Reporting · UK SRS implementation
UK SRS implementation checklist: tasks, owners and sign-off
UK SRS implementation for listed companies now runs to a fixed timetable: the FCA’s final rules in PS26/19 apply to accounting periods beginning on or after 1 January 2027, comply or explain.
This checklist breaks the work into four phases and 25 tasks, with a suggested owner, the evidence that shows each task is done, and the provision behind it.
The order and timing of the work are set out in the UK SRS implementation guide; this page is the list you run it from.
The date
When will UK SRS be implemented? From 1 January 2027, for listed companies
The standards exist already: the Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026, for voluntary use by any entity.
The obligation is the FCA’s: its rules come into force on 1 January 2027 and reach companies listed in UKLR 6, 14, 15, 16 and 22.
They apply comply or explain across both standards, so nothing in UK SRS becomes mandatory for a listed company; each disclosure is made or explained.
The consultation, CP26/5, had proposed mandatory UK SRS S2 and a signposting statement for secondary listings; UK SRS comply or explain sets out what the final rules changed.
For UK SRS S2 itself, the standard in outline is on UK SRS S2 and its full requirements on UK SRS S2 climate disclosures.
Phase 1 · Before the first period
Scope, gaps and the mandate
Everything here should be finished before the first day of your first accounting period beginning on or after 1 January 2027.
| Task | Suggested owner | Done when | Provision |
|---|---|---|---|
| Confirm the UKLR category and the first accounting period caught | Company secretary | Category and first-period start date minuted | PS26/19 ¶¶3.6, 3.12 |
| Decide whether to adopt early for a period beginning before 1 January 2027 | Board | Decision minuted; reliefs still available | PS26/19 ¶3.19 |
| Gap assessment of current TCFD reporting against UK SRS S2, paragraph by paragraph | Sustainability lead with finance | Gap register by paragraph | UK SRS S2 ¶¶5–37 |
| Climate risk and opportunity register with time horizons | Risk function | Register reviewed by the overseeing committee | UK SRS S2 ¶10 · S1 ¶18 |
| Write climate oversight into terms of reference and role descriptions | Board, via the company secretary | Updated terms of reference | UK SRS S2 ¶6(a)(i) |
| Set the briefing cadence and board-pack content | Chair and company secretary | Board calendar with climate items | UK SRS S2 ¶6(a)(iii) |
Phase 2 · From day one of the period
Data, scenarios and controls
The first period is the data year: capture starts on its first day, and the harder analysis runs alongside.
| Task | Suggested owner | Done when | Provision |
|---|---|---|---|
| Align the emissions boundary with the consolidation boundary | Group finance | Boundary memo signed off | UK SRS S1 ¶20 · S2 ¶29(a)(iv) |
| Capture Scope 1 and 2, location-based Scope 2 included | Sustainability lead | Data captured through the period, not rebuilt at year-end | UK SRS S2 ¶29(a)(i)–(v) |
| Screen Scope 3 categories and plan supplier data for the relief year | Procurement with sustainability | Category screen and data plan | UK SRS S2 ¶29(a)(vi), ¶¶B38–B57 |
| Run climate scenario analysis and record inputs and assumptions | Strategy with risk | Scenarios, horizons and assumptions documented | UK SRS S2 ¶22 |
| Assess current and anticipated financial effects | Finance | Quantified effects, or reasons and qualitative effects where not | UK SRS S2 ¶¶15–21 |
| Describe the controls over sustainability data and who reviews them | Finance or internal audit | Control descriptions and review evidence | UK SRS S2 ¶6(b)(ii) · CGC 2024 Provision 29 |
Phase 3 · During and after the period
Disclosures, explanations and statements
Draft the explanations and the required statements alongside the disclosures, not after them.
