UK SRS · Compliance checklist
UK SRS compliance checklist: what the annual report and the files must hold
UK SRS compliance for a listed company means meeting the FCA’s final rules in PS26/19: disclose in accordance with UK SRS, or explain, and make four further statements.
The rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
This checklist sets out every statement the annual financial report needs, pillar by pillar, with the FCA’s own nine preparation steps and the evidence behind them.
Start here
Two kinds of compliance, and why they differ
“UK SRS compliance” can mean compliance with the FCA’s listing rules, or compliance with the standards themselves.
The listing rules are met by disclosing in accordance with UK SRS or by explaining, under UKLR 6.6.6R as amended from 1 January 2027.
The standards are met only by meeting every requirement, and only then may a company make “an explicit and unreserved statement of compliance” under UK SRS S1 ¶72.
The FCA’s draft Technical Note 803.1 says there is no separate compliance statement under the listing rules.
What an explanation must contain is on UK SRS comply or explain; this page is the checklist that sits around it.
The rules apply to UKLR 6, 14, 15, 16 and 22, with no size threshold; the FCA considered one and rejected it.
A company that explains against part of UK SRS S2 meets the FCA’s rule.
It cannot make the UK SRS statement of compliance for UK SRS S2, which UK SRS S1 ¶72 reserves for full compliance.
Checklist 1
Every statement the annual financial report needs
From the rules as made. The same requirements sit in UKLR 14.3.24R, 16.3.23R and 22.2.24R for the other categories.
| Item | Rule | Applies to | |
|---|---|---|---|
| ☐ | Climate disclosures under UK SRS S2 — or a statement summarising the requirements not met, the reasons, and any steps planned | UKLR 6.6.6R(7A) | All five categories |
| ☐ | Sustainability disclosures under UK SRS S1 — or a statement of the risks and opportunities not disclosed and why | UKLR 6.6.6R(7B)(a)–(b) | All five categories |
| ☐ | If no UK SRS S1 risks or opportunities were identified, a statement of that fact | UKLR 6.6.6R(7B)(c) | All five categories |
| ☐ | If a Scope 3 or climate-first relief is used, a statement naming the transitional provision and the paragraph of the standard | UKLR TP 16.4R(2), 16.5R(2) | All five categories |
| ☐ | Where in the annual financial report (or other document, by cross-reference) the disclosures and explanations are | UKLR 6.6.6R(8)(c) | All five categories |
| ☐ | Whether third-party assurance was obtained; if so, provider, what was assured and to what level, standards used, and where the report is | UKLR 6.6.6R(8)(d) | All five categories |
| ☐ | Whether a climate-related transition plan is published, and where; or why not | UKLR 6.6.6R(8)(e) | UKLR 6, 16 and 22 |
| ☐ | A UK SRS statement of compliance, only for a standard met in full | UK SRS S1 ¶¶72–73B | Where applicable |
Cross-references to another report are allowed where UK SRS S1 ¶¶B45–B47 permit them, and the location statement must say where the information is.
Overseas companies in UKLR 14 and 15 may rely on home-jurisdiction reporting and cross-refer to it, but must explain wherever UK SRS is not met in full.
The disclosures in detail are on UK SRS requirements, and the dates that apply to you on the UK SRS deadline.
Checklist 2
Pillar by pillar: what a full disclosure covers
Where you comply rather than explain, these are the areas each pillar must cover, taken from UK SRS S1 and S2.
