UK SRS compliance · Listed companies
UK SRS compliance: what PS26/19 requires
On 30 September 2026 the FCA published final rules in PS26/19 that make UK SRS compliance a listing-rule matter.
Listed companies in scope report against UK SRS S1 and S2, or explain why not, for accounting periods beginning on or after 1 January 2027.
For every other UK entity the standards remain voluntary; the reference coverage of the UK SRS regime sits on the family’s hub.
Scope
Who has to comply, and who does not
PS26/19 applies to companies with listings in five UK Listing Rules categories.
CP26/5 had proposed a lighter statement for secondary listings and depositary receipts; the final rules put them on the same comply-or-explain basis as everyone else.
The consultation estimated that around 600 listed companies would be affected; PS26/19 does not give a total.
Investment funds, open-ended investment companies, shell companies and issuers of debt, securitised derivatives and miscellaneous securities are outside the rules.
AIM companies, private companies and LLPs have no UK SRS obligation, and no private-company threshold has been proposed.
The fuller UK SRS timeline shows how the dates fit together.
| Listing category | Position |
|---|---|
| UKLR 6 — commercial companies | In scope |
| UKLR 14 — secondary listing | In scope |
| UKLR 15 — depositary receipts | In scope |
| UKLR 16 — non-equity and non-voting equity shares | In scope |
| UKLR 22 — transition | In scope |
| UKLR 11, 12, 13, 17, 18, 19 — funds, OEICs, shells, debt, securitised derivatives, miscellaneous | Excluded |
Comply or explain
How comply or explain works under PS26/19
The FCA’s policy statement adopts “a comply or explain approach across all categories of disclosures” (¶1.7).
A company makes each UK SRS disclosure, or explains why it has not.
The FCA says an explanation should help investors understand “the issuer’s position and any next steps” (¶2.17), and should be clear about any sustainability-related risks or opportunities that have not been disclosed (¶2.25).
The disclosures and explanations go in the company’s annual financial report (¶2.24).
A company using a transitional relief states that it is doing so, and “no further explanation on the matters provided for in the reliefs is required during the relief period” (¶3.20).
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).
The new rules replace the existing TCFD-aligned disclosures (¶1.10), which the FCA summarises on its page of sustainability reporting requirements.
The FCA is consulting until 28 October 2026 on Technical Note 803.1, set out in Primary Market Bulletin 66, on applying comply or explain proportionately (¶1.9).
The reliefs, for a calendar-year company
- FY 2027First period in scope
Scope 3 relief and S1 non-climate relief both available; state their use.
- FY 2028Scope 3 relief ends
Scope 3 reported or explained. S1 non-climate relief still available.
- FY 2029S1 relief ends
Every UK SRS disclosure reported or explained.
Derived from FCA PS26/19 ¶¶3.14 and 3.18: initial application is the first period beginning on or after 1 January 2027 and before 1 January 2028.
What you comply with
The UK SRS compliance framework
UK SRS S1 — general requirements
The foundation: materiality, the reporting entity, connected information and the four-part core content in UK SRS S1 ¶25.
- Governance structures and oversight of sustainability risks
- How strategy and the business model respond to them
- Risk management processes and their integration into overall risk management
- Metrics and targets, and progress against them
The standards were endorsed for the UK by the Secretary of State under the government’s endorsement framework, and the Department for Business and Trade published them; they are the UK versions of the ISSB standards.
UK SRS S2 — climate disclosures
The climate content, built on the four-pillar structure of the TCFD, which disbanded on 12 October 2023.
- Physical and transition risk assessment
- Scenario analysis commensurate with the entity’s circumstances, with no scenario prescribed
- Gross Scope 1, 2 and 3 emissions measured under the GHG Protocol
- Information about a transition plan, where one exists
The Transition Plan Taskforce has concluded its work, and its disclosure framework is now archived guidance, not a standard.
CP26/5, published on 30 January 2026, had proposed mandatory UK SRS S2 climate reporting for in-scope listed companies; PS26/19 replaced that with comply or explain.
UK SRS is separate from the FCA’s Sustainability Disclosure Requirements and investment labels, which apply to FCA-regulated firms and their products, not to listed companies as issuers.
The listing rules themselves are made under section 73A of the Financial Services and Markets Act 2000.
The statement of compliance
What you can say, and what you cannot
UK SRS S1 ¶72 requires an entity that meets all the requirements to make “an explicit and unreserved statement of compliance”.
