UK SRS S2 · Requirements reference
UK SRS S2 climate disclosures: every requirement, by paragraph
UK SRS S2 climate disclosures are set out in 37 numbered paragraphs, three added paragraphs on Category 15, and an application guidance appendix with the same authority as the body of the standard.
This page lists what each paragraph asks for, in the standard’s own order, and then what the FCA’s final rules in PS26/19 attach to it.
How to read it
The map of the standard, before the detail
The standard’s front matter says all paragraphs have equal authority, and that paragraphs in bold state the main principles.
It also says UK SRS S2 “should be read in the context of its objective and UK SRS S1”, and ¶C2 requires the two to be applied at the same time.
Appendix B is not optional reading: each appendix is stated to be “an integral part” of the standard.
The body paragraphs carry the same numbers as IFRS S2, so a paragraph reference from an ISSB source still lands in the right place, but the Appendix C references do not.
The overview of the standard and its status is on UK SRS S2, and the combined disclosure set for S1 and S2 is on UK SRS requirements.
A clause-by-clause commentary on the UK SRS S2 standard is kept on our sister reference.
| Part | Paragraphs | Holds |
|---|---|---|
| Objective and scope | ¶¶1–4 | The financial test; physical and transition risks, opportunities |
| Governance | ¶¶5–7 | Oversight body, management's role |
| Strategy | ¶¶8–23 | Risks, business model, transition plan, financial effects, resilience |
| Risk management | ¶¶24–26 | Processes and their integration |
| Metrics and targets | ¶¶27–37, 29A–29C | Seven metric categories, industry metrics, targets |
| Appendix A | — | Defined terms |
| Appendix B | ¶¶B1–B71 | Application guidance, same authority |
| Appendix C | ¶¶C1–C6 | Application and transition, including the Scope 3 relief |
Pillar 1 · ¶¶5–7
Governance: who oversees climate, and how
The objective in ¶5 is to show the governance processes, controls and procedures used to monitor, manage and oversee climate-related risks and opportunities.
A governance body can be a board, a committee or an equivalent body charged with governance, or an individual.
Paragraph 6(a)(v) links forward to the remuneration metric at ¶29(g), so the governance text and the remuneration figure have to agree.
Paragraph 7 tells the entity to avoid duplication: where sustainability oversight is integrated, one integrated governance disclosure can serve S1 and S2.
How boards take on responsibility for the disclosures and explanations is covered in UK SRS board oversight.
| ¶ | Disclose |
|---|---|
| 6(a) | The governance body(s) or individual(s) responsible for oversight, identified by name of body or role |
| 6(a)(i) | How the responsibility appears in terms of reference, mandates, role descriptions and policies |
| 6(a)(ii) | How it determines that the right skills and competencies are available or will be developed |
| 6(a)(iii) | How and how often it is informed about climate-related risks and opportunities |
| 6(a)(iv) | How it weighs climate in strategy, major transactions and risk management, including trade-offs |
| 6(a)(v) | How it oversees target-setting and progress, and whether performance metrics sit in remuneration policies |
| 6(b)(i) | Whether management's role is delegated to a position or committee, and how that is overseen |
| 6(b)(ii) | Whether management uses controls and procedures, and how they integrate with other functions |
Pillar 2 · ¶¶8–21
Strategy: risks, business model, plans and money
Paragraph 9 lists five things users must be able to understand, and ¶¶10–22 set out how each is met.
