Data quality assessment
• Estimation methodologies
• Boundary setting
• Double counting avoidance
• Assurance readiness
• Year-on-year consistency

How Carbon Legal Supports UK SRS Implementation

A typical UK SRS implementation engagement for a listed company involves:

Phase 1: Assessment (2-3 months)

Gap analysis against S1 and S2 requirements
Data availability and quality assessment
Governance structure review
Implementation roadmap development

Phase 2: Implementation (4-6 months)

Process design and documentation
Scope 3 methodology development
Transition plan framework
Training and capability building

Get UK SRS Implementation Support

Frequently Asked Questions

When do UK SRS become mandatory?

FCA CP26/5 proposes mandatory UK SRS for premium and standard listed companies from accounting periods beginning on or after 1 January 2027. The consultation closes in April 2026 with final rules expected mid-2026.

Do UK SRS replace TCFD reporting?

Yes. For listed companies, UK SRS will replace TCFD listing rules. UK SRS S2 incorporates and extends TCFD requirements with additional metrics and more detailed disclosure requirements.

Is Scope 3 reporting mandatory under UK SRS?

Yes, where material. UK SRS S2 requires disclosure of Scope 3 emissions. Companies must assess all 15 GHG Protocol categories and report material categories using appropriate measurement or estimation methods.

Will UK SRS require external assurance?

The FCA consultation indicates a phased approach to assurance. Initially, limited assurance may be required for certain metrics, moving to reasonable assurance over time. Final requirements pending consultation outcome.

How do UK SRS relate to SECR?

SECR remains in place for large companies. UK SRS substantially extends beyond SECR requirements. Companies subject to both must comply with both, though UK SRS disclosures will satisfy SECR climate-related requirements.

Ready for UK SRS Implementation?

With mandatory reporting from January 2027, preparation must begin now. Our UK SRS implementation experts can guide you through every step.

Book UK SRS Consultation Download Readiness Checklist