UK SRS · S1 and S2 · listed companies
UK SRS compliance: the FCA’s final rules, S1, S2 and 2027
UK SRS compliance for listed companies is now settled: the FCA’s Policy Statement PS26/19, published on 30 September 2026, requires reporting against UK SRS S1 and S2 on a comply-or-explain basis.
The rules apply to accounting periods beginning on or after 1 January 2027, with first reports in 2028; the standards themselves remain voluntary for everyone else.
Status
Where UK SRS stands at 30 September 2026
UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026, as the UK endorsement of the ISSB’s IFRS S1 and S2.
The standards carry no effective date of their own; the government removed it so that timing could be set separately, by regulators or by legislation.
For listed companies, that timing is now set by the FCA, using its listing-rule powers under section 73A of the Financial Services and Markets Act 2000.
PS26/19 responds to the FCA’s consultation CP26/5, published on 30 January 2026 and closed on 20 March 2026.
The FCA moved away from making UK SRS S2 mandatory, citing proportionality for smaller issuers and the complexity of mixing mandatory and comply-or-explain rules, and adopted comply or explain across all categories of disclosure.
For any other entity, UK SRS remains voluntary; the clause-by-clause reference is on uksrs.org.uk’s pages for UK SRS S1 and UK SRS S2.
CP26/5 proposed making UK SRS S2 mandatory for three listing categories.
The final rules in PS26/19 put all of UK SRS — S1, S2 and Scope 3 — on comply or explain, and extend it to secondary listings and depositary receipts.
Timeline
The UK SRS compliance timeline
The FCA’s rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028 (PS26/19 ¶3.12).
A company with a 31 December year end therefore reports on 2027 in its annual financial report published during 2028.
For accounting periods beginning before 1 January 2027, the FCA’s existing TCFD-aligned disclosure rules remain the listing-rule position, and UK SRS may be used voluntarily.
Two transitional reliefs phase the work in: one year for Scope 3 and two years for UK SRS S1 non-climate matters.
From periods beginning on or after 1 January 2029, both reliefs have expired, and every UK SRS requirement is on comply or explain.
- 30 Jan 2026FCA CP26/5 published
Consultation closed 20 March 2026.
- 25 Feb 2026UK SRS S1 and S2 published
Department for Business and Trade; voluntary use.
- 30 Sep 2026FCA PS26/19: final rules
Comply or explain across UK SRS.
- 15 Dec 2026ISSA (UK) 5000 effective
For voluntary assurance engagements.
- 1 Jan 2027Rules apply
Accounting periods beginning on or after this date.
- 1 Jan 2028Scope 3 relief ends
For periods beginning on or after this date.
- 1 Jan 2029S1 “climate-first” relief ends
All reliefs expired.
Scope
Who is in scope for UK SRS compliance
The FCA’s rules follow the listing category, not company size.
| Listing category | Under PS26/19 |
|---|---|
| Equity shares — commercial companies (UKLR 6) | UK SRS S1 and S2, comply or explain |
| Equity shares — international commercial companies, secondary listing (UKLR 14) | UK SRS S1 and S2, comply or explain — CP26/5 had proposed a signposting statement instead |
| Depositary receipts (UKLR 15) | UK SRS S1 and S2, comply or explain — likewise changed from CP26/5 |
| Non-equity shares and non-voting equity shares (UKLR 16) | UK SRS S1 and S2, comply or explain |
| Equity shares — transition (UKLR 22) | UK SRS S1 and S2, comply or explain |
| Closed-ended funds (UKLR 11), open-ended investment companies (UKLR 12), shell companies (UKLR 13), debt and debt-like securities, securitised derivatives, warrants and options (UKLR 17–19) | Outside the rules |
CP26/5, the consultation, estimated that around 600 listed companies would be affected; PS26/19 widened reporting to the secondary listing and depositary receipt categories as well.
Companies outside the listed perimeter have no UK SRS duty; large companies continue to make climate-related financial disclosures under section 414CB of the Companies Act 2006, and the government has confirmed that UK SRS S2 is a national reporting framework for section 414CB(6).
The government’s Modernising corporate reporting consultation, open until 30 November 2026, says only that it will consider how UK SRS should be reflected in the Companies Act 2006; no threshold for private companies has been proposed.
For how UK SRS fits beside the other regimes, see our carbon compliance overview and the SECR compliance guide.