| ¶ | Requirement | Detail |
|---|---|---|
| 10(a) | Describe the risks and opportunities | Those that could reasonably be expected to affect the entity's prospects |
| 10(b) | Classify each risk | Physical risk or transition risk, for every risk identified |
| 10(c) | Give each a time horizon | Short, medium or long term, for every risk and opportunity |
| 10(d) | Define the horizons | How short, medium and long term are defined and linked to planning horizons |
| 11–12 | Information used | All reasonable and supportable information; the Industry-based Guidance may be referred to |
| 13(a)–(b) | Business model and value chain | Current and anticipated effects, and where risks are concentrated (places, facilities, asset types) |
| 14(a)(i)–(iii) | Response in strategy | Changes to the business model and resource allocation; direct and indirect mitigation and adaptation |
| 14(a)(iv) | Transition plan | Any plan the entity has, with key assumptions and dependencies |
| 14(a)(v), (b), (c) | Targets, resourcing, progress | How targets will be met, how the plans are resourced, and progress on plans disclosed before |
| 15–16 | Financial effects | Current effects; material-adjustment risks to carrying amounts; expected changes to position, performance and cash flows |
| 17–18 | How to estimate | A single amount or a range; an approach commensurate with skills, capabilities and resources |
| 19–21 | When numbers may be omitted | Effects not separately identifiable, or too uncertain, or (for anticipated effects) no skills or resources; then explain and give qualitative information |
Paragraph 10 has four limbs, and the two most often dropped are (b), the classification of every risk as physical or transition, and (d), the link between the horizons and the entity’s own planning horizons.
Paragraph 12 is one of three places where UK SRS S2 says the entity “may” refer to the Industry-based Guidance, where IFRS S2 says “shall”.
Paragraph 16(b) asks for the risks and opportunities with a significant risk of a material adjustment to carrying amounts within the next annual reporting period, which ties the strategy pillar to the financial statements.
The exemptions in ¶¶19–20 are not a way out of disclosure: ¶21 then requires the reason, the affected line items, and combined quantitative information unless that would not be useful.
Pillar 2 · ¶22
Climate resilience and scenario analysis
The operative sentence of ¶22 is that the entity “shall use climate-related scenario analysis to assess its climate resilience using an approach that is commensurate with the entity’s circumstances”.
Paragraph 22(a) asks for the assessment itself: the implications for strategy and business model, the significant areas of uncertainty, and the capacity to adjust or adapt.
That capacity is broken into three: financial resources and their flexibility, the ability to redeploy, repurpose, upgrade or decommission assets, and the effect of current and planned climate investments (¶22(a)(iii)).
Paragraph B18 allows the scenario analysis to follow a multi-year strategic planning cycle, so ¶22(b) may be unchanged from one year to the next.
It does not extend that to the assessment: “an assessment of the entity’s resilience is required to be carried out annually”.
What this means for a listed company is on climate scenario analysis under UK SRS.
¶22(b) — how and when the analysis was done
| Limb | Disclose |
|---|---|
| (b)(i) | Inputs: the scenarios and their sources; whether a diverse range was used; whether each relates to transition or physical risk; whether one is aligned with the latest international agreement on climate change; why each is relevant; the time horizons; the scope of operations |
| (b)(ii) | Key assumptions: climate policies where it operates; macroeconomic trends; national or regional variables; energy use and mix; technology |
| (b)(iii) | The reporting period in which the analysis was carried out |
Pillar 3 · ¶¶24–26
Risk management: the process, not the risks
The risks themselves are disclosed under strategy; this pillar is about the machinery that finds and ranks them.
Paragraph 25(a) asks for the processes and policies used to identify, assess, prioritise and monitor climate-related risks, in six limbs.
Those limbs are the inputs and parameters, whether scenario analysis informs identification, how nature, likelihood and magnitude are assessed, whether climate is prioritised against other risks, how risks are monitored, and what changed from last year.
Paragraph 25(b) asks the same for opportunities, including whether scenario analysis informs them.
Paragraph 25(c) asks how far these processes are integrated into, and inform, the entity’s overall risk management process.
Paragraph 26 repeats the no-duplication rule from governance for companies that run sustainability risk management on an integrated basis.
