UK SRS · Reporting guidance
UK SRS reporting guidance: where the disclosures go, when, and in what form
UK SRS reporting guidance starts with mechanics: the standards say what to disclose, but a report also needs a location, a publication date, a shape and a set of statements.
UK SRS S1 settles the first three, and for listed companies the FCA’s final rules in PS26/19 add the statements, for periods beginning on or after 1 January 2027.
This page walks through each, paragraph by paragraph.
Two routes in
Voluntary reporting and the FCA route work differently
The Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026, and GOV.UK says they are available for voluntary use “by any entity that chooses to do so”.
A voluntary reporter needs no registration or approval, but the compliance claim is all or nothing: S1 ¶72 says disclosures shall not be described as complying “unless they comply with all the requirements”.
Listed companies in five categories are on a different footing: the FCA’s rules require them to report against UK SRS or explain, for accounting periods beginning on or after 1 January 2027.
The consultation, CP26/5, had proposed mandatory UK SRS S2 for three categories and a signposting statement for the other two; the final rules put all five on comply or explain.
The FCA’s decisions are set out on UK SRS and the FCA, and your own first period on the UK SRS deadline page.
| Voluntary use | FCA listing rules | |
|---|---|---|
| Who | Any entity that chooses to | UKLR 6, 14, 15, 16 and 22 |
| From | Now | Periods beginning on or after 1 Jan 2027 |
| If a requirement is not met | No compliance claim can be made | Explain: what, why, and any steps |
| Reliefs | Those in the standards, disclosed | The FCA’s transitional reliefs, stated |
| Extra statements | None | Location, assurance, transition plan |
Location
Where the disclosures go, and why the location matters
UK SRS S1 ¶60 requires the disclosures “as part of its general purpose financial reports”.
¶61 lists possible homes such as management commentary, and names the “strategic report”, which is where most UK companies will put them.
¶62 allows them to share a location with other regulatory information, provided they are “clearly identifiable and not obscured” by it.
¶63 allows information to be included by cross-reference to another report the company publishes, on the conditions beside this text.
For listed companies, the FCA says it is “maintaining the requirement for climate-related disclosures and/or explanations, including on Scope 3 emissions, to be included in companies’ annual reports”, with cross-referencing where S1 allows it.
UKLR 6.6.6R(8)(c) then requires a statement of where in the annual financial report the disclosures and explanations can be found.
Location also decides legal protection: the government has confirmed that UK SRS disclosure within the strategic report brings the section 463 protections into play automatically.
The government’s own consultation on modernising corporate reporting restates the limit: unless section 463 is expanded, only UK SRS disclosures included within the strategic report will be covered.
Cross-referencing: the conditions in UK SRS S1 ¶B45
- The cross-referenced information is available on the same terms as the disclosures.
- It is available at the same time.
- The complete set of disclosures is not made less understandable.
Under ¶B46, cross-referenced material becomes part of the disclosures and must itself comply with UK SRS.
Source: UK SRS S1 ¶¶63, B45–B46
Timing
When: the same day, for the same period
UK SRS S1 ¶64 says the disclosures shall be reported “at the same time as” the financial statements and cover the same reporting period.
IFRS S1 had a first-year relief allowing sustainability information to follow the accounts; the government removed it from UK SRS S1 (consultation response, Annex A).
So alignment with the accounts timetable applies from the first report, not the second.
For listed companies, DTR 4.1.3R requires the annual financial report to be public at the latest four months after the year-end, and the sustainability disclosures travel with it.
Comparatives are required for all amounts under ¶70, but the FCA relieves the first period of them (PS26/19 ¶3.25), and a comparative for Scope 3 is needed only from the period after Scope 3 is first disclosed.
