UK SRS Compliance Framework
Complete UK SRS compliance guide covering FCA CP26/5 framework, S1 & S2 standards, implementation requirements, and mandatory compliance obligations for UK listed companies.
For comprehensive scope analysis, see our main UK SRS page, or engage specialist UK SRS consultants for readiness and S1/S2 disclosure drafting.
Compliance overview
FCA analysis under CP26/5 identifies around 600 listed companies across UK Listing Rules categories 6, 14, 15, 16 and 22, of which 515 (categories 6, 16 and 22) would be required to comply with mandatory UK SRS S2 climate reporting; the remaining 89 (categories 14 and 15) would make a signposting statement instead.
FCA · CP26/5
On the FCA’s own cost-benefit analysis, around 600 listed companies are affected; 515 of them — UKLR categories 6, 16 and 22 — would be required to comply. The other 89, in categories 14 and 15, would make a signposting statement instead.
FCA · CP26/5 cost-benefit analysis
FCA proposal for in-scope UK-listed companies to begin mandatory UK SRS reporting for financial years starting January 2027.
FCA · Implementation Timeline
The interval between the two published dates. It is not a published estimate of how long the work takes — no such figure exists, because no UK entity has yet been required to produce a UK SRS report.
DBT publication date · FCA CP26/5 proposed commencement
Limited assurance likely required initially, with reasonable assurance expected for certain metrics in subsequent years.
FRC · Assurance Framework
One-year comply-or-explain relief for Scope 3 emissions, with mandatory comprehensive reporting from 2028.
UK SRS S2 · Transitional Provisions
S1 & S2 requirements
UK SRS S1 - General Requirements
Fundamental sustainability disclosure requirements
Core framework for UK SRS sustainability-related financial disclosures covering governance, strategy, risk management, and metrics across all material sustainability matters.
Key Requirements:
- • Board oversight and governance processes
- • Strategy integration and business model impacts
- • Risk identification and management processes
- • Performance metrics and target setting
- • Materiality assessment and disclosure
UK SRS S2 - Climate Disclosures
Climate-related financial disclosure requirements
Comprehensive climate-related disclosures covering GHG emissions, transition risks, physical risks, opportunities, and climate resilience planning.
Key Requirements:
- • Scope 1, 2, and 3 GHG emissions reporting
- • Climate risk assessment and disclosure
- • Scenario analysis and stress testing
- • Transition planning and net-zero commitments
- • Climate-related financial impact quantification
Compliance checklist
🏛️ Governance & Strategy
Board-level oversight and strategic integration requirements
📊 Data & Reporting Systems
Technical infrastructure and data collection capabilities
👥 Capabilities & Skills
Internal expertise and capability development
⚖️ Legal & Regulatory
Regulatory compliance and legal framework alignment
Implementation roadmap
- • Governance setup
- • Initial capability assessment
- • FCA final rules analysis
- • Data collection systems
- • Process establishment
- • Staff training
- • Pilot disclosures
- • Process testing
- • Final preparations
- • Annual reporting
- • Continuous improvement
- • Regulatory engagement
Begin compliance preparation immediately, even before final FCA rules are published.
Early implementation reduces compliance risk if the FCA confirms its CP26/5 proposal, under which UK SRS S2 would apply to accounting periods beginning on or after 1 January 2027. The Policy Statement is expected in autumn 2026 and has not been published.
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