UK SRS and the FCA: how the standards become rules
The UK Sustainability Reporting Standards are written by the Department for Business and Trade, but they only bind listed companies once the FCA puts them into the UK Listing Rules.
That is what consultation paper CP26/5 proposes to do.
This page sets out the FCA’s jurisdiction, exactly who falls in scope under the listing categories, the proposed timeline, and how the rules will be enforced.
The FCA’s role and jurisdiction
Two different bodies sit behind UK SRS, and keeping them apart is the key to understanding the regime.
The Department for Business and Trade writes the standards. It published UK SRS S1 and S2 on 25 February 2026 for voluntary use[3].
The Financial Conduct Authority decides whether listed companies must use them. It does this through the UK Listing Rules, which it has statutory power to set under the Financial Services and Markets Act 2000[1].
So the standards already exist, but they do not yet bind anyone. They become mandatory for listed issuers only when the FCA confirms the rules proposed in CP26/5[1].
CP26/5: turning standards into Listing Rules
On 30 January 2026 the FCA published Consultation Paper CP26/5, “Aligning listed issuers’ sustainability disclosures with international standards”[1].
It proposes replacing the existing TCFD-aligned Listing Rules with rules requiring in-scope listed companies to report against UK SRS S2 for financial years beginning on or after 1 January 2027[2].
The consultation ran for seven weeks and closed on 20 March 2026. The FCA is now reviewing responses and aims to publish a Policy Statement, with final rules, in autumn 2026[1].
For the consultation process itself — including the parallel DBT and assurance consultations — see our dedicated consultation tracker.
The listing categories that fall in scope
Scope is defined by the UK Listing Rules (UKLR) categories, not by the old “premium” and “standard” listing labels, which the FCA retired when it restructured its listing regime in 2024.
The full UK SRS reporting obligation falls on three categories: UKLR 6 (commercial companies), UKLR 16 (non-equity shares and non-voting equity shares) and UKLR 22 (transition)[2].
The FCA estimates this covers around 500 primary-listed companies[2].
Issuers in UKLR categories 14 and 15 — secondary listings and depositary receipts — face a lighter, transparency-only obligation: they state which sustainability standard they apply in their home jurisdiction rather than report in full against UK SRS[2].
| UKLR category | Who it covers | Obligation under CP26/5 |
|---|---|---|
| UKLR 6 | Commercial companies (equity shares) | Full UK SRS S2 / S1 reporting |
| UKLR 16 | Non-equity shares & non-voting equity shares | Full UK SRS S2 / S1 reporting |
| UKLR 22 | Transition category | Full UK SRS S2 / S1 reporting |
| UKLR 14 | Secondary listings (equity shares) | Transparency statement only |
| UKLR 15 | Depositary receipts | Transparency statement only |
What is required, and from when
CP26/5 phases the requirements in, easing the hardest disclosures over later years.
UK SRS S2 climate disclosures (excluding Scope 3) would be mandatory from the first in-scope period[2].
Scope 3 emissions move to a comply-or-explain basis from 1 January 2028, with an optional further one-year deferral, and UK SRS S1 follows on a comply-or-explain basis from 1 January 2029[2].
| Requirement | Who | From | Basis |
|---|---|---|---|
| UK SRS S2 climate (excluding Scope 3) | UKLR 6, 16, 22 (~500 cos) | FY beginning on/after 1 Jan 2027 | Mandatory |
| Scope 3 emissions | Same in-scope companies | FY beginning on/after 1 Jan 2028 | Comply-or-explain (1-yr relief, optional further year) |
| UK SRS S1 (non-climate) | Same in-scope companies | FY beginning on/after 1 Jan 2029 | Comply-or-explain (2-yr relief) |
| Transparency statement only | UKLR 14, 15 (secondary listings & DRs) | FY beginning on/after 1 Jan 2027 | State home-jurisdiction standard |
For the climate standard in detail, see UK SRS S2 climate disclosures, and for every date in one place, the deadline tracker.
The end of the TCFD-aligned Listing Rules
Since 2021 the FCA has required listed companies to report on a comply-or-explain basis against the recommendations of the Task Force on Climate-related Financial Disclosures[5].
The TCFD was disbanded in October 2023, and its work was folded into the ISSB standards on which UK SRS is built[5].
