UK SRS and the FCA: the final rules in PS26/19

On 30 September 2026 the FCA published PS26/19, its final rules requiring listed companies to report against the UK Sustainability Reporting Standards on a comply or explain basis. The rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028, and they replace the existing TCFD-aligned listing rules. Companies may use a one-year relief for Scope 3 emissions and a two-year relief for wider sustainability disclosures under UK SRS S1.

No. CP26/5 proposed making UK SRS S2 climate disclosures mandatory, excluding Scope 3, but the final rules adopt comply or explain across all categories of disclosure. A listed company in scope either discloses in accordance with UK SRS or explains what it has not disclosed and why.

Companies listed in the commercial companies (UKLR 6), international commercial companies secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity shares and non-voting equity shares (UKLR 16) and transition (UKLR 22) categories. Closed-ended investment funds, open-ended investment companies, shell companies, and debt, securitised derivative and miscellaneous securities issuers are excluded. CP26/5 estimated that around 600 listed companies would be affected; PS26/19 gives no total count.

CP26/5, Aligning listed issuers' sustainability disclosures with international standards, was the FCA consultation published on 30 January 2026 and closed on 20 March 2026. It proposed replacing the TCFD-aligned listing rules with UK SRS reporting, with UK SRS S2 mandatory apart from Scope 3, and a signposting statement only for secondary listings and depositary receipts. PS26/19 is the Policy Statement that answers it.

The instrument comes into force on 1 January 2027 and the rules apply to accounting periods beginning on or after that date. For a 31 December year-end the first report covers the 2027 financial year and is published in 2028. A company whose period began before 1 January 2027 keeps to the TCFD-aligned rules for that period or may adopt UK SRS early.

Yes. PS26/19 says the rules "will replace the existing TCFD aligned disclosures". The TCFD-aligned rule in UKLR 6.6.6R(8) continues to apply to accounting periods beginning before 1 January 2027, and the FCA proposes to delete its TCFD technical note, TN 802.3, when the new guidance is finalised.

No. A listed company states whether or not it has obtained third-party assurance, and if it has, names the provider, what was assured and to what level, the standards used and where any published report can be found. The FCA says it does not consider it the appropriate time to introduce mandatory assurance but will keep it under review.

The FCA will monitor and enforce compliance with its UK SRS and transition-plan rules together with the FRC. It intends to publish updated information on its supervisory approach in the second half of 2027, in time for the first reporting season, and is consulting until 28 October 2026 on Technical Note 803.1, which sets out what it expects when a company complies or explains.

The UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, made by the FCA Board on 24 September 2026 under powers including sections 73A and 96 of the Financial Services and Markets Act 2000. It comes into force on 1 January 2027 and amends UKLR 6.6, 11.4, 14.3, 15.3, 16.3 and 22.2 and ESG 2.2.6R, with transitional provisions in UKLR TP 16.