UK SRS requirements: what the standards actually ask for
UK SRS asks companies to disclose, across four pillars, the sustainability and climate risks and opportunities that could affect their value. This is the definitive breakdown of every requirement — the disclosures themselves, who must meet them and when, the six UK amendments, and assurance — with each figure tied to a DBT, FCA or FRC source.
What “UK SRS requirements” actually means
“UK SRS requirements” is shorthand for the disclosure rules in two standards published by the Department for Business and Trade on 25 February 2026 for voluntary use[1]: UK SRS S1, covering general sustainability-related financial disclosures, and UK SRS S2, covering climate-related disclosures.
Both are UK-endorsed versions of the ISSB’s IFRS S1 and IFRS S2.
The core test is enterprise value. A company must disclose the sustainability and climate-related risks and opportunities that could reasonably be expected to affect its prospects — its cash flows, access to finance and cost of capital — over the short, medium and long term[5].
Crucially, the standards do not decide who must report or when. That is set separately by the FCA for listed companies and by the government for everyone else. The standards define what a report must contain.
UK SRS also requires where and when the information appears: disclosures form part of a company’s general purpose financial reports, published at the same time and for the same period as the financial statements[5].
The four pillars every UK SRS report is built on
Both standards share the four-pillar architecture inherited from the TCFD framework. Each pillar has a stated objective and a set of specific disclosures required to meet it[3].
| Pillar | What it requires | Objective |
|---|---|---|
| Governance | The board or individuals responsible for oversight, and the controls and processes used to monitor and manage sustainability and climate risks and opportunities. | Let investors understand how the company governs these issues. |
| Strategy | How risks and opportunities affect the business model, strategy and financial planning over the short, medium and long term — including climate resilience and scenario analysis. | Show the effect on the company’s prospects and value. |
| Risk management | The processes used to identify, assess, prioritise and monitor sustainability and climate risks — and how these integrate with overall risk management. | Show that risks are being managed, not just described. |
| Metrics & targets | Cross-industry metrics (including Scope 1, 2 and 3 GHG emissions), industry-based metrics, and any targets set or required by law. | Let investors track performance and progress against targets. |
UK SRS S1 applies this architecture to all material sustainability topics — not only climate — including nature, social and governance matters where they affect enterprise value[5].
UK SRS S2 applies the same four pillars specifically to climate-related physical and transition risks, and to climate-related opportunities[3].
The climate-specific requirements in UK SRS S2
UK SRS S2 carries the most detailed obligations, because it builds on — and replaces — the TCFD rules that have applied to listed companies since 2021.
Greenhouse gas emissions. Companies must measure and disclose Scope 1, Scope 2 and Scope 3 emissions using the GHG Protocol Corporate Standard[3]. Scope 3 — value-chain emissions across the 15 GHG Protocol categories — is required where material, subject to transitional relief (see scope and timeline below).
Scenario analysis. Where climate risk is material, companies must use climate-related scenario analysis to assess resilience, disclosing the scenarios used and whether one is aligned with the latest international agreement on climate change — currently the Paris Agreement[3].
Transition plans. If a company has a climate transition plan, its targets, actions and resources must be disclosed[3].
Financed emissions. Banks, insurers and asset managers face additional disclosure of financed emissions, with a UK-added explanation requirement (paragraph B59A)[4].
Who must meet the requirements — and from when
The standards are voluntary today. Mandatory application is being introduced in layers through the FCA’s CP26/5 proposals, which would replace the TCFD-aligned Listing Rules for accounting periods beginning on or after 1 January 2027[2].
| Requirement | Who | From | Basis |
|---|---|---|---|
| UK SRS S2 climate (excluding Scope 3) | ~500 primary-listed cos (UKLR 6, 16, 22) | FY beginning on/after 1 Jan 2027 | Mandatory |
| Scope 3 emissions | Same in-scope companies | FY beginning on/after 1 Jan 2028 | Comply-or-explain (1-yr relief) |
| UK SRS S1 non-climate | Same in-scope companies | FY beginning on/after 1 Jan 2029 | Comply-or-explain (2-yr relief) |
| Transparency statement only | Secondary listings & depositary receipts (UKLR 14, 15) | FY beginning on/after 1 Jan 2027 | Disclose home-jurisdiction standard |
For a calendar-year reporter, a 2027 start means the first UK SRS-aligned report is published in 2028[2].
Closed-ended investment funds, open-ended investment companies, shell companies and pure debt-securities issuers are outside the proposed scope[2].
Extending requirements to large private companies is a separate workstream: the government has signalled a consultation but has confirmed no thresholds — see our UK SRS intelligence hub and the deadline tracker.
