The FCA Policy Statement: why the autumn 2026 window matters
The FCA consulted, listed companies responded, and the consultation closed on 20 March 2026.
What remains is the single most consequential document left on the calendar: the Policy Statement that turns CP26/5 from proposal into rule.
This is our reading of the three outcomes it could deliver, what is at stake for the roughly 500 companies in scope, and why the timing of that autumn 2026 window is the part to watch.
Where the timing stands
On 30 January 2026 the FCA published Consultation Paper CP26/5, “Aligning listed issuers’ sustainability disclosures with international standards”[1].
The consultation ran for seven weeks and closed on 20 March 2026[1].
The FCA has said it will review the feedback and aims to publish a Policy Statement in autumn 2026, subject to the final UK SRS, with the rules coming into force from 1 January 2027[1].
Until that Policy Statement is issued, the mandatory dates in CP26/5 are proposals, not law.
That is the distinction this page is about.
Three outcomes the Policy Statement could deliver
A Policy Statement is not a formality. The FCA has been explicit that its final rules are subject to the feedback received and to the final UK SRS[1].
Three broad outcomes are worth distinguishing, because each changes the work in-scope companies should be doing now.
| Outcome | What it would look like | Implication for reporters |
|---|---|---|
| Adopt as drafted | The FCA confirms CP26/5 substantially unchanged | The working assumptions hold; preparation continues to plan |
| Modify after feedback | Changes to the comply-or-explain perimeter, transitional reliefs or guidance | Re-test the gap analysis against the final wording |
| Adjust the timeline | A deferral of the proposed 1 Jan 2027 start date | More runway, but no reason to pause governance and data work |
The first outcome is the path of least disruption: the proposals become the rule, and the preparation already under way simply continues.
The second is the most likely source of detail to watch. CP26/5 itself proposes a comply-or-explain approach for some of the newer or more challenging aspects of reporting, and that perimeter is exactly the kind of design choice feedback can move[1].
The third — a timing change — is the one reporters tend to hope for and should plan least around.
A later start date would relieve pressure, but the underlying capability work does not get easier for being deferred.
What is at stake, and for whom
CP26/5 proposed that the new UK SRS-aligned rules apply to companies in UK Listing Rules categories 6, 16 and 22 — commercial companies, non-equity and non-voting equity shares, and the transition category[2].
Commentary on the consultation describes this as roughly 500 primary-listed companies[2].
For those companies, the proposal is mandatory reporting against UK SRS S2 on climate, with Scope 3 emissions and the broader UK SRS S1 disclosures on a comply-or-explain basis[1].
Secondary listings and depositary receipts in UKLR categories 14 and 15 would instead make a transparency statement identifying the home-jurisdiction standard they follow, rather than reporting against UK SRS in full[2].
| Requirement | Who | From | Basis |
|---|---|---|---|
| UK SRS S2 climate (excluding Scope 3) | ~500 primary-listed cos (UKLR 6, 16, 22) | FY beginning on/after 1 Jan 2027 | Mandatory |
| Scope 3 emissions | Same in-scope companies | FY beginning on/after 1 Jan 2028 | Comply-or-explain (1-yr relief) |
| UK SRS S1 (non-climate) | Same in-scope companies | FY beginning on/after 1 Jan 2029 | Comply-or-explain (2-yr relief) |
| Transparency statement only | Secondary listings & depositary receipts (UKLR 14, 15) | FY beginning on/after 1 Jan 2027 | State home-jurisdiction standard |
The standards themselves are already settled. DBT published the final UK SRS S1 and S2 on 25 February 2026, available for voluntary use, so the Policy Statement is about the listing-rule obligation rather than the content of the standards[3].
For the full picture of who falls in scope, see our UK SRS × FCA framework.
Why the autumn 2026 window matters
The proposed rules apply to accounting periods beginning on or after 1 January 2027[1].
A company with a calendar-year financial year would therefore begin its first in-scope period only weeks after an autumn 2026 Policy Statement.
That is a narrow runway between final rules and first reporting period — and the closer the Policy Statement slips toward the year end, the narrower it becomes.
The point is not that companies are waiting on the Policy Statement to start work.
The standards are published and the proposals are public.
