UK SRS · Scope
Who needs UK SRS? Scope under the FCA’s final rules
UK SRS scope was settled on 30 September 2026: the FCA’s final rules in PS26/19 reach companies listed in five UK Listing Rules categories, on a comply-or-explain basis.
They apply to accounting periods beginning on or after 1 January 2027, and every other UK entity may use the standards voluntarily.
Pick your market in the checker below, or read on for each category, AIM, private companies and groups.
Am I in scope?
The answer by market and category
Scope is decided by where a company’s securities are listed, not by its size, turnover or sector.
The FCA considered a size threshold and did not adopt one, saying climate exposure depends on a company’s business model and industry rather than its size.
The five categories in scope are listed at ¶3.6 of PS26/19, and the six left out, with the FCA’s reasons, at ¶3.7.
The category titles are the FCA’s own, from UKLR 1.1.
Being in scope means reporting against UK SRS or explaining, not complying in full: the made rule for commercial companies is UKLR 6.6.6R(7A) and (7B).
The checker restates the published rules; it is not advice on your own listing.
UK SRS scope checker
Where are your securities admitted?
Report against UK SRS S1 and S2, or explain, for accounting periods beginning on or after 1 January 2027 (PS26/19 ¶¶3.6, 3.12).
The Scope 3 relief (one year) and the climate-first relief (two years) run from initial application; state that you use them.
Also state where the disclosures are, whether any were assured, and whether you have published a transition plan.
Restates FCA PS26/19 ¶¶1.7, 3.6–3.7, 3.12; LSE AIM Rules for Companies; Companies Act 2006 ss.414CA–414CB. Not advice on your own listing.
Final rules
Five categories in, six left out
The five in-scope categories share one requirement; the differences are in the transition-plan statement and in what an overseas issuer may rely on.
| UKLR chapter | Category | Under PS26/19 |
|---|---|---|
| 6 | Equity shares (commercial companies) | Comply or explain |
| 14 | Equity shares (international commercial companies secondary listing) | Comply or explain; home reporting may be relied on; no transition-plan statement |
| 15 | Certificates representing certain securities (depositary receipts) | Comply or explain; home reporting may be relied on; no transition-plan statement |
| 16 | Non-equity shares and non-voting equity shares | Comply or explain |
| 22 | Equity shares (transition) | Comply or explain |
| 11 | Closed-ended investment funds | Excluded: obligations sit with the asset manager |
| 12 | Open-ended investment companies | Excluded: obligations sit with the asset manager |
| 13 | Shell companies | Excluded |
| 17 | Debt and debt-like securities | Excluded: not proportionate or effective |
| 18 | Securitised derivatives | Excluded: not proportionate or effective |
| 19 | Warrants, options and other miscellaneous securities | Excluded: not proportionate or effective |
The rules sit in amended UKLR 6.6, 11.4, 14.3, 15.3, 16.3 and 22.2, with transitional provisions in UKLR TP 16 (PS26/19 ¶¶3.9–3.10).
Every in-scope company also states where its disclosures are, whether any were assured, and (outside UKLR 14 and 15) whether it has published a transition plan.
What those statements contain is on UK SRS requirements, and what an explanation contains is on UK SRS comply or explain.
Numbers
How many companies? The final rules do not say
The Policy Statement gives no count of the companies its rules reach.
The consultation, CP26/5, estimated from the Official List as at January 2025 that around 600 listed companies would be affected by its proposals.
That was the consultation’s estimate, and the Official List changes as companies list and delist.
CP26/5 had split its population between those it proposed to make report and those it proposed only to make a signposting statement; the final rules put both on one route.
PS26/19 ¶4.35 says the 89 issuers identified in the secondary listing and depositary receipts categories “are subject to the same requirements as domestic listed issuers”.
Whether your company is in scope turns on its listing category, which your company secretary or broker can confirm from the Official List.
Around 600: CP26/5’s estimate of listed companies affected by its proposals (Annex 2 ¶43).
89: issuers the FCA identified with listings in the secondary listing or depositary receipts categories (PS26/19 ¶4.35).
No total: PS26/19 does not state one.
International issuers
Secondary listings and depositary receipts: now in
This is the largest change to scope between the consultation and the final rules.
CP26/5 proposed that UKLR 14 and 15 issuers make a statement signposting the sustainability reporting required in their home jurisdiction.
PS26/19 ¶1.7 instead requires them “to also report against UK SRS on a comply or explain basis”.
The FCA says a company whose home-jurisdiction reporting aligns with the outcomes of UK SRS “may already broadly comply” and may rely on that reporting to reduce duplication.