For a December year-end, that makes 30 April 2028 the latest publication date for the first report; the UK SRS deadline page gives the date for any year-end.
| UK SRS S1 | Rule |
|---|---|
| ¶64 | Report at the same time as the financial statements, for the same period |
| ¶65 | Normally 12 months; a 52-week period is not precluded |
| ¶66 | If the period changes, say which period, why, and that amounts are not entirely comparable |
| ¶¶67–68 | Update for information about year-end conditions received before authorisation; disclose later events that could influence users |
| ¶70 | Comparatives for all amounts, and for narrative where useful |
Boundary and connections
One reporting entity, and visible connections
¶20 requires the disclosures to be “for the same reporting entity as the related financial statements”, so the group boundary is the accounts’ boundary.
¶21 asks for two kinds of connection to be visible: between the risks and opportunities themselves, and between disclosures, both within the sustainability section and across to the financial statements.
¶22 requires the disclosures to identify the financial statements they relate to, and ¶24 requires the same presentation currency.
¶23 requires data and assumptions to be consistent with those in the financial statements, to the extent the accounting standards allow.
In drafting terms that means cross-references both ways: from a climate risk to the note that carries the affected balance, and from that note back to the risk.
How to build the data on that boundary is covered in the UK SRS implementation guide.
The filter
Materiality: financial, and set by judgement
UK SRS S1 ¶3 covers risks and opportunities that “could reasonably be expected to affect the entity’s cash flows, its access to finance or cost of capital over the short, medium or long term”.
¶17 requires disclosure of material information about them, and ¶18 defines material as information whose omission, misstatement or obscuring could reasonably be expected to influence decisions that primary users of general purpose financial reports make.
¶14 calls materiality “an entity-specific aspect of relevance”, and the application guidance sets no numerical thresholds.
The judgement decides what reaches the report at all, and a listed company that explains a gap will be read against its own principal risks.
The test in depth, and how it differs from the EU approach, is on UK SRS materiality.
It is not the EU’s double materiality, which adds the company’s impacts on people and the environment as a test in their own right.
A topic that matters to wider stakeholders but could not reasonably be expected to affect the company’s prospects is outside UK SRS S1 (¶6).
The shape
Four pillars, for every material topic
UK SRS S1 ¶25 gives every disclosure the same four headings: governance, strategy, risk management, and metrics and targets.
| UK SRS S1 | UK SRS S2 | |
|---|---|---|
| Covers | All sustainability-related risks and opportunities that could reasonably be expected to affect prospects | Climate-related physical and transition risks, and climate-related opportunities |
| Role | General requirements and the reporting mechanics | The climate detail |
| Structure | Four pillars for each material topic (¶25) | Four pillars for climate (¶¶5–37) |
| Notable content | Materiality, reporting entity, location, timing, compliance statement | Emissions, scenario analysis, seven cross-industry metric categories, targets |
| Avoiding duplication | Connected information (¶¶21–24) | Integrated governance and risk disclosures (¶¶7, 26) |
The pillars are not a menu: for each material topic a company works through all four.
Where oversight or risk management is run on an integrated basis, UK SRS S2 ¶¶7 and 26 allow one integrated disclosure instead of a separate one for each topic.
The two standards are introduced on what UK SRS S1 and S2 are, and the general requirements are read clause by clause on the sister reference to UK SRS S1.
Every disclosure requirement is listed on UK SRS requirements, and how to write the climate pillars on how to write a UK SRS S2 disclosure.
Listed companies
The statements the FCA adds to the annual financial report
Under the rules as made in PS26/19, a listed company’s annual financial report carries up to six UK SRS items.
| Item | What it says | Rule |
|---|---|---|
| Climate | UK SRS S2 disclosures, or a summary of requirements not met, the reasons, and any steps planned | UKLR 6.6.6R(7A) |
| Wider sustainability | UK SRS S1 disclosures, or the risks or opportunities not disclosed and why; or that none were identified | UKLR 6.6.6R(7B) |
| Relief | That a transitional relief is being used, naming the provision and the paragraph of the standard | UKLR TP 16.4R(2), 16.5R(2) |
| Location | Where the disclosures and explanations can be found, including cross-references | UKLR 6.6.6R(8)(c) |
| Assurance | Whether third-party assurance was obtained; if so provider, scope, level, standards and where the report is | UKLR 6.6.6R(8)(d) |
| Transition plan | Whether a climate transition plan is published and where, or why not (UKLR 6, 16 and 22) | UKLR 6.6.6R(8)(e) |
There is no separate compliance statement under the listing rules; the UK SRS statement under S1 ¶72 can be made only where every requirement of a standard is met.
