UK SRS timeline — every date, and which ones are fixed

The UK SRS timeline end to end, and the eighteen quiet months in the middle

Nine milestones carry the UK SRS timeline, and three of them happened in a seven-week window in early 2026.

Then nothing. Between 20 March 2026 and the Policy Statement the FCA has not yet published, the regulatory record is empty.

Scroll, and the rail below moves through the nine in order. Each one names the document that states it and whether anyone has actually decided it.

Every card above restates a date that is set out again, with its source, in the milestone record below and in the primary sources. The rail is display, not navigation.

Every published milestone on the UK SRS timeline, in order

The UK SRS implementation record does not begin in 2026. It begins with the TCFD-aligned listing rules the proposal would replace.

Fourteen milestones, each with the document that states it, and each marked according to whether anyone has decided it.

Where a date is proposed, the word proposed is on it. Where nobody has set a date, it says so.

What actually happened on the one date that happened

DBT did three things on 25 February 2026, and only the first is usually reported.

It published UK SRS S1 and UK SRS S2 — the UK’s versions of the ISSB’s IFRS S1 and IFRS S2, assessed and endorsed for use in the United Kingdom. DBT, UK SRS S1 and S2

It published the government response to the exposure-draft consultation, which is where the UK modifications are set out and justified. DBT, Government response

And it made both standards available for voluntary use immediately, by any entity, in whole or in part.

Six UK modifications, and one of them changes this timeline

The government response lists the changes made on endorsement. Most are narrow. The one that matters to a timeline is the third: the removal of the effective-date clauses.

The others, briefly: references to SASB materials changed from “shall refer to and consider” to “may refer to”; the requirement to use the Global Industry Classification Standard removed from S2; the IFRS S1 relief allowing sustainability information to be published at a different time from the financial statements removed; the durations of the non-climate and Scope 3 reliefs removed; a new paragraph on financed emissions in S2; and two new paragraphs in S1 on the compliance statement and on the primacy of UK law and regulation.

Neither standard contains a start date, and that is deliberate

IFRS S1 and IFRS S2 carry effective dates. UK SRS S1 and UK SRS S2 do not, because the UK took them out.

The government response states the change plainly: the effective date has been removed from UK SRS S1, “meaning that entities can apply the Standard when they choose to do so, unless required by UK law or regulations”. DBT, Government response

The exposure draft had said the same thing prospectively: “Any effective date for application of this Standard will be set out in the relevant legislation or regulation.”

Why this is the most useful fact on the page

It means the question “when does UK SRS start?” has no answer inside the standards, and cannot have one.

The start date is whatever a regulator or a statute says it is, for the entities that regulator or statute covers. Today there is exactly one candidate — the FCA’s proposal — and it has not been made.

UK SRS S1 goes further and says so in the standard itself, at paragraph 73B: application is “subject to any rules, requirements, regulations or legislation” in the Companies Act 2006 or determined by the FCA. UK SRS S1

What the FCA has actually proposed, and what it has not

CP26/5 is a consultation paper. It proposes; it does not enact.

Read at the level of what it would change, there are three proposals, and the third is the one that turns UK SRS from a document into an obligation.

One — delete the TCFD rules

CP26/5 proposes to “delete our current TCFD-aligned climate disclosure rules”. The regime that has applied since 2021 would go. CP26/5

Two — require UK SRS instead

In-scope listed companies would report against UK SRS S2 for climate, and in time UK SRS S1 for wider sustainability matters.

Three — commence on 1 January 2027

CP26/5 says both things at once, and they are not the same thing: “Those rules would come into force on 1 January 2027”, and “The new rules would then apply to accounting periods beginning on or after 1 January 2027.” CP26/5, chapter 8

The first is when the rulebook changes. The second is which of your accounting periods the changed rulebook reaches.

“Autumn 2026” is an aim, and it carries a condition

The single most consequential item on the UK SRS timeline is the one nobody can put in a calendar.

The FCA’s formulation, unchanged on its reporting-requirements page as last updated on 5 June 2026: it will “aim to publish a Policy Statement in autumn 2026, subject to the final UK SRS, with the rules coming into force from 1 January 2027.” FCA, Sustainability reporting requirements

Three things that sentence does not say

It does not name a month within autumn, or a day.

