UK SRS · Systems
UK SRS software: what a reporting system must be able to do
UK SRS software is a label, not a category any regulator recognises: nothing in UK SRS or the FCA’s rules in PS26/19 requires, approves or certifies a system.
What the standards do require is a set of outputs, and a system either produces them or it does not.
This page lists those outputs provision by provision, so that any product, or any spreadsheet, can be tested against them; we do not rank or recommend products.
Where things stand
Is there UK SRS software? Not as a regulated category
The Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026, and the FCA’s rules for listed companies followed on 30 September 2026.
The rules apply comply or explain to accounting periods beginning on or after 1 January 2027, so the first reporting season is 2028; any product sold as “UK SRS ready” before that has not yet produced a report under the rules.
Most are extensions of tools built for IFRS S2, TCFD, the EU’s standards or emissions accounting, which overlap with UK SRS S2 because it is the UK-endorsed version of IFRS S2.
Overlap is not the same as producing the disclosure, and the UK has its own additions: the FCA’s statements, and UK SRS S2 ¶B59A, which requires financial institutions to explain why if financed emissions cannot be reliably estimated for the period.
The consultation behind the rules, CP26/5, had proposed mandatory UK SRS S2; the final rules are comply or explain throughout, which matters for software because the explanations need a home too.
We have not tested any reporting product.
So we do not rank, price or characterise them, and no product on the market is described here from anything but the requirements.
What to test
Sixteen outputs a UK SRS system must be able to produce
Each row is a requirement in the standards or the rules; the right-hand column is our reading of what that means for a system.
| Requirement | Provision | What it means for a system |
|---|---|---|
| Same reporting entity as the financial statements | UK SRS S1 ¶20 | The organisational hierarchy comes from the consolidation, and changes to it flow through |
| Scope 1 and 2 split between the consolidated group and other investees | UK SRS S2 ¶29(a)(iv) | Associates, joint ventures and unconsolidated subsidiaries can be tagged and reported separately |
| Location-based Scope 2, plus contractual-instrument information | UK SRS S2 ¶29(a)(v) | Both bases held side by side, with the instruments behind any market-based figure |
| Scope 3 by GHG Protocol category | UK SRS S2 ¶29(a)(vi) | Category-level data and inclusion decisions, not a single total |
| Measurement approach, inputs, assumptions and changes, with reasons | UK SRS S2 ¶29(a)(iii) | A change log for factors and methods, dated and explained |
| Emission factors that best represent the activity; primary data preferred | UK SRS S2 ¶¶B29, B40, B47 | Factor sources recorded per line; supplier-specific factors where available |
| Extent of Scope 3 measured from specific or verified inputs | UK SRS S2 ¶B56 | A data-quality flag on every Scope 3 line that can be summarised |
| Other cross-industry metrics: vulnerable and aligned assets, capital deployed, carbon price, remuneration | UK SRS S2 ¶29(b)–(g) | Links to asset registers and finance data, not just emissions |
| Targets: gross and net, scopes, carbon credits, performance and trends | UK SRS S2 ¶¶35–36 | Gross and net held separately; planned credits with their scheme and type |
| Scenario analysis: scenarios, sources, horizons, assumptions, period | UK SRS S2 ¶22(b) | A record of the analysis, even if the modelling is done elsewhere |
| Comparatives; metrics defined consistently over time | UK SRS S1 ¶¶52, 70 | Prior-period figures held alongside, and a record of any redefinition |
| Data and assumptions consistent with the accounts; same presentation currency | UK SRS S1 ¶¶23–24 | Shared assumptions with finance, and currency amounts in the group’s presentation currency |
| Disclosures published with the financial statements | UK SRS S1 ¶64 · DTR 4.1.3R | A close timetable that finishes with the accounts, at most four months after year-end |
| Explanations: requirements not met, reasons, steps | UKLR 6.6.6R(7A)(b), (7B)(b) | A comply, explain or relief register that can be exported and reviewed |
| Controls that support oversight | UK SRS S2 ¶6(b)(ii) · CGC Provision 29 | Review and approval steps recorded, with who did what and when |
| Assurance statement facts | UKLR 6.6.6R(8)(d) | An evidence trail an assurer could follow, whether or not one is engaged |
Scope 3 is where most tools are weakest, and where UK SRS is most specific about categories and data quality.
UK SRS S2 ¶B57 presumes Scope 3 “can be estimated reliably using secondary data and industry averages”, so a system must handle spend- and activity-based estimates as well as supplier data, and show which is which.
A system that cannot break Scope 3 into the GHG Protocol categories will need replacing, not upgrading, before Scope 3 is disclosed or explained from the second period.
How to prioritise the categories is covered in Scope 3 reporting under UK SRS, and the UK factor sets in UK emission factors.
Build or buy
Spreadsheets or a platform: what decides it
Neither the standards nor the rules require software, and a first voluntary or first-period report can be built in spreadsheets by a company with mature SECR and TCFD reporting.
The case for a platform grows with four pressures, set out beside this text, and each has a provision behind it.
