Who needs UK SRS: are you actually in scope?
The honest answer for most organisations today is no one is required to apply UK SRS yet.
The standards published in February 2026 are voluntary.
The mandatory regime is a separate FCA proposal that would capture roughly 500 primary-listed companies first, with a future government consultation deciding whether large private companies follow.
This page sets out exactly who is in scope, who is not, and from when.
Right now, UK SRS is voluntary for everyone
The single most important fact about scope is the one most often misstated: as things stand, no organisation is legally obliged to report against UK SRS.
The Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026, and made them available for voluntary use[1].
A company can choose to adopt them early, but there is no registration, notification or approval process, and no penalty for not doing so[3].
Mandatory reporting is a separate question, decided not by the standards themselves but by the FCA’s Listing Rules and, in future, by company law.
Who would have to comply, and from when
The mandatory regime begins with listed companies. Under the FCA’s CP26/5 consultation, around 500 primary-listed companies would be required to apply UK SRS S2[2].
These are companies in UK Listing Rules categories 6, 16 and 22 — commercial companies, non-equity and non-voting equity shares, and the transition category[2].
The table below is the clearest available answer to who must comply, with what, and from when.
| Who | Requirement | From | Basis |
|---|---|---|---|
| Primary-listed companies (UKLR 6, 16, 22) — ~500 firms | UK SRS S2 climate (excluding Scope 3) | FY beginning on/after 1 Jan 2027 | Mandatory |
| Same in-scope companies | Scope 3 emissions | FY beginning on/after 1 Jan 2028 | Comply-or-explain (1-yr relief) |
| Same in-scope companies | UK SRS S1 (non-climate) | FY beginning on/after 1 Jan 2029 | Comply-or-explain (2-yr relief) |
| Secondary listings & depositary receipts (UKLR 14, 15) | Transparency statement only | FY beginning on/after 1 Jan 2027 | Disclose home-jurisdiction standard |
| Large private companies & LLPs | To be decided | Not yet set | Future MCR consultation |
| Any other entity | None (may adopt voluntarily) | N/A | Voluntary |
All of these dates remain FCA proposals until the Policy Statement expected in autumn 2026[2].
For a calendar-year reporter, a 1 January 2027 start means the first UK SRS-aligned report is published in 2028. The full sequence is set out in our deadline tracker.
Secondary listings: a transparency statement, not full reporting
Not every in-scope listing category faces the same burden. Companies in UK Listing Rules categories 14 and 15 — secondary listings and depositary receipts — are treated differently[2].
Rather than applying UK SRS S1 and S2 in full, CP26/5 proposes that these issuers include a statement in their annual financial report describing the sustainability disclosures they make under their primary-listing or home-jurisdiction requirements[2].
The point is to avoid duplicating obligations that international issuers already meet in the market where they are primarily listed, while still giving UK investors a clear signpost to those disclosures.
Large private companies: a future consultation, not a current rule
CP26/5 is explicit that its proposals relate only to certain categories of listed company[2].
Large, economically significant private companies are not in scope of the FCA proposals. They fall instead within the government’s Modernising Corporate Reporting programme, under which a separate consultation is expected during 2026[4].
No thresholds, scope or start date have been confirmed. Any figure circulating now — a turnover test, an employee count, a specific year — is speculation until that consultation is published[4].
Private companies that already report energy and carbon data may want to start from where they are; our analysis of the adjacent regimes sits in the UK SRS requirements guide.
Which entities are excluded
Several listing categories are deliberately left out of the proposals. CP26/5 does not extend to closed-ended investment funds, shell companies, debt and debt-like securities, securitised derivatives, or warrants, options and other miscellaneous securities[2].
