UK SRS: What Businesses Need to Know in 2026

The UK Sustainability Reporting Standards (UK SRS) are already published, and for listed companies they are about to become reporting rules. The FCA has confirmed that its new rules, built on UK SRS S1 and S2, apply to accounting periods beginning on or after 1 January 2027 on a comply or explain basis. Whether the standards will reach other companies is still undecided, and a government consultation on corporate reporting stays open until 30 November 2026. If you lead sustainability or finance reporting at a UK business, the sections below show where you stand today and what to plan for.

UK SRS matter to sustainability and finance teams because they set out what investors will expect to find in an annual report. That means how climate and other sustainability risks affect the company’s prospects, laid out in a structure that mirrors financial reporting. Companies can apply S1 and S2 in whole or in part today. Compulsion arrives through other routes, with the FCA’s listing rules first and company law possibly later.

What do UK SRS S1 and S2 require?

UK SRS S1 and S2 ask a company to explain, under four headings, how sustainability-related risks and opportunities affect its business and its finances. Those headings (governance, strategy, risk management, and metrics and targets) are the ones the TCFD framework used.

S2 is the climate standard. It covers Scope 1 and 2 emissions, Scope 3 emissions, targets and progress against them, and a company’s climate transition plan if it has one, because S2 does not oblige anyone to have a plan. S1 covers every other sustainability-related risk and opportunity that could affect the company’s prospects.

The UK versions follow the text of the ISSB’s IFRS S1 and S2, issued in June 2023, with a few changes. The references to SASB industry guidance say “may”, so using it is optional, and the ISSB’s December 2025 amendments to its climate standard are carried into S2. The time-limited reliefs that the ISSB wrote into its own standards do not appear in the UK versions. FCA rules or government regulations set them instead.

UK SRS build on the TCFD’s four headings and add a standardised, investor-focused structure, with climate disclosures first and wider sustainability topics following.

The FCA introduced TCFD-aligned disclosure rules for premium-listed companies in 2020 and extended them to other listed issuers in 2021. The TCFD framework was set up in 2015 and disbanded in 2023. The ISSB standards incorporate the TCFD recommendations, and the FCA is replacing its TCFD-aligned listing rules with rules based on UK SRS.

How do the UK SRS compare with CSRD and US rules?

The UK SRS, the EU’s CSRD and US state climate laws each start from a different question.

Because UK SRS follow the ISSB baseline, companies that report in both the UK and the EU can use the interoperability guidance that the IFRS Foundation and EFRAG published in 2024, which maps the ESRS to the ISSB standards.

The only UK SRS reporting rules confirmed so far are the FCA’s, and they apply to accounting periods beginning on or after 1 January 2027 for companies listed in five categories of the UK Listing Rules. For every other company, no duty exists yet and the government has not decided whether to create one.

The five categories are:

• commercial companies (UKLR 6)
• international commercial companies with a secondary listing (UKLR 14)
• depositary receipts (UKLR 15)
• non-equity shares and non-voting equity shares (UKLR 16)
• the transition category (UKLR 22)

Ninety-four of the 110 respondents to the FCA’s consultation backed this scope. The FCA first proposed that secondary-listed and depositary receipt issuers would only point to their home-country reporting. It then changed course: they now report against UK SRS on a comply or explain basis too, and may rely on home-jurisdiction reporting where it meets the UK SRS outcomes. The rules do not cover closed-ended investment funds and open-ended investment companies (UKLR 11 and 12), shell companies (UKLR 13), or debt and debt-like securities, securitised derivatives and miscellaneous securities (UKLR 17 to 19).

What about private companies and LLPs?

No legislation yet requires private companies or LLPs to report under UK SRS, and they can use the standards voluntarily. The government’s consultation on modernising corporate reporting opened on 7 September 2026 and closes at 11:59pm on 30 November 2026. It asks whether non-financial reporting requirements for private companies are worth keeping and proposes no change to the existing climate-related financial disclosure duties. A review of the existing climate disclosure rules is expected to finish by spring 2027.

