UK SRS · Consultations
UK SRS consultation: every consultation, and what each one decided
The main UK SRS consultation, the FCA’s CP26/5, closed on 20 March 2026 and was answered on 30 September 2026 by the final rules in PS26/19.
The one still open for listed companies is the FCA’s draft guidance on how to comply or explain, with feedback due by 28 October 2026.
This page tracks every consultation behind the regime: what it asked, where it stands, and what it changed.
At a glance
The consultations that built the regime
Six consultations, run by three bodies, each deciding a different thing — keeping them apart is most of the work.
| Consultation | Run by | Window | Status | What it decides |
|---|---|---|---|---|
| Exposure drafts of UK SRS S1 and S2 | DBT | 25 Jun – 17 Sep 2025 | Final | The content of the standards; issued 25 Feb 2026 |
| Assurance oversight regime | DBT | 25 Jun – 17 Sep 2025 | Final | A voluntary, FRC-operated regime; response 30 Jan 2026 |
| Climate-related transition plans | Government | 25 Jun – 17 Sep 2025 | No date | Whether to require plans; no outcome published |
| CP26/5 — listed-company rules | FCA | 30 Jan – 20 Mar 2026 | Final | Comply or explain from 2027; answered by PS26/19 |
| Modernising corporate reporting | Government | 7 Sep – 30 Nov 2026 | Proposed | Company reporting reform; will “consider” UK SRS in the Companies Act |
| Draft TN 803.1 (PMB 66) | FCA | 30 Sep – 28 Oct 2026 | Proposed | How to comply and how to explain |
Read in date order, the standards were drafted and finalised by government, and then handed to the FCA to attach to the listing rules.
The dates as a sequence are on the UK SRS timeline, and your own first period on the UK SRS deadline.
The main event
FCA CP26/5: what it proposed, and what the FCA decided
The FCA published CP26/5, “Aligning listed issuers’ sustainability disclosures with international standards”, on 30 January 2026.
It proposed replacing the TCFD-aligned listing rules with requirements to report against UK SRS, for accounting periods beginning on or after 1 January 2027.
Its central proposal was mandatory UK SRS S2, excluding Scope 3, for the commercial companies, non-equity shares and transition categories.
CP26/5 estimated that around 600 listed companies would be affected; the Policy Statement gives no total.
The consultation closed on 20 March 2026, and PS26/19 answered it on 30 September 2026 with comply or explain across UK SRS.
The FCA says it changed the climate basis because some respondents questioned whether mandating UK SRS S2 would be proportionate and would support the international competitiveness of UK companies (¶1.5).
The rules in full are on UK SRS and the FCA, and what comply or explain asks of a company on UK SRS comply or explain.
| CP26/5 proposed | PS26/19 decided | |
|---|---|---|
| UK SRS S2 (excl. Scope 3) | Mandatory | Comply or explain |
| Scope 3 | Comply or explain after 1 year | Kept |
| UK SRS S1 beyond climate | Comply or explain after 2 years | Kept |
| UKLR 14 and 15 | Signposting statement | Comply or explain against UK SRS |
| Start | Periods from 1 Jan 2027 | Kept |
| Early adopters | No reliefs | May use the reliefs |
What respondents said
The CP26/5 feedback, question by question
PS26/19 gives counts for each question, and no single total of respondents.
On mandatory climate reporting, many buy-side and professional-services respondents were in favour, while listed companies were “more mixed” (¶¶2.14–2.15).
Some respondents asked for a size threshold; the FCA rejected it, because climate exposure depends on business model and industry, not size.
On UK SRS S1, more than a quarter of those who agreed asked for a clear path towards mandatory adoption (¶2.28).
On assurance, over 90% of those answering supported the transparency statement, and respondents suggested review periods of two to five years before any mandate (¶¶2.47, 2.56).
On overseas issuers, some warned that exempting them could push UK companies to downgrade to a secondary listing, which is why the FCA brought them in (¶2.67).
Open now
Draft Technical Note 803.1: how to respond, and by when
The rules are final, but the guidance on applying them is not.
Through Primary Market Bulletin 66 the FCA is consulting on draft Technical Note 803.1, on updates to TN 801.4, and on deleting TN 802.3, its technical note on the TCFD-aligned rules.