CP26/5 proposes removing the TCFD-aligned Listing Rules entirely and pointing the rules at UK SRS S2 and S1 instead[2].
The familiar four-pillar architecture — governance, strategy, risk management, and metrics and targets — carries over, so the shape of disclosure is continuous even as the underlying standard changes. See our board oversight analysis for what the governance pillar now demands.
How the FCA will enforce the rules
The FCA enforces the Listing Rules through its existing supervisory powers under the Financial Services and Markets Act 2000[1].
CP26/5 says the FCA will set out its approach to monitoring and enforcing the new sustainability rules in a future Primary Market Bulletin[2].
The Primary Market Bulletin is the channel the FCA routinely uses to communicate supervisory expectations to listed issuers, so reporters should treat the bulletin — when it appears — as the practical statement of what “good” compliance looks like.
UK SRS and the FCA: frequently asked questions
What is the FCA’s role in UK SRS?
The Financial Conduct Authority is the body that decides whether and how UK-listed companies must report against the UK Sustainability Reporting Standards. The standards themselves are issued by the Department for Business and Trade; the FCA writes the UK Listing Rules that make them mandatory for listed issuers. Its consultation CP26/5, published on 30 January 2026, proposes replacing the existing TCFD-aligned Listing Rules with rules requiring in-scope listed companies to report against UK SRS S2 for financial years beginning on or after 1 January 2027.
Which companies fall within the FCA’s proposed UK SRS scope?
CP26/5 applies the new requirements to UK Listing Rules categories 6 (commercial companies), 16 (non-equity shares and non-voting equity shares) and 22 (transition). The FCA estimates this covers around 500 primary-listed companies. Issuers in UKLR categories 14 and 15 (secondary listings and depositary receipts) face a lighter, transparency-only requirement: they state which sustainability standard they apply in their home jurisdiction rather than report in full against UK SRS. The earlier listing-regime language of "premium" and "standard" listing was retired when the FCA restructured its listing categories in 2024.
When does mandatory FCA reporting against UK SRS begin?
The FCA proposes that UK SRS S2 climate disclosures become mandatory for financial years beginning on or after 1 January 2027. Scope 3 emissions move to a comply-or-explain basis for periods beginning on or after 1 January 2028, with an optional further one-year deferral, and UK SRS S1 (non-climate) follows on a comply-or-explain basis from 1 January 2029. These dates remain proposals until the FCA confirms them in its Policy Statement, which it aims to publish in autumn 2026.
How does CP26/5 change the existing TCFD Listing Rules?
Since 2021 the FCA has required listed companies to report on a comply-or-explain basis against the recommendations of the Task Force on Climate-related Financial Disclosures. The TCFD was disbanded in 2023, and its work was absorbed into the ISSB standards on which UK SRS is based. CP26/5 proposes replacing the TCFD-aligned Listing Rules entirely with rules pointing to UK SRS S2 and S1, so the four-pillar structure — governance, strategy, risk management, metrics and targets — carries over while the underlying standard changes.
How will the FCA enforce the new rules?
The FCA enforces the Listing Rules through its existing supervisory powers under the Financial Services and Markets Act 2000. CP26/5 states that the FCA will set out its approach to monitoring and enforcing compliance with the new sustainability rules in a future Primary Market Bulletin — the standard channel the FCA uses to communicate supervisory expectations to listed companies.
- CP26/5: Aligning listed issuers’ sustainability disclosures with international standards — Financial Conduct Authority · Published 30 Jan 2026; closed 20 Mar 2026; Policy Statement expected autumn 2026
- CP26/5 consultation paper (PDF) — scope, transitional reliefs and enforcement approach — Financial Conduct Authority · UKLR 6/14/15/16/22 scope; Primary Market Bulletin enforcement; Ch. 8 transitional provisions
- UK Sustainability Reporting Standards (guidance) — GOV.UK / Department for Business and Trade · UK SRS S1 and S2 published 25 Feb 2026 for voluntary use; government process
- Sustainability reporting developments — frequently asked questions — Financial Reporting Council · Section 414CB(2A) designation; interaction of FCA rules with the standards
- TCFD Final Recommendations (October 2017); TCFD disbanded October 2023 — Task Force on Climate-related Financial Disclosures · The framework CP26/5 proposes to replace in the Listing Rules