Some companies already report climate information under company law. For financial years starting on or after 6 April 2022, certain UK companies with more than 500 employees include climate-related financial disclosures in their strategic report. They are traded, banking and insurance companies, AIM companies, and companies with turnover above £500 million. Large LLPs follow a parallel rule. Those duties continue, and the consultation indicates that disclosures listed companies make under the FCA’s revised rules will count as meeting them. Energy and carbon reporting under SECR is a separate regime. Two questions readers often ask, on SECR and on legal status, are answered in the Q&A at the end.

On 30 September 2026 the FCA published PS26/19, a policy statement that replaces its TCFD-aligned listing rules with rules requiring listed companies to report against UK SRS S1 and S2 on a comply or explain basis.

Under comply or explain, a company either follows the standard or states in its annual report which requirements it has not met, why, and what it plans to do about it. The FCA’s January 2026 consultation paper, CP26/5, had proposed making UK SRS S2 climate disclosures mandatory, with comply or explain only for S1 and Scope 3. Some respondents questioned whether that was proportionate for smaller companies and for the UK’s competitiveness as a listing venue, so the FCA applied comply or explain to everything. More than 90% of those who answered the question had backed replacing the TCFD-aligned rules with UK SRS.

What must listed companies publish?

Each in-scope company includes four items in its annual financial report:

• climate disclosures in line with UK SRS S2, or a statement of the requirements it has not met, the reasons and the steps it plans to take
• the same for non-climate risks and opportunities under UK SRS S1, or a statement that it has identified none
• whether it has published a climate transition plan and where, or why it has not (the FCA does not require a plan)
• whether it has obtained third-party assurance and, if so, the provider, the disclosures covered, the level and the standard used

Cross-referencing to another report is allowed. Secondary-listing and depositary receipt issuers make the assurance statement but fall outside the transition plan requirement. The FCA is also finalising a technical note on what a good explanation looks like, and its consultation on that note closed on 28 October 2026.

What reliefs apply?

Listed companies can leave out Scope 3 disclosures for the first year and non-climate S1 disclosures for the first two years without explaining why, as long as the annual report states which relief is in use. The reliefs run from the first accounting period beginning on or after 1 January 2027.

What do directors need to know about liability?

Climate and sustainability disclosures look forward, which raises the question of director liability. Under section 463 of the Companies Act 2006, directors are liable only to the company. Liability arises only if they knew a statement in the strategic report, directors’ report, remuneration report or corporate governance statement was untrue or misleading, were reckless about it, or dishonestly concealed a material fact. Nobody else can claim against them for relying on those reports. The government’s consultation notes that this protection may need extending if sustainability disclosures move outside the reports it covers.

UK SRS are available for voluntary use now. The deadline that matters for listed companies is the first accounting period beginning on or after 1 January 2027, with first reports due in 2028. The UK SRS timeline below is current as at 6 November 2026.

Which consultations affect the UK SRS?

Three processes are still ahead, and a fourth has just closed:

• Government, corporate reporting: the consultation on modernising corporate reporting runs until 30 November 2026, covers how sustainability reporting under UK SRS will be integrated into the reporting framework, and the government aims to publish its outcome within six months of closing.
• Government, climate disclosure review: the review of the existing Companies Act climate disclosure rules is due to finish by spring 2027.
• Energy and carbon reporting: the Department for Energy Security and Net Zero has said it intends to hold a separate consultation on SECR reform later in 2026.
• FCA technical note: the consultation on how companies should write their explanations closed on 28 October 2026, and the FCA aims to finalise the guidance before the rules start.

Start your UK SRS compliance work with a gap analysis against S1 and S2. The FCA’s rules reach listed companies from accounting periods beginning in 2027, and any other company can adopt the standards earlier if it wants to.

UK SRS S2 asks for Scope 1, 2 and 3 emissions, and gathering consistent data from sites, invoices and suppliers usually takes longer than reading the standard. Greenly calculates Scope 1, 2 and 3 emissions from your activity and spend data and keeps an audit trail from each reported figure back to its source, which is what an assurance provider asks to see. The same dataset feeds UK SRS S1 and S2 reporting, so no figure is entered twice. For Scope 3, the supplier portal sends reminders and collects supplier data in one place, so the one-year relief for listed companies works as a planning window. More than 4,000 companies measure their emissions with Greenly, and over 500 million tonnes of CO2e are monitored on the platform.