UK SRS reporting · How the report is built
UK SRS reporting guidance: building the first report
This UK SRS reporting guidance follows a first report from materiality to the statement of compliance, using the text of UK SRS S1 and S2 at each step.
For listed companies the deadline is now fixed: the FCA’s PS26/19 applies UK SRS on a comply-or-explain basis to periods beginning on or after 1 January 2027.
It is an independent summary, not guidance with any authority.
Principles
Three principles that run through the report
Data quality. The qualitative characteristics in UK SRS S1 Appendix D include faithful representation and verifiability, which in practice means a clear audit trail, consistent methods and figures that can be recalculated.
The general requirements behind that are set out on the family’s page on UK SRS S1.
Connected information. UK SRS S1 ¶¶21–24 require the links between sustainability disclosures and the financial statements to be visible, with the same data and assumptions used in both.
Ready for assurance, if chosen. No UK SRS report has to be assured, but the voluntary UK standard is ISSA (UK) 5000, issued by the Financial Reporting Council on 12 November 2025 and effective for periods beginning on or after 15 December 2026.
Step 1
Materiality: deciding what goes in
A UK SRS report starts from a list of the sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s cash flows, access to finance or cost of capital (UK SRS S1 ¶3).
Information about them is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions of investors, lenders and other creditors (¶18).
The standard sets no numerical threshold for materiality (¶B19), so the judgement and its reasoning belong on file.
In practice that means a risk assessment, conversations with investors and lenders, a look at how peers report, and board sign-off of the resulting list.
The standards were published on 25 February 2026; our guide to the UK Sustainability Reporting Standards covers who has to report and when.
UK SRS looks at how sustainability matters affect the entity’s prospects.
Impacts on people and the environment count only where they feed back into cash flows, access to finance or cost of capital.
Double materiality is the EU’s CSRD test, not the UK’s.
Step 2
Data collection systems, built to be tested
The data a report needs follows from the materiality list, but climate data is always needed, because UK SRS S2 applies to every reporter.
| Data | What UK SRS asks | Source of method |
|---|---|---|
| Scope 1 and 2 emissions | Absolute gross emissions; Scope 2 location-based, with contractual instruments (UK SRS S2 ¶29(a)). | GHG Protocol Corporate Standard; DESNZ conversion factors for UK activity data. |
| Scope 3 emissions | Absolute gross value-chain emissions and the categories included; financed emissions for banks, insurers and asset managers. | GHG Protocol Scope 3 Standard. |
| Exposure metrics | Amount and share of assets or activities vulnerable to transition and physical risks, or aligned with opportunities (¶29(b)–(d)). | The entity's own asset and activity data. |
| Capital, carbon price, pay | Capital deployed to climate risks and opportunities; any internal carbon price; climate-linked executive pay (¶29(e)–(g)). | Finance and remuneration records. |
| Other sustainability topics | Metrics for any other material risk or opportunity under UK SRS S1 ¶¶45–53. | Topic by topic; S1 says an entity "may" consider the SASB Standards. |
Each figure needs a recorded method, source and factor version, so it can be recalculated by someone who did not build it.
Scope 3 is where data is thinnest; the Scope 3 Standard sets the categories, and the report discloses which are included.
Step 3
Climate analysis and scenario choice
UK SRS S2 requires the entity to use climate-related scenario analysis to assess its climate resilience, with an approach commensurate with its circumstances (¶22).
It prescribes no scenario, and no temperature pathway is mandatory.
Each climate risk is classed as physical or transition, and placed on the entity’s own short, medium and long-term horizons, linked to its planning cycle (¶10).
Published reference sets can serve as a starting point: the NGFS scenarios and the IEA’s Net Zero Emissions by 2050 scenario, whose 2025 edition peaks at around 1.65 °C about 2050.
Both are revised periodically, so the report names the vintage used.
| UK SRS S2 ¶22(b) asks you to disclose | |
|---|---|
| Inputs | Which scenarios, their sources, the range, transition or physical, alignment with the latest international agreement, time horizons, scope of operations |
| Assumptions | The key assumptions made |
| Timing | The reporting period in which the analysis was carried out |
Step 4
Preparing the report itself
The finished report has a fixed shape, and the closing statement is the part most often got wrong.
