Commentary · FCA Policy Statement
The FCA Policy Statement: what PS26/19 decided
The FCA Policy Statement on UK SRS arrived on 30 September 2026 as PS26/19, inside the autumn window the FCA had given.
It did not simply confirm CP26/5: the final rules put all of UK SRS on a comply-or-explain basis, from accounting periods beginning on or after 1 January 2027.
This is our reading of how the wait ended, which of the outcomes we set out came to pass, and what the timing leaves a listed company to do.
How the wait ended
Eight months from consultation to final rules
The FCA published CP26/5 on 30 January 2026 and closed it on 20 March 2026.
Its consultation page said the FCA would review the feedback and aim to publish a Policy Statement in autumn 2026.
That is what happened: the FCA Board made the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026 on 24 September 2026, and PS26/19 followed on 30 September.
The Policy Statement gives the instrument no FCA number, so neither do we.
The content of the standards was never in play at this stage.
DBT had already published the final UK SRS S2 and UK SRS S1 on 25 February 2026 for voluntary use, and the government’s guidance still describes them as available to any entity that chooses to use them.
What the Policy Statement decided was the listing-rule obligation: who must report against UK SRS, on what basis, and from when.
The full rulebook is set out on our page on the FCA’s UK SRS rules.
From proposal to first report
- 30 Jan 2026CP26/5 published
Proposes mandatory UK SRS S2, excluding Scope 3.
- 25 Feb 2026UK SRS S1 and S2 published
DBT; available for voluntary use.
- 20 Mar 2026CP26/5 closes
The FCA says it aims to publish in autumn 2026.
- 24 Sep 2026Instrument made
By order of the FCA Board.
- 30 Sep 2026PS26/19 published
With PMB 66 and draft TN 803.1.
- 28 Oct 2026Guidance comments close
Draft TN 803.1, TN 801.4 updates, TN 802.3 deletion.
- 1 Jan 2027Rules in force
Periods beginning on or after this date.
- 2028First reports
In annual financial reports for the first in-scope period.
Sources: FCA CP26/5 page; DBT; FCA PS26/19 ¶¶1.9, 3.12, Appendix 1
Forecast against outcome
Three outcomes we set out, and the one that happened
Before publication, this page set out three broad outcomes a Policy Statement could deliver. Here is how each one played out.
| Outcome we described | What PS26/19 did | Verdict |
|---|---|---|
| Adopt CP26/5 as drafted | Did not happen. The proposed mandatory basis for UK SRS S2 was dropped, and the signposting route for UKLR 14 and 15 was replaced. | No |
| Modify after feedback | Happened. Comply or explain now runs "across all categories of disclosures" (¶1.7); secondary listings and depositary receipts report against UK SRS; early adopters may use the reliefs (¶3.19). | Yes |
| Adjust the timeline | Did not happen. The FCA kept "the implementation timelines we consulted on" (¶1.11): periods from 1 January 2027, a 1-year Scope 3 relief, a 2-year UK SRS S1 relief. | No |
The modification was larger than the second row of our old table implied.
We had pictured changes at the edges of comply or explain, such as the reliefs or the guidance.
Instead the FCA moved the centre: UK SRS S2 climate reporting, which CP26/5 would have made mandatory, now sits on the same comply-or-explain footing as Scope 3 and UK SRS S1.
The FCA’s own reasoning, in PS26/19 paragraph 1.2, is that a comply-or-explain approach lets issuers reflect differences in business model, strategy and risk profile instead of applying the standards mechanically.
Paragraph 1.8 then says the changes from the consultation “are not viewed as significant” when set against both the proposals and the existing TCFD-aligned rules, which were already comply or explain.
That is a fair description of the legal basis, since listed companies have reported on comply or explain since the TCFD rule began.
It understates the change in signal, in our view: the consultation told the market that climate reporting was about to become compulsory, and the final rules say it is not.
Who pushed for each change, and who did not get what they asked for, is the subject of our commentary on the industry response to CP26/5.
What the timing settled
Four questions the Policy Statement closed
The most practical thing the Policy Statement did was end the ambiguity over the relief periods.
CP26/5 described a one-year Scope 3 relief and a two-year relief for UK SRS S1, but the final standards DBT published in February carry no fixed time limit on those reliefs.
PS26/19 explains why: the standards now say that where an entity must apply them under UK law or regulation, the application of the reliefs is decided by the FCA’s rules or government regulations.
The FCA’s rules now fix them, in UKLR TP 16: the Scope 3 relief covers periods beginning on or after 1 January 2027 and before 1 January 2028, and the UK SRS S1 relief the following year as well.