The FCA is consulting on guidance about explaining in draft Technical Note 803.1, published with Primary Market Bulletin 66, with comments due by 28 October 2026.
The draft is proposed guidance, not final, and the FCA aims to finalise it before the rules come into force.
The FCA intends to say more about its supervisory approach in the second half of 2027, ahead of the first reporting season in 2028.
Each statement is worked through on UK SRS comply or explain and listed as a checklist on the UK SRS compliance checklist.
Reliefs
Two kinds of relief, not to be confused
The standards contain reliefs of their own, and the government removed their time limits so that their availability would be set by legislation or regulation.
The FCA then set those limits for listed companies: one year for Scope 3 and two years for the climate-first relief, counted by accounting period from initial application.
A voluntary reporter can use the standards’ reliefs too, provided it discloses them.
The price differs by relief: a company using the Scope 3 relief can still assert compliance with UK SRS S2, but one using the climate-first relief cannot assert compliance with UK SRS S1 (¶73A).
| Relief | Where | Time limit |
|---|---|---|
| Scope 3 not disclosed | UK SRS S2 ¶C4 · UKLR TP 16.4R | Standard: none. FCA: first period |
| Climate-first (S1 beyond climate) | UK SRS S1 ¶E3 · UKLR TP 16.5R | Standard: none. FCA: first two periods |
| Previous GHG measurement method | UK SRS S2 ¶C3 | First annual reporting period |
| Law prohibits disclosure; commercially sensitive opportunity | UK SRS S1 ¶73 | None; compliance can still be claimed |
Alongside
How UK SRS sits beside SECR and the Companies Act
UK SRS does not replace Streamlined Energy and Carbon Reporting, which stays in the directors’ report under Schedule 7 of SI 2008/410, for quoted companies of any size and large unquoted companies and LLPs.
The government has proposed abolishing the directors’ report and letting companies place SECR disclosures elsewhere in the annual report; that is a consultation proposal, not law, and who reports under SECR is unchanged.
For the Companies Act climate-related financial disclosures, the government has confirmed that UK SRS S2 is a national reporting framework for section 414CB(6), so a company reporting in accordance with UK SRS S2 need not duplicate them.
The government has also said it will consider the future of those section 414CB(2A) obligations, and its modernising corporate reporting consultation is open until 30 November 2026.
The FRC’s sustainability reporting FAQs add that new or amended ISSB standards do not apply in the UK unless the UK endorses them.
The UK regimes side by side are mapped on UK sustainability reporting.
To ask about a specific report, you can book a free 15-minute call.
Frequently asked
UK SRS reporting guidance — frequently asked
Where do UK SRS disclosures go in the annual report?
UK SRS S1 paragraph 60 requires them as part of the general purpose financial reports, and paragraph 61 names the strategic report among the possible locations. For listed companies the FCA rules require the disclosures and any explanations in the annual financial report, with cross-referencing allowed where UK SRS S1 paragraphs B45 to B47 permit it, and a statement of where they can be found. The government has confirmed that UK SRS disclosure in the strategic report is covered by section 463 of the Companies Act.
When do you have to publish UK SRS disclosures?
At the same time as the related financial statements, and for the same reporting period (UK SRS S1 paragraph 64). UK SRS did not carry over the IFRS S1 first-year relief that allowed sustainability information to follow the accounts. For a listed company, DTR 4.1.3R requires the annual financial report to be public at the latest four months after the year-end.
What materiality test does UK SRS use?
Financial materiality. UK SRS S1 paragraph 3 covers risks and opportunities that could reasonably be expected to affect the entity’s cash flows, its access to finance or cost of capital over the short, medium or long term. Paragraph 18 treats information as material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users of general purpose financial reports make. The standard sets no numerical thresholds.
What is the difference between UK SRS S1 and UK SRS S2?
