UK SRS S2: climate-related disclosures, in detail
UK SRS S2 is the UK’s climate standard — the endorsement of IFRS S2, organised around four pillars and anchored by seven cross-industry climate metrics.
This page sets out what S2 actually requires: the metrics, the GHG Protocol scopes, scenario analysis, transition plans, and who falls in scope and when.
What UK SRS S2 is
UK SRS S2 is the UK’s climate-related disclosure standard. The Department for Business and Trade published it on 25 February 2026, alongside UK SRS S1, and made it available for voluntary use[2].
It is the UK endorsement of the ISSB’s IFRS S2, adjusted by six narrow UK-specific amendments rather than rewritten[2].
S2 keeps the four-pillar architecture that climate reporters will recognise from TCFD and IFRS S2: governance, strategy, risk management, and metrics and targets[1].
For the wider picture of what both standards require, see our UK SRS requirements analysis.
The four pillars
Every S2 disclosure maps to one of four pillars. The standard sets out the requirements pillar by pillar, with paragraph references that assurance providers and the FRC will expect reporters to be able to point to[1].
| Pillar | Paragraphs | What it covers |
|---|---|---|
| Governance | 5–8 | Board oversight and management responsibility for climate-related risks and opportunities |
| Strategy | 9–22 | Risks and opportunities, financial effects, scenario analysis and transition-plan disclosure |
| Risk management | 23–28 | How climate risks are identified, assessed, prioritised and integrated into wider risk processes |
| Metrics & targets | 27–37 | Cross-industry climate metrics, GHG emissions, industry metrics and climate-related targets |
Two pillars carry most of the new burden. Strategy houses the scenario-analysis requirement at paragraph 22; metrics and targets houses the cross-industry metrics and GHG emissions at paragraphs 29 to 37[1].
The seven cross-industry climate metrics
Paragraph 29 requires every reporter, in every sector, to disclose seven categories of cross-industry climate metric. This is the most quantitative part of S2[1].
| Para | Metric | What S2 asks for |
|---|---|---|
| 29(a) | GHG emissions | Absolute gross emissions in tonnes of CO2e, classified into Scope 1, 2 and 3 |
| 29(b) | Transition-risk exposure | Amount and percentage of assets or activities vulnerable to transition risk |
| 29(c) | Physical-risk exposure | Amount and percentage of assets or activities vulnerable to physical risk |
| 29(d) | Opportunity exposure | Amount and percentage of assets or activities aligned with climate opportunities |
| 29(e) | Capital deployment | Capital expenditure, financing or investment deployed towards climate risks and opportunities |
| 29(f) | Internal carbon price | Whether and how a carbon price is used in decisions, and the price per tonne of CO2e |
| 29(g) | Executive remuneration | Percentage of executive remuneration linked to climate-related considerations |
The physical-risk metric at 29(c) is often the sharpest break from TCFD: it asks for a quantified amount and percentage, not a narrative discussion of exposure[1].
GHG emissions: Scope 1, 2 and 3 on the GHG Protocol
Paragraph 29(a) requires absolute gross greenhouse-gas emissions, classified into Scope 1, Scope 2 and Scope 3, measured in line with the GHG Protocol Corporate Standard[5].
Scope 3 — value-chain emissions — follows the GHG Protocol Corporate Value Chain (Scope 3) Standard, which sets out 15 categories: 8 upstream and 7 downstream[4].
| Scope | What it covers | GHG Protocol basis |
|---|---|---|
| Scope 1 | Direct emissions from owned or controlled sources | Corporate Standard |
| Scope 2 | Indirect emissions from purchased electricity, heat, steam and cooling | Corporate Standard / Scope 2 guidance |
| Scope 3 | Indirect value-chain emissions across 15 categories (upstream and downstream) | Corporate Value Chain (Scope 3) Standard |
For in-scope listed companies, the FCA proposes that Scope 3 be reported on a comply-or-explain basis, with one year of transitional relief from initial application[3].
The detail of value-chain measurement and that relief is in our Scope 3 under UK SRS analysis.
Climate scenario analysis
Paragraph 22 requires an entity to disclose information that lets users understand the resilience of its strategy and business model to climate-related changes, and to use climate-related scenario analysis to assess that resilience[1].
The approach must be commensurate with the entity’s circumstances — the standard does not prescribe a fixed set of scenarios for every reporter[1].
The disclosure obligation is the entity’s interpretation of what the analysis means for the business, supported by the scenarios, time horizons and assumptions it used[1].
Transition-plan disclosure
S2’s strategy pillar requires an entity to disclose information about any climate-related transition plan it has, including the targets and assumptions underpinning it, as part of explaining how it plans to respond to climate-related risks and opportunities[1].
The FCA does not propose to mandate that companies produce a transition plan — that is a matter for Government — but it does require disclosure of whether and where any plan is published[3].
In other words, S2 governs how a transition plan is disclosed if you have one; it does not, by itself, compel you to write one.
Scope and timeline
UK SRS S2 is currently voluntary for all entities[2].
