UK SRS · The standards and who reports
UK Sustainability Reporting Standards: the 2026 guide
The UK Sustainability Reporting Standards are two standards, UK SRS S1 and UK SRS S2, issued for the UK on 25 February 2026 for voluntary use by any entity.
Listed companies now have a firmer duty: the FCA’s PS26/19, published on 30 September 2026, requires them to report against UK SRS or explain why not, for accounting periods beginning on or after 1 January 2027.
What they are
What are the UK Sustainability Reporting Standards?
UK SRS are UK versions of the ISSB’s IFRS S1 and IFRS S2.
They are issued by the Secretary of State for Business and Trade and, in their own words, “have not been prepared or endorsed by the International Sustainability Standards Board”.
The UK-specific differences are set out in Annex A of the government response, whose scoping rule is that where a requirement is not in the table, “there are no differences between the two”.
The largest difference is that there is no effective date in either standard, so they bind nobody until a law or regulation says so.
The standards require disclosure of risks and opportunities that could reasonably be expected to affect an entity’s cash flows, its access to finance or its cost of capital over the short, medium or long term (UK SRS S1 ¶3).
The dedicated editorial site for the UK sustainability reporting standards tracks the standards and their process in detail, and our own page on UK SRS S1 and S2 walks through the two texts.
| UK SRS S1 | UK SRS S2 | |
|---|---|---|
| Subject | All sustainability-related risks and opportunities | Climate-related risks and opportunities |
| Role | General requirements: materiality, connected information, location, timing, compliance | The climate disclosures, applied with S1 |
| Based on | IFRS S1 (June 2023) | IFRS S2 as amended in December 2025 |
| Reliefs in the standard | Climate-first (¶E3), no time limit | Scope 3 (¶C4), no time limit; GHG method (¶C3), first year |
Scope
Who reports under UK SRS, and on what basis
Since 30 September 2026 there are three groups, and only the first has an obligation.
| Group | Who | Basis |
|---|---|---|
| Listed companies in scope | Commercial companies (UKLR 6), secondary listings (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16), transition category (UKLR 22). | Report against UK SRS S1 and S2, or explain, for periods beginning on or after 1 January 2027 (PS26/19). |
| Excluded listing categories | Closed-ended investment funds (UKLR 11), open-ended investment companies (UKLR 12), shell companies (UKLR 13), debt and debt-like securities (UKLR 17), securitised derivatives (UKLR 18), warrants, options and other miscellaneous securities (UKLR 19). | No UK SRS listing-rule obligation. |
| Everyone else | Private companies, AIM companies, LLPs, public bodies, charities. | Voluntary. No threshold proposed. |
The FCA’s consultation, CP26/5, estimated that around 600 listed companies would be affected; the final policy statement gives no total of its own.
CP26/5 had proposed a lighter statement for secondary listings and depositary receipts, and the final rules bring them onto comply or explain with everyone else.
It had also proposed that UK SRS S2 be mandatory apart from Scope 3, and the final rules do not do that: “a comply or explain approach across all categories of disclosures” (PS26/19 ¶1.7).
What that means for a listed company in practice is set out on our UK SRS compliance page.
UK SRS S1
UK SRS S1: the general requirements in detail
UK SRS S1 is the foundation: it sets the rules that every UK SRS disclosure follows, climate or not.
Materiality is judged by the decisions of primary users of general purpose financial reports (¶18), and the standard sets no thresholds for it (¶B19).
The disclosures cover the same reporting entity as the financial statements (¶20) and must be connected to them, with consistent data and assumptions (¶¶21–24).
They are provided as part of the general purpose financial reports (¶60), at the same time as the financial statements (¶64), and close with an explicit and unreserved statement of compliance (¶72).
UK SRS S1 ¶E2 requires S1 and S2 to be applied together, and ¶E3 permits an entity to report on climate alone, at the price, under ¶73A, of not asserting compliance with UK SRS S1.
In the standard that climate-first relief has no time limit; for listed companies, PS26/19 limits it to two years.
The core content, UK SRS S1 ¶25
| Pillar | What it covers |
|---|---|
| Governance (¶¶26–27) | Board oversight; management's role; skills and competencies; how often the board is informed; how the risks feed into strategy and decisions. |
| Strategy (¶¶28–42) | Risks and opportunities; business model and value chain; strategy and decisions; financial position, performance and cash flows; resilience. |
| Risk management (¶¶43–44) | Processes to identify, assess, prioritise and monitor; integration with overall risk management. |
| Metrics and targets (¶¶45–53) | Metrics required by a standard; metrics the entity uses; targets and progress against them. |
UK SRS S2
UK SRS S2: climate disclosure requirements
UK SRS S2 asks for each climate-related risk to be classed as physical or transition, and for the time horizon over which it could bite.
Physical risks
Event-driven (acute) risks, such as floods, storms and wildfires, and chronic risks from longer-term shifts in climate patterns, such as rising temperatures and sea levels.
Assessed across sites, assets and the value chain.
Transition risks
Risks from the move to a lower-carbon economy: policy, legal, technological, market and reputational.