| Task | Suggested owner | Done when | Provision |
|---|---|---|---|
| Draft the four pillars for climate | Sustainability lead with finance | Draft section of the strategic report | UK SRS S1 ¶25 · S2 |
| Keep a comply, explain or relief register and draft each explanation | Company secretary with finance | Register and explanations: what, why, what next | UKLR 6.6.6R(7A)(b), (7B)(b) · draft TN 803.1 |
| Word the statement that a relief is being used | Company secretary | Statement naming the transitional provision and the paragraph of the standard | UKLR TP 16.4R(2), 16.5R(2) |
| Decide the transition-plan statement | Board | Published and where, or why not (UKLR 6, 16 and 22 only) | UKLR 6.6.6R(8)(e) |
| Map where each disclosure sits, including cross-references | Company secretary | Location map | UKLR 6.6.6R(8)(c) · S1 ¶¶B45–B47 |
| Reconcile data and assumptions with the financial statements | Group finance | Consistency check signed off | UK SRS S1 ¶23 |
| Answer the remuneration question | Remuneration committee | Whether and how climate affects executive pay, and the percentage | UK SRS S2 ¶29(g) |
Phase 4 · Before publication
Assurance decision and board approval
The last phase turns a draft into the company’s published statements, with named people accountable for them.
| Task | Suggested owner | Done when | Provision |
|---|---|---|---|
| Decide whether to obtain third-party assurance, and over what | Audit committee | Decision recorded; engagement letter if any | UKLR 6.6.6R(8)(d) |
| Word the assurance statement | Company secretary | Whether obtained; if so provider, scope, level, standards, report location | UKLR 6.6.6R(8)(d)(i)–(iv) |
| Word the UK SRS compliance statement, or decide none can be made | Company secretary | Explicit and unreserved statement, only if every requirement is met | UK SRS S1 ¶¶72, 73A |
| Approve the strategic report | Board | Approved and signed by a director or the secretary | CA 2006 s.414D(1) |
| Make the responsibility statements | Persons responsible within the issuer | Named, with their functions | DTR 4.1.12R |
| Publish the annual financial report | Company secretary | Public within four months of year-end | DTR 4.1.3R |
Accountability
Who signs what, and on what authority
The listing rules put the UK SRS requirements on the listed company, and Primary Market Bulletin 66 reminds issuers of Listing Principle 1: adequate procedures, systems and controls to comply with their obligations.
Where the disclosures sit in the strategic report, section 414D(1) of the Companies Act 2006 requires the report to be “approved by the board of directors and signed on behalf of the board by a director or the secretary”.
Section 414D(2) makes it an offence for a director to approve a non-compliant strategic report knowingly or recklessly and fail to take reasonable steps to prevent it.
DTR 4.1.12R requires responsibility statements from “the persons responsible within the issuer”, named with their functions, covering the financial statements and a fair review in the management report.
Commercial companies applying the UK Corporate Governance Code 2024 also make a Provision 29 declaration on material controls, which the FRC says extends to narrative and ESG reporting controls, for financial years beginning on or after 1 January 2026.
The Code itself contains no sustainability reporting requirement; its hook is the controls declaration.
The board’s part in full, from the governance disclosures to section 172, is on UK SRS board oversight.
Every sign-off in this list already exists for the annual report.
UK SRS puts more of the report’s content under them.
Two standards
What S1 and S2 each ask, and when each bites
UK SRS S2 is the climate standard; UK SRS S1 sets the general framework and applies it to every other sustainability-related risk and opportunity.
S1 does not name the topics: a company identifies them through its own materiality judgement, and S1 ¶55 lets it refer to the SASB Standards and other sources of guidance.
The general requirements are read clause by clause on the sister reference to UK SRS S1, and both standards are introduced on what UK SRS S1 and S2 are.
The two-year climate-first relief is the reason S1 work can start later, but the materiality work for S1 is worth doing in the first period, because the register serves both.
When the relief ends, an S1 explanation names the risks or opportunities not disclosed and the reasons, and a company that identified none says so.
| UK SRS S2 | UK SRS S1 | |
|---|---|---|
| Covers | Climate-related risks and opportunities | All sustainability-related risks and opportunities that could reasonably be expected to affect prospects |
| First period | Comply or explain (Scope 3 relieved) | Relief: state its use |
| Second period | Comply or explain, Scope 3 included | Relief: state its use |
| Third period | Comply or explain | Comply or explain |
| Explanation covers | The requirements not met | The risks or opportunities not disclosed |
From TCFD
What carries over from TCFD, and what needs more work
What a TCFD reporter reuses
- The four-pillar structure: governance, strategy, risk management, metrics and targets.
- Climate risk identification and assessment processes.
- Scope 1 and 2 measurement and reporting.
- Board and committee oversight arrangements.
- Scenario analysis methods and tools already in use.
What UK SRS asks for in more detail
- Scope 3 by GHG Protocol category, after the one-year relief (S2 ¶29(a)(vi)).
