Analysis · UK SRS readiness
UK SRS readiness checklist: a self-assessment
UK SRS readiness now has a fixed date: the FCA’s final rules in PS26/19 apply to accounting periods beginning on or after 1 January 2027, on a comply-or-explain basis.
This is not a survey of how ready the market is; no primary source measures that, and we have not run one.
It is a checklist for testing your own company, built around one idea: under comply or explain, you can be ready to comply, or ready to explain well.
A note on evidence
Why this is a checklist, not a survey
Readiness is often reported as a percentage of companies that are “prepared”.
We publish no such figure, because we know of no primary survey that measures UK SRS readiness, and this site has not run one.
The best official evidence is qualitative and comes from the FCA itself.
PS26/19 says the existing TCFD-aligned rules have supported high levels of disclosure among the largest issuers, and that respondents saw UK SRS as a significant expansion that will need time to build capability, systems, controls and data quality.
The last formal measurement of listed-company climate reporting is the FCA’s 2022 review of TCFD-aligned disclosures, which found the most common gaps in the quantitative elements, such as scenario analysis and metrics and targets.
What the regulators’ reviews found, in more detail, is on our page on UK climate reporting reviews.
TCFD-aligned rules “have supported high levels of disclosure, particularly among the largest issuers” (PS26/19 ¶1.5).
Respondents said UK SRS “represents a significant expansion from TCFD-aligned reporting” (¶2.83).
Listed companies asked for time to build data systems, governance and controls (¶2.15).
Who, and by when
Your first three periods, and what each asks
The FCA rules phase in by accounting period, not by calendar year. This is what each period asks of a company in scope.
| Accounting period beginning | UK SRS S2 (climate) | Scope 3 | UK SRS S1 (beyond climate) |
|---|---|---|---|
| Before 1 January 2027 | TCFD-aligned rules continue, or adopt UK SRS early | Early adopters may use the relief | Early adopters may use the relief |
| 1 January 2027 to before 1 January 2028 | Comply or explain | Relief available: state that it is used | Relief available: state that it is used |
| 1 January 2028 to before 1 January 2029 | Comply or explain | Comply or explain | Relief available: state that it is used |
| On or after 1 January 2029 | Comply or explain | Comply or explain | Comply or explain |
In scope are companies in UKLR 6, 14, 15, 16 and 22; funds, shell companies and debt and miscellaneous securities are excluded.
The disclosures go in the annual financial report, which DTR 4.1.3R requires within four months of the year-end, so first reports appear during 2028.
Any company can also prepare on its own terms: the standards have been available for voluntary use since 25 February 2026.
For the scope mechanics see the FCA’s UK SRS rules, and for your own dates the UK SRS deadline page.
Our read
Two finishing lines: comply, or explain well
Under CP26/5, readiness for UK SRS S2 would have meant one thing: being able to comply.
Under the final rules it can mean either of two things.
A company is ready to comply when it can make the disclosures in accordance with UK SRS.
It is ready to explain when it can set out, for UK SRS S2, a summary of the requirements not met, the reasons and any steps it plans, and, for UK SRS S1, the risks or opportunities not disclosed and why.
The FCA’s draft Technical Note 803.1 says an explanation can be short and proportionate but should not omit material information, and describes good explanations as clear, concise, cogent and issuer-specific.
It is draft guidance, open for comment until 28 October 2026.
In our view, being ready to explain is harder than it sounds: a reason a board can defend requires the company to know why it cannot comply, which means doing much of the analysis anyway.
The mechanics are set out on our UK SRS comply or explain page.
What a UK SRS S2 explanation must contain
| UKLR 6.6.6R(7A)(b) | In practice |
|---|---|
| (i) a summary of the requirements not met | Named by heading or paragraph |
| (ii) the reasons | Specific to the company, not generic |
| (iii) any steps taken or planned | No timeframe required |
Sources: UKLR 6.6.6R(7A) as made (PS26/19 Appendix 1); draft TN 803.1
The checklist
Twelve questions to test your readiness
For each area, answer the question and compare your evidence with the right-hand columns. It carries no score: readiness is a direction of travel, not a percentage.