What the report contains
- Governance disclosures (S1 ¶¶26–27; S2 ¶¶5–7)
- Strategy, including climate resilience (S1 ¶¶28–42; S2 ¶¶8–23)
- Risk management (S1 ¶¶43–44; S2 ¶¶24–26)
- Metrics and targets (S1 ¶¶45–53; S2 ¶¶27–37)
- Comparative information for the prior period (S1 ¶70), unless a relief applies
- The statement of compliance (S1 ¶72), with any reliefs disclosed
- For listed companies: whether there is a transition plan and where to find it, and, if assurance was obtained, the provider, scope and standards
Three shapes of compliance statement
Full. “An explicit and unreserved statement of compliance” with UK SRS (S1 ¶72).
Climate only. No assertion of compliance with UK SRS S1; the use of ¶E3 is disclosed instead (¶73A). Compliance with UK SRS S2 may still be asserted, with the reliefs used stated beside it.
Listed, using an FCA relief. The use of the relief is stated in the annual financial report, and no further explanation is needed during the relief period (PS26/19 ¶3.20).
UK SRS is the UK endorsement of IFRS S1 and IFRS S2, issued by the ISSB in June 2023, so material written for the ISSB standards refers to the same body paragraphs, though the appendices were renumbered.
The disclosures sit in the general purpose financial reports (S1 ¶60), and material information can be included by cross-reference to another report if it is available on the same terms and at the same time (¶B45).
For a listed company, PS26/19 keeps the disclosures and any explanations in the annual financial report.
Placing them in the strategic report also brings them within the section 463 safe harbour, which the government has confirmed in its consultation response.
Before sign-off, the usual checks are a data accuracy review, a check against each paragraph, internal audit where it exists, a legal read of forward-looking statements, and board approval.
Common challenges
Where first reports get stuck, and what helps
Scope 3 data. Supplier data is often unavailable in a first year, so one route is a spend-based estimate refined with supplier data over time, with the method disclosed.
Listed companies also have a one-year Scope 3 relief, and a voluntary reporter can rely on UK SRS S2 ¶C4, which has no time limit.
Scenario expertise. Starting from a published scenario set, named and dated, is simpler than building one, and the depth required scales with the entity’s exposure.
Siloed systems. Connected information needs finance and sustainability to share data and assumptions, which is a governance decision before it is a systems one.
Financed emissions. Where they cannot be estimated for the same period as the financial statements, UK SRS S2 ¶B59A requires an explanation of why, which is stricter than the ISSB text.
Timing
What the dates mean for a first report
The FCA’s rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
A company whose period begins before that date can keep using the TCFD-aligned rules for it, or adopt UK SRS early (PS26/19 ¶3.19).
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.
The FRC’s sustainability reporting FAQs cover how the reliefs work for voluntary reporters.
What the rules require of a listed company is set out on our UK SRS compliance page, and the two standards themselves on our UK SRS standards page.
SRS Report is an independent reference site, but if it would help to talk through your UK SRS reporting position, you can book a free 15-minute call, or return to the SRS Report home page.
The first period in scope starts on 1 January 2027.
Its data has to be captured during 2027, for a report published in 2028.
Frequently asked
Questions people ask
Is there official UK SRS reporting guidance?
The standards carry their own application guidance in Appendix B of each, which has the same authority as the rest of the standard. The FRC publishes sustainability reporting FAQs. For listed companies, 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. This page is an independent summary, not guidance with any authority.
Where do I start with UK SRS reporting?
With materiality under UK SRS S1: identify the sustainability-related risks and opportunities that could reasonably be expected to affect the entity's cash flows, access to finance or cost of capital, and decide which information about them would influence the decisions of investors and lenders. Climate is always assessed under UK SRS S2. The data, governance and scenario work follow from that list.
Does UK SRS use double materiality?
No. UK SRS uses single, financial materiality: information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions of primary users of general purpose financial reports. Impact on people and the environment is relevant only where it feeds back into the entity's prospects. Double materiality is the EU's CSRD approach.
Where is a UK SRS report published?