- Current and anticipated financial effects, as a single amount or a range, with reasons where not quantified (S2 ¶¶15–21).
- Information about any transition plan the company has (S2 ¶14(a)(iv)), plus the FCA statement on whether one is published.
- For each greenhouse gas target: scopes, gross or net, sectoral decarbonisation approach and planned carbon credits (S2 ¶36).
- Governance described paragraph by paragraph, down to briefing frequency and remuneration (S2 ¶6).
Two things UK SRS does not require are often assumed: it does not require a transition plan, and it does not require targets validated by any particular body.
The FCA says in PS26/19 that it is “not requiring listed companies to produce transition plans”, and UK SRS S2 ¶36(d) asks only whether a target was derived using a sectoral decarbonisation approach.
A company that does use the Science Based Targets initiative should note its own statement that Version 1.3.1 of its net-zero standard applies to 2026 submissions and Version 2.0 validation opens in early 2027 (SBTi standards and guidance).
The gap analysis in full is on TCFD vs UK SRS.
Where the time goes
Three tasks that take longest
This is our reading of where the effort concentrates, based on what each requirement asks; it is not a regulator’s view.
Value-chain data
The data sits with suppliers and customers. UK SRS S2 ¶B57 presumes Scope 3 can be estimated reliably from secondary data and industry averages, which makes a first estimate possible while better inputs are built.
Climate scenario analysis
UK SRS S2 ¶22 requires scenario analysis with an approach commensurate with the company’s circumstances, and disclosure of the scenarios, inputs, assumptions and horizons used. Depth scales; the duty does not.
Oversight you can evidence
UK SRS S2 ¶6 asks how and how often the board is informed and how it weighs climate in major decisions. That is answered from minutes and papers from the period, so the arrangements must exist before it starts.
Each has its own page: Scope 3 reporting under UK SRS, Scope 3 emissions reporting in the UK and climate scenario analysis under UK SRS.
Many preparers draw scenarios from the NGFS Scenarios Portal, a network of central banks and supervisors, but UK SRS S2 mandates no particular scenario set.
Outside references
The bodies behind the checklist, and what each is for
The International Sustainability Standards Board issued IFRS S1 and S2, and UK SRS is the UK-endorsed version of them.
The GHG Protocol Corporate Value Chain (Scope 3) Standard defines the 15 categories UK SRS S2 refers to.
The Transition Plan Taskforce published its Disclosure Framework in October 2023, and its materials passed to the IFRS Foundation in October 2024.
The TPT’s former site, transitiontaskforce.net, now hosts the International Transition Plan Network.
The FCA’s own materials are the PS26/19 page, the draft Technical Note 803.1 and Primary Market Bulletin 66.
For a question about a specific plan, get in touch or book a free 15-minute call.
Status, in one line each
- FCA — makes the listing rules that require UK SRS reporting.
- ISSB — sets IFRS S1 and S2, the base UK SRS endorses.
- GHG Protocol — the measurement standard UK SRS S2 names.
- NGFS, TPT, SBTi — reference material; none is required by UK SRS.
Frequently asked
UK SRS implementation — frequently asked
When will UK SRS be implemented?
For listed companies in UKLR 6, 14, 15, 16 and 22, the FCA’s rules come into force on 1 January 2027 and apply to accounting periods beginning on or after that date, on a comply-or-explain basis, with first reports in 2028. The standards themselves were published on 25 February 2026 and can be used voluntarily by any entity now. No date has been set for anyone else.
Who is responsible for UK SRS implementation inside a company?
Legally, the company: the listing rules place the requirements on the listed company, and the annual financial report is the issuer’s. In practice the work runs across finance, the company secretary, risk, the sustainability team and the board’s committees, and the board approves the strategic report in which the disclosures usually sit. How a company divides the tasks is its own decision; the owners on this page are a suggested split, not a rule.
Who signs off UK SRS disclosures?
The board. Where the disclosures sit in the strategic report, section 414D of the Companies Act 2006 requires that report to be approved by the board and signed on its behalf by a director or the company secretary. DTR 4.1.12R also requires responsibility statements from the persons responsible within the issuer, covering the financial statements and the management report.
What is the first task on a UK SRS implementation checklist?