A company using a relief states that it is doing so, and PS26/19 paragraph 3.20 says no further explanation is needed during the relief period.
When a relief expires nothing becomes mandatory; the matter moves onto the comply-or-explain rule like everything else (¶¶3.23–3.24).
The mechanics of an explanation are set out on our page on UK SRS comply or explain.
| Question open before 30 Sep | Answer in PS26/19 |
|---|---|
| Mandatory or comply or explain? | Comply or explain across all UK SRS (¶¶1.2, 1.7) |
| Start date? | Periods beginning on or after 1 January 2027 (¶3.12) |
| How long do the reliefs run? | Scope 3: 1 year; UK SRS S1 beyond climate: 2 years (¶3.14) |
| Can early adopters use the reliefs? | Yes (¶3.19), reversing CP26/5 |
The runway
About three months to the first period
Before publication, this page warned that an autumn Policy Statement would leave a narrow runway before the first proposed period.
That runway is now measurable.
A company with a calendar financial year starts its first in-scope period on 1 January 2027, about three months after the rules were published.
The guidance on how to explain is shorter still on certainty: draft Technical Note 803.1 is out for comment until 28 October 2026, and the FCA aims to finalise it before the rules come into force.
Two things make the squeeze smaller than it looks.
First, the obligation bites on the annual financial report, which DTR 4.1.3R requires within four months of the year-end, so a 2027 period is reported during 2028.
Second, comply or explain means a company that is not ready for a requirement can say so, with reasons and (for UK SRS S2) the steps it plans to take.
Our view is that the real deadline is not 1 January 2027 but the point in 2027 by which data for the period must be captured: emissions, governance evidence and risk analysis for a year that has already begun cannot be reconstructed cheaply at year-end.
Every year-end, worked through to its first reporting date, is on the UK SRS deadline page.
Rules published: 30 September 2026.
First in-scope period starts: 1 January 2027.
Guidance: draft until after 28 October 2026.
Annual financial report due: by 30 April 2028, under DTR 4.1.3R.
Still open
What the Policy Statement left for later
| Open item | Who decides | When |
|---|---|---|
| Technical Note 803.1 on comply or explain | FCA (draft guidance) | Comments by 28 October 2026; to be finalised before 1 January 2027 |
| TN 801.4 updates and deletion of TN 802.3 | FCA, consulted on in PMB 66 | Same deadline, 28 October 2026 |
| FCA webinar on the new requirements | FCA | 19 October 2026 |
| Supervisory approach to UK SRS | FCA, with the FRC | Second half of 2027, before the first reporting season |
| Mandatory assurance | FCA keeps the case "under review" | No date |
| Modernising corporate reporting | Government consultation | Closes 30 November 2026 |
| Transition plan requirements | Government | Consultation closed 17 September 2025; no outcome published when last checked |
Draft TN 803.1 is proposed guidance, not final, and it matters more than its status suggests.
It is where the FCA sets out how much detail an explanation needs, gives examples, and deals with the interaction between comply or explain and the UK SRS statement of compliance.
Comments go to the address given in Primary Market Bulletin 66 by 28 October 2026.
PS26/19 also says the FCA does not expect to carry out a formal post-implementation review, relying instead on ongoing monitoring of the market.
For how the consultations fit together, including those run by DBT, see the UK SRS consultation tracker.
What to do this quarter
Five decisions before 1 January 2027
These are the decisions the timing forces on a company in scope, in the order we would take them.
1. Confirm your listing category and year-end. The rules reach UKLR 6, 14, 15, 16 and 22, and the first period is the first one that begins on or after 1 January 2027.
2. Decide which reliefs you will use. Using the Scope 3 or UK SRS S1 relief needs only a statement that you are relying on it.
3. Decide, requirement by requirement, where you expect to comply and where you expect to explain. An explanation against UK SRS S2 must summarise the unmet requirements, give reasons and set out any steps planned.
4. Read draft TN 803.1 and respond by 28 October 2026 if it does not work for you. It is the only part of the regime still open to comment.
5. Start capturing 2027 data from 1 January 2027. The reporting comes in 2028; the evidence has to be collected during the year.
The CP26/5 proposals remain worth reading as the explanation of why the regime looks as it does, but they are no longer the working baseline.
The cost side of these decisions, in the FCA’s own figures, is on our UK SRS cost analysis.
To talk a specific position through, you can book a free 15-minute call.