It does not commit: aim is doing real work in a regulator’s sentence.

And subject to the final UK SRS was written before 25 February 2026, when the final standards did not exist. That condition has now been satisfied — which removes one of the two obstacles the FCA named, and leaves the other, which is simply the time it takes to answer a consultation.

What a company should do with a date it cannot get

Work backwards from the proposed 1 January 2027 commencement anyway, and treat the Policy Statement as the point at which your plan stops being contingent.

If the Policy Statement lands in, say, October 2026, an in-scope company with a December year-end has roughly ten weeks between knowing the final rules and beginning the first proposed in-scope period. That is the compression this timeline is really about, and it is why the preparation work below is worth starting before the rule exists.

Who the proposal would cover: around 600 companies, of which 515 would have to comply

The scope is narrower than most coverage suggests, and the numbers come from the FCA’s own cost-benefit analysis rather than from anyone’s estimate.

On the FCA’s analysis, “around 600 listed companies would be affected by our proposals”, and of those, “515 listed companies with listings in either the commercial companies, non-equity shares and non-voting equity shares, or transition categories will be required to comply”. CP26/5, cost-benefit analysis

That is UK Listing Rules categories 6, 16 and 22. The remaining 89 sit in categories 14 and 15 and get a different, lighter requirement — see secondary listings and depositary receipts.

Categories and requirements as proposed in CP26/5; the current TCFD requirement for category 6 sits at UKLR 6.6.6R(8).

Secondary listings and depositary receipts get a signpost, not a standard

Companies whose only UK listing is a secondary listing or a depositary receipt are in scope of the proposal, but not in scope of UK SRS reporting.

CP26/5 proposes removing the TCFD requirement for these categories and replacing it with a statement in the annual financial report setting out “Any climate and/or wider sustainability disclosure requirements… to which the company is subject in relation to equity shares in their primary overseas listing location”. CP26/5, chapter 9

The cost-benefit analysis describes the requirement the same way: disclosure of the rules that apply in the company’s primary listing location or place of incorporation, or which it voluntarily adopts.

The TCFD rules have been running since 2021, and the proposal would delete them

Anyone searching for a TCFD reporting requirements UK timeline is really asking two questions: what applies now, and what replaces it.

What applies now

For equity shares in the commercial companies category, UKLR 6.6.6R(8) requires a comply-or-explain statement that the company has included climate-related financial disclosures “consistent with the TCFD Recommendations and Recommended Disclosures”. FCA Handbook, UKLR 6.6

It has applied to premium listed commercial companies for accounting periods beginning on or after 1 January 2021, and to standard listed shares and depositary receipts for periods beginning on or after 1 January 2022. FCA, PS21/23

The requirement now sits across five listing categories. FCA, Sustainability reporting requirements

What would replace it

UK SRS S2 for the three reporting categories, and a signposting statement for the other two. The TCFD framework itself is not disappearing from the world — its recommendations are carried through into IFRS S2 and therefore into UK SRS S2 — but the FCA rule that names TCFD would go.

Until the Policy Statement is published, the TCFD rules remain the live obligation. That is the practical answer for the 2026 reporting year and it is the sentence most timelines leave out.

A fuller comparison of the two frameworks sits on TCFD vs UK SRS, and the current UK TCFD landscape on TCFD reporting.

Scope 3 would arrive a year after everything else

CP26/5 proposes “non-disclosure under UK SRS S2 regarding Scope 3 emissions for a period of 1-year” from initial application. CP26/5, chapter 8

So on the proposed timetable, Scope 1 and Scope 2 would be disclosed for accounting periods beginning on or after 1 January 2027, and Scope 3 for periods beginning on or after 1 January 2028.

Two things the relief does not do

The measurement work itself is covered on UK SRS Scope 3 reporting and Scope 3 emissions reporting.

Wider sustainability reporting would not begin until 2029

UK SRS S1 covers sustainability-related risks and opportunities beyond climate. Under the proposal it would be the last thing to bite.