| Area | Question to ask | Ready to comply looks like | Ready to explain looks like |
|---|---|---|---|
| Scope and dates | Which listing category are we in, and when does our first period begin? | Category and first period confirmed and minuted | Same: this one cannot be explained |
| Governance | Who on the board owns the UK SRS disclosures, and where are they discussed? | A named owner and a standing board or committee slot | A named owner who has approved what will be explained and why |
| Materiality | Can we say which risks and opportunities could affect cash flows, access to finance or cost of capital? | A documented assessment under UK SRS S1 ¶¶3 and 18 | A documented assessment that identifies what is not yet covered |
| Scope 1 and 2 | Can we produce these reliably each year? | Source data, method and controls an assurer could follow | In our view a weak candidate for explaining where the company already reports under SECR |
| Scope 3 | Which of the fifteen categories matter, and do we have supplier data? | A category screen and data plan in motion | Relief used for the first period, then reasons and planned steps |
| Scenario analysis | Does our analysis test the resilience of strategy, and does it reach the board? | Analysis used in strategic and capital decisions | A clear account of what exists, what is missing and the plan |
| Metrics and targets | Which climate targets do we have, and how do we measure progress? | Targets, KPIs and their calculation disclosed | A statement of which requirements are not met and why |
| UK SRS S1 beyond climate | Which other sustainability risks and opportunities are material? | An assessment ready before the relief ends | Relief used for two periods, then risks named and reasons given |
| Explanations | For each requirement we will not meet, can we give company-specific reasons? | Not applicable | Drafted explanations, tested against draft TN 803.1 |
| Location | Where in the annual financial report will the disclosures sit? | Placement agreed; any cross-reference meets UK SRS S1 ¶¶B45–B47 | Same |
| Transition plan statement | Have we published a transition plan, and where? | Location ready to state (UKLR 6, 16, 22) | Reasons ready if none is published |
| Assurance statement | Will we obtain assurance, and over what? | Provider, scope, level and standard ready to name | A statement that none was obtained |
The steepest climb
Scope 3 and scenario analysis take longest
Two capabilities have the longest lead times, and both depend on people outside the reporting team.
Scope 3 emissions. UK SRS S2 requires an entity to consider all fifteen categories of the GHG Protocol Scope 3 Standard and disclose which it includes.
The data sits with suppliers and customers, so the work of collecting it starts long before the report.
The one-year relief exists because this is hard; treating the first period as build time, not a pause, is what readiness looks like here.
The detail is in UK SRS Scope 3 reporting.
Scenario analysis. UK SRS S2 asks for the resilience of strategy and business model to climate change, informed by scenario analysis.
It was among the most common gaps when the FCA reviewed the first TCFD-aligned reports, and some listed companies asked the FCA to let them explain against it, which the final rules now allow.
The method is covered in climate scenario analysis under UK SRS.
Assurance readiness
Build as if it will be assured
Assurance is voluntary under the FCA rules, but the annual financial report must say whether it was obtained.
The FRC’s ISSA (UK) 5000 is available for voluntary use and takes effect for periods beginning on or after 15 December 2026.
The FCA says it will keep the case for mandatory assurance under review.
Data assembled in spreadsheets without an audit trail is expensive to make assurable after the event, so records of sources, factor versions, estimates and approvals are worth building in from the first period.
The FCA’s own list of nine preparation steps, from Primary Market Bulletin 66, is set out in order on our UK SRS compliance checklist.
A structured route through the build is in the UK SRS implementation guide; what the standards require, pillar by pillar, is on our UK SRS requirements page and in the family’s reference on UK SRS requirements.
The CP26/5 consultation explains why the regime took its final shape, and you can book a free 15-minute call to test your own answers.
Frequently asked
Questions people ask
Who needs to be ready for UK SRS?
Listed companies in UK Listing Rules categories 6, 14, 15, 16 and 22. Under the FCA's final rules in PS26/19 they must report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. Closed-ended and open-ended funds, shell companies, and debt and miscellaneous securities are excluded. No other UK entity is required to use UK SRS, though any entity may use it voluntarily.
Is there a UK SRS readiness survey?
Not one this site can cite. We have not run a survey and know of no primary-source survey measuring how ready UK listed companies are for UK SRS. The closest official evidence is the FCA's own account: PS26/19 says the TCFD-aligned rules have supported high levels of disclosure, particularly among the largest issuers, and that respondents described UK SRS as a significant expansion from TCFD-aligned reporting. This page is a self-assessment checklist instead.
When does a company need to be ready?