Oversight and management
- The body or individuals responsible for oversight of sustainability-related risks and opportunities
- How they are informed, and how often
- Management’s role in processes, controls and procedures
- Whether and how climate considerations factor into executive remuneration (UK SRS S2 ¶29(g))
Risks, business model and resilience
- The risks and opportunities, and the time horizons over which each could have effects
- Effects on the business model and value chain
- Effects on strategy and decision-making, including any transition plan
- Current and anticipated effects on financial position, performance and cash flows
- Climate resilience, assessed with scenario analysis commensurate with your circumstances (UK SRS S2 ¶22)
Processes
- How risks are identified, assessed, prioritised and monitored
- How opportunities are identified, assessed, prioritised and monitored
- How these processes are integrated into overall risk management
- Consistency with the principal risks and uncertainties in the management report (DTR 4.1.8R)
Measurement
- Gross Scope 1, 2 and 3 emissions under the GHG Protocol (Scope 3 subject to the first-period relief)
- Scope 2 location-based, with information on contractual instruments
- Assets or activities vulnerable to transition and physical risks, and aligned with opportunities
- Capital deployment and internal carbon prices
- Targets, and progress against them
Emissions are measured under the GHG Protocol Corporate Standard and the Scope 3 Standard; the Scope 3 build is on Scope 3 reporting under UK SRS.
Any area you cannot yet cover goes into an explanation, not a gap; the governance pillar and who signs off are on UK SRS board oversight.
Checklist 3
The FCA’s nine preparation steps, in its own order
Alongside the final rules, the FCA published Primary Market Bulletin 66, which lists nine steps it encourages listed companies to take.
It adds two reminders that shape a compliance plan.
The first is Listing Principle 1, UKLR 2.2.1R: a listed company must take reasonable steps to maintain adequate procedures, systems and controls to comply with its obligations, which includes sustainability reporting.
The second is DTR 4.1.8R: where climate or sustainability risks are among the principal risks and uncertainties, a company that explains should consider how those risks are otherwise reflected in its reporting.
The FCA also notes that companies may adopt the new rules before 1 January 2027 and use the transitional provisions.
A step-by-step plan built on these is on the UK SRS implementation guide, and a shorter route in on getting started.
Primary Market Bulletin 66
- Understand and engage with the new requirements, including the proposed Technical Note
- Identify financially material sustainability and climate-related risks and opportunities
- Review governance arrangements
- Integrate those risks and opportunities within corporate strategy
- Assess the resilience of the business model and strategy
- Develop the data, metrics and targets needed
- Establish internal controls and review processes
- Build organisational capabilities and provide training
- Engage with investors on their disclosure expectations
Source: FCA, Primary Market Bulletin 66, 30 September 2026
Checklist 4
The evidence to keep behind the report
A comply-or-explain register: one line per UK SRS S2 requirement and per UK SRS S1 risk or opportunity, marked comply, explain or relief, with the reason, the owner and the next step.
The materiality assessment behind it, because an explanation that treats a topic as immaterial has to survive a reader comparing it with the principal-risks section.
The emissions calculation file: boundaries, activity data, conversion factors, and any change of method, so that a comparative can be produced in the second period.
The judgements and estimates, which UK SRS S1 ¶¶74–86 requires a company to disclose where they have the most significant effect.
Board minutes approving the disclosures and the explanations together with the accounts, because UK SRS S1 ¶64 puts them on the same day.
If assurance is sought, the engagement letter and scope, so the assurance statement can name what was assured and to what level; ISSA (UK) 5000 is the FRC standard a provider may use.
The register and the file below are how we would organise the evidence.
The rules require the statements; they do not prescribe the working papers.
Oversight
Who checks, and what they look at
The FCA will monitor and enforce compliance with its UK SRS and transition-plan rules together with the FRC (PS26/19 ¶2.82).
It intends to publish updated information on its supervisory approach in the second half of 2027, before the first reporting season.
It says it will monitor compliance, the proportion of companies that explain rather than comply, costs, and investors’ views of usefulness, and does not expect a formal post-implementation review (Annex 2).
The FCA’s guidance consultation on how to comply and explain is open until 28 October 2026; how to respond is on the UK SRS consultation.
The rules in full are on UK SRS and the FCA, and the government’s account of the standards in its UK SRS guidance.
Getting help
Where to go next
We are an independent reference, and we do not perform compliance steps or sign anything off.
Consultancy capability exists for gap analysis and drafting; specialist UK SRS consultants are listed on a sister site, and the family’s UK SRS reference site carries the standards in depth.