The second period is the usual turning point: for a December year-end, Scope 3 is disclosed or explained from the period beginning 1 January 2028, after the one-year relief.
Controls matter whichever route is chosen: commercial companies make a Provision 29 declaration on material controls, which the FRC says extends to narrative and ESG reporting, for financial years beginning on or after 1 January 2026.
The timing of each step is set out in the UK SRS implementation guide.
| Pressure | Why it matters | Provision |
|---|---|---|
| Scope 3 by category | Many lines, many sources, a quality flag on each | S2 ¶¶29(a)(vi), B56 |
| Year-on-year consistency | Metrics defined consistently; comparatives for every amount | S1 ¶¶52, 70 |
| Audit trail | Board sign-off and any assurance rely on it | UKLR 6.6.6R(8)(d); CGC Provision 29 |
| Close timetable | Disclosures land with the accounts | S1 ¶64 |
Buy once, reuse
What CDP, SECR and ESOS tools already cover
Few listed companies start from nothing, so the efficient question is how much existing data a system can reuse without re-keying.
| Existing reporting | What it already holds | What UK SRS adds |
|---|---|---|
| CDP | A questionnaire CDP says has been aligned with IFRS S2 since 2024 | The FCA’s statements, UK SRS S1 topics, and UK differences such as ¶B59A |
| SECR | Energy use, emissions from fuel, facilities and purchased energy, and at least one emissions intensity ratio | Scope 3, the consolidated-group split, governance, strategy, risk management, scenario analysis, six more metric categories |
| ESOS | Total energy consumption and audit findings for large undertakings | Emissions measured under the GHG Protocol, and everything beyond energy |
| TCFD-aligned reporting | The four-pillar narrative and, often, Scope 1 and 2 | Paragraph-level requirements, timing with the accounts, the FCA’s statements |
Most companies in scope already report SECR energy and carbon data, many hold audit data from ESOS, and listed companies have climate narrative from their TCFD reporting.
A platform that needs the same meter reading entered once for SECR, again for CDP and again for UK SRS adds cost rather than removing it.
CDP’s own alignment statement refers to IFRS S2, not UK SRS S2; the difference is small in the standard and larger once the FCA’s statements are added.
The wider buyer-side view of emissions tools is on carbon reporting software, and broader ESG suites on ESG reporting platforms.
Digital reporting
Tagging: not required for UK SRS, required for the accounts
In CP26/5 the FCA asked whether investors wanted digital tagging of sustainability information and whether issuers were ready for it.
Respondents saw benefits, especially for quantitative metrics such as Scope 1, 2 and 3 emissions, but cautioned that tagging should follow once taxonomy, practice, systems and capability mature.
The FCA’s answer in PS26/19 is quoted beside this text: no tagging requirement for UK SRS disclosures.
That is different from the accounts: DTR 4.1.18R already requires annual financial reports containing IFRS consolidated financial statements to be tagged using a generally accepted taxonomy.
A system that can tag sustainability data is therefore a choice today, not a compliance need.
What the FCA said, in PS26/19
“Based on feedback, and consistent with our consultation position, we are not proposing requirements for issuers to digitally tag their sustainability disclosures. However, we continue to engage with the Government on the regulatory framework for digital reporting in the UK.”
Source: FCA PS26/19, response on Questions 18 and 19
Evaluation
Questions to put to any vendor, with your own data
Each question asks for an output the provisions require; a demonstration on sample data proves less than one on yours.
Show our Scope 1 and 2 split between the consolidated group and our associates and joint ventures.
UK SRS S2 ¶29(a)(iv)
Show location-based Scope 2 beside the market-based figure and the instruments behind it.
UK SRS S2 ¶29(a)(v)
Show Scope 3 by category, with the factor source and a data-quality flag on each line.
UK SRS S2 ¶¶29(a)(vi), B56
Show what happens to prior-year figures when an emission factor or method changes.
UK SRS S2 ¶29(a)(iii) · S1 ¶¶52, 70
Show a net target with its associated gross target and the planned carbon credits.
UK SRS S2 ¶36
Export our comply, explain or relief register by paragraph.
UKLR 6.6.6R(7A)(b)
Show who approved each figure and when, in a form an assurer could follow.
UKLR 6.6.6R(8)(d)
Show a close that finishes with the accounts.
UK SRS S1 ¶64
Any published vendor price should be read with its date; we do not state prices ourselves.
For the outputs the finished annual report must contain, see the UK SRS compliance checklist; to talk through an evaluation, book a free 15-minute call.
Frequently asked
UK SRS software — frequently asked
Is there dedicated UK SRS software?
Nothing in UK SRS or the FCA’s rules requires, approves or certifies any software. The standards were published on 25 February 2026 and the FCA’s rules on 30 September 2026, so products describing themselves as UK SRS ready are mostly extending tools built for IFRS S2, TCFD, CSRD or emissions accounting. Judge any tool by whether it produces what the provisions on this page require, not by the label.
Do we need software to comply with UK SRS, or can we use spreadsheets?
