UK SRS reporting guidance: how to actually report

Where the disclosures go, and when

The first practical question is not what to write but where to put it. UK SRS S1 requires an entity to provide its sustainability-related financial disclosures as part of its general purpose financial reports — the same reports that carry the financial statements^[1].

In practice that usually means the management commentary or a similar report.

For most UK companies that is the strategic report within the annual report.

Cross-referencing to information published elsewhere is permitted, but only under the conditions the standard sets out.

The disclosures must be for the same reporting entity as the related financial statements^[1]. You cannot report sustainability for one boundary and your accounts for another.

Timing is just as strict. An entity must report its sustainability-related financial disclosures at the same time as, and for the same reporting period as, the related financial statements^[1].

The four-pillar structure

UK SRS keeps the four-pillar structure inherited from the TCFD and carried through into IFRS S2^[2]. Every material topic is reported across the same four headings, which gives disclosures a consistent shape whatever the subject.

The pillars are not a menu.

For each topic you judge to be material, you work through all four — governance through to metrics.

The discipline is in applying the same structure consistently, so users can compare one topic, and one company, against another.

What S1 and S2 each require

UK SRS S1 is the general standard. It applies to all sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s prospects, reported across the four pillars^[1]. It also sets the cross-cutting rules — where disclosures go, when, materiality, and the statement of compliance.

UK SRS S2 is the climate standard. It covers climate-related risks and opportunities in detail, including greenhouse gas emissions and climate scenario analysis, again across the same four pillars^[2].

The relationship is hierarchical: S1 tells you how to report on any sustainability topic; S2 tells you what to report on climate specifically. S2 sits inside the S1 framework rather than alongside it. Our S1 and S2 explainer sets out the split in more depth.

Materiality: enterprise value

UK SRS uses enterprise value, or financial, materiality — a single, investor-focused, outside-in test^[1]. Information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions that primary users of general purpose financial reports make on the basis of those reports.

This is the IFRS single-materiality approach. The six UK amendments did not move UK SRS to the EU’s double-materiality model^[3], so the test is whether a sustainability matter affects the value, financing or performance of the business — not the full impact of the business on the world.

Voluntary adoption versus the FCA mandatory route

There are two routes into UK SRS reporting, and they work differently.

Voluntary adoption. UK SRS S1 and S2 were published on 25 February 2026 and are available for voluntary use by any UK entity, listed or private, of any size — with no registration, notification or approval needed^[3]. But voluntary adoption is effectively all-or-nothing on the compliance claim: if you describe your disclosures as complying with UK SRS, S1 paragraph 72 requires an explicit and unreserved statement of compliance, and you may not claim compliance unless you meet all the requirements^[1].

The FCA mandatory route. The FCA’s CP26/5 consultation proposes mandatory UK SRS S2 (climate) reporting for in-scope listed companies — UK Listing Rules categories 6, 14, 15, 16 and 22 — for accounting periods beginning on or after 1 January 2027^[4]. The FCA is expected to confirm the final rules in a Policy Statement in autumn 2026. Our UK SRS × FCA framework sets out who falls in scope.

Comply-or-explain and the transitional reliefs

On the mandatory FCA route, not everything lands at once. The proposals phase in the harder elements through comply-or-explain and time-limited reliefs^[4].

Two kinds of relief should not be confused. The deferral dates above are CP26/5 timing-specific reliefs that apply to in-scope listed companies from their FCA initial application^[4].

Separately, the standards themselves contain reliefs — for Scope 3, for the GHG Protocol measurement basis, and for comparative information — that any adopter, including a voluntary one, may rely on, provided the use is disclosed^[1]. Our deadline tracker lays out every date in one place, and the requirements page covers what each pillar actually demands.

One further point on status: the FRC confirms that the section 414CB(2A) designation applies to voluntary UK SRS S2 adopters as well as mandatory ones^[5]. Adopting voluntarily does not put you outside the relevant statutory framework.

UK SRS reporting guidance: frequently asked questions