Sector intelligence: which regime bites hardest

There is no single answer, because the regime that bites hardest differs by sector. For listed banks, insurers and asset managers the heaviest UK SRS item is financed emissions under UK SRS S2 paragraphs B59 to B63A. For energy and heavy industry, the UK Emissions Trading Scheme already prices and verifies Scope 1 emissions, so the work shifts to transition risk. For manufacturers and retailers, Scope 3 in the supply chain is the steepest climb.

The FCA rules apply the same comply-or-explain basis to every company in scope, whatever its sector or size. The FCA rejected a size threshold, saying climate impact depends on business model and industry, not size, and giving energy and transport companies as examples of those likely to be highly affected. The standards themselves carry sector-specific content, such as the financed-emissions requirements in UK SRS S2.

Entities engaged in asset management, commercial banking or insurance disclose additional information about financed emissions, which are part of Scope 3 Category 15, under UK SRS S2 paragraphs B59 to B63A. The UK added paragraph B59A: where an entity cannot reliably estimate financed emissions for the same reporting period as its financial statements, it must say why, describe its approach and set out a plan with a timeline. It is an added duty, not a relief.

No. PS26/19 excludes closed-ended investment funds (UKLR 11) and open-ended investment companies (UKLR 12), because the FCA regulates investment vehicles through obligations on the asset manager. Asset managers remain subject to the FCA's ESG sourcebook, where FCA 2026/59, in force from 25 September 2026, replaced product-level TCFD metrics with duties to describe climate risks in retail communications and to provide Scope 1, 2 and 3 data on request.

They are separate regimes that share data. The UK ETS requires covered installations, aircraft operators and, from 1 July 2026, ships of 5,000 gross tonnage and above on domestic voyages to monitor, report and verify emissions and surrender allowances. That verified Scope 1 data feeds UK SRS S2 metrics, but UK SRS also asks about transition risk and resilience, which the UK ETS does not.

Yes. SECR (energy and carbon information in the directors' report) and ESOS (a four-yearly energy assessment scheme) are separate legal obligations with their own scope tests, and nothing in the FCA's UK SRS rules removes them. ESOS Phase 4 has a qualification date of 31 December 2026 and a compliance date of 5 December 2027.

For most, purchased goods and services upstream, and for many consumer goods the use of sold products downstream. UK SRS S2 requires an entity to consider all fifteen GHG Protocol Scope 3 categories and disclose which it includes; the one-year FCA relief lets a company state that it is not yet disclosing Scope 3 for its first period.

Not directly. UK CBAM is a tax on the embodied emissions of certain imported aluminium, cement, fertiliser, hydrogen, and iron and steel goods, commencing on 1 January 2027, with the importer liable. It is not a disclosure regime. For a company exposed to it, the carbon cost is a transition risk that its UK SRS S2 disclosures may need to describe.