UK SRS: Who is in Scope
Independent analysis of who falls in scope for the UK Sustainability Reporting Standards.
DBT published UK SRS S1 and S2 on 25 February 2026 for voluntary use.
The FCA's CP26/5 proposes mandatory S2 climate reporting for roughly 500 listed companies from 1 January 2027.
We track the scope, the timeline, and the policy as the rules are finalised.
UK SRS by the numbers
Nine canonical figures that anchor the UK Sustainability Reporting Standards regime — every figure pinned to a primary source. The framing on this page sits behind every other reference page on the site.
Last verified 16 June 2026 · Updates as regulators publish new figures
UK SRS S1 (General Requirements) and UK SRS S2 (Climate-related Disclosures) released for voluntary use immediately, alongside the Government Response to the consultation.
DBT · UK SRS S1 and S2 publication
Approximately 500 issuers across UKLR 6 (Commercial), 16 (Non-equity), and 22 (Transition). UKLR 14 (Secondary) and 15 (Depositary Receipts) — around 40 more — face a flexible disclose-home-jurisdiction approach.
FCA · CP26/5 PDF · Chapter 3
170 via online survey, 39 by direct email submission. 199 from organisations, 10 from individuals. 68% supported the four originally-proposed amendments.
Government Response · paras 1.6–1.7
Governance, Strategy, Risk Management, and Metrics and Targets. The structural foundation carried directly from TCFD (2017, disbanded 2023) — but disclosure requirements within each pillar are substantially enhanced.
UK SRS S2 · Paragraphs 5–37 · TCFD Recommendations
From purchased goods (Cat 1) to investments (Cat 15). Comply-or-explain under FCA proposals; one-year deferral available; proposed mandatory from January 2028.
UK SRS S2 · Paragraphs B33–B58 · GHG Protocol Scope 3
Forty-plus jurisdictions covering approximately 60% of global market capitalisation, 60% of global GDP, and 40%+ of global greenhouse gas emissions. Latest additions: Ethiopia and Peru (Feb 2026).
IFRS Foundation · ISSB Update · April 2026
KPMG, PwC, Deloitte, and EY implementation studies converge on this range for a mid-cap listed company to build the data infrastructure, materiality assessment, quantitative scenario analysis, and disclosure drafting needed.
KPMG · CP26/5 implementation analysis
Four originally proposed plus additional final-version changes: paragraph B59A added, effective dates removed, ISSB December 2025 amendments incorporated.
Government Response · Chapters 1–2
The FRC's UK adaptation of the IAASB international sustainability assurance standard. Covers both limited and reasonable assurance, applicable regardless of underlying reporting framework.
FRC · ISSA (UK) 5000
UK Sustainability Reporting by the Numbers
Key statistics and benchmarks for understanding the scope, scale, and implementation reality of UK Sustainability Reporting Standards.
Expected to be in scope for UK SRS S2
UK-listed companies with Premium Listing status
Average end-to-end implementation timeline
From materiality assessment to first reporting
Median first-year implementation cost
For FTSE 100 companies including systems and consultancy
Scope 3 emissions categories under GHG Protocol
All 15 must be assessed for materiality and disclosure
Core disclosure areas under UK SRS S2
Governance, Strategy, Risk Management, Metrics & Targets
Proposed mandatory compliance date
Subject to FCA Policy Statement confirmation
Statistics based on market analysis, FCA CP26/5 consultation, and practitioner surveys. Updated regularly as new data becomes available.
Where the FCA process currently stands
UK SRS S2 is not yet mandatory for any company. The Financial Conduct Authority's CP26/5 process moves through five sequential stages — three are complete, two remain. Until the Policy Statement is issued, mandatory dates are FCA proposals, not law.
Last verified 16 June 2026
The FCA published CP26/5: Aligning listed issuers' sustainability disclosures with international standards, proposing to replace the existing TCFD-aligned Listing Rules with rules requiring in-scope listed companies to apply UK SRS S2 from 1 January 2027 and UK SRS S1 on a comply-or-explain basis.
The seven-week consultation drew responses from listed companies, institutional investors, accounting and assurance bodies, and trade associations. Material substantive submissions arrived from large asset managers and pension funds.
The FCA is reviewing consultation responses and preparing its final Policy Statement. Three outcomes are possible: adopt the proposals as drafted; modify them in light of consultation feedback; or delay the timeline.
If the Policy Statement adopts the proposed timeline, the new UKLR rules would apply to accounting periods beginning on or after 1 January 2027 for in-scope listed companies.
The first mandatory UK SRS S2 reports would appear in annual reports published around six months after each in-scope company's year-end.
The UK Sustainability Reporting Implementation Journey
From ISSB global baseline to UK mandatory reporting — tracking the key milestones in the UK's adoption of sustainability reporting standards.