TN 803.1 sets out the level of detail the FCA expects when a company prepares UK SRS disclosures, including when it chooses to explain.
It includes illustrative explanations and a table of when a company can and cannot make the UK SRS statement of compliance.
The FCA aims to finalise the guidance before the rules come into force on 1 January 2027 (PS26/19 ¶1.9).
It is also holding a webinar on 19 October 2026, announced on the PS26/19 page.
A useful response answers the three questions, uses the draft’s own paragraph references, and gives concrete examples of where the guidance would or would not work for your company.
Responding to PMB 66
Deadline: 28 October 2026
Send to: primarymarketbulletin@fca.org.uk
The FCA’s three questions:
- Do you agree with the proposed expectations for complying?
- Do you agree with the proposed expectations for explaining?
- Do you agree with the proposed guidance for international companies?
Source: FCA Primary Market Bulletin 66
How the standards were made
The DBT exposure-draft consultation
Before the FCA could write rules, the standards had to exist.
The Department for Business and Trade consulted on exposure drafts of UK SRS S1 and S2 from 25 June to 17 September 2025.
It received 209 responses, and published the final standards and its government response on 25 February 2026.
The response confirmed the standards for voluntary use, removed their effective dates and the time limits on the reliefs, and left timing to the FCA and legislation.
The government proposed six amendments in June 2025; the final differences are listed in Annex A of the response, which carries no count.
What changed on endorsement is on UK SRS endorsement, and what the final standards require on UK SRS requirements and UK SRS S2.
The government’s standing account is its UK SRS guidance, and a fuller standards reference sits on the family’s UK SRS reference site.
A separate workstream
The assurance and transition-plan consultations
Alongside the exposure drafts, the government consulted on an oversight regime for sustainability assurance, and drew 99 responses.
Its response of 30 January 2026 chose a voluntary regime operated by the FRC, with legislation for a statutory regime left for when parliamentary time allows.
The FRC had already issued ISSA (UK) 5000 on 12 November 2025, for voluntary use.
The third consultation in the same window, on climate-related transition plan requirements, had no published outcome when last checked.
PS26/19 avoided pre-empting it: listed companies say whether they publish a transition plan and where, or why not, and no one is required to have one.
Open until 30 November
Modernising corporate reporting: what it says about UK SRS
The government published Modernising corporate reporting on 7 September 2026, and it closes on 30 November 2026.
It proposes removing the directors’ report, which would move SECR disclosures to another part of the annual report without changing who reports (¶149).
It says DESNZ intends to consult on SECR and ESOS later in 2026 (¶150), and that the climate-related financial disclosure regulations are under a separate post-implementation review.
It says the government has no plans to require assurance over future UK SRS reporting “at this stage” (¶178).
On private companies it proposes no threshold and no date; the scope picture is on who needs UK SRS, and the regimes that do apply today on ESG reporting requirements in the UK.
The consultation document itself is on GOV.UK.
Nothing in it applies to anyone yet.
On UK SRS it says the government “will consider how UK SRS should be reflected in the Companies Act 2006”, and proposes nothing more.
Often confused
One FCA consultation that is not about UK SRS
The FCA’s CP26/17, Quarterly Consultation Paper No. 52, proposed removing product-level TCFD reporting requirements for asset managers.
It is a different rulebook, the ESG Sourcebook, and a different population from the listed companies PS26/19 covers.
PS26/19 touches the ESG Sourcebook only to let firms with a TCFD entity report cross-refer to their UK SRS disclosures (ESG 2.2.6R).
If you want to talk through a response to any open consultation, you can book a free 15-minute call.
Frequently asked
UK SRS consultation — frequently asked
Is the UK SRS consultation still open?
The FCA's CP26/5 consultation closed on 20 March 2026 and the FCA published its final rules, PS26/19, on 30 September 2026. What is open now is the FCA's consultation on draft Technical Note 803.1, its guidance on how to comply or explain, with feedback due by 28 October 2026. The government's Modernising corporate reporting consultation is also open until 30 November 2026.
What was FCA CP26/5?
