UK SRS readiness: what good preparation looks like

Why this page has no readiness percentages

Readiness is often discussed in the language of surveys — a headline percentage of companies that are “prepared”, another that have “begun”.

We do not publish those figures, because there is no primary survey we can stand behind.

On this site, a number without a primary source is removed rather than paraphrased.

So instead of inventing a measurement of the market, we describe what good preparation actually consists of, and let in-scope companies judge their own position against it.

Who needs to be ready, and by when

Under the FCA’s CP26/5 proposals, mandatory UK SRS S2 climate reporting would apply to listed companies in UK Listing Rules categories 6, 16 and 22 — around 500 primary-listed companies — for accounting periods beginning on or after 1 January 2027^[1].

Scope 3 emissions move to a comply-or-explain basis from 1 January 2028 after a one-year transitional relief, and UK SRS S1 non-climate disclosures follow on comply-or-explain from 1 January 2029^[1].

These dates remain FCA proposals until the Policy Statement, expected in autumn 2026, is published^[1]. Any company can also prepare on its own terms: the standards have been available for voluntary use since 25 February 2026^[2].

For the precise scope mechanics, see our UK SRS × FCA framework and the deadline tracker.

What good preparation looks like

UK SRS S2 keeps the four-pillar structure inherited from the TCFD — governance, strategy, risk management, and metrics and targets^[2]. Readiness, in practice, means building capability across five connected areas that sit beneath those pillars.

Governance and materiality come first

Governance and materiality are the foundation because they determine the shape of everything downstream. UK SRS S2 opens with the governance pillar, and the UK amendments reinforce board-level accountability for climate oversight^[2].

Good governance readiness rarely means a new committee.

More often it means folding climate oversight into the board and audit-committee routines that already exist, with a named role accountable for the disclosures.

Materiality is the other foundation. UK SRS uses an enterprise-value materiality lens — the question is which sustainability matters could reasonably affect the company’s prospects, judged from an investor’s point of view^[2]. A documented assessment that can be explained and defended is itself a readiness asset.

For what the standards require pillar by pillar, see our UK SRS requirements analysis.

GHG data: Scope 1, 2 and especially Scope 3

Emissions data is where readiness is most often tested. UK SRS S2 follows the GHG Protocol, which splits emissions into Scope 1 (direct), Scope 2 (purchased energy) and Scope 3 (the value chain)^[2].

Scope 1 and 2 are usually tractable, because they rest on a company’s own meters, fuel use and energy invoices.

The work there is about repeatability and controls, not about finding the data.

Scope 3 is the steep climb. The GHG Protocol sets out fifteen Scope 3 categories spanning upstream and downstream activity, and the data lives with suppliers and customers rather than inside the company^[4].

The one-year transitional relief that defers mandatory Scope 3 reporting to 1 January 2028 exists precisely because this data is harder to assemble^[1]. Treating that year as build time — not as a pause — is what readiness looks like here.

We go deeper on the value chain in our UK SRS Scope 3 reporting analysis.

Scenario analysis and assurance readiness

Scenario analysis sits under the strategy pillar. UK SRS S2 asks companies to assess the resilience of their strategy to climate-related risks, which in practice means testing the business model against different climate pathways^[2].

The readiness signal here is whether scenario analysis informs strategy or merely decorates a report.

Analysis that feeds capital allocation and risk appetite is robust; analysis bolted on at the end is not.

Assurance readiness is the final discipline. The FCA does not propose to mandate assurance in CP26/5^[1], but the FRC has published the voluntary UK sustainability assurance standard, ISSA (UK) 5000, finalised on 12 November 2025 and effective from 15 December 2026^[3].

Designing data, controls and audit trails so that disclosures could withstand external limited assurance is sensible even where assurance is not yet required — and it is far cheaper to build in than to retrofit.

The gaps that appear most often

Across the capability areas, the same weak points recur.

We set them out as patterns to check against, not as measured frequencies — we have no sourced survey to quantify them.

Scope 3 left until last. Because it is the hardest, value-chain data is often deferred — but it is also the area with the longest lead time, since it depends on suppliers responding.

Materiality treated as a formality. A materiality assessment produced to tick a box, rather than to genuinely shape what is governed and measured, leaves the rest of the disclosure without an anchor.

Scenario analysis disconnected from strategy. Analysis that never reaches the board or capital plan satisfies the letter of the strategy pillar while missing its intent.

Controls bolted on late. Data assembled in spreadsheets without an audit trail is expensive to make assurance-ready after the fact.

A readiness checklist

Use the following as a structured self-assessment.

It mirrors the five capability areas and the dates that frame them, and it deliberately carries no scoring — readiness is a direction of travel, not a percentage.

A step-by-step path through the work is in our UK SRS implementation guide.

UK SRS readiness: frequently asked questions