Pillar 4 · ¶¶27–32
Metrics: greenhouse gases and six more categories
Paragraph 28 splits the pillar into the cross-industry categories at ¶¶29–31, industry-based metrics at ¶32, and targets at ¶¶33–37.
| ¶ | What is disclosed |
|---|---|
| 29(a)(i) | Absolute gross Scope 1, Scope 2 and Scope 3 emissions for the period, in metric tonnes of CO₂ equivalent |
| 29(a)(ii) | Measured under the GHG Protocol Corporate Standard (2004), unless a jurisdictional authority or the listing exchange requires another method |
| 29(a)(iii) | The measurement approach, inputs and assumptions, why they were chosen, and any changes during the period |
| 29(a)(iv) | Scope 1 and 2 split between the consolidated accounting group and other investees |
| 29(a)(v) | Location-based Scope 2, plus information about contractual instruments where necessary |
| 29(a)(vi) | For Scope 3, the categories included and, for asset management, commercial banking or insurance, financed emissions |
| 29A–29C | Category 15 may be limited to financed emissions and exclude derivatives; if so, explain what was treated as a derivative, and give total Category 15 and the financed subtotal |
| 29(b) | Amount and percentage of assets or business activities vulnerable to transition risks |
| 29(c) | Amount and percentage of assets or business activities vulnerable to physical risks |
| 29(d) | Amount and percentage of assets or business activities aligned with climate-related opportunities |
| 29(e) | Capital expenditure, financing or investment deployed towards climate-related risks and opportunities |
| 29(f) | Whether and how a carbon price is used in decision-making, and the price per metric tonne |
| 29(g) | Whether and how climate is factored into executive remuneration, and the percentage of executive management remuneration linked to it |
| 32 | Industry-based metrics for the entity's business model or activities; the Industry-based Guidance may be referred to |
Emissions are measured under the GHG Protocol Corporate Standard, and Scope 3 categories follow the Scope 3 Standard (2011).
Paragraph B30 removes any doubt on Scope 2: the entity “is required to disclose its Scope 2 greenhouse gas emissions using a location-based approach”.
Market-based Scope 2 is optional under UK SRS S2, and how location and market figures differ in the UK is covered on Scope 2 market-based emissions.
Paragraph 30 applies the reasonable-and-supportable-information test to ¶29(b)–(d) only, and ¶31 points ¶29(b)–(g) to the guidance at ¶¶B64–B65.
A company that discloses ¶29 in full has met one of the three metric limbs in ¶28, not the pillar.
Pillar 4 · ¶¶33–37
Targets: eight descriptors each, and more for emissions
Paragraph 33 covers targets the entity has set and any it is required to meet by law or regulation, quantitative and qualitative.
Paragraph 34(a) asks whether the target and its method were validated by a third party, which is where a science-based target validation is reported.
How the SBTi validates targets is on science-based targets.
Paragraph 36(c) is the one most often missed: a company that discloses a net emissions target must also disclose the gross target behind it.
Paragraph 37 keeps IFRS S2’s “shall refer to and consider” for target metrics, unlike ¶¶12, 23 and 32, which the UK softened to “may”.
| ¶ | For each target |
|---|---|
| 33(a)–(h) | Metric; objective; part of the entity; period; base period; milestones and interim targets; absolute or intensity; how the latest international agreement informed it |
| 34(a)–(d) | Third-party validation of the target and method; review process; metrics used to monitor; revisions and why |
| 35 | Performance against the target, with an analysis of trends or changes |
| 36(a)–(d) | For emissions targets: gases covered; scopes covered; gross or net (a net target needs its gross target too); sectoral decarbonisation approach |
| 36(e) | Planned use of carbon credits for a net target: reliance, the verifying scheme, nature-based or technological, reduction or removal, and permanence |
| 37 | The entity shall consider cross-industry and industry-based metrics when choosing target metrics |
Appendix B · ¶¶B32–B63A
Scope 3 and financed emissions, in the application guidance
Paragraph B32 requires the entity to consider its entire value chain and “all 15 categories” of Scope 3, and to disclose which it includes.
Considering all fifteen is not the same as reporting all fifteen, and ¶B33 makes the categories disclosure compulsory whatever measurement method is used.
The measurement framework at ¶¶B38–B54 asks the entity to prioritise direct measurement, primary data, timely data that reflects the jurisdiction and technology, and verified data.
Paragraph B56 then asks how far the Scope 3 figure uses inputs from specific value-chain activities and how far it uses verified inputs.
Paragraph B57 presumes Scope 3 can be estimated reliably from secondary data; in rare impracticable cases the entity discloses how it manages Scope 3 instead.