CP26/5, Aligning listed issuers' sustainability disclosures with international standards, was published on 30 January 2026 and closed on 20 March 2026. It proposed replacing the TCFD-aligned listing rules with UK SRS reporting from accounting periods beginning on or after 1 January 2027, with UK SRS S2 mandatory apart from Scope 3, and a signposting statement for secondary listings and depositary receipts.
What did the FCA change after the consultation?
It moved UK SRS S2 from a proposed mandatory basis to comply or explain, so the whole of UK SRS is now comply or explain, and it brought secondary listings and depositary receipts into UK SRS reporting instead of the proposed signposting statement. It also let early adopters use the transitional reliefs. The start date, the one-year Scope 3 and two-year UK SRS S1 reliefs, and the transition-plan and assurance statements were kept.
How do I respond to the FCA's UK SRS guidance consultation?
The FCA is consulting through Primary Market Bulletin 66 on draft Technical Note 803.1, updates to TN 801.4 and the deletion of TN 802.3. Comments go to primarymarketbulletin@fca.org.uk by 28 October 2026. The FCA asks whether respondents agree with its proposed expectations for complying, for explaining, and for international companies.
How many responses did the UK SRS exposure-draft consultation receive?
The Department for Business and Trade received 209 responses to its consultation on the UK SRS exposure drafts, which ran from 25 June to 17 September 2025: 199 from organisations and 10 from individuals. Of the 184 who answered the question, 68% (125) agreed with the four UK amendments the TAC had recommended.
How many responses did CP26/5 receive?
PS26/19 reports responses question by question rather than as a single total. For example, 94 of 110 respondents supported the proposed scope, over 90% of those answering supported replacing the TCFD-aligned rules with UK SRS, and 78 of 113 agreed with comply or explain for UK SRS S1.
Was there a separate consultation on assurance?
Yes. The government consulted on an oversight regime for sustainability assurance between 25 June and 17 September 2025, and responded on 30 January 2026 with a voluntary regime operated by the FRC. The FRC issued the assurance standard ISSA (UK) 5000 in November 2025. Neither the FCA nor the government requires assurance of UK SRS disclosures.
Will private companies be consulted on UK SRS?
The government's Modernising corporate reporting consultation, published on 7 September 2026 and open until 30 November 2026, says the government will consider how UK SRS should be reflected in the Companies Act 2006. It makes no proposal and sets no threshold or date for private companies.
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 AuthorityCP26/5 consultation page
Opened 30 January 2026, closed 20 March 2026.
- Financial Conduct AuthorityCP26/5 consultation paper (PDF)
What the FCA proposed on 30 January 2026, including mandatory UK SRS S2, and the ~600 estimate in Annex 2 ¶43.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards (PDF)
The FCA’s response to CP26/5: feedback by question (¶¶2.7–2.84) and the final rules.
- 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).
- Department for Business and TradeExposure drafts: UK Sustainability Reporting Standards — consultation and outcome
25 June to 17 September 2025; 209 responses.
- Department for Business and TradeGovernment response to the UK SRS exposure-draft consultation
¶1.6 (199 organisations, 10 individuals); ¶1.17 (68% agreed with the TAC amendments); Annex A.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
"Available for voluntary use, by any entity that chooses to do so."
- Department for Business and TradeAssurance of sustainability reporting — consultation
25 June to 17 September 2025.
- Department for Business and TradeOversight regime for sustainability assurance — government response
30 January 2026: a voluntary, FRC-operated regime; ¶1.15 register "well ahead of the 1 January 2027 reporting year".
- Financial Reporting CouncilFRC takes steps to support quality and consistency in sustainability assurance
ISSA (UK) 5000, 12 November 2025.
- GOV.UKClimate-related transition plan requirements — consultation
Ran 25 June – 17 September 2025; no outcome published when re-checked on 28 September 2026.
- 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.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document (PDF)
¶¶149–150 (SECR location; a DESNZ SECR and ESOS consultation), ¶¶154–155 (UK SRS), ¶178 (no plans for assurance).
- Financial Conduct AuthorityCP26/17 — Quarterly Consultation Paper No. 52
Proposes removing product-level TCFD reporting for asset managers; separate from UK SRS.
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