UK SRS implementation trends: what companies are actually doing
With the FCA proposing mandatory UK SRS S2 reporting from 1 January 2027 for around 500 in-scope listed companies, the question is no longer whether to prepare but how.
This is a qualitative read of the directions of travel we can actually observe — the TCFD-to-UK SRS transition, the Scope 3 data build, scenario-analysis capability and assurance readiness.
We do not publish adoption percentages: no reliable primary source exists for them, so we describe behaviour rather than invent numbers.
A read of the direction of travel, not a scoreboard
There is a lot of confident commentary about how ready UK companies are for sustainability reporting, and most of it quotes adoption percentages that no one can source.
We take a different line.
The honest, sourceable picture is qualitative: we can see what in-scope companies are working on, because the standard and the proposed rules tell us what the gaps are.
The fixed points are clear. The Department for Business and Trade published UK SRS S1 and S2 for voluntary use on 25 February 2026[2], and the FCA has proposed making UK SRS S2 mandatory for accounting periods beginning on or after 1 January 2027 for around 500 primary-listed companies in UK Listing Rules categories 6, 16 and 22[1].
Everything below is about how companies are closing the distance between today and that date.
From TCFD compliance to UK SRS S2
Most in-scope companies are not starting from a blank page. They already report under the TCFD-aligned Listing Rules that have applied to premium-listed commercial companies since 2021[4].
UK SRS S2 retains the four TCFD pillars — governance, strategy, risk management, and metrics and targets — so the dominant transition activity is mapping existing disclosures across rather than rebuilding them from scratch[1].
The work that remains is closing the gaps the standard adds on top of TCFD: a sharper link between climate and the financial statements, fuller Scope 3 coverage, and more rigorous scenario analysis.
For the structural detail of what the standard requires, see our UK SRS requirements analysis and the TCFD vs UK SRS comparison.
| Pillar | Already covered under TCFD | Where UK SRS S2 raises the bar |
|---|---|---|
| Governance | Board oversight and management role | Connection to remuneration and integration into wider risk processes |
| Strategy | Qualitative risks and opportunities | Quantified, financially-connected scenario analysis |
| Risk management | Identification and assessment processes | Integration with enterprise-wide risk management |
| Metrics & targets | Scope 1 and 2 emissions, some Scope 3 | Fuller Scope 3 across the 15 value-chain categories |
The Scope 3 data build
For most in-scope companies, the single largest piece of preparation work is Scope 3 — the value-chain emissions that sit beyond their own operations and energy use.
The GHG Protocol Corporate Value Chain (Scope 3) Standard defines 15 categories of these emissions, split between upstream activities like purchased goods and services and downstream activities like the use of sold products[5].
They are hard precisely because the data sits with suppliers and customers rather than inside the company, which is why so much current activity is about building supplier data-collection and estimation capability.
The FCA has acknowledged the difficulty directly: under CP26/5, Scope 3 emissions move to a comply-or-explain basis with one year of transitional relief, applying from accounting periods beginning on or after 1 January 2028[1].
We set out the practicalities in our UK SRS Scope 3 reporting guide.
Building scenario-analysis capability
The most consequential capability gap is climate scenario analysis, and we know this from the regulator rather than from survey guesswork.
In its January 2025 thematic review of the first cycle of mandatory climate-related financial disclosures, the FRC found the quality of scenario analysis varied widely, with many companies offering only qualitative assessments[3].
Companies rarely explained their assumptions or quantified how different climate scenarios would affect the business, and the FRC recommended detailed, quantitative analyses tied directly to business strategy[3].
That is the bar UK SRS S2 expects companies to clear, so the observable trend is investment in modelling capability — in-house or bought in — to move from narrative scenarios to numbers.
Getting ready for assurance
Assurance is not yet mandatory — the FCA’s CP26/5 does not require UK SRS disclosures to be assured[1].
But the direction is set. The FRC published the voluntary UK sustainability assurance standard, ISSA (UK) 5000, on 12 November 2025, with effect from 15 December 2026[6].
The practical consequence is that the better-prepared companies are building auditable data trails — documented methodologies, source records and controls — so that their numbers could withstand assurance whether or not it is required in the first reporting cycles.
Treating data as if it will be assured is, in effect, the discipline that makes the rest of the implementation hold together.
Climate-first sequencing
The four trends are not parallel projects competing for attention — they fall into a sequence the rules themselves imply.
Climate comes first. UK SRS S2 is proposed as mandatory from 1 January 2027, while the broader, non-climate UK SRS S1 is proposed only on a comply-or-explain basis from 1 January 2029[1].
