UK SRS implementation guide: work back from your first period

The Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026.

The standards themselves carry no effective date; the obligation to use them comes from the FCA’s listing rules.

Those rules were made on 24 September 2026 and published in PS26/19 on 30 September 2026, in force from 1 January 2027.

They apply to companies listed in UKLR 6, 14, 15, 16 and 22, and they apply comply or explain “across all categories of disclosures”, climate included (¶1.7).

The consultation, CP26/5, had proposed mandatory UK SRS S2 reporting; the final rules dropped that, and UK SRS and the FCA sets out everything else the Policy Statement decided.

Outside those five categories, UK SRS remains available for voluntary use, and no requirement or threshold has been proposed for private companies.

The government’s modernising corporate reporting consultation, open until 30 November 2026, is where any wider change would start.

The reliefs tell you the order the FCA expects a company to build in.

PS26/19 ¶3.14 gives one year’s non-disclosure of Scope 3 under UK SRS S2 and two years’ non-disclosure under UK SRS S1 for non-climate matters.

Nothing relieves the rest of UK SRS S2, so governance, strategy, risk management and Scope 1 and 2 emissions are disclosed or explained from the first period.

“Climate first” does not mean UK SRS S1 is idle: the guidance at UKLR 6.6.6A G reminds companies to apply the parts of S1 that relate to climate reporting, including its conceptual foundations and its general requirements.

Using the climate-first relief has a price in the standard itself: UK SRS S1 ¶73A says a company using it “is not permitted to assert compliance with UK SRS S1”.

It can still assert compliance with UK SRS S2, provided it discloses its use of the reliefs alongside that statement.

The sister reference covering UK SRS S1 and S2 reads the two standards side by side, and UK SRS requirements lays out the full disclosure set.

Listed companies are not starting from zero: the FCA’s TCFD-aligned rules already required disclosure against all 11 recommended disclosures on a comply-or-explain basis (¶2.3).

The final rules “will replace the existing TCFD aligned disclosures” (¶1.10), and over 90% of respondents to that question supported replacing them (¶2.13).

The four-pillar architecture carries over, which means an existing climate governance statement, risk process and Scope 1 and 2 inventory are the starting point, not wasted work.

What is new is specificity: UK SRS asks paragraph by paragraph for things the recommendations described in outline, such as the split of emissions between the consolidated group and other investees.

The tightest change is timing, because the disclosures must now land with the financial statements and on the same reporting entity.

The gap analysis in full is on TCFD vs UK SRS, and the rules that apply until the switch are on TCFD reporting.

Scope 3 is usually the longest build, because the data sits with suppliers and customers rather than inside the company.

UK SRS S2 ¶29(a)(vi) asks which of the GHG Protocol Scope 3 categories are included, and financed emissions for asset managers, banks and insurers.

The measurement framework at ¶¶B38–B57 prioritises direct measurement and primary data, all else being equal, but presumes Scope 3 “can be estimated reliably using secondary data and industry averages” (¶B57).

That presumption is what makes a first-year estimate possible: screen the categories, estimate the material ones from spend or activity data, and improve the inputs over time.

Companies already disclosing Scope 3 under the TCFD-aligned rules may keep doing so during the relief, and the rules do not prevent it (¶3.22).

How to prioritise the categories is covered in Scope 3 reporting under UK SRS, and the UK rules across regimes in Scope 3 emissions reporting.