UK SRS · Requirements
UK SRS requirements: what S1 and S2 ask a company to disclose
UK SRS requirements are the disclosure requirements in UK SRS S1 and UK SRS S2, issued on 25 February 2026.
Both ask for the risks and opportunities that could reasonably be expected to affect a company’s cash flows, access to finance or cost of capital, across four pillars.
Under the FCA’s final rules, PS26/19, listed companies report against them on a comply-or-explain basis from accounting periods beginning on or after 1 January 2027.
Start here
Three questions that get blurred
“UK SRS requirements” is used for three different things, and most confusion comes from mixing them.
The first is content: what a report prepared under the standards must contain.
That is fixed by the two standards, which the government says are “available for voluntary use, by any entity that chooses to do so”.
The second is obligation: who must use them, and from when.
The standards contain no effective date, deliberately, and the only obligation is the FCA’s, for listed companies, on comply or explain.
The third is quality: whether anyone checks the disclosures, which today is a choice, not a rule.
This page covers the first question in full and the other two in outline; the rules themselves are on UK SRS and the FCA, and the status of every workstream on the UK SRS hub.
A paragraph-by-paragraph reference for UK SRS S1 sits on the family’s UK SRS reference site, which also sets both standards side by side.
| Question | Answered by | Status |
|---|---|---|
| What must be disclosed? | UK SRS S1 and S2 | Final, 25 Feb 2026 |
| Who must report, from when? | FCA listing rules (PS26/19) | Final, from periods beginning 1 Jan 2027 |
| How good must the data be? | Assurance: ISSA (UK) 5000, voluntary | Not required |
| Anyone else? | Government, Companies Act | No proposal |
The disclosures
The four pillars every UK SRS report is built on
Both standards use the four-pillar structure; UK SRS S1 applies it to every material sustainability topic and UK SRS S2 to climate.
| Pillar | What it requires | Where (UK SRS S1) |
|---|---|---|
| Governance | The governance body or individuals responsible for oversight of sustainability-related risks and opportunities, and management’s role in the processes, controls and procedures used to monitor and manage them. | ¶¶26–27 |
| Strategy | The risks and opportunities; their effect on the business model and value chain; on strategy and decision-making; on financial position, performance and cash flows now and anticipated; and the resilience of strategy and business model. | ¶¶28–42 |
| Risk management | The processes used to identify, assess, prioritise and monitor sustainability-related risks and opportunities, and how they are integrated into overall risk management. | ¶¶43–44 |
| Metrics and targets | Performance in relation to the risks and opportunities, including metrics required by a UK SRS standard, and progress towards any targets set or required by law. | ¶¶45–53 |
The pillars are the same four inherited from the TCFD framework, which is why a company already reporting under the TCFD-aligned listing rule starts with the architecture in place.
What changes is the reach: UK SRS S1 asks about all sustainability-related risks and opportunities, not only climate.
The materiality test
UK SRS S1 ¶3 sets the scope: 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.
Information is material under ¶18 if omitting, misstating or obscuring it could reasonably be expected to influence the decisions primary users of general purpose financial reports make on the basis of those reports.
That is a single, financial materiality test, and it is not the EU’s double materiality; the comparison is on UK SRS materiality.
General requirements
The disclosures cover the same reporting entity as the financial statements (¶20), are connected to them (¶¶21–24), and are reported at the same time (¶64).
A company that meets every requirement makes an explicit and unreserved statement of compliance (¶72); ¶73A limits that statement where the climate-first relief is used.
Climate
What UK SRS S2 adds for climate
UK SRS S2 applies the four pillars to climate-related physical and transition risks and to climate-related opportunities.
Its metrics and targets pillar has three limbs: the cross-industry metric categories (¶¶29–31), industry-based metrics (¶32) and targets (¶¶33–37).
Greenhouse gas emissions
¶29(a) requires absolute gross Scope 1, Scope 2 and Scope 3 emissions, with Scope 1 and 2 measured under the GHG Protocol Corporate Standard.
Scope 2 is disclosed location-based, with information about contractual instruments, and Scope 3 by category, under the GHG Protocol Scope 3 Standard.