You can book a free 15-minute call, or contact us with a correction or a question.
Frequently asked
UK SRS compliance — frequently asked
What does UK SRS compliance mean for a listed company?
Under the FCA's final rules (PS26/19), a listed company in UKLR 6, 14, 15, 16 or 22 complies by including in its annual financial report either disclosures prepared in accordance with UK SRS S1 and S2, or statements explaining what it has not disclosed and why, plus statements on where the disclosures are, on assurance, and on transition plans. The rules apply to accounting periods beginning on or after 1 January 2027.
Is complying with the FCA rules the same as complying with UK SRS?
No. A company that explains against part of UK SRS can meet the FCA's rules in full while being unable to make the UK SRS statement of compliance. UK SRS S1 paragraph 72 reserves that statement for disclosures that meet every requirement, and the FCA's draft Technical Note 803.1 says there is no separate compliance statement under the listing rules.
What statements must the annual financial report contain?
Climate disclosures under UK SRS S2 or an explanation; wider sustainability disclosures under UK SRS S1 or an explanation, or a statement that no relevant risks or opportunities were identified; a statement of any transitional relief being used; where the disclosures and explanations can be found; whether third-party assurance was obtained and, if so, its details; and, for UKLR 6, 16 and 22, whether a climate-related transition plan is published and where, or why not.
What steps does the FCA recommend to prepare for UK SRS?
In Primary Market Bulletin 66 the FCA encourages listed companies to understand the new requirements and the proposed Technical Note; identify financially material risks and opportunities; review governance; integrate them into strategy; assess resilience; develop data, metrics and targets; establish internal controls and review processes; build capability and training; and engage with investors on their expectations.
Is there a size threshold for UK SRS compliance?
No. Scope is set by listing category, not size. Respondents to CP26/5 suggested a size threshold, and the FCA rejected it on the grounds that climate risk depends on a company's business model and industry, not its size, and that thresholds would make comparisons harder.
Does UK SRS compliance require assurance?
No. The company must say whether it obtained third-party assurance and, if it did, name the provider, what was assured and to what level, the standards used and where any published report can be found. It need not explain why it did not seek assurance.
Who is responsible for UK SRS compliance inside a company?
The issuer. The listing rules place the requirements on the listed company, Listing Principle 1 (UKLR 2.2.1R) requires adequate procedures, systems and controls to comply with its obligations, and DTR 4.1 makes the issuer responsible for the information in its annual financial report. How boards divide the work is covered on the board oversight page.
How will the FCA check UK SRS compliance?
The FCA will monitor and enforce its UK SRS rules together with the FRC, and intends to publish updated information on its supervisory approach in the second half of 2027, before the first reporting season. It will monitor, among other things, the share of companies that explain rather than comply.
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)
UKLR 6.6.6R(7A), (7B) and (8) and UKLR TP 16 as made (Appendix 1); size threshold rejected; supervision (¶2.82); monitoring (Annex 2).
- 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; Listing Principle 1 and DTR 4.1.8R reminders; TN 803.1 consultation to 28 October 2026.
- 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 (make the annual financial report public at the latest four months after year-end) and DTR 4.1.8R (principal risks and uncertainties).
- Department for Business and TradeUK SRS S1 General Requirements (PDF)
¶¶3, 18 (materiality), 25 (core content), 60–64 (location and timing), 72–73B (compliance statement), E3 (climate-first).
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF)
¶29 (GHG Protocol measurement), B59A (financed emissions), C3–C4 (first-year and Scope 3 reliefs).
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
"Available for voluntary use, by any entity that chooses to do so."
- GHG ProtocolCorporate Accounting and Reporting Standard
The Scope 1 and 2 measurement basis UK SRS S2 ¶29 names.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The Scope 3 measurement basis and its 15 categories.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
The FRC assurance standard a provider may use if a company seeks assurance.
- Financial Conduct AuthorityCP26/5 consultation paper (PDF)
The consultation, and the ~600 affected-company estimate at Annex 2 ¶43.