UK SRS timeline: every date, and which ones are decided

Until 30 September 2026 the UK SRS timeline had one decided date on it that mattered, 25 February 2026, and a row of FCA proposals after it.

PS26/19 turned those proposals into rules, with one large change: UK SRS S2 is on comply or explain, not mandatory.

The FCA Board made the instrument on 24 September 2026, and it comes into force on 1 January 2027.

The dates CP26/5 consulted on were kept: “To give industry time to prepare, we are using the implementation timelines we consulted on” (¶1.11).

What is left open is guidance, supervision and everything outside the listing rules.

This page is the sequence; your own first period is on the UK SRS deadline, and the rules in full on UK SRS and the FCA.

UK SRS is an endorsement of the ISSB’s IFRS S1 and S2, and the government response lists the changes the UK made on the way.

Most of them are narrow and leave the calendar alone.

Three of them are the reason this page looks the way it does.

The first took the effective dates out of both standards, so a UK company reads its start date in the FCA’s rules or, one day, in legislation, never in the standard.

The second took the time limits out of the two big reliefs, which is why their one-year and two-year lengths are FCA rules in UKLR TP 16 rather than paragraphs of UK SRS.

The third removed the IFRS S1 relief that let an entity publish its first sustainability disclosures after its financial statements, so the UK calendar has no catch-up season.

The UK also added a financed-emissions paragraph to UK SRS S2 and two paragraphs to S1 on the compliance statement and on the primacy of UK law, neither of which changes a date.

The substance of each difference, paragraph by paragraph, is on UK SRS endorsement.

Strip PS26/19 down to its effect on dates and it makes three moves.

It retires the TCFD-aligned rule for new periods. PS26/19 ¶1.10 says the new rules replace the TCFD-aligned disclosures, which have run for premium-listed commercial companies since 2021 and for standard-listed shares and depositary receipts since 2022.

It puts UK SRS in their place, on comply or explain. The made text is new UKLR 6.6.6R(7A) for UK SRS S2 and (7B) for UK SRS S1, with mirror provisions in the other in-scope categories.

Under (7A) a company either makes the UK SRS S2 disclosures or states which requirements it has not met, why, and any steps it is taking or plans to take; no timeframe is required.

Under (7B) the explanation is by risk or opportunity rather than by requirement: the company names the sustainability-related risks and opportunities it has identified but not disclosed on.

It starts on 1 January 2027 and never earlier. The instrument comes into force on that day and reaches accounting periods beginning on or after it, so no company’s current year is caught.

Three statements in UKLR 6.6.6R(8) ride along: where the disclosures are, whether any were assured and by whom, and whether the company has a transition plan and where it is.

Early adopters keep the reliefs: a company that applies UK SRS to a period beginning before 1 January 2027 may use them then and again in its first period in scope (¶3.19), a reversal of CP26/5.

The regime being replaced began with PS20/17, which required premium-listed commercial companies to make a comply-or-explain statement against the TCFD recommendations for periods beginning on or after 1 January 2021.

PS21/23 extended it to standard-listed shares and depositary receipts for periods beginning on or after 1 January 2022.

After the 2024 listing reforms the rule sits in UKLR 6.6.6R(8) and its equivalents across five listing categories, and it is still the live rule for periods beginning before 1 January 2027.

The TCFD itself completed its work and was disbanded in 2023, as the Financial Stability Board recorded; its recommendations live on inside the ISSB Standards.

The UK endorsement ran through the TAC’s recommendations, the exposure drafts and the government response.

How the final standards differ from the ISSB’s, and what happened to the proposed amendments, is on UK SRS endorsement.

The current UK TCFD position is on TCFD reporting, and the rule-by-rule comparison on TCFD vs UK SRS.

The FCA opened CP26/5 on 30 January 2026, before the final standards existed, and consulted on the exposure-draft reliefs.

The standards were issued 26 days later, on 25 February 2026, and CP26/5 closed on 20 March.

PS26/19 followed on 30 September, kept the dates and changed the basis for climate.

It also brought secondary listings and depositary receipts into UK SRS reporting, where CP26/5 had proposed only a signposting statement.

The consultation in detail, and what respondents said, is on the UK SRS consultation.

The commencement formula, “accounting periods beginning on or after 1 January 2027”, lands on a different day for every year-end.