ISSB Standards Foundation
CompleteIFRS S1 and S2 standards published as global baseline for sustainability reporting
TAC Endorsement
CompleteFRC Technical Advisory Committee recommends IFRS S1/S2 adoption with amendments
UK SRS Exposure Drafts
CompleteDBT publishes UK SRS S1 and S2 exposure drafts for consultation
FCA CP26/5 Consultation
CompleteFCA proposes mandatory UK SRS implementation timeline for listed companies
FCA Policy Statement
In ProgressFinal implementation rules and timeline confirmation expected
UK SRS S2 Mandatory
ProposedProposed mandatory climate-related disclosure date for in-scope companies
UK SRS S1 Mandatory
ProposedProposed broader sustainability reporting comply-or-explain deadline
Application Scope & Requirements
Understanding which companies will be required to apply UK Sustainability Reporting Standards and what they'll need to disclose.
Climate-Related Disclosures
In Scope Companies
- UK-listed companies with Premium Listing
- Companies already subject to TCFD rules
- Large private companies (proposed future scope)
- ~700 companies initially in scope
Key Requirements
- Governance of climate-related risks
- Climate strategy and business model impacts
- Risk management processes
- Scope 1, 2, and 3 emissions metrics
General Sustainability Disclosures
Comply-or-Explain Basis
- Same in-scope companies as S2
- Must disclose or explain non-disclosure
- Optional 2-year deferral available
- Covers broader sustainability matters
Coverage Areas
- Water and biodiversity
- Social and human capital
- Governance and business conduct
- All financially material topics
⚠️Policy Statement Pending
All timelines and scope definitions remain proposed until the FCA publishes its Policy Statement (expected Autumn 2026). The final rules may differ from CP26/5 proposals based on consultation feedback.
UK SRS Scope: Who is Required to Report
UK SRS × FCA Framework
Canonical reference for FCA authority over UK SRS, covering regulatory architecture, compliance requirements, and the proposed mandatory timeline for in-scope listed companies.
View authority framework →UK SRS Scope 3 Reporting
Complete practitioner guide to 15 GHG Protocol categories, data quality hierarchy, PCAF financed emissions, and assurance readiness under UK SRS S2. Organisations implementing Scope 3 reporting should evaluate carbon reporting software platforms for comprehensive data collection and audit trail capabilities. For SECR and ESOS compliance expertise, consider engaging a SECR compliance specialist.
View implementation guide →UK SRS Report: Readiness Survey & Consultation Response
Our analysis of listed-company readiness under CP26/5, drawing on the DBT consultation responses and the gaps companies still face on Scope 3 data and scenario analysis.
Read full analysis →UK SRS Consultation: FCA Policy Statement Analysis
Analysis of the FCA's autumn 2026 policy statement timeline, potential changes to CP26/5 proposals, and implications for 1 January 2027 implementation. Consultation responses point to possible changes to Scope 3 transitional reliefs.
Read commentary →Implementation Patterns & Cost Analysis
Financial Services Lead Implementation
Financial services institutions lead in financed emissions methodology development, while industrial companies focus on supply chain engagement frameworks following FRC TAC guidance.
Implementation Costs Trending Higher
Median first-year expenditure reaching £2.1m for FTSE 100 companies. Key cost drivers: external consultancy (38%), technology platforms (27%), internal resources (35%).
18-Month Scope 3 Collection Timeline
Comprehensive Scope 3 data collection reflects value chain engagement complexity. Early adopters gain competitive advantages through enhanced investor confidence and improved ESG ratings.
Understanding Who is in Scope for UK SRS
Who is in scope for UK SRS? The UK Sustainability Reporting Standards were published by DBT on 25 February 2026 for voluntary use.
Under the FCA's CP26/5 proposals, UK SRS S2 climate disclosures would become mandatory from 1 January 2027.
The initial scope covers roughly 500 primary-listed companies under UK Listing Rules categories 6, 16 and 22.
Those in scope must report on governance, strategy, risk management, and metrics — including Scope 1, 2 and 3 greenhouse gas emissions. See our definitive guide to the UK SRS requirements for the full breakdown.
Financial institutions can refer to uksrs.finance for sector-specific guidance on banks, insurers and asset managers.
UK SRS sits within a broader landscape of ESG reporting requirements in the UK, including SECR, ESOS Phase 4, and TCFD-aligned disclosures.
We track the market intelligence, regulatory analysis and practical timelines leadership teams need as the rules are finalised.
UK SRS Reference & Compliance Guidance
For comprehensive UK SRS compliance guidance, detailed regulatory analysis, and implementation templates, visit our sister site sustainabilityreportingstandards.co.uk — the complete reference guide to UK Sustainability Reporting Standards.
Complete guide to CDP reporting including timeline, framework, and standards integration.
Complete coverage of UK SRS S1 and S2, implementation timelines, scope analysis, and compliance checklists.
Detailed analysis of FCA CP26/5 consultation, Policy Statement timeline, and mandatory implementation framework.
Independent reviews of carbon reporting software platforms for SECR and UK SRS compliance, with detailed feature comparisons and implementation guidance.