An entity using the climate-first relief (UK SRS S1 ¶E3) “is not permitted to assert compliance with UK SRS S1” and discloses its use of the relief instead (¶73A).
In the standards, that relief and the Scope 3 relief in UK SRS S2 ¶C4 have no time limit; for listed companies, PS26/19 limits them to two years and one year.
A company that explains rather than discloses on a point has not met all the requirements, and ¶72’s unreserved statement is written for one that has.
A company reporting on climate only cannot write that it complies with UK SRS S1.
It can write that it complies with UK SRS S2, if it discloses the reliefs it used.
Readiness
A UK SRS readiness plan, against the real dates
The phases below are a readiness plan, not a statutory timetable. The only fixed date is the start of the first period in scope.
| Phase | When | What happens |
|---|---|---|
| 1 — Assessment | Now | Gap analysis against S1 and S2 using the DBT guidance and the standards; review of existing TCFD and SECR reporting; data availability; governance structure. |
| 2 — Build | Before the first period begins (1 January 2027 for calendar-year companies) | Data collection systems, internal controls and board and management training; professional bodies such as the ICAEW publish technical material for finance teams. |
| 3 — Capture | Through the first period | Emissions and metrics captured as the year runs; scenario analysis carried out; any reliefs chosen and recorded. |
| 4 — Report | With the annual financial report, from 2028 | Disclosures, explanations, relief statements and the statement of compliance; assurance only if chosen, under standards such as ISSA (UK) 5000. |
The FRC’s UK sustainability assurance standard, ISSA (UK) 5000, was published on 12 November 2025 and is effective for periods beginning on or after 15 December 2026, with early application permitted; the Financial Reporting Council issued it for voluntary use.
The government has decided on a voluntary, opt-in register of sustainability assurance providers, to be run by the FRC; it is not yet live.
A step-by-step account of building the report is in our UK SRS reporting guidance.
By sector
UK SRS compliance by sector
The standards are the same for every company; the difficult disclosures differ by sector.
Financial services
Financed emissions, part of Scope 3 Category 15, for asset management, commercial banking and insurance (UK SRS S2 ¶29(a)(vi)), with an explanation required under ¶B59A where they cannot be estimated for the same period.
Banks and insurers also manage climate risk under the PRA’s SS5/25, which replaced SS3/19 and adds no disclosure requirement; the PRA’s October 2021 climate change adaptation report predates it.
Energy and utilities
Transition risk, capital deployment and targets carry most of the weight.
Gas and electricity network licensees also publish an Annual Environmental Report under their licence conditions, set by Ofgem; it is a separate obligation from UK SRS.
Manufacturing
Supply-chain emissions, where Scope 3 category selection does most of the work.
Manufacturers asked by customers or investors may also answer CDP’s questionnaire, whose scores have no regulatory status; see our page on CDP reporting.
Real estate
Physical risk to assets and building emissions, disclosed as exposure metrics under UK SRS S2 ¶29(b)–(c).
Building ratings such as BREEAM assess individual buildings; they can inform the data but are not a UK SRS requirement.
Technology
Purchased electricity for data centres drives Scope 2, and the location-based figure is always disclosed, with contractual instruments reported alongside it.
Retail and consumer goods
Purchased goods, and the use and end-of-life treatment of sold products, are Scope 3 categories 1, 11 and 12, reported alongside transition risks from changing demand.
More on the report as a document is on the SRS Report home page.
Talk it through
An independent reference, not a consultancy
SRS Report is an independent reference site; it does not perform any part of anyone’s compliance and is not regulated by the FCA or any other body.
If it would help to talk through S1 and S2 for your organisation, you can book a free 15-minute call or reach us through the contact page.
Frequently asked
Questions people ask
What does UK SRS compliance mean for a listed company?
From accounting periods beginning on or after 1 January 2027, a company with a listing in UKLR 6, 14, 15, 16 or 22 reports against UK SRS S1 and S2 in its annual financial report, or explains why it has not made a disclosure. The FCA's final rules, PS26/19, published on 30 September 2026, apply comply or explain across all categories of disclosure, including UK SRS S2.
What is the UK SRS deadline?
For listed companies in scope, the rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028. A company with a 31 December year end reports on 2027 in its annual financial report published in 2028. There is no deadline for anyone else, because the standards are voluntary outside the listing rules.