From the start of its first accounting period beginning on or after 1 January 2027, because the data for that period is collected during it. The report itself goes in the annual financial report, due within four months of the year-end under DTR 4.1.3R, so the first reports appear in 2028. The Scope 3 relief covers periods beginning before 1 January 2028 and the UK SRS S1 relief periods beginning before 1 January 2029.
What is the hardest UK SRS capability to build?
Usually Scope 3 emissions data, because it sits with suppliers and customers; UK SRS S2 requires an entity to consider all fifteen GHG Protocol Scope 3 categories. Scenario analysis is the other common gap: the FCA's 2022 review of TCFD-aligned disclosures found the most common gaps were in the quantitative elements, such as scenario analysis and metrics and targets.
Can a company be ready without complying in full?
Yes. Under comply or explain, a company that cannot yet meet a UK SRS S2 requirement may instead summarise the unmet requirements, give its reasons and set out any steps it is taking or plans to take. Being ready to explain well, with issuer-specific reasons a board can stand behind, is a legitimate state of readiness for a first period. The FCA's draft Technical Note 803.1 describes a good explanation as clear, concise, cogent and issuer-specific.
Does UK SRS readiness require assurance?
No. The FCA rules require a statement of whether assurance was obtained, and if so the provider, scope, level and standards used. Assurance itself is voluntary. The FRC's ISSA (UK) 5000 is available for voluntary use and takes effect for periods beginning on or after 15 December 2026. Designing data and controls so that they could be assured is still sensible readiness work.
Where should a company start?
With its listing category and year-end, which fix whether and when the rules apply. Then governance and materiality, because they decide what must be measured and who signs it off. Then emissions data, scenario analysis and the controls behind them. Decide early where you expect to comply and where you expect to explain, and read the FCA's draft Technical Note 803.1, which is open for comment until 28 October 2026.
Does readiness mean publishing a transition plan?
No. The FCA does not require listed companies to produce a transition plan. Companies in UKLR 6, 16 and 22 must state whether they have published one and where, or why they have not. The statement does not apply to secondary listings or depositary receipts.
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 (PDF)
Scope (¶¶3.6–3.7), dates and reliefs (¶¶3.12–3.24), the state of TCFD reporting (¶1.5), issuers' need for time (¶2.15), "a significant expansion" (¶2.83), and the made rules in Appendix 1.
- Financial Conduct AuthorityPS26/19 landing page
First published 30 September 2026: comply or explain across UK SRS; Technical Note feedback by 28 October 2026; FCA webinar on 19 October 2026; supervisory information in the second half of 2027.
- FCA HandbookUKLR 6.6 — annual financial report (commercial companies)
UKLR 6.6.6R(7A) and (7B) as made (disclose or explain), and (8)(c)–(e): location, assurance and transition-plan statements.
- Financial Conduct AuthorityDraft Technical Note 803.1 — UK SRS sustainability disclosures for listed companies (PDF, for consultation)
Draft guidance: what an explanation must contain, proportionality, the statement of compliance (Annex 1) and four illustrative explanations (Annex 2).
- Financial Conduct AuthorityPrimary Market Bulletin 66 — draft Technical Note 803.1 (comply or explain)
Published 30 September 2026: consults on TN 803.1, TN 801.4 updates and deleting TN 802.3; comments to primarymarketbulletin@fca.org.uk by 28 October 2026; nine preparation steps.
- FCA HandbookDTR 4.1 — annual financial report
DTR 4.1.3R: annual financial report within four months of the year-end.
- Financial Conduct AuthorityCP26/5 consultation page
The consultation the final rules answer.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
UK SRS S1 and S2 published 25 February 2026; voluntary for any entity.
- Department for Business and TradeUK SRS S1 General Requirements (PDF)
¶3 (risks and opportunities), ¶18 (materiality), ¶¶B45–B47 (cross-reference).
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF)
Governance, strategy, risk management, metrics and targets; ¶B32 on Scope 3 categories.
- Financial Conduct AuthorityReview of TCFD-aligned disclosures by premium listed commercial companies (July 2022)
The most common gaps were in the quantitative elements, such as scenario analysis and metrics and targets.
- Financial Reporting CouncilISSA (UK) 5000 — the UK sustainability assurance standard
Issued for voluntary use; effective for periods beginning on or after 15 December 2026.
- GHG ProtocolCorporate Value Chain (Scope 3) Accounting and Reporting Standard
The fifteen Scope 3 categories.
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