The FCA’s UK SRS rules: what the annual report must contain

The rule began as CP26/5, published on 30 January 2026 and closed on 20 March 2026 (consultation page).

It was made by the FCA Board on 24 September 2026 and published on 30 September as PS26/19, whose Appendix 1 is the instrument itself: the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026.

The instrument carries no FCA number in the Policy Statement, and none is given here.

Listing rules are made under Part 6 of the Financial Services and Markets Act 2000, including section 73A.

The guidance is not finished: Primary Market Bulletin 66 consults on draft Technical Note 803.1, with comments to primarymarketbulletin@fca.org.uk by 28 October 2026, and the FCA aims to finalise it before the rules come into force.

What each step settled is set out on the UK SRS timeline, and what the consultation proposed against what was made on the UK SRS consultations.

The rule reaches companies on the Official List in five categories (PS26/19 ¶3.6).

For investment vehicles, the FCA says “the best way to introduce requirements … is through obligations on the asset manager”, and for debt and similar securities it does “not consider it to be proportionate or effective to extend requirements” (¶3.7).

International companies with a secondary listing and depositary-receipt issuers were brought onto the same basis as domestic companies; the FCA counted 89 of them in its consultation-stage analysis (¶4.35).

Those issuers “may therefore rely on home-jurisdiction reporting to reduce duplication”, and explain where UK SRS requirements are not met in full.

The Policy Statement gives no total; CP26/5 estimated that around 600 listed companies would be affected, and that remains the consultation’s estimate.

AIM companies, private companies and LLPs are not reached at all; the standards stay voluntary for them, and the entity-level tests are on UK SRS scope.

Initial application is the start of the first annual reporting period beginning on or after 1 January 2027 but before 1 January 2028 (¶3.18).

A company using either relief states that it is doing so in its annual financial report, and “no further explanation … is required during the relief period”, because using a relief “does not engage our ‘explain’ rules” (¶3.20).

It must still make the location, assurance and transition-plan statements while a relief runs.

The Scope 3 relief in UK SRS S2 ¶C4 is untimed in the standard; the FCA gives it its one-year limit at UKLR TP 16.17R(2).

For a period beginning before 1 January 2027, a company chooses between the TCFD-aligned rules in force immediately before that date and early adoption of the new ones; early adopters “can use the same transitional reliefs” (¶3.19), which reverses the consultation’s proposal.

The reliefs as dates, by the year a company’s period begins, are on the UK SRS deadline.

The new limbs take the place of the TCFD-aligned disclosure rule for listed companies, which UKLR 6.6.6R(8) carried until now.

Limb (8) is rewritten rather than deleted: it now holds the location, assurance and transition-plan statements (Appendix 1).

The TCFD technical note, TN 802.3, is proposed for deletion and TN 801.4 for update, both in PMB 66; TN 802.3 stays live guidance on the old rules until then.

A separate instrument, FCA 2026/59, in force since 25 September 2026, replaced product-level TCFD reporting by asset managers and asset owners (Handbook Notice 144); it is not the listed-company rule.

The FCA says it will keep the case for mandatory sustainability assurance under review; ISSA (UK) 5000 is effective for periods beginning on or after 15 December 2026 for engagements that are obtained.

The FCA estimates a net present value of £174.10m for the final rules over ten years (PS26/19 ¶4.28), and will supervise alongside the FRC, with updated information on its approach in the second half of 2027.

The ISSB standards the new rules point at, through UK SRS, are on the IFRS Foundation’s navigator.