Comply or explain
How comply or explain and the reliefs work
Under comply or explain, a listed company either makes the UK SRS disclosures or explains why it has not.
The FCA’s stated reasoning (PS26/19 ¶1.3) is that where an issuer does not provide financially material information, a proportionate explanation of its reasoning and judgement can itself be useful to investors.
| Accounting periods beginning | What applies |
|---|---|
| Before 1 Jan 2027 | The existing TCFD-aligned rules; UK SRS available for voluntary use |
| 1 Jan 2027 – 31 Dec 2027 | UK SRS S1 and S2 on comply or explain; Scope 3 and S1 non-climate reliefs available |
| 1 Jan 2028 – 31 Dec 2028 | Scope 3 relief expired; S1 non-climate relief still available |
| On or after 1 Jan 2029 | All reliefs expired; comply or explain across UK SRS |
A company using a relief says so in its annual financial report; during the relief period no further explanation is required.
The standards’ own reliefs also apply: no comparative information in the first year, and a one-year relief to keep an existing greenhouse gas measurement method.
The standards
What UK SRS S1 and S2 ask for
Who oversees sustainability-related risks and opportunities
The board or committee responsible, and how management is involved.
Effects on the business model and cash flows
Including climate resilience, tested with scenario analysis under S2.
How risks are identified and managed
And how that process sits in the wider risk framework.
The numbers
Under S2, gross Scope 1, 2 and 3 emissions measured under the GHG Protocol, and any targets set.
The four areas are the architecture TCFD established; the requirements inside each are more detailed, and the four pillars are explained in the guide to the four pillars of sustainability reporting.
Information is disclosed where it could reasonably be expected to affect the entity’s cash flows, its access to finance or its cost of capital.
UK SRS S1 requires the disclosures to be for the same reporting entity as the financial statements (¶20), connected to them (¶¶21–24), and published at the same time and for the same period (¶64).
Emissions are measured in accordance with the GHG Protocol Corporate Standard, and reported gross — carbon credits are never netted off.
The UK’s differences from the ISSB baseline are listed in Annex A of the government’s consultation response.
The emissions inventory behind the metrics is the subject of our emissions compliance consultants guide.
Transition plans and assurance
Two statements, not two obligations
PS26/19 keeps both statements CP26/5 proposed.
A listed company discloses whether it has a climate-related transition plan and where to find it; it may publish the plan on its own or inside other reporting.
It also discloses whether it has obtained assurance over its UK SRS disclosures and, if it has, the provider, which disclosures were assured and the assurance standards applied.
Neither statement requires a company to have a transition plan or to buy assurance.
The Financial Reporting Council issued ISSA (UK) 5000 on 12 November 2025 for voluntary use; it applies to engagements on periods beginning on or after 15 December 2026, or as at a date on or after it.
State whether you have a climate-related transition plan and where it can be found — or explain why not.
State whether assurance was obtained, and if so the provider, which disclosures were assured and the standards used.
Readiness
Getting ready for UK SRS reporting
A company with mature TCFD reporting starts from a strong base: the move is one of deepening and formalising, not starting again.
Gap analysis
Map current TCFD disclosures to UK SRS S1 and S2, paragraph by paragraph, and mark where you will comply and where you may explain.
Reliefs and explanations
Decide whether to use the Scope 3 and S1 reliefs in 2027, and what an honest explanation would say where you will not disclose.
Data
Scope 1 and 2 on the GHG Protocol from 2027 periods; Scope 3 across the value chain from 2028 periods, unless explained.
Finance and sustainability
Same entity, same period, same publication date as the accounts — the finance team owns part of this.
The same energy data that feeds SECR gives a head start on Scope 1 and 2.
What a UK SRS consultancy does, and how to choose one, is on our UK SRS consultancy page.
Our sister reference site uksrs.org.uk covers the standards clause by clause, and srsreport.co.uk covers the data and implementation side.
Carbon Legal is an independent guide, not a firm that prepares disclosures; it can introduce you to independent specialists — get in touch or book a free 15-minute call.
Frequently asked
UK SRS compliance — frequently asked
What are UK SRS S1 and S2?
UK SRS S1 and S2 are the UK Sustainability Reporting Standards, published by the Department for Business and Trade on 25 February 2026. S1 sets the general requirements for sustainability-related financial disclosures; S2 covers climate. They are the UK endorsement of the ISSB’s IFRS S1 and S2, with the UK differences listed in Annex A of the government’s consultation response.