CP26/5 proposes “non-disclosure under UK SRS S1 for non-climate matters for a period of 2-years from initial application”. CP26/5, chapter 8

Two years from accounting periods beginning on or after 1 January 2027 puts non-climate reporting at periods beginning on or after 1 January 2029 — and a first report published during 2030 for a December year-end.

The mechanism inside the standard is UK SRS S1 paragraph E3, the climate-first provision. Using it costs the compliance statement: paragraph 73A says an entity using E3 “is not permitted to assert compliance with UK SRS S1 and shall disclose use of this provision instead”. UK SRS S1

So a company on the relief would report climate under S2 and say, in terms, that it is not claiming S1 compliance. That disclosure is itself part of the first-year output.

The one-year and two-year reliefs are not in the standards

This is the finding that changes how the rest of the timeline should be read, and it is stated in the government response rather than in either standard.

On endorsement, the UK removed the durations from the reliefs. The government response says the standards “no longer specify how long the reliefs for non-climate reporting and Scope 3 reporting may be applied”. DBT, Government response

What survives in the standards is the anchor, not the length: the reliefs are available “In the first annual reporting period in which an entity is required to use this Standard under UK law or regulations”.

Why this matters to a date

Every “Scope 3 from 2028, S1 from 2029” timeline on the internet — including the one this page replaces — is quoting the FCA’s proposed durations and attributing them to the standards.

They are the FCA’s, they are proposed, and they are set out in CP26/5 chapter 8. If the Policy Statement changes them — and a consultation exists precisely so that responses can change things — the standards will not need to be amended at all, because the standards never carried the numbers.

Two consequences follow. The 2028 and 2029 dates are more likely to move than the 2027 one, because they are pure rule-making rather than a commencement date the FCA has repeated in three places. And a company outside the FCA’s perimeter that adopts UK SRS voluntarily gets the reliefs with no duration attached, because nothing has made it “required to use” the standard in the first place.

Sustainability disclosures must be published on the same day as the accounts

IFRS S1 allowed an entity to publish sustainability information later than its financial statements. The UK removed that relief on endorsement.

UK SRS S1 paragraph 64 is one sentence: “An entity shall report its sustainability-related financial disclosures at the same time as its related financial statements.” UK SRS S1

The government response records the change as the “removal of the transitional relief in IFRS S1 that allowed reporting entities to publish sustainability information at a different time to financial statements”.

What this does to the plan

It collapses the sustainability reporting calendar into the financial reporting calendar, which is already the tightest calendar a listed company has.

There is no catch-up window.

For most in-scope companies this is the single biggest practical consequence on the whole timeline, and it is a decision the UK has already taken — it does not depend on the Policy Statement at all.

No comparatives in the first period

UK SRS carries first-period relief from comparative information, and CP26/5 restates it: “In accordance with the UK SRS, listed companies are not required to disclose comparative information for the first accounting period” in which the disclosures are made. CP26/5

This matters to a timeline in a way that is easy to miss. Without it, a company facing a first proposed in-scope period beginning 1 January 2027 would need a complete, standard-quality 2026 data set as well — which would move the real start of the work back a full year.

Which GHG Protocol, and the first-year escape hatch

UK SRS S2 names its measurement basis explicitly, and the UK did not change it.

Scope 1 and 2 are measured in accordance with the “Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004)”, and Scope 3 in accordance with the “Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (2011)”. UK SRS S2

A first-year relief lets an entity use a method other than the 2004 standard, which exists for companies already reporting on another basis — typically a jurisdiction-mandated one.

The government response describes it as a relief “related to the use of a method other than the ‘Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004)’ in the first year of reporting”.

For a UK company already reporting under SECR the practical work is smaller than it looks: SECR already runs on the GHG Protocol and the DESNZ conversion factors. DESNZ, 2026 conversion factors

The factor set and what changed in 2026 sits on UK emissions factors; the SECR overlap on SECR.

Assurance has its own dates, and one of them is fixed

The assurance track runs alongside the reporting track and is further ahead of it, which is the opposite of what most people assume.