Banks, insurers and asset managers disclose financed emissions under ¶¶B59–B63A, and ¶B59A is the one place the UK text asks for more than IFRS S2.
The one-year FCA relief, the categories and the data hierarchy are worked through on Scope 3 reporting under UK SRS.
Where it is impracticable to reliably estimate financed emissions for the same period as the financial statements, disclose:
(a) why it cannot do so;
(b) the measurement approach, inputs and assumptions for any financed emissions reported; and
(c) its plan, including the timeline, to report them for the same period.
¶14(a)(iv)
Transition plans: disclose one if you have one
UK SRS S2 does not require a company to have a transition plan.
Paragraph 14(a)(iv) requires information about “any climate-related transition plan the entity has”, including key assumptions and the dependencies it relies on.
The FCA’s final rules add a statement: whether the listed company has published a climate-related transition plan, where, or why it has not.
The FCA says in PS26/19 that it is “not requiring listed companies to produce transition plans”.
The government’s transition-plan consultation ran from 25 June to 17 September 2025, and no response had been published when it was re-checked on 28 September 2026.
What a UK transition plan contains, and where the policy stands, is on transition plans in the UK.
What the listing rules attach
What the FCA’s rules add to the standard
The standard says what a disclosure contains; the listing rules say what a listed company must do with it.
Under UKLR 6.6.6R(7A), a commercial company includes UK SRS S2 disclosures or explains, for accounting periods beginning on or after 1 January 2027.
The FCA’s guidance at UKLR 6.6.6A G reminds a company to apply the parts of UK SRS S1 that relate to climate, and names paragraphs such as ¶¶10–24 and ¶¶60–71 as potentially relevant.
Assurance is not required: the duty is to say whether it was obtained, and the FRC’s ISSA (UK) 5000 is the standard a provider may use if it is.
The same limbs apply to secondary listings, depositary receipts, UKLR 16 and UKLR 22 issuers, except that the transition-plan statement does not apply to UKLR 14 and 15.
Who is in scope is on who needs UK SRS, the rules in full on UK SRS and the FCA, and the first period by year-end on the UK SRS deadline page.
| UKLR 6.6.6R | Statement in the annual financial report |
|---|---|
| (7A)(a) | Climate-related financial disclosures prepared in accordance with UK SRS S2 |
| (7A)(b) | Or: a summary of the requirements not met, the reasons, and any steps planned |
| (8)(c) | Where the disclosures and explanations are, with cross-reference allowed under UK SRS S1 ¶¶B45–B47 |
| (8)(d) | Whether any disclosures were assured; if so, provider, what and to what level, standards used, and where the report is |
| (8)(e) | Whether a climate-related transition plan is published, and where, or why not |
Frequently asked
UK SRS S2 requirements — frequently asked
What are the four pillars of UK SRS S2, and which paragraphs hold them?
Governance is at paragraphs 5–7, strategy at paragraphs 8–23, risk management at paragraphs 24–26, and metrics and targets at paragraphs 27–37, with paragraphs 29A–29C added for Category 15 emissions. Appendix B is application guidance with the same authority as the body of the standard, and Appendix C holds the application and transition provisions.
What does UK SRS S2 require on governance?
Paragraph 6(a) requires the entity to identify the governance body or individual responsible for oversight of climate-related risks and opportunities and to disclose five things about them: how the responsibility appears in terms of reference and role descriptions, how skills are ensured, how and how often they are informed, how climate is weighed in strategy and major transactions, and how targets are overseen, including links to remuneration. Paragraph 6(b) covers management's role and the controls and procedures used.
What does paragraph 22 of UK SRS S2 require?
Paragraph 22 requires information about the resilience of the entity's strategy and business model to climate-related changes, and says the entity shall use climate-related scenario analysis using an approach commensurate with its circumstances. Paragraph 22(a) covers the resilience assessment and paragraph 22(b) covers how and when the analysis was carried out, including the scenarios, their sources, the key assumptions and the time horizons.
What must be disclosed for each climate-related target under UK SRS S2?