Scope 3 is the hardest data set in the standard; the 15 GHG Protocol categories and the relief are covered on their own page.
Scenario analysis
¶22 requires a company to “use climate-related scenario analysis to assess its climate resilience using an approach that is commensurate with the entity’s circumstances”.
The proportionality lies in how it is done, not whether: Appendix B ¶B8 lets the approach reflect the information available without undue cost or effort.
Transition plans and financed emissions
UK SRS S2 does not require a company to have a transition plan, but where it has one it must disclose information about it.
¶B59A is the one place UK SRS asks for more than IFRS S2: a company that finds it impracticable to estimate financed emissions for the reporting period must explain why.
References to the industry-based guidance changed from “shall” to “may” at ¶¶12, 23 and 32, so it is optional in the UK.
UK SRS S2 ¶29 — the cross-industry metrics
- Greenhouse gases: gross Scope 1, 2 and 3
- Assets or activities vulnerable to transition risks
- Assets or activities vulnerable to physical risks
- Assets or activities aligned with climate opportunities
- Capital deployment towards climate risks and opportunities
- Internal carbon prices
- Climate considerations in executive remuneration
Source: UK SRS S2 ¶29(a)–(g); body paragraphs follow IFRS S2 numbering
Listed companies
What the FCA’s rules attach to the standards
PS26/19 does not rewrite the standards; it adds, through UKLR 6.6.6R and its twins in UKLR 14, 15, 16 and 22, a set of statements that sit around them.
| Rule as made | What the annual financial report must contain | Mandatory or comply or explain? |
|---|---|---|
| UKLR 6.6.6R(7A) | Climate disclosures under UK SRS S2, or a statement of the requirements not met, the reasons, and the steps planned | Comply or explain |
| UKLR 6.6.6R(7B) | Wider sustainability disclosures under UK SRS S1, or a statement of the risks and opportunities not disclosed and why; or that none was identified | Comply or explain |
| UKLR 6.6.6R(8)(c) | Where the disclosures and explanations can be found | Required |
| UKLR 6.6.6R(8)(d) | Whether third-party assurance was obtained, and details if so | Required statement; assurance itself not required |
| UKLR 6.6.6R(8)(e) | Whether a climate-related transition plan is published and where, or why not | Required statement; no plan required (not UKLR 14, 15) |
| UKLR TP 16.4R–16.5R | A statement that a Scope 3 or climate-first relief is being used | Required when a relief is used |
The rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
The one-year Scope 3 relief and the two-year climate-first relief run from that first period; your own dates are on the UK SRS deadline.
How to build an explanation that meets UKLR 6.6.6R(7A) and (7B) is on UK SRS comply or explain.
The FCA’s own summary of what it decided, and how it differs from the consultation, is on UK SRS and the FCA.
UK adaptations
How the final standards differ from IFRS S1 and S2
The UK standards are close to the ISSB’s IFRS S1 and IFRS S2, and the authoritative list of differences is Annex A of the government response.
The effective-date clauses were removed, so the standards apply when an entity chooses to use them, unless UK law or regulation requires it.
The Scope 3 relief (UK SRS S2 ¶C4) and the climate-first relief (UK SRS S1 ¶E3) lost their time limits, which are now set by FCA rules or legislation.
The IFRS S1 relief allowing sustainability disclosures to be published after the financial statements was removed.
References to SASB Standards and industry-based guidance changed from “shall” to “may”.
UK SRS S1 ¶¶73A and 73B were added, on the compliance statement and on the primacy of UK law and regulation.
UK SRS S2 ¶B59A was added, the one change that adds a duty rather than relaxing one.
UK SRS S2 also absorbs the ISSB’s own December 2025 amendments to IFRS S2, which are the ISSB’s changes, not the UK’s.
The drafts the government consulted on are in the exposure draft, and the endorsement process is on UK SRS endorsement.
The government consulted on six proposed amendments in June 2025.
Some were not adopted and others were added, and Annex A of the response, which lists the final differences, carries no total.
“Where requirements in the standards are not included in the table, there are no differences between the two.”
Law or standard?
Is UK SRS legislation, or regulation?