Wherever UK SRS requirements are not met in full, such a company must explain, and the FCA’s draft guidance shows an overseas company explaining Scope 3 gaps that its home rules do not yet require.
The transition-plan statement in UKLR 6.6.6R(8)(e) does not apply to these two categories.
A company incorporated overseas with equity shares in the commercial companies category is in UKLR 6, so it reports on the same basis as a UK company.
Other markets
AIM companies: outside the listing rules, maybe inside company law
The FCA’s UK SRS requirements are listing rules, and AIM is not the Official List.
The London Stock Exchange’s AIM Rules for Companies require an admission document to state that “AIM securities are not admitted to the official list”.
So an AIM company has no UK SRS obligation under PS26/19, and may use the standards voluntarily.
It may still have a climate reporting duty under the Companies Act: section 414CA(1)(e) reaches a company whose securities are admitted to trading on AIM.
That duty applies only to a company that is not small or medium-sized and has more than 500 employees, or a group with more than 500 (s.414CA(3)–(4)).
A company caught by it can meet the disclosures with UK SRS S2, which the government has confirmed is a national reporting framework under section 414CB(6).
Unlisted companies
Private companies: no UK SRS duty, and none proposed
No rule requires a private company to report against UK SRS, and no government document proposes a threshold or a date for one.
The government’s Modernising corporate reporting consultation, published on 7 September 2026 and open until 30 November 2026, says it “will consider how UK SRS should be reflected in the Companies Act 2006”.
That is the whole of the position: no mechanism, no population and no timetable.
Large private companies are not outside climate reporting altogether: a “high turnover company”, with turnover over £500 million, and more than 500 employees has the Companies Act climate-related financial disclosure duty.
UK SRS S2 can be used to meet that duty, and the FRC says there is no need to duplicate the disclosures so long as its use is clearly referenced.
Energy and carbon reporting under SECR is a separate duty again, set out on Streamlined Energy and Carbon Reporting.
The cluster reference on UK sustainability reporting standards sets out what each standard asks for, whichever route brings a company to it.
| Regime | Private companies |
|---|---|
| UK SRS under the FCA rules | Not in scope |
| UK SRS in the Companies Act | Government "will consider"; no proposal |
| Companies Act climate disclosures (s.414CB) | Turnover over £500m and more than 500 employees |
| Voluntary use of UK SRS | Open to any entity |
Groups and funds
Subsidiaries, parents and investment vehicles
The obligation falls on the issuer whose securities are listed, not on every company in its group.
UK SRS S1 ¶20 requires the disclosures to be for the same reporting entity as the related financial statements, which for a listed parent is normally its consolidated group.
So a subsidiary’s risks and emissions are reported through the parent’s disclosures, and the subsidiary has no UK SRS duty of its own unless it has securities in one of the five categories.
UK SRS S2 ¶29(a)(iv) then asks the group to split Scope 1 and 2 between the consolidated accounting group and other investees such as associates and joint ventures.
Closed-ended funds and open-ended investment companies are out of scope because the FCA prefers to regulate their managers (PS26/19 ¶3.7).
Asset managers already produce climate reports under the FCA’s ESG sourcebook, a regime separate from UK SRS.
Timing
When an in-scope company first reports
The rules apply to accounting periods beginning on or after 1 January 2027, “with first reporting in 2028” (PS26/19 ¶3.12).
A company whose period began before that date may stay on the TCFD-aligned rules for that period, or adopt UK SRS early and still use the reliefs (¶3.19).
The one-year Scope 3 relief and the two-year relief for non-climate UK SRS S1 disclosures run from initial application.
Your own dates for every year-end are worked out on the UK SRS deadline page.
The rules, their history and their supervision are on UK SRS and the FCA, and how the consultation shaped them on the UK SRS consultation.
To check your own position, you can book a free 15-minute call.
| Year-end | First period in scope | Report published |
|---|---|---|
| 31 December | 1 Jan 2027 – 31 Dec 2027 | By 30 April 2028 at the latest |
| 31 March | 1 Apr 2027 – 31 Mar 2028 | By 31 July 2028 at the latest |
| 30 June | 1 Jul 2027 – 30 Jun 2028 | By 31 October 2028 at the latest |
Frequently asked
Who needs UK SRS — frequently asked
Who needs to comply with UK SRS?