In practice that means the FCA chose not to apply the rules to categories such as the closed-ended investment funds category or the shell companies category, keeping the proposed scope aligned with the existing climate-disclosure rules rather than widening it[2].
| Excluded category | Status under CP26/5 |
|---|---|
| Closed-ended investment funds | Not in scope |
| Shell companies | Not in scope |
| Debt and debt-like securities | Not in scope |
| Securitised derivatives | Not in scope |
| Warrants, options & other miscellaneous securities | Not in scope |
How to work out whether scope applies to you
Start with the only question that creates a current obligation: is the entity primary-listed in UK Listing Rules category 6, 16 or 22?
If yes, plan on UK SRS S2 for accounting periods beginning on or after 1 January 2027, subject to the FCA Policy Statement[2].
If the entity is a secondary listing or depositary receipt issuer (UKLR 14 or 15), the likely obligation is a transparency statement rather than full reporting[2].
If the entity is a large private company, there is no current obligation — but the Modernising Corporate Reporting consultation is the next event to watch, and gathering data now makes any future requirement easier to meet[4].
Who needs UK SRS: frequently asked questions
Does anyone have to comply with UK SRS yet?
No. UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 and are available for voluntary use. No entity is legally required to apply them today. The mandatory regime comes from the FCA, whose CP26/5 consultation proposed compulsory climate reporting from accounting periods beginning on or after 1 January 2027 for in-scope listed companies. Those proposals do not become law until the FCA issues its Policy Statement, which is expected in autumn 2026.
Which companies would be in scope of mandatory UK SRS?
Under FCA CP26/5, around 500 primary-listed companies would have to apply UK SRS S2. These are companies in UK Listing Rules categories 6 (commercial companies), 16 (non-equity and non-voting equity shares) and 22 (the transition category). The proposals deliberately match the existing TCFD-aligned scope rather than extending it to new categories of company.
What about secondary listings and depositary receipts?
Companies in UK Listing Rules categories 14 (secondary listings) and 15 (depositary receipts) are treated differently. Rather than applying UK SRS S1 and S2 in full, CP26/5 proposes that they include a transparency statement in their annual financial report describing the sustainability disclosures they make under their home-jurisdiction or primary-listing requirements. This is designed to avoid duplicating obligations these international issuers already meet elsewhere.
Will large private companies have to report?
Not yet, and not under CP26/5. The FCA proposals cover only certain categories of listed company. The government has signalled a separate consultation on extending UK SRS to large, economically significant private companies and LLPs under its Modernising Corporate Reporting programme, expected during 2026. No thresholds, scope or timeline have been confirmed — those decisions await the consultation.
Which entities are excluded from the proposals?
CP26/5 excludes several listing categories: closed-ended investment funds, shell companies, debt and debt-like securities, securitised derivatives, and warrants, options and other miscellaneous securities. The FCA chose not to extend the proposed rules to categories such as the UKLR 11 closed-ended investment funds category or the UKLR 13 shell companies category.
When would the first mandatory reports appear?
CP26/5 proposes that in-scope companies report UK SRS S2 climate disclosures for accounting periods beginning on or after 1 January 2027. For a calendar-year reporter that means the first UK SRS-aligned report is published in 2028. Scope 3 emissions move to a comply-or-explain basis a year later, and UK SRS S1 non-climate disclosures follow on a comply-or-explain basis from 1 January 2029.
- UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — GOV.UK / Department for Business and Trade · Standards published 25 Feb 2026 — available for voluntary use
- CP26/5: Aligning listed issuers’ sustainability disclosures with international standards — Financial Conduct Authority · Scope: UKLR 6/16/22 mandatory; UKLR 14/15 transparency statement; closed 20 Mar 2026
- UK Sustainability Reporting Standards (guidance) — GOV.UK / Department for Business and Trade · Government process, voluntary status and next steps
- Modernising Corporate Reporting — Written Ministerial Statement — GOV.UK · Future consultation on private-company scope expected during 2026
- Sustainability reporting developments — frequently asked questions — Financial Reporting Council · Voluntary and mandatory adoption position; s.414CB(2A) designation