Is UK SRS mandatory?
Not in the strict sense. The standards themselves carry no effective date and are voluntary for any entity. For listed companies, the FCA’s final rules in Policy Statement PS26/19 (September 2026) require reporting against UK SRS S1 and S2 on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027: a company either makes the disclosures or explains why it has not. No law requires a private company to report against UK SRS.
When do the first UK SRS reports appear?
In 2028. The FCA’s rules apply to accounting periods beginning on or after 1 January 2027, so a company with a 31 December year end reports on its 2027 year in its annual financial report published during 2028.
Who has to comply with UK SRS?
Under PS26/19, issuers listed in five categories: commercial companies (UKLR 6), international commercial companies with a secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16) and the transition category (UKLR 22). Closed-ended investment funds, open-ended investment companies, shell companies and issuers of debt, securitised derivatives, warrants and options are outside the rules.
Does UK SRS require Scope 3 emissions from 2027?
No. The FCA gives a one-year transitional relief for Scope 3: a company using it states that it has done so and needs no further explanation. From accounting periods beginning on or after 1 January 2028 the relief has expired and Scope 3 falls under the same comply-or-explain rule as the rest of UK SRS.
What changed between CP26/5 and the final rules?
CP26/5 (January 2026) proposed making UK SRS S2 mandatory for three listing categories, with comply-or-explain only for Scope 3 and UK SRS S1, and a signposting statement for secondary listings and depositary receipts. PS26/19 moved all of UK SRS to comply-or-explain and brought secondary listings and depositary receipts into UK SRS reporting on the same basis. The dates and the one- and two-year reliefs stayed as consulted on.
Does UK SRS require external assurance?
No. A listed company states whether it has obtained assurance over its UK SRS disclosures and, if so, the provider, which disclosures were assured and the assurance standards used. ISSA (UK) 5000, issued by the FRC on 12 November 2025 for voluntary use, applies to engagements on periods beginning on or after 15 December 2026; it governs how an engagement is done, not whether one is required.
Do private companies have to report under UK SRS?
No, and no threshold for private companies has been proposed. The government’s Modernising corporate reporting consultation of 7 September 2026 says only that it will consider how UK SRS should be reflected in the Companies Act 2006. Private companies may adopt UK SRS voluntarily.
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.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026 for voluntary use.
- Department for Business and TradeUK SRS S1 General Requirements — final standard (PDF)
¶20 same reporting entity; ¶¶21–24 connected information; ¶64 timing.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — final standard (PDF)
Gross Scope 1, 2 and 3 emissions under the GHG Protocol.
- Department for Business and TradeGovernment response to the UK SRS consultation
Annex A: the UK differences from IFRS S1 and S2; UK SRS S2 as a national reporting framework for s.414CB(6).
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards
First published 30 September 2026: the FCA has finalised rules requiring listed companies to report against UK SRS on a comply-or-explain basis.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards (PDF)
September 2026. The final rules: comply or explain across UK SRS; scope ¶3.6–3.7; dates and reliefs ¶¶3.12–3.24.
- Financial Conduct AuthorityCP26/5 — consultation page
Published 30 January 2026, closed 20 March 2026.
- Financial Conduct AuthorityCP26/5: Aligning listed issuers’ sustainability disclosures with international standards (PDF)
What was proposed, for comparison with PS26/19.
- legislation.gov.ukFinancial Services and Markets Act 2000, section 73A
The power under which the FCA makes listing rules.
- legislation.gov.ukCompanies Act 2006, section 414CB
The climate-related financial disclosure duty for large companies; (6) national reporting frameworks.
- GOV.UKModernising corporate reporting — consultation (7 September 2026)
The government “will consider how UK SRS should be reflected in the Companies Act 2006”.
- Financial Reporting CouncilISSA (UK) 5000 — General Requirements for Sustainability Assurance Engagements (PDF)
Issued 12 November 2025 for voluntary use; ¶15 effective date.
- GHG ProtocolCorporate Accounting and Reporting Standard
The measurement basis UK SRS S2 requires for emissions.
- IFRS FoundationInternational Sustainability Standards Board
IFRS S1 and S2, the baseline UK SRS endorses.