The FCA’s CP26/5 proposes making S2 mandatory for in-scope listed companies — those in UK Listing Rules categories 6, 16 and 22, around 500 companies — for accounting periods beginning on or after 1 January 2027[3].
Scope 3 would apply on a comply-or-explain basis with one year of transitional relief from initial application[3].
These remain proposals: the consultation closed on 20 March 2026 and the FCA is expected to publish a Policy Statement with final rules in autumn 2026[3].
| Requirement | From | Basis |
|---|---|---|
| UK SRS S2 climate (excluding Scope 3) | FY beginning on/after 1 Jan 2027 | Mandatory |
| Scope 3 emissions | FY beginning on/after 1 Jan 2028 | Comply-or-explain (1-yr relief) |
| UK SRS S1 (non-climate) | FY beginning on/after 1 Jan 2029 | Comply-or-explain |
For how the FCA turns the standard into Listing Rules, see our UK SRS × FCA framework and the deadline tracker.
How S2 disclosures are assured
The Financial Reporting Council published the voluntary UK sustainability assurance standard, ISSA (UK) 5000, on 12 November 2025, effective 15 December 2026[6].
CP26/5 does not itself mandate assurance of S2 disclosures; the FCA’s proposals leave assurance voluntary for now[3].
ISSA (UK) 5000 distinguishes limited assurance — a negative “nothing has come to our attention” conclusion — from reasonable assurance, a positive “fairly stated” conclusion[6].
UK SRS S2: frequently asked questions
What is UK SRS S2?
UK SRS S2 is the UK climate-related disclosure standard, published by the Department for Business and Trade on 25 February 2026 alongside UK SRS S1. It is the UK endorsement of the ISSB’s IFRS S2, adjusted by six narrow UK-specific amendments. It organises climate disclosure around four pillars — governance, strategy, risk management, and metrics and targets — and is available now for voluntary use.
What are the four pillars of UK SRS S2?
UK SRS S2 keeps the TCFD-derived four-pillar structure inherited from IFRS S2: governance (paragraphs 5–8), strategy (paragraphs 9–22), risk management (paragraphs 23–28), and metrics and targets (paragraphs 27–37). Strategy is where the scenario-analysis and transition-plan requirements sit; metrics and targets is where the GHG emissions and cross-industry climate metrics sit.
What are the cross-industry climate metrics under S2?
UK SRS S2 paragraph 29 requires seven cross-industry metric categories: absolute gross GHG emissions classified by Scope 1, 2 and 3; the amount and percentage of assets or activities vulnerable to transition risk; the same for physical risk; assets or activities aligned with climate opportunities; capital deployed towards climate risks and opportunities; whether and how an internal carbon price is used and the price per tonne of CO2e; and the percentage of executive remuneration linked to climate considerations.
Does S2 require Scope 3 emissions reporting?
Yes. Paragraph 29(a) requires absolute gross greenhouse-gas emissions classified into Scope 1, Scope 2 and Scope 3, measured in line with the GHG Protocol Corporate Standard and the Corporate Value Chain (Scope 3) Standard, which sets out 15 Scope 3 categories. For in-scope listed companies, the FCA’s CP26/5 proposes that Scope 3 be reported on a comply-or-explain basis with one year of transitional relief from initial application.
Is climate scenario analysis mandatory under S2?
Yes. Paragraph 22 of UK SRS S2 requires an entity to disclose information that enables users to understand the resilience of its strategy and business model to climate-related changes, and to use climate-related scenario analysis to assess that resilience using an approach commensurate with its circumstances. The disclosure obligation is the entity’s interpretation of what the analysis means for the business, supported by the methodology and assumptions it used.
Who has to apply UK SRS S2, and from when?
UK SRS S2 is currently voluntary for all entities. The FCA’s CP26/5 proposes making it mandatory for in-scope listed companies — those in UK Listing Rules categories 6, 16 and 22, around 500 companies — for accounting periods beginning on or after 1 January 2027. Those proposals are not yet law; the FCA is expected to publish a Policy Statement with final rules in autumn 2026.
- UK SRS S2 Climate-related Disclosures — GOV.UK / Department for Business and Trade · Standard text, February 2026 — pillars, paragraph 22 (scenario analysis), paragraphs 27–37 (metrics & targets)
- UK Sustainability Reporting Standards (UK SRS S1 and UK SRS S2) — GOV.UK / DBT · Published 25 February 2026; six UK-specific amendments; available for voluntary use
- CP26/5: Aligning listed issuers’ sustainability disclosures with international standards — Financial Conduct Authority · Proposed mandatory UK SRS S2 from 1 Jan 2027; Scope 3 comply-or-explain; closed 20 Mar 2026
- Corporate Value Chain (Scope 3) Accounting and Reporting Standard — GHG Protocol · 15 Scope 3 categories — 8 upstream, 7 downstream
- Corporate Accounting and Reporting Standard — GHG Protocol · Scope 1 and Scope 2 accounting methodology referenced by UK SRS S2
- ISSA (UK) 5000 — sustainability assurance standard — Financial Reporting Council · Published 12 November 2025; effective 15 December 2026