Neither UK SRS nor the FCA requires software. Spreadsheets can work for a first year, particularly for a company already producing SECR and TCFD reporting. They get harder to control once Scope 3 is reported by category, figures must be consistent year on year, and an audit trail is needed for board sign-off or assurance. For a December year-end, Scope 3 is disclosed or explained from the period beginning 1 January 2028.
What should a UK SRS software evaluation test?
Ask the vendor to produce, from your own data, the outputs the provisions require: Scope 1 and 2 split between the consolidated group and other investees; location-based Scope 2; Scope 3 by GHG Protocol category with the measurement approach and changes; the other cross-industry metrics; target progress with gross and net figures; comparatives; and an export of your comply-or-explain register. A dashboard demonstration is not evidence that a tool can produce a disclosure.
Does CDP software cover UK SRS?
Partly. CDP says its questionnaire has been aligned with IFRS S2 since 2024, and UK SRS S2 is based on IFRS S2, so data structured for CDP maps to much of UK SRS S2. It does not produce the UK-specific items: the FCA’s comply-or-explain statements, relief statements, the location, assurance and transition-plan statements, or UK SRS S1 for other sustainability topics.
Does SECR software cover UK SRS?
Only a slice of it. SECR requires energy use, the emissions from fuel combustion, facilities and purchased electricity, heat, steam or cooling, and at least one intensity ratio, in the directors’ report. UK SRS S2 asks for gross Scope 1, 2 and 3, split and measured in specific ways, plus governance, strategy, risk management, scenario analysis and six further metric categories.
Do UK SRS disclosures have to be digitally tagged?
No. In PS26/19 the FCA says it is not proposing requirements for issuers to digitally tag their sustainability disclosures, while it continues to engage with the government on digital reporting. The existing tagging requirement in DTR 4.1 applies to annual financial reports containing IFRS consolidated financial statements.
Can software write the comply-or-explain statements?
It can hold the register behind them. The statements themselves are the company’s: under UKLR 6.6.6R(7A)(b) an explanation summarises the requirements not met, the reasons and any steps planned, and the FCA’s draft guidance expects it to be specific to the issuer. A generated explanation that reads the same for every company is what that guidance warns against.
Do you recommend or rank UK SRS software?
No. We have not tested any product, so we do not rank, price or characterise them. This page sets out what the standards and rules require a system to produce, so that a company can test products against those requirements itself.
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)
¶6(b)(ii) (controls), ¶22 (scenario analysis), ¶29 (seven metric categories, emissions measurement and disaggregation), ¶¶35–36 (targets), ¶¶B29, B40, B47, B56–B57 (emission factors and the data hierarchy).
- Department for Business and TradeUK SRS S1 General Requirements (PDF)
¶20 (reporting entity), ¶¶23–24 (consistent data, same currency), ¶52 (consistent metrics), ¶64 (timing), ¶70 (comparatives).
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — publication page
Published 25 February 2026.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
"Available for voluntary use, by any entity that chooses to do so."
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards (PDF)
Comply or explain across UK SRS; the response to Questions 18–19 on digital reporting (no tagging requirement); UKLR 6.6.6R(7A)–(8) as made.
- Financial Conduct AuthorityPS26/19 landing page
First published 30 September 2026: comply or explain across UK SRS; Technical Note feedback by 28 October 2026; FCA webinar on 19 October 2026; supervisory information in the second half of 2027.
- Financial Conduct AuthorityDraft Technical Note 803.1 — UK SRS sustainability disclosures for listed companies (PDF, for consultation)
Draft guidance: what an explanation must contain, proportionality, the statement of compliance (Annex 1) and four illustrative explanations (Annex 2).
- FCA HandbookDTR 4.1 — annual financial report
DTR 4.1.3R: the four-month publication deadline the system has to meet.
- Financial Conduct AuthorityTechnical Note 507.2 — digital tagging of annual financial reports (PDF)
DTR 4.1.18R: IFRS consolidated financial statements tagged using a generally accepted taxonomy.
- GHG ProtocolA Corporate Accounting and Reporting Standard
The Scope 1 and 2 measurement basis named in UK SRS S2 ¶29(a)(ii).
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The Scope 3 categories referred to in UK SRS S2 ¶29(a)(vi).
- CDPFramework alignment
CDP’s own statement that its questionnaire has been aligned with IFRS S2 since 2024.
- legislation.gov.ukSI 2008/410 Schedule 7, Part 7 (SECR, quoted companies)
Energy use, emissions from fuel, facilities and purchased energy, and at least one intensity ratio.
- Financial Reporting CouncilUK Corporate Governance Code 2024
Provision 29 controls declaration, extended to narrative and ESG reporting controls, from financial years beginning on or after 1 January 2026.
- Financial Reporting CouncilAssurance standards, including ISSA (UK) 5000
The standard an assurer would work to, if assurance is commissioned.
- Financial Conduct AuthorityCP26/5 consultation paper (PDF)
The consultation, including its discussion questions on digital reporting, that PS26/19 answers.
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