So the rational order of work is: convert the TCFD baseline to S2, build the Scope 3 data, harden scenario analysis, prepare for assurance — and leave the wider S1 disclosures to the later runway the timeline grants.
For the full set of dates in one place, see the UK SRS deadline tracker.
| Work-stream | Driven by | Why it comes when it does |
|---|---|---|
| Map TCFD disclosures to UK SRS S2 | Existing Listing Rules base | Lowest-effort starting point; the structure already exists |
| Build Scope 3 data | 15 GHG Protocol categories | Longest lead time; one-year relief runs to 2028 |
| Quantify scenario analysis | FRC review findings | Highest-scrutiny gap in first-cycle reporting |
| Prepare for assurance | ISSA (UK) 5000 (voluntary) | Discipline that underpins all of the above |
UK SRS implementation trends: frequently asked questions
What are the main UK SRS implementation trends right now?
With the FCA proposing mandatory UK SRS S2 reporting from 1 January 2027 for roughly 500 in-scope listed companies, the visible trends are: converting existing TCFD-aligned disclosures into the UK SRS S2 structure; building Scope 3 emissions data ahead of the one-year transitional relief that runs to 2028; strengthening climate scenario analysis, which the FRC found was the weakest area in first-cycle mandatory climate reporting; and preparing for assurance against the FRC’s ISSA (UK) 5000 standard. These are qualitative directions of travel, not adoption percentages — no reliable, primary-sourced figure exists for how far each company has progressed.
Who is actually in scope, and from when?
The FCA’s CP26/5 proposes that companies in UK Listing Rules categories 6, 16 and 22 — about 500 primary-listed companies — report against UK SRS S2 (climate) for accounting periods beginning on or after 1 January 2027. Scope 3 emissions move to a comply-or-explain basis with one year of transitional relief, and UK SRS S1 (non-climate) follows on a comply-or-explain basis from 1 January 2029. These remain FCA proposals until the Policy Statement, expected in autumn 2026.
Why does the TCFD-to-UK SRS transition matter for in-scope companies?
Most in-scope companies already report under the TCFD-aligned Listing Rules that have applied since 2021, so they are not starting from zero. UK SRS S2 retains the four TCFD pillars — governance, strategy, risk management, and metrics and targets — which lets companies map existing disclosures across rather than rebuild them. The work is in closing the gaps the standard adds, particularly on Scope 3, quantified scenario analysis and connection to the financial statements.
How much of the data-build effort is about Scope 3?
A large share of it. The GHG Protocol Corporate Value Chain (Scope 3) Standard defines 15 categories of value-chain emissions, and for many companies these dominate the total footprint while being the hardest to measure because the data sits with suppliers and customers. The FCA’s proposed one-year transitional relief for Scope 3 — comply-or-explain from accounting periods beginning on or after 1 January 2028 — is precisely a recognition of that difficulty.
What did the FRC find about scenario analysis quality?
In its January 2025 thematic review of the first cycle of mandatory climate-related financial disclosures, the FRC found the quality of scenario analysis varied widely, with many companies offering only qualitative assessments, rarely explaining their assumptions or quantifying the financial impact of different climate scenarios. The FRC recommended detailed, quantitative scenario analyses tied directly to business strategy — which is why scenario-analysis capability is a focus of pre-2027 preparation.
Is assurance mandatory yet?
No. The FCA’s CP26/5 does not mandate assurance of UK SRS disclosures. The FRC published the voluntary UK sustainability assurance standard, ISSA (UK) 5000, on 12 November 2025, effective 15 December 2026. Many in-scope companies are nonetheless treating assurance readiness — auditable data, documented methodologies and controls — as part of implementation, in anticipation of a future oversight regime.
- CP26/5: Aligning listed issuers’ sustainability disclosures with international standards — Financial Conduct Authority · Scope (UKLR 6, 16, 22), proposed dates, Scope 3 relief, S1 2029; closed 20 Mar 2026
- UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — GOV.UK / Department for Business and Trade · Standards published 25 February 2026; available for voluntary use
- Thematic Review: Climate-related Financial Disclosures by AIM and Large Private Companies — Financial Reporting Council · Published 21 January 2025; findings on governance, Scope 3 and scenario-analysis quality
- Review of TCFD-aligned disclosures by premium listed commercial companies — Financial Conduct Authority · Baseline practice on TCFD-aligned reporting that UK SRS S2 builds upon
- Corporate Value Chain (Scope 3) Accounting and Reporting Standard — GHG Protocol · 15 categories of value-chain emissions, split upstream and downstream
- FRC issues ISSA (UK) 5000 sustainability assurance standard — Financial Reporting Council · Voluntary UK assurance standard, published 12 Nov 2025; effective 15 Dec 2026