Only a company whose year runs January to December starts on 1 January 2027 itself.

Every other company has a last TCFD-aligned year that finishes during 2027 and a first UK SRS year that starts on the day after it.

The planner beside this text lays out the three periods the reliefs are measured against, from the month your year ends.

The year-end table under the dates ahead does the same for the four commonest UK year-ends.

The September year-end is the one that surprises people: its first UK SRS year starts in October 2027 and its first report is not due until January 2029.

It also gets less relief than its calendar suggests, because its second period begins on 1 October 2028, after the Scope 3 cut-off of 1 January 2028.

The same arithmetic, with the publication date for every month-end, is on the UK SRS deadline.

A relief on this timeline is a relief from disclosure, not from measurement.

The Scope 3 relief covers one period, and the period after it is comply or explain, so a company that spends the relief year not building Scope 3 data arrives at the second period with a choice between a weak disclosure and an explanation.

The climate-first relief has a cost written into the standard: UK SRS S1 ¶73A says a company using it is not permitted to assert compliance with UK SRS S1, though it may still state compliance with UK SRS S2.

Companies already disclosing Scope 3 under the TCFD-aligned rules may keep doing so while the relief is available; the FCA’s rules do not prevent it (¶3.22).

Early adopters, whose periods begin before 1 January 2027, may use the reliefs too, and then use them again for their first period in scope.

How a company states that it is relying on a relief, and what an explanation must contain once the relief has gone, is on UK SRS comply or explain.

IFRS S1 allowed an entity, in its first year, to publish sustainability information after its financial statements; the UK removed that relief on endorsement.

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

The first-period comparative relief helps: a company is not required to disclose comparative information for its first period under the rules (¶3.25).

So a company does not need a full 2026 data set to start in 2027, although a baseline is still useful.

A first-year relief also lets a company keep a greenhouse gas measurement method other than the GHG Protocol Corporate Standard, if it used one immediately before (¶3.16).

UK companies already reporting under SECR use the DESNZ conversion factors, set out with what changed in 2026 on UK emissions factors; live grid data is on UK grid carbon intensity.

For the SECR overlap, see SECR on the family reference site.

“How long does a sustainability statement take to complete?” is the question this page is asked most often, and it has no published answer.

No regulator publishes a duration for preparing one, and no UK listed company has yet reported under the rules.

What is published is the end point, and a first report is best planned backwards from it.

The report date. The disclosures sit in the annual financial report, which DTR 4.1.3R requires to be public at the latest four months after the year-end.

The same-day rule. UK SRS S1 ¶64 puts the sustainability disclosures on the same day as the financial statements, so they share the audit-season timetable.

The sign-off. The management report’s description of principal risks, under DTR 4.1.8R, is covered by the directors’ responsibility statement, and the climate risks a company discloses under UK SRS S2 will be read beside it.

The order of work. The FCA’s Primary Market Bulletin 66 lists nine preparation steps, from understanding the requirements to engaging investors, and the checklist beside this text sets them out.

Data comes sixth in the FCA’s list, after governance, strategy and resilience, which is a reason not to start a first-year project with the data.

The FCA’s own cost model gives a sense of scale without a duration: for a large issuer that complies in full it assumes incremental costs of £127,900 one-off and £194,700 a year over TCFD-aligned reporting (PS26/19 Table 5).

Those are the FCA’s modelled averages, in pounds, and not a quote for any company.

A dry run on the 2026 year, the last one outside the rules for December year-ends, is the cheapest way to find out how long your own report takes.

The government consulted on climate-related transition plan requirements from 25 June to 17 September 2025, and no outcome had been published when last checked.

The two implementation routes it consulted on carry no implementation date.

PS26/19 asks listed companies only to say whether they publish a transition plan and where, or why not, and the FCA avoided pre-empting the government.

On private companies, Modernising corporate reporting (7 September to 30 November 2026) says the government “will consider how UK SRS should be reflected in the Companies Act 2006”, and proposes nothing more.

Any threshold attributed to UK SRS for private companies is not a government figure; the scope picture is on who needs UK SRS.

Separately, the FCA’s CP26/17 on product-level TCFD reporting for asset managers has been made as FCA 2026/59, in force since 25 September 2026 (Handbook Notice 144); it is not part of UK SRS.