As part of the entity's general purpose financial reports, at the same time as the financial statements (UK SRS S1 paragraphs 60 and 64). Listed companies put the disclosures and any explanations in their annual financial report. Information can be included by cross-reference to another report, provided it is available on the same terms and at the same time.
What does the statement of compliance say?
An entity that meets all the requirements makes an explicit and unreserved statement of compliance (UK SRS S1 paragraph 72). An entity using the climate-only relief may not assert compliance with UK SRS S1 and discloses the relief instead, though it may still assert compliance with UK SRS S2 if it discloses the reliefs used. A listed company using an FCA relief states its use in the annual financial report.
Do I have to report Scope 3 in the first year?
Not if you use the relief. For listed companies, PS26/19 gives a one-year Scope 3 relief from the start of the first period beginning in 2027, during which the company only states that it is using it. A voluntary reporter can rely on UK SRS S2 paragraph C4, which carries no time limit. After the relief, Scope 3 is reported or explained like every other disclosure.
Which climate scenarios should we use?
UK SRS S2 does not prescribe any. It requires scenario analysis commensurate with the entity's circumstances and disclosure of the scenarios used, their sources, and whether they align with the latest international agreement on climate change. Published reference sets, such as the NGFS scenarios or the IEA's Net Zero Emissions by 2050 scenario, can serve as a starting point, provided the report names the vintage used.
Does a UK SRS report need external assurance?
No. Assurance is not required under UK SRS or PS26/19. A listed company that obtains it names the provider, which disclosures were assured and the standards used. ISSA (UK) 5000, issued by the FRC for voluntary use, is effective for engagements on periods beginning on or after 15 December 2026.
Are directors protected for forward-looking UK SRS statements?
The government has confirmed that UK SRS disclosures included in the strategic report fall within the section 463 Companies Act safe harbour, which limits directors' liability to the company to cases of knowledge, recklessness or dishonest concealment. Disclosures placed outside the strategic report are not covered unless section 463 is expanded.
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, ¶¶3, 18, 20–24, 60–64, 72–73A, B45–B46, Appendices B and D (PDF)
Materiality, connected information, location, timing, cross-reference and compliance.
- Department for Business and TradeUK SRS S2, ¶¶10, 22, 29, B59A and Appendix C (PDF)
Climate risks, scenario analysis, metrics and the reliefs.
- Department for Business and TradeGovernment response to the UK SRS consultation, Chapter 3
The section 463 safe harbour for UK SRS disclosure in the strategic report.
- Department for Business and TradeConsultation response PDF, Annex A
The UK differences, including ¶B59A and the untimed reliefs.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Final rules, 30 September 2026.
- Financial Conduct AuthorityPS26/19 policy statement, ¶¶1.9, 2.24, 2.37, 2.45, 3.12–3.20 (PDF)
Location in the annual financial report, reliefs, transition plans, assurance and TN 803.1.
- IFRS FoundationIFRS Sustainability Standards Navigator
IFRS S1 and S2, issued June 2023, which UK SRS endorses.
- IFRS FoundationIFRS S2 (December 2025 text), ¶¶10, 22, 29, B8
The paragraph text UK SRS S2 carries.
- GHG ProtocolCorporate Accounting and Reporting Standard
Scope 1 and 2 measurement.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The Scope 3 categories to consider.
- Department for Energy Security and Net ZeroGovernment conversion factors for company reporting
UK emission factors, published annually.
- Network for Greening the Financial SystemNGFS Scenarios Portal
A reference scenario set; name the vintage.
- International Energy AgencyWEO 2025 — Net Zero Emissions by 2050 scenario
Published 12 November 2025; peaks around 1.65 °C about 2050.
- Financial Reporting CouncilISSA (UK) 5000, ¶15 (PDF)
Effective for periods beginning on or after 15 December 2026.
- Financial Reporting CouncilFRC issues ISSA (UK) 5000 (12 November 2025)
For voluntary use by UK assurance providers.
- Financial Reporting CouncilSustainability Reporting Developments: FAQs
The FRC on the reliefs and financed emissions.
- legislation.gov.ukCompanies Act 2006, section 463
The directors' liability safe harbour.