UK SRS S1 sets the general requirements for all sustainability-related financial disclosures, including materiality, location, timing and the statement of compliance, and asks for disclosures on every material sustainability-related risk and opportunity. UK SRS S2 applies that framework to climate in detail, including greenhouse gas emissions, scenario analysis and seven cross-industry metric categories.
Can a company report under UK SRS voluntarily?
Yes. The standards are available for voluntary use by any entity, with no registration or approval. A voluntary reporter that describes its disclosures as complying with UK SRS must meet every requirement and make an explicit and unreserved statement of compliance under UK SRS S1 paragraph 72. Reliefs in the standards can be used if their use is disclosed.
Can UK SRS disclosures sit in a separate sustainability report?
Only by cross-reference, on conditions. UK SRS S1 paragraph B45 allows it provided the cross-referenced information is available on the same terms and at the same time, and the complete set of disclosures is not made less understandable; the cross-referenced material then becomes part of the disclosures. The FCA rules keep the requirement for climate disclosures and explanations to be included in the annual report, with cross-referencing where UK SRS S1 permits it.
Who has to report under UK SRS, and from when?
Under the FCA’s final rules (PS26/19), companies listed in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reports in 2028. No other UK entity is required to use UK SRS, and no private-company requirement has been proposed.
Does UK SRS replace SECR or the Companies Act climate disclosures?
It replaces neither. SECR stays in the directors’ report under its own regulations. For the Companies Act climate-related financial disclosures, the government has confirmed UK SRS S2 is a national reporting framework for section 414CB(6), so companies reporting in accordance with UK SRS S2 do not need to duplicate those disclosures. The FCA’s UK SRS rules do replace its TCFD-aligned listing rules.
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.
- Department for Business and TradeUK SRS S1 General Requirements (PDF)
¶¶3, 14, 17–18 (materiality), 20–24 (reporting entity, connected information), 25 (core content), 60–63 (location), 64–68 (timing), 70 (comparatives), 72–73B (compliance), B45–B46 (cross-reference).
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF)
¶¶7 and 26 (integrated disclosures), ¶¶C3–C4 (reliefs).
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — publication page
Published 25 February 2026.
- 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 TradeGovernment response to the UK SRS exposure-draft consultation
Annex A (the IFRS S1 first-year timing relief removed); Chapter 3 (UK SRS S2 a national reporting framework for s.414CB(6); s.463 applies to UK SRS disclosure in the strategic report).
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards (PDF)
Comply or explain across UK SRS (¶¶1.2, 1.7), scope (¶3.6), dates and reliefs (¶¶3.12–3.25), location response after ¶2.24, and UKLR 6.6.6R(7A)–(8) and TP 16 as made.
- 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 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).
- 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.
- FCA HandbookUKLR 6.6 — annual financial report (commercial companies)
UKLR 6.6.6R: today (8) is the TCFD-aligned comply-or-explain rule; from 1 January 2027 PS26/19 inserts (7A) UK SRS S2 and (7B) UK SRS S1 on comply or explain, and recasts (8) as the location, assurance and transition-plan statements.
- FCA HandbookDTR 4.1 — annual financial report
DTR 4.1.3R: annual financial report public at the latest four months after year-end.
- legislation.gov.ukCompanies Act 2006, section 463 — liability for false or misleading statements in reports
The protection the government says applies to UK SRS disclosure placed in the strategic report.
- legislation.gov.ukCompanies Act 2006, section 414CB
s.414CB(6): information published under a national, EU-based or international reporting framework may be specified instead of repeated.
- legislation.gov.ukSI 2008/410 Schedule 7, Parts 7 and 7A (SECR)
SECR’s directors’ report duties, separate from UK SRS.
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
Voluntary use; UK SRS S2 as a national reporting framework; endorsement of later ISSB amendments.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Published 7 September 2026, closes 30 November 2026: proposes abolishing the directors’ report (moving SECR) and restates that s.463 covers only UK SRS disclosure within the strategic report (¶160).
- Financial Conduct AuthorityCP26/5 consultation page
The consultation PS26/19 finalises.
Continue reading