The standard exists

The FRC issued ISSA (UK) 5000 in November 2025. It is effective for assurance engagements on sustainability information reported for periods “beginning on or after December 15, 2026 or as at a specific date on or after December 15, 2026”, and “Earlier application of this ISSA (UK) is permitted”. FRC, ISSA (UK) 5000

That 15 December 2026 date is not a proposal. It is the effective date of an issued standard, and it lands two weeks before the FCA’s proposed commencement.

The oversight regime is voluntary, and not statutory

The government’s response of 30 January 2026 confirmed it would “move forward with plans to establish a voluntary oversight regime for sustainability assurance in the UK”, and that “The regime will be operated by the FRC”. DBT, Assurance government response

It is voluntary because the legislation that would have made it statutory is not coming: the response records that “the government has since taken the decision not to proceed with the Audit Reform Bill”, and that legislation would follow “as and when Parliamentary time allows”.

Nothing in CP26/5 requires assurance of UK SRS disclosures. A company obtaining assurance in 2027 is doing so because its board or its investors want it, not because a rule says so — and it should build the extra weeks into the plan accordingly, because the same-day publication rule gives it nowhere to put them.

Private companies: no date, no threshold, and a consultation that has not appeared

The most common misreading of the UK SRS timeline is that it applies to companies generally. On the current record it does not apply to anyone at all, and the only proposal on the table covers listed companies.

The government response parked private companies in a separate programme: the government “will consider whether to require private companies to report information in accordance with UK SRS as part of that exercise”, the exercise being Modernising Corporate Reporting. DBT, Government response

It said the MCR consultation would come “shortly” and “later this year”. As at 19 August 2026 no such consultation has been published on GOV.UK.

Respondents asked for “‘economically-significant private entities’ (or companies) be clearly defined”. No definition and no threshold has been set. Any turnover or employee figure you see attached to UK SRS and private companies is somebody’s guess.

Transition plans: consulted on in 2025, still unanswered

The government consulted on climate-related transition plan requirements between 25 June and 17 September 2025, covering UK-regulated financial institutions and FTSE 100 companies. GOV.UK, Transition plan requirements

Eleven months after it closed, the consultation page still reads “We are analysing your feedback.”

Two options were consulted on: requiring entities to “explain why they have not disclosed a transition plan”, or requiring them to “develop a transition plan and disclose this”. GOV.UK, Implementation routes

No implementation date was floated in the consultation. If you have seen a transition-plan timeline with dates on it, those dates are not in the government’s document.

The link to UK SRS is real but indirect: the UK SRS government response notes respondents suggesting “that UK SRS S2 was a suitable foundation for transition plans, with potential amendments”. UK SRS S2 already requires disclosure of a transition plan where an entity has one; a separate requirement to have one is what remains undecided.

The standards are usable today, and using them is the only way to move the date forward

The timeline’s awkward shape — one real date, then a wait — has one constructive reading.

Both standards are available now, to any entity, “in whole or in part, as they see fit”. Nothing stops a company running a full UK SRS S2 dry run on its 2026 year. GOV.UK, UK Sustainability Reporting Standards

For an in-scope listed company that is not enthusiasm, it is arithmetic: if the Policy Statement lands in late autumn 2026, the gap between knowing the final rules and starting the first period they cover is measured in weeks.

What a dry run buys you

The disclosure set itself is on UK SRS requirements, the S2 climate detail on UK SRS S2, and a step-by-step route on the implementation guide.

Four ways 1 January 2027 could still move

A page that marks dates as proposed owes the reader an account of how a proposed date actually changes.

The Policy Statement slips

Autumn 2026 is an aim. A regulator that publishes final rules in, say, December 2026 for a commencement on 1 January 2027 gives in-scope companies effectively no notice, which is itself an argument for moving the commencement.

The consultation responses move it

Consultations exist so that responses can change proposals. The commencement date and the relief durations were both consulted on, and both can come back different.

The reliefs move without the commencement moving

This is the most likely change and the least reported, because the relief durations live in the FCA’s rules rather than in the standards — see where the reliefs live. Extending Scope 3 relief to two years would change 2028 and leave 2027 untouched.

Something upstream changes

The standards themselves are not fixed forever: they are UK endorsements of ISSB standards, and the ISSB continues to work. A material amendment upstream would have to be assessed and endorsed here first.