Frequently asked
Questions people ask
When was the FCA UK SRS Policy Statement published?
On 30 September 2026, as PS26/19, "Aligning listed issuers' sustainability disclosures with international standards". It answers CP26/5, which the FCA published on 30 January 2026 and closed on 20 March 2026. The FCA had said it aimed to publish in autumn 2026, and it did. The rules themselves were made by the FCA Board on 24 September 2026.
Is UK SRS mandatory for listed companies after PS26/19?
No. The final rules adopt a comply-or-explain approach across all of UK SRS, UK SRS S2 climate disclosures included. CP26/5 had proposed making UK SRS S2 mandatory apart from Scope 3; PS26/19 did not adopt that. A listed company in scope either reports in accordance with UK SRS or explains what it has not disclosed, why, and (for UK SRS S2) what steps it is taking.
When do the new FCA rules apply?
To accounting periods beginning on or after 1 January 2027, with first reporting in 2028. The instrument comes into force on 1 January 2027. A company whose financial year starts later than 1 January first reports against the new rules for the first period that begins on or after that date.
Did the FCA change the start date after the consultation?
No. PS26/19 kept the implementation timeline it consulted on: periods beginning on or after 1 January 2027, a one-year Scope 3 relief and a two-year relief for UK SRS S1 beyond climate. What changed was the basis (comply or explain throughout), the treatment of secondary listings and depositary receipts, and the position of early adopters, who may now use the reliefs.
What is the legal instrument behind PS26/19?
The UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, set out in Appendix 1 of PS26/19. It was made by order of the FCA Board on 24 September 2026 and comes into force on 1 January 2027. The Policy Statement does not give the instrument an FCA number, so this page does not either.
What is still open after PS26/19?
The guidance. The FCA is consulting on draft Technical Note 803.1, on how to comply or explain, alongside updates to TN 801.4 and the deletion of TN 802.3, in Primary Market Bulletin 66. Comments are due by 28 October 2026, and the FCA aims to finalise the guidance before the rules come into force. The FCA also plans a webinar on 19 October 2026 and updated information on its supervisory approach in the second half of 2027.
How long is the runway between the Policy Statement and the first period?
For a company with a calendar financial year, about three months: the rules were published on 30 September 2026 and its first in-scope period starts on 1 January 2027. The first annual financial report under the rules is then due, under DTR 4.1.3R, within four months of that year ending, which for a 31 December 2027 year-end means by 30 April 2028.
Did the FCA say the changes from CP26/5 were significant?
No. PS26/19 paragraph 1.8 says the changes from the consultation "are not viewed as significant" when compared with the proposals and with the existing TCFD-aligned rules. The FCA nonetheless updated its cost-benefit analysis, which now puts the net present value of the rules at £174.10m, about £60m lower than the CP26/5 proposals.
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)
The final rules: comply or explain across UK SRS (¶¶1.2, 1.7), changes "not viewed as significant" (¶1.8), guidance consultation (¶1.9), timeline kept (¶1.11), reliefs now set by FCA rules (response after ¶2.91), dates (¶¶3.12–3.24), NPV (¶4.4), Appendix 1 made 24 September 2026.
- 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.
- 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.
- 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 AuthorityCP26/5 consultation paper (PDF)
The consultation of 30 January 2026: the proposed mandatory UK SRS S2, signposting for UKLR 14 and 15, and the rule barring early adopters from the reliefs.
- Financial Conduct AuthorityCP26/5 consultation page
Opened 30 January 2026, closed 20 March 2026; still reads that the FCA aims to publish a Policy Statement in autumn 2026.
- FCA HandbookUKLR 6.6 — annual financial report (commercial companies)
UKLR 6.6.6R: the TCFD-aligned rule in force today, which PS26/19 replaces from 1 January 2027 with the UK SRS limbs (7A), (7B) and a recast (8).
- FCA HandbookDTR 4.1 — annual financial report
DTR 4.1.3R: the annual financial report is made public at the latest four months after the end of the financial year.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
DBT published UK SRS S1 and S2 on 25 February 2026.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
UK SRS is available for voluntary use by any entity; the FCA rules decide who must comply or explain.
- Financial Reporting CouncilSustainability reporting developments — FAQs
New or amended ISSB requirements do not apply in the UK until endorsed.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Published 7 September 2026, closes 30 November 2026; ¶¶154–155 on UK SRS and the Companies Act.
- GOV.UKClimate-related transition plan requirements — consultation
Ran 25 June – 17 September 2025; no outcome published when re-checked on 28 September 2026.