Is UK SRS S2 mandatory for listed companies?
No. The FCA's consultation, CP26/5, had proposed making UK SRS S2 mandatory apart from Scope 3. The final rules in PS26/19 do not: they adopt "a comply or explain approach across all categories of disclosures". A company either makes each UK SRS S2 disclosure or explains why not.
What has to go into an explanation?
The FCA expects clear explanations to investors about any sustainability-related risks or opportunities that have not been disclosed, so that investors understand the issuer's position and any next steps. The FCA is consulting until 28 October 2026 on Technical Note 803.1, guidance on applying comply or explain proportionately, and aims to finalise it before the rules come into force.
What reliefs are available?
Two transitional reliefs: non-disclosure under UK SRS S1 for non-climate matters for two years from initial application, and non-disclosure of Scope 3 emissions under UK SRS S2 for one year. The date of initial application is the start of the first period beginning in 2027. A company using either relief states that it is doing so in its annual financial report, and no further explanation is needed during the relief period.
Do we need a transition plan to comply?
No. PS26/19 requires listed companies to disclose whether they have a climate-related transition plan and, if so, where it can be found. There is no duty to have one, and UK SRS S2 asks for information about a plan only where one exists.
Is assurance required for UK SRS compliance?
No. Where a listed company obtains assurance, it names the provider, which disclosures were assured and which assurance standards were used. ISSA (UK) 5000 is available for voluntary use, and the government has asked the FRC to run a voluntary register of sustainability assurance providers.
Does UK SRS apply to private companies or AIM companies?
No. The listing rules apply only to the five listing categories in scope, and no UK law requires a private company to report against UK SRS. The Modernising corporate reporting consultation, open until 30 November 2026, says the government will consider how UK SRS should be reflected in the Companies Act 2006, without a proposal, mechanism or date.
Do we need UK SRS compliance software?
Nothing in UK SRS or the listing rules requires any software. What the standards require is data that is complete, consistent with the financial statements and able to be evidenced, and a spreadsheet, a carbon accounting tool or an ESG data platform can each meet that if the method and controls are documented.
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
Final rules, first published 30 September 2026.
- Financial Conduct AuthorityPS26/19 policy statement, ¶¶1.2, 1.7, 1.9–1.10, 2.17–2.29, 2.37, 2.45, 3.6–3.7, 3.12–3.20 (PDF)
Comply or explain, scope, location, explanations, reliefs, transition plans, assurance.
- Financial Conduct AuthorityCP26/5 consultation paper (PDF)
Published 30 January 2026; proposed mandatory S2 excluding Scope 3; estimated around 600 companies affected.
- Financial Conduct AuthorityCP26/5 consultation page
Closed 20 March 2026.
- Financial Conduct AuthoritySustainability reporting requirements
The listing-rule framework the new rules replace.
- Financial Conduct AuthorityPS23/16: Sustainability Disclosure Requirements (SDR) and investment labels
The separate regime for FCA-regulated firms; not UK SRS.
- legislation.gov.ukFinancial Services and Markets Act 2000, section 73A
The power under which the listing rules are made.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
Voluntary use by any entity.
- Department for Business and TradeUK SRS S1, ¶¶25, 60, 72, 73A (PDF)
Core content, location and the statement of compliance.
- Department for Business and TradeUK SRS S2, ¶¶22, 29, B59A, C3–C4 (PDF)
Scenario analysis, emissions, financed emissions and the reliefs.
- Department for Business and TradeFramework and terms of reference for developing UK SRS
How the standards were endorsed: TAC, PIC and the Secretary of State.
- IFRS FoundationIFRS Sustainability Standards Navigator
IFRS S1 and S2.
- Task Force on Climate-related Financial DisclosuresTCFD — disbanding notice and archived recommendations
Disbanded 12 October 2023.
- GHG ProtocolGHG Protocol standards
The measurement basis for emissions.
- Bank of England (PRA)SS5/25 — Enhancing banks' and insurers' approaches to managing climate-related risks
Replaced SS3/19 on 3 December 2025; adds no disclosure requirement.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
Voluntary; effective for periods beginning on or after 15 December 2026.
- Department for Business and TradeAssurance oversight regime — government response (30 January 2026)
A voluntary, opt-in register for assurance providers.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Open until 30 November 2026; no private-company UK SRS proposal.