People search for “UK SRS legislation” and “UK SRS regulations”, and the accurate answer is that UK SRS is neither on its own.
The standards are issued by the Secretary of State for Business and Trade and contain the machinery to be required by UK law, but no requirement.
The requirement for listed companies is regulation: FCA rules, made by the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, which comes into force on 1 January 2027.
The Companies Act route is recognition, not obligation: the government confirmed that UK SRS S2 is a national reporting framework for section 414CB(6).
So a company already making climate-related financial disclosures under the Companies Act can use UK SRS S2 disclosures to meet them without duplicating the information.
Those Companies Act duties apply to large companies and LLPs by turnover and employee tests, and are a separate regime, reviewed separately by the government.
The government’s Modernising corporate reporting consultation, open until 30 November 2026, says only that it “will consider how UK SRS should be reflected in the Companies Act 2006”.
The FRC’s FAQs carry the regulator’s own account of how the pieces fit.
| Instrument | What it does for UK SRS |
|---|---|
| UK SRS S1 and S2 | Standards; no effective date; voluntary for any entity |
| UK Listing Rules, as amended by PS26/19 | Comply or explain for UKLR 6, 14, 15, 16 and 22 |
| Companies Act 2006 s.414CB(6) | UK SRS S2 is a national reporting framework for climate-related financial disclosures |
| Companies Act 2006 s.463 | Safe harbour for UK SRS disclosure placed in the strategic report |
Data quality
Assurance: state it, do not have to obtain it
Neither UK SRS nor the FCA’s final rules require assurance of UK SRS disclosures.
A listed company must say whether or not it obtained third-party assurance, and if it did, name the provider, what was assured and to what level, the standards used and where any published report can be found.
The FCA does not require an explanation where no assurance was sought, and says it will keep the case for mandating assurance under review.
The FRC issued ISSA (UK) 5000 on 12 November 2025 for voluntary use, effective for engagements on periods beginning on or after 15 December 2026, with earlier application permitted.
The government’s response on an oversight regime for sustainability assurance chose a voluntary regime operated by the FRC; the register it described had not opened when we last checked.
Voluntary assurance, and what a first engagement involves, is covered on sustainability assurance in the UK.
In practice
What meeting the requirements involves
Start with the FCA’s nine preparation steps and the checklist built on them, on the UK SRS compliance checklist.
Decide early which disclosures will be complied with and which explained, because the compliance statement depends on it.
Build Scope 1 and 2 from the same data a company already uses for SECR, and plan Scope 3 against the relief year.
Timetable the disclosures with the accounts, because UK SRS S1 ¶64 allows no later publication.
Consultancy capability exists for gap analysis and drafting, and you can book a free 15-minute call if you want to talk it through.
Frequently asked
UK SRS requirements — frequently asked
What are the UK SRS requirements?
UK SRS requirements are the disclosure requirements in two standards issued on 25 February 2026: UK SRS S1 (general requirements for sustainability-related financial information) and UK SRS S2 (climate-related disclosures). Both require information across four pillars — governance, strategy, risk management, and metrics and targets — about the risks and opportunities that could reasonably be expected to affect a company's cash flows, its access to finance or its cost of capital over the short, medium or long term.
Are UK SRS requirements mandatory?
Not as such. The standards are available for voluntary use by any entity. For listed companies in UKLR 6, 14, 15, 16 and 22, the FCA's final rules in PS26/19 require reporting against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027: a company either discloses in accordance with UK SRS or explains what it has not disclosed and why. No other UK entity is required to use UK SRS.
Is UK SRS legislation or regulation?
Neither on its own. UK SRS S1 and S2 are standards issued by the Secretary of State for Business and Trade; they contain no effective date and bind no one by themselves. The obligation for listed companies comes from FCA rules — the UK Listing Rules as amended by the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, made under the Financial Services and Markets Act 2000. The Companies Act 2006 recognises UK SRS S2 as a national reporting framework for the climate-related financial disclosures in section 414CB.
What are the four pillars of UK SRS?