Confirm your listing category and your first accounting period beginning on or after 1 January 2027. The rules apply only to UKLR 6, 14, 15, 16 and 22, and every other date in the plan works back from the start of that first period.
Does UK SRS require science-based targets?
No. UK SRS S2 requires a company to disclose the climate-related targets it has set and any it is required to meet by law, and, for each greenhouse gas target, details such as the scopes covered, whether it is gross or net, whether it was derived using a sectoral decarbonisation approach and any planned use of carbon credits. It does not require a target to be set or validated by any particular body.
Does UK SRS require a transition plan?
No. The FCA’s rules require a statement of whether a climate-related transition plan has been published and where, or why not, and UK SRS S2 asks for information about any transition plan the company has. The FCA says in PS26/19 that it is not requiring listed companies to produce transition plans. The statement does not apply to UKLR 14 and 15.
Do secondary listings and depositary receipt issuers have to implement UK SRS?
Yes, on the same comply-or-explain basis as domestic companies. The FCA says a company whose home-jurisdiction reporting aligns with the outcomes of UK SRS may already broadly comply and may rely on it, but must explain wherever UK SRS requirements are not met in full.
How is this checklist different from the UK SRS compliance checklist?
This checklist is the project: the tasks, their order, their owners and their sign-offs. The compliance checklist is the output: the statements the finished annual report must contain. Use this one to run the work and the other to check the result.
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 (¶3.12), early adopters (¶3.19), relief statements (¶3.20), no duty to produce a transition plan, and UKLR 6.6.6R(7A)–(8) and TP 16 as made (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.
- Financial Conduct AuthorityPrimary Market Bulletin 66 — draft Technical Note 803.1 (comply or explain)
The nine preparation steps and the reminder of Listing Principle 1 (adequate procedures, systems and controls).
- 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).
- FCA HandbookUKLR 6.6 — annual financial report (commercial companies)
UKLR 6.6.6R: today (8) is the TCFD-aligned comply-or-explain rule; from 1 January 2027 PS26/19 inserts (7A) UK SRS S2 and (7B) UK SRS S1 on comply or explain, and recasts (8) as the location, assurance and transition-plan statements.
- FCA HandbookDTR 4.1 — annual financial report
DTR 4.1.3R (four months to publish) and DTR 4.1.12R (responsibility statements by the persons responsible within the issuer).
- Department for Business and TradeUK SRS S1 General Requirements (PDF)
¶¶20, 23 (boundary and consistency), 25 (four pillars), 55 (sources of guidance), 72 (compliance statement), B45–B47 (cross-reference).
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF)
¶6 (governance), ¶14(a)(iv) (transition plan information), ¶¶15–22 (financial effects and scenario analysis), ¶29 (metrics), ¶36 (greenhouse gas targets).
- legislation.gov.ukCompanies Act 2006, section 414D — approval and signing of the strategic report
(1) approved by the board and signed by a director or the secretary; (2) the offence for approving a non-compliant report.
- Financial Reporting CouncilUK Corporate Governance Code 2024
Provision 29 board declaration on material controls, extended to narrative and ESG reporting controls; financial years beginning on or after 1 January 2026.
- Financial Reporting CouncilAssurance standards, including ISSA (UK) 5000
The standard an assurer would use if assurance is commissioned; voluntary.
- IFRS FoundationInternational Sustainability Standards Board
The standard-setter whose IFRS S1 and S2 UK SRS is based on.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The Scope 3 categories referred to in UK SRS S2 ¶29(a)(vi).
- Network for Greening the Financial SystemNGFS Scenarios Portal
A reference scenario set many preparers use; UK SRS S2 requires scenario analysis but mandates no particular scenarios.
- Transition Plan TaskforceTPT Disclosure Framework (October 2023, PDF)
The UK disclosure framework for transition plans; its materials passed to the IFRS Foundation in October 2024.
- Science Based Targets initiativeStandards and guidance
Version 1.3.1 of the Corporate Net-Zero Standard for 2026 submissions; Version 2.0 validation from early 2027.
- Financial Conduct AuthorityCP26/5 consultation page
The consultation (30 January to 20 March 2026) that PS26/19 finalises.
Continue reading
Read next
UK SRS implementation guide
The roadmap: what to build first, and by when, worked back from your first period.
UK SRS compliance checklist
The statements the finished annual report must contain.
UK SRS board oversight
The governance disclosures and the board’s legal duties behind them.