Under the FCA's final rules in PS26/19, companies with securities in five UK Listing Rules categories must report against UK SRS on a comply-or-explain basis: UKLR 6 commercial companies, UKLR 14 secondary listings, UKLR 15 depositary receipts, UKLR 16 non-equity and non-voting equity shares, and UKLR 22 the transition category. The rules apply to accounting periods beginning on or after 1 January 2027. Everyone else may use UK SRS voluntarily.
How many companies are in scope of UK SRS?
The FCA's final rules give no total. The consultation, CP26/5, estimated that around 600 listed companies would be affected; that was the consultation's estimate. PS26/19 says the 89 issuers the FCA identified in the secondary listing and depositary receipts categories are now subject to the same requirements as domestic listed issuers.
Do secondary listings and depositary receipts have to report against UK SRS?
Yes, on a comply-or-explain basis. CP26/5 had proposed only a statement signposting home-jurisdiction reporting; the final rules replaced that. A company whose home reporting aligns with the outcomes of UK SRS may rely on it, but must explain wherever UK SRS requirements are not met in full. The transition-plan statement does not apply to these two categories.
Do AIM companies have to report against UK SRS?
Not under the FCA's rules. The UK SRS requirements sit in the UK Listing Rules, and the AIM Rules for Companies state that AIM securities are not admitted to the official list. An AIM company with more than 500 employees that is not small or medium-sized may have the separate Companies Act climate-related financial disclosure duty, which UK SRS S2 can be used to meet.
Do private companies have to report against UK SRS?
No. No UK SRS requirement applies to private companies and no threshold has been proposed. Large private companies may already have the Companies Act climate-related financial disclosure duty in sections 414CA and 414CB, and UK SRS S2 is a national reporting framework they can use to meet it. The government's Modernising corporate reporting consultation, open until 30 November 2026, says it will consider how UK SRS should be reflected in the Companies Act.
Are investment funds and investment trusts in scope?
No. PS26/19 excludes closed-ended investment funds (UKLR 11) and open-ended investment companies (UKLR 12), because the FCA considers the best way to introduce requirements for investment vehicles is through obligations on the asset manager. Shell companies and issuers of debt, securitised derivatives, warrants and options are also excluded.
Does a subsidiary of a listed company have to report under UK SRS?
Not in its own right, unless it has its own securities in one of the five categories. The listed company reports for the same reporting entity as its financial statements, which for a group is normally the consolidated group, so subsidiaries' risks and emissions are captured in the parent's report.
When do in-scope companies first report under UK SRS?
The rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028. A calendar-year company's first period is the year to 31 December 2027. A company whose period began before 1 January 2027 stays on the TCFD-aligned rules for that period or may adopt UK SRS early.
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.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards (PDF)
Scope (¶3.6), exclusions and reasons (¶3.7), secondary listings and DRs (¶1.7 and the response after ¶2.67), dates (¶3.12), early adoption (¶3.19), the 89 issuers (¶4.35).
- 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.
- FCA HandbookUKLR 1.1 — the listing categories
The titles of UKLR 6, 11–19 and 22.
- FCA HandbookUKLR 6.6 — annual financial report (commercial companies)
UKLR 6.6.6R(7A), (7B) and (8) as they apply from 1 January 2027.
- Financial Conduct AuthorityCP26/5 consultation paper (PDF)
The proposal: mandatory UK SRS S2 for UKLR 6, 16 and 22, a signposting statement for UKLR 14 and 15, and the "around 600" estimate at Annex 2 ¶43.
- Financial Conduct AuthorityCP26/5 consultation page
Opened 30 January 2026, closed 20 March 2026.
- London Stock ExchangeAIM Rules for Companies (PDF)
The required statement that AIM securities are not admitted to the official list.
- legislation.gov.ukCompanies Act 2006, section 414CA
Who has the climate-related financial disclosure duty: (1)(a)–(e) including AIM companies, (2A) turnover over £500m, (4) the 500-employee floor.
- legislation.gov.ukCompanies Act 2006, section 414CB
s.414CB(6): UK SRS S2 as a national reporting framework for that duty.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
UK SRS "available for voluntary use, by any entity that chooses to do so".
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
UK SRS S1 and S2 published 25 February 2026.
- Financial Reporting CouncilSustainability reporting developments — FAQs
Voluntary users may use the reliefs without time limit.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
¶¶154–155: the government will consider how UK SRS should be reflected in the Companies Act; ¶178: no plans for mandatory assurance of UK SRS reporting.
- Department for Business and TradeUK SRS S1 General Requirements (PDF)
¶20: disclosures are for the same reporting entity as the related financial statements.
- FCA HandbookESG 2.2 — TCFD entity report
The asset managers' and asset owners' own climate report, separate from UK SRS.
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