Opportunities are disclosed alongside them.
| Emissions | What UK SRS S2 ¶29(a) asks for | Listed companies under PS26/19 |
|---|---|---|
| Scope 1 | Absolute gross direct emissions, GHG Protocol Corporate Standard. | Comply or explain from periods beginning 1 January 2027. |
| Scope 2 | Absolute gross indirect emissions from purchased energy, location-based, plus contractual instruments. | Comply or explain from periods beginning 1 January 2027. |
| Scope 3 | Absolute gross value-chain emissions, with the categories included. | Comply or explain, after a one-year relief during which only its use is stated. |
Emissions are measured under the GHG Protocol Corporate Standard, and the value-chain categories come from the Scope 3 Standard.
DESNZ publishes UK emission factors for activity data each year as the government conversion factors.
An entity with asset management, commercial banking or insurance activities also discloses financed emissions (¶29(a)(vi)).
Where financed emissions cannot be estimated for the same period as the financial statements, UK SRS S2 ¶B59A requires the entity to explain why, the one place the UK text is stricter than the ISSB’s.
Scenario analysis is required: UK SRS S2 ¶22 asks the entity to assess its climate resilience with an approach commensurate with its circumstances.
The standard names no scenario; it asks the entity to disclose, among the inputs, whether its analysis is aligned with the latest international agreement on climate change.
Reference sets such as the NGFS scenarios and the IEA’s Net Zero Emissions by 2050 scenario are widely used, and neither is mandated.
A transition plan is disclosed where the entity has one; the government’s consultation on transition plans closed on 17 September 2025 and no duty to have one exists.
Timeline
The UK SRS timeline, as it stands
The rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
The date of initial application is the start of a listed company’s first period beginning in 2027 (PS26/19 ¶3.18).
The Scope 3 relief runs for one year from that date and the UK SRS S1 relief for two, so for a company with a calendar year end they cover the 2027 report, and the 2027 and 2028 reports, respectively.
A company whose period began before 1 January 2027 can keep using the TCFD-aligned rules for that period or adopt UK SRS early (¶3.19).
No further phase covering large private companies, AIM companies or others has been proposed by the government or the FCA.
- 25 Feb 2026Standards published
UK SRS S1 and S2 for voluntary use.
- 30 Sep 2026FCA final rules
PS26/19: comply or explain for listed companies in scope.
- 28 Oct 2026Technical Note consultation closes
TN 803.1, guidance on applying comply or explain.
- 30 Nov 2026Modernising corporate reporting closes
The government will consider how UK SRS is reflected in the Companies Act.
- 1 Jan 2027Rules apply
Accounting periods beginning on or after this date.
- 2028First reports
Annual financial reports for the first period in scope.
Sources: DBT · FCA PS26/19 ¶¶1.9, 3.12 · BIST, Modernising corporate reporting
Preparation
How to prepare for UK SRS, in three stages
| Stage | Work | Anchor in the standards |
|---|---|---|
| 1 — Assess the current state | Gap analysis against S1 and S2; review existing TCFD and SECR reporting; identify data gaps; assess governance. | UK SRS S1 ¶25 core content; the Annex A differences. |
| 2 — Build capability | Sustainability governance with a named owner; data systems with recorded methods; training for finance and risk teams. | UK SRS S1 ¶¶26–27; UK SRS S2 ¶29(a). |
| 3 — Implement and report | Scenario analysis; disclosure of any transition plan; a dry run of the report; a decision on voluntary assurance. | UK SRS S2 ¶22; S1 ¶¶60, 64, 72; ISSA (UK) 5000. |
Every step above needs an owner.
A company without a sustainability team can cover the first reporting cycle through fractional recruitment, with a part-time head of sustainability who runs the gap analysis and data build and then hands the process over.
The same climate data can be asked for in public sector tenders, where suppliers keep it current in RFP software, and how a company talks about it publicly is a question for a go-to-market strategy agency, not only the reporting team.
A step-by-step account of building the report is in our UK SRS reporting guidance.
Common difficulties
Where first UK SRS reports get stuck
Scope 3 data. Supplier data is often thin in a first year, so the method, the data used and the categories included are disclosed alongside the figure.
Scenario analysis. Climate modelling is specialist work; the depth required scales with the entity’s circumstances, and the scenarios chosen and their sources are disclosed.
Joining up finance and sustainability. The connected-information requirement (UK SRS S1 ¶¶21–24) means the same assumptions must run through both, which is an organisational problem before it is a reporting one.
Systems. Figures rebuilt in spreadsheets each year are hard to evidence; a recorded method and factor version makes each figure traceable, which is what an assurance practitioner tests.
Scenario analysis scales with the entity’s circumstances (IFRS S2 ¶B8, carried into UK SRS S2).
Listed companies get a one-year Scope 3 relief and a two-year S1 relief.
An explanation is a permitted answer under comply or explain.
Resources
Where to go next
The FRC’s sustainability reporting FAQs explain how the untimed reliefs work for voluntary reporters.