Six UK amendments that change the requirements
UK SRS is near-identical to IFRS S1 and S2, but six narrow amendments change how the requirements apply in practice[4].
| Amendment | What changed | Why it matters |
|---|---|---|
| Effective date removed | The fixed 1 Jan 2024 ISSB effective date is removed; timing is set by UK legislation or FCA rules. | Lets any entity adopt voluntarily; relief clocks start at mandatory use, not early adoption. |
| Climate-first relief reworked | The relief to report climate only in year one is aligned to UK phasing (S2 first, S1 later). | Gives in-scope companies more calendar time for non-climate disclosures. |
| SASB “shall” → “may” | Use of SASB industry guidance becomes optional rather than mandatory. | Removes a hard obligation; SASB stays a reference, not a mandate. |
| GICS requirement removed | Mandatory use of the GICS industry-classification system is dropped. | Removes a licensing barrier, especially for financed-emissions disaggregation. |
| Delayed-reporting relief removed | The relief to publish sustainability disclosures after the financial statements is removed. | Forces connectivity — disclosures align in time with the financial statements. |
| Financed emissions / connectivity clarified | A UK explanation requirement is added (para B59A) and connectivity is clarified for the UK framework. | Tightens financial-sector and Strategic Report alignment. |
Assurance: required to state, not yet required to obtain
UK SRS itself does not mandate external assurance. Under CP26/5 the FCA proposes a disclose-or-explain approach: a company must state whether its sustainability disclosures have been assured, and give details, but is not yet compelled to obtain assurance[2].
To support quality, the FRC published ISSA (UK) 5000, a voluntary UK sustainability assurance standard, in November 2025[6].
It applies to both limited and reasonable assurance and is effective for engagements covering periods beginning on or after 15 December 2026[7].
UK SRS disclosures also overlap with existing Companies Act 2006 duties, including the Non-Financial and Sustainability Information Statement — so in-scope companies are already meeting adjacent requirements[5].
UK SRS requirements: frequently asked questions
What are the UK SRS requirements?
UK SRS requirements are the disclosure rules set out in two standards: UK SRS S1 (general sustainability-related financial disclosures) and UK SRS S2 (climate-related disclosures). Both require information across four pillars — governance, strategy, risk management, and metrics and targets — about the sustainability and climate risks and opportunities that could reasonably affect a company’s enterprise value. The standards were published by the Department for Business and Trade on 25 February 2026 for voluntary use.
What are the four pillars of UK SRS reporting?
Both UK SRS S1 and S2 are structured around the same four pillars inherited from the TCFD framework: governance (the board and management oversight of sustainability and climate matters), strategy (how risks and opportunities affect the business model and financial planning over the short, medium and long term), risk management (the processes used to identify, assess and manage those risks), and metrics and targets (the measures and goals used to track performance, including greenhouse gas emissions).
Does UK SRS require Scope 3 emissions reporting?
Yes, where material — but with relief. UK SRS S2 requires disclosure of Scope 1, Scope 2 and Scope 3 greenhouse gas emissions measured using the GHG Protocol. Under the FCA’s CP26/5 proposals, Scope 1 and Scope 2 would be mandatory from the first reporting period, while Scope 3 moves to a comply-or-explain basis with a one-year transitional relief, becoming required for accounting periods beginning on or after 1 January 2028.
Who must comply with UK SRS requirements?
The standards themselves do not set scope — that is done separately. Under the FCA’s proposed Listing Rules (CP26/5), around 500 primary-listed companies (UK Listing Rules categories 6, 16 and 22) would have to apply UK SRS S2 for accounting periods beginning on or after 1 January 2027. A smaller group of secondary-listing and depositary-receipt issuers (UKLR 14 and 15) face transparency-only requirements. The UK government is expected to consult separately on extending requirements to large private companies.
How do UK SRS requirements differ from IFRS S1 and S2?
UK SRS S1 and S2 are based directly on the ISSB’s IFRS S1 and S2, with six narrow UK-specific amendments: the fixed effective date is removed (timing is set by UK legislation or FCA rules); the climate-first transitional relief is reworked to match UK phasing; references to SASB industry guidance change from “shall” to “may”; the mandatory use of the GICS industry-classification system is removed; the relief allowing sustainability disclosures to be published after the financial statements is removed; and financed-emissions and connectivity provisions are clarified for the UK context.
Do UK SRS disclosures need to be assured?
Not yet mandatorily. Under CP26/5 the FCA proposes a disclose-or-explain approach: companies must state whether their sustainability disclosures have been assured and give details, but are not yet required to obtain assurance. The FRC published ISSA (UK) 5000, a voluntary UK sustainability assurance standard, in November 2025, effective for engagements covering periods beginning on or after 15 December 2026.
Where in the annual report must UK SRS disclosures appear?
UK SRS requires sustainability-related financial disclosures to form part of a company’s general purpose financial reports, reported at the same time and for the same reporting period as the related financial statements. This “connectivity” requirement is designed to give investors a coherent view linking sustainability information to the financial statements.
- UK Sustainability Reporting Standards — GOV.UK (Department for Business and Trade) · Publication, voluntary use and government process
- CP26/5: Aligning listed issuers’ sustainability disclosures with UK SRS — Financial Conduct Authority · Scope, timeline and transitional reliefs
- UK SRS S2 Climate-related Disclosures (final standard) — GOV.UK / DBT · Pillar objectives, scenario analysis, GHG and metrics
- Exposure draft of UK SRS S1 and S2 — government response (the six amendments) — GOV.UK / DBT · UK-specific amendments to IFRS S1/S2
- Sustainability Reporting Developments: Frequently Asked Questions — Financial Reporting Council · Key elements of UK SRS S1/S2 and Companies Act overlap
- FRC takes steps to support quality and consistency in sustainability assurance (ISSA (UK) 5000) — Financial Reporting Council · Voluntary UK sustainability assurance standard
- Developing an oversight regime for assurance of sustainability disclosures: government response — GOV.UK / DBT · ISSA (UK) 5000 effective date and oversight