Paragraph 33 requires, for each target, the metric used, the objective, the part of the entity it covers, the period, the base period, any milestones, whether it is absolute or intensity-based, and how the latest international agreement on climate change informed it. Paragraph 34 covers how targets are set, reviewed and validated, paragraph 35 performance against them, and paragraph 36 extra detail for greenhouse gas targets, including gross versus net and planned use of carbon credits.
What is paragraph B59A of UK SRS S2?
Paragraph B59A is a UK addition. When an entity determines it is impracticable to reliably estimate its financed emissions for the same reporting period as the related financial statements, it must disclose why, the measurement approach, inputs and assumptions used for any financed emissions it does report, and its plan, including the timeline, to report financed emissions for the same period as the financial statements.
Does UK SRS S2 require market-based Scope 2?
No. Paragraph 29(a)(v) requires location-based Scope 2 emissions and information about contractual instruments where that is necessary to inform users. Paragraph B30 says the entity is required to disclose Scope 2 using a location-based approach, and paragraph B31 says it might also disclose market-based figures.
Can a company leave out quantitative financial effects under UK SRS S2?
In limited cases. Paragraph 19 allows omission where the effects are not separately identifiable or measurement uncertainty is so high that the numbers would not be useful, and paragraph 20 allows it for anticipated effects where the entity lacks the skills, capabilities or resources. Paragraph 21 then requires an explanation, qualitative information identifying the affected line items, and combined quantitative information unless that would not be useful.
What do the FCA rules add to UK SRS S2?
Under the final rules in PS26/19, a listed company either includes disclosures prepared in accordance with UK SRS S2 or a statement of the requirements not met, the reasons, and the steps it plans. It also states where the disclosures are, whether any were assured and by whom, and whether it has published a transition plan. The rules apply to accounting periods beginning on or after 1 January 2027 on a comply-or-explain basis.
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 S2 Climate-related Disclosures (PDF)
Read in full: ¶¶5–7 governance, ¶¶8–23 strategy, ¶¶24–26 risk management, ¶¶27–37 metrics and targets, ¶¶29A–29C, ¶¶B18, B30–B33, B38–B57, B59–B59A, C4.
- Department for Business and TradeUK SRS S1 General Requirements (PDF)
¶¶B45–B47 (cross-reference), ¶73A (compliance statement with reliefs); the S1 paragraphs UKLR 6.6.6A G points to.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
Published 25 February 2026, available for voluntary use.
- Department for Business and TradeUK SRS consultation response, Annex A (PDF)
B59A is the one UK addition to the body of UK SRS S2; ¶¶12, 23, 32 soften "shall" to "may".
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards (PDF)
Comply or explain for UK SRS S2 (¶1.7); location, assurance and transition-plan statements; UKLR 6.6.6R(7A) and (8)(c)–(e) as made in Appendix 1.
- FCA HandbookUKLR 6.6 — annual financial report (commercial companies)
UKLR 6.6.6R(7A) and (8) as they apply from 1 January 2027.
- Financial Conduct AuthorityCP26/5 consultation page
The consultation that proposed mandatory UK SRS S2; superseded by PS26/19.
- GHG ProtocolCorporate Accounting and Reporting Standard
The Scope 1 and 2 basis in UK SRS S2 ¶29(a)(ii) (2004 edition).
- GHG ProtocolCorporate Value Chain (Scope 3) Standard (2011)
The 15 categories UK SRS S2 ¶B32 requires an entity to consider.
- IFRS FoundationAmendments to Greenhouse Gas Emissions Disclosures (Amendments to IFRS S2), December 2025 (PDF)
The ISSB source of ¶¶29A–29C, carried into UK SRS S2.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
The FRC assurance standard a provider may use if a company chooses assurance; issued 12 November 2025, effective for periods beginning on or after 15 December 2026, required of no one.
- GOV.UKClimate-related transition plan requirements — consultation
Ran 25 June – 17 September 2025; no government response published when re-checked on 28 September 2026.
- Financial Reporting CouncilSustainability reporting developments — FAQs
New or amended ISSB standards do not apply in the UK without endorsement.
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