The point is that the document removes the last uncertainty just as the first proposed period opens, so anything left until then is left late.
For the full sequence of dates from publication to mandatory reporting, see our deadline tracker and the wider consultation tracker.
What to do before the Policy Statement lands
Treat the CP26/5 proposals as the working baseline rather than waiting for confirmation.
Map your governance, strategy, risk management and metrics against UK SRS S2, the four-pillar structure the standard inherits from the ISSB framework[3].
Identify Scope 3 data gaps early, since the comply-or-explain basis still requires a defensible explanation where you cannot yet report[1].
Confirm the accounting-period start date that governs when any mandatory requirement first applies, and remember that the section 414CB(2A) designation applies whether UK SRS is adopted voluntarily or mandatorily[5].
Done before autumn 2026, this work means the Policy Statement confirms or refines a plan already in motion — rather than starting the clock.
FCA Policy Statement timing: frequently asked questions
When will the FCA publish its UK SRS Policy Statement?
The FCA has said it aims to publish a Policy Statement in autumn 2026, subject to the final UK SRS, with the new rules coming into force from 1 January 2027 for accounting periods beginning on or after that date. The CP26/5 consultation closed on 20 March 2026, so the Policy Statement is the next formal milestone. Until it is issued, the mandatory dates set out in CP26/5 remain FCA proposals rather than law.
What is FCA CP26/5?
CP26/5, "Aligning listed issuers’ sustainability disclosures with international standards", is the FCA consultation published on 30 January 2026. It proposed replacing the existing TCFD-aligned Listing Rules with rules requiring in-scope listed companies in UK Listing Rules categories 6, 16 and 22 to report against UK SRS S2 from 1 January 2027, with Scope 3 emissions and UK SRS S1 on a comply-or-explain basis. The consultation closed on 20 March 2026.
Which outcomes are possible from the Policy Statement?
Broadly three. The FCA could adopt the CP26/5 proposals as drafted; modify them in light of consultation feedback, for example by adjusting the comply-or-explain perimeter or the transitional reliefs; or adjust the timeline, deferring the 1 January 2027 start date. The FCA has been explicit that the Policy Statement is subject to the final UK SRS and to the feedback it received, so some change from the consultation draft is possible.
Who is in scope of the proposed rules?
CP26/5 proposed that the new UK SRS-aligned rules apply to companies in UK Listing Rules categories 6 (commercial companies), 16 (non-equity shares and non-voting equity shares) and 22 (transition). Commentary on the consultation describes this as roughly 500 primary-listed companies. Secondary listings and depositary receipts in UKLR categories 14 and 15 would instead make a transparency statement identifying the home-jurisdiction standard they follow.
Why does the autumn 2026 window matter?
Because the proposed first mandatory reporting applies to accounting periods beginning on or after 1 January 2027, a company with a calendar-year financial year would begin its first in-scope period only weeks after an autumn 2026 Policy Statement. The closer the Policy Statement slips toward the year end, the shorter the runway between final rules and the first reporting period. That compression is the central timing risk for in-scope reporters.
What should in-scope companies do before the Policy Statement?
Treat the CP26/5 proposals as the working baseline. Map your governance, strategy, risk management and metrics against UK SRS S2; identify Scope 3 data gaps; and confirm your accounting-period start date, since that determines when any mandatory requirement first bites. Doing this work before the Policy Statement means the document confirms or refines a plan already underway, rather than starting the clock.
- CP26/5: Aligning listed issuers’ sustainability disclosures with international standards — Financial Conduct Authority · Published 30 Jan 2026; closed 20 Mar 2026; Policy Statement expected autumn 2026; rules from 1 Jan 2027
- CP26/5 consultation paper (PDF) — Financial Conduct Authority · Scope (UKLR 6, 14, 15, 16, 22), transitional reliefs and implementation detail
- UK Sustainability Reporting Standards (guidance) — GOV.UK / Department for Business and Trade · UK SRS S1 and S2 published 25 February 2026; available for voluntary use
- UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — GOV.UK / DBT · Final standards and government response, 25 February 2026
- Sustainability reporting developments: frequently asked questions — Financial Reporting Council · Section 414CB(2A) designation applies to voluntary and mandatory adopters alike