Governance (the body or individuals responsible for oversight, and management's role), strategy (the risks and opportunities, their effect on the business model, value chain, strategy, financial position and resilience), risk management (the processes used to identify, assess, prioritise and monitor them) and metrics and targets (how performance is measured and progress tracked). UK SRS S1 sets them out at paragraph 25; UK SRS S2 applies them to climate.
Does UK SRS require Scope 3 emissions reporting?
UK SRS S2 requires absolute gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions, measured under the GHG Protocol. It also contains a Scope 3 relief with no time limit of its own. Under the FCA's final rules a listed company may rely on that relief for its first period in scope, stating that it is doing so; after that, Scope 3 is disclosed or its omission explained under comply or explain.
How do UK SRS S1 and S2 differ from IFRS S1 and S2?
Very little in substance. The government's authoritative list of differences is Annex A of its consultation response of 25 February 2026, which carries no count. The main ones: the effective dates were removed; the Scope 3 and climate-first reliefs lost their time limits, which are now set by FCA rules or legislation; references to SASB and industry-based guidance changed from "shall" to "may"; the IFRS S1 relief allowing sustainability disclosures after the financial statements was removed; paragraphs 73A and 73B were added on compliance statements and UK law; and UK SRS S2 paragraph B59A adds a duty to explain where financed emissions cannot be estimated.
Do UK SRS disclosures need to be assured?
No. Neither the standards nor the FCA's final rules require assurance. A listed company must state whether or not it has obtained third-party assurance and, if it has, name the provider, what was assured and to what level, and the standards used. The FRC's ISSA (UK) 5000 is available for voluntary use and is effective for engagements on periods beginning on or after 15 December 2026.
Where in the annual report do UK SRS disclosures go?
The FCA's rules require the disclosures, and any explanations, to be included in the annual financial report, and allow cross-referencing to another report where UK SRS S1 paragraphs B45 to B47 permit it; the company says where they can be found. UK SRS S1 paragraph 64 requires sustainability-related financial disclosures to be reported at the same time as the related financial statements. The government has confirmed that if UK SRS disclosure is placed in the strategic report, the safe harbour in section 463 of the Companies Act applies.
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, 18 (materiality), 25 (core content), 60–64 (location and timing), 72–73B (compliance statement), E3 (climate-first).
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF)
¶29 (GHG Protocol measurement), B59A (financed emissions), C3–C4 (first-year and Scope 3 reliefs).
- Department for Business and TradeGovernment response to the UK SRS exposure-draft consultation
Annex A (the differences from IFRS S1 and S2), Chapter 3 (s.414CB(6) and s.463), ¶1.21 (voluntary use).
- 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 TradeExposure draft of UK SRS S1 and UK SRS S2
The June 2025 drafts, and the amendments the government proposed before finalising.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards (PDF)
Comply or explain across UK SRS (¶1.2); UKLR 6.6.6R(7A), (7B) and (8) as made; reliefs (¶¶3.14–3.24).
- Financial Conduct AuthorityCP26/5 consultation page
The consultation PS26/19 finalised.
- legislation.gov.ukCompanies Act 2006, section 414CB
s.414CB(6): UK SRS S2 is a national reporting framework for the climate-related financial disclosures.
- Financial Reporting CouncilSustainability reporting developments — FAQs
New or amended ISSB standards do not apply in the UK without endorsement.
- Financial Reporting CouncilFRC takes steps to support quality and consistency in sustainability assurance
ISSA (UK) 5000 issued 12 November 2025, for voluntary use.
- Department for Business and TradeOversight regime for sustainability assurance — government response
30 January 2026: a voluntary, FRC-operated regime; ¶1.15 register "well ahead of the 1 January 2027 reporting year".
- IFRS FoundationIFRS S1 General Requirements
The ISSB baseline UK SRS S1 endorses.
- IFRS FoundationIFRS S2 Climate-related Disclosures
The ISSB baseline UK SRS S2 endorses, as amended by the ISSB in December 2025.
- GHG ProtocolCorporate Accounting and Reporting Standard
The Scope 1 and 2 measurement basis UK SRS S2 ¶29 names.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The Scope 3 measurement basis and its 15 categories.
- ICAEWIFRS S1 and IFRS S2 in the UK
Professional-body overview; context only, never the source of a figure.
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