UK SRS and SECR run side by side, and our page on UK SRS vs SECR sets out what each asks for.
Our page on CDP reporting covers where the CDP questionnaire overlaps with UK SRS S2.
SRS Report is an independent reference site, not a consultancy, but if it would help to talk through where UK SRS applies to you, you can book a free 15-minute call.
Frequently asked
Questions people ask
What are the UK Sustainability Reporting Standards?
The UK Sustainability Reporting Standards (UK SRS) are two standards issued by the Secretary of State for Business and Trade and published on 25 February 2026: UK SRS S1, the general requirements for disclosing sustainability-related financial information, and UK SRS S2, the climate-related disclosures. They are the UK versions of the ISSB's IFRS S1 and IFRS S2, with the differences listed in Annex A of the government's consultation response.
Are the UK Sustainability Reporting Standards mandatory?
The standards themselves are available for voluntary use by any UK entity and contain no effective date. Listed companies are the exception: the FCA's final rules in PS26/19, published on 30 September 2026, require companies in five listing categories to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
Who has to report under UK SRS?
Companies with listings in the commercial companies (UKLR 6), secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16) and transition (UKLR 22) categories, on a comply-or-explain basis. The FCA's consultation, CP26/5, estimated around 600 listed companies would be affected. Investment funds, shell companies and debt issuers are excluded, and no private-company requirement has been proposed.
When do the UK Sustainability Reporting Standards apply?
For listed companies in scope, from accounting periods beginning on or after 1 January 2027, with first reporting in 2028. Scope 3 emissions have a one-year relief and UK SRS S1 non-climate disclosures a two-year relief, during which the company only states that it is using the relief. Voluntary users can apply the standards now.
What is the difference between UK SRS and IFRS S1 and S2?
UK SRS removes the effective dates, softens the reference to SASB and industry-based guidance from "shall" to "may", leaves the climate-first and Scope 3 reliefs untimed so that law or regulation sets their length, adds paragraph 73A on the statement of compliance, and adds paragraph B59A, which requires an explanation where financed emissions cannot be estimated for the same period. Annex A of the government response lists the differences and states that anything not listed is the same.
Does UK SRS S2 require a 1.5°C scenario?
No. UK SRS S2 paragraph 22 requires climate-related scenario analysis using an approach commensurate with the entity's circumstances, and asks the entity to disclose, among the inputs, whether its analysis is aligned with the latest international agreement on climate change. It names no scenario and does not mandate the NGFS or IEA scenario sets.
Do private companies have to report under UK SRS?
No. No UK law requires a private company to report against UK SRS, and no size threshold for private companies has been proposed. 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.
Does UK SRS require a transition plan?
No. UK SRS S2 asks for information about a transition plan where the entity has one. PS26/19 requires listed companies to disclose whether they have a climate-related transition plan and, if so, where it can be found; it does not require them to have one.
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; both standards are 45 pages.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
The source for voluntary use by any entity.
- Department for Business and TradeUK SRS S1 General Requirements, ¶¶3, 17–25, 26–53, 73A and Appendix E (PDF)
The materiality test, the core content and the climate-first relief.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures, ¶¶22, 29, B59A and Appendix C (PDF)
Scenario analysis, the metric categories, financed emissions and the reliefs.
- Department for Business and TradeGovernment response to the UK SRS consultation, Annex A
The final differences from IFRS S1 and S2.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Final rules published 30 September 2026.
- Financial Conduct AuthorityPS26/19 policy statement, ¶¶1.7, 2.37, 2.45, 3.6–3.7, 3.12–3.20 (PDF)
Scope, exclusions, dates, reliefs, transition plans and assurance.
- Financial Conduct AuthorityCP26/5 consultation paper, Annex 2 ¶43 (PDF)
The consultation that preceded the final rules, and its estimate of around 600 affected companies.
- IFRS FoundationIFRS S2 Climate-related Disclosures (December 2025 text), ¶¶22, 29, B8
The text UK SRS S2 is based on.
- IFRS FoundationUse of IFRS Sustainability Disclosure Standards by jurisdiction
The UK sits in the snapshot tier, as at the page's 16 July 2026 stamp.
- GHG ProtocolCorporate Accounting and Reporting Standard
The measurement basis UK SRS S2 ¶29(a) requires.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The Scope 3 categories.
- Department for Energy Security and Net ZeroGovernment conversion factors for company reporting
The UK emission factors published each year.
- Network for Greening the Financial SystemNGFS Scenarios Portal
A reference scenario set; not required by UK SRS.
- International Energy AgencyWorld Energy Outlook 2025 — Net Zero Emissions by 2050
A reference scenario, published 12 November 2025; not required by UK SRS.
- Department for Energy Security and Net ZeroClimate-related transition plan requirements — consultation
Ran 25 June to 17 September 2025; no duty to have a transition plan exists.
- Financial Reporting CouncilSustainability Reporting Developments: FAQs
The FRC on using the reliefs without time limits as a voluntary reporter.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
Issued 12 November 2025 for voluntary use.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Open until 30 November 2026; no private-company UK SRS proposal.