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UK SRS 2026 · the year the rules were settled

UK SRS in 2026: what the year settled, and what is left

2026 is the year UK SRS went from draft to rule: the standards were published on 25 February, and the FCA’s final rules followed on 30 September.

Nobody reports under UK SRS in 2026; listed companies in scope start with accounting periods beginning on or after 1 January 2027, on a comply-or-explain basis.

What is left of 2026 is a short list of decisions, each tied to a provision, and four dates.

What 2026 settled

Nine months, from proposal to rule

The year opened with the government telling the FCA, on 5 January, that the standards’ reliefs would lose their time limits and that timing would be left to regulation.

The FCA consulted on 30 January in CP26/5, three and a half weeks before the final standards existed, and described its proposals as subject to them.

The standards arrived on 25 February, with no effective date, and have been available to anyone since.

The rules were made on 24 September and published on 30 September: comply or explain across all of UK SRS, five listing categories, reliefs of one year for Scope 3 and two for the rest of UK SRS S1 (PS26/19).

In the same week a separate FCA instrument replaced product-level TCFD reporting for asset managers (Handbook Notice 144).

Every step, with its status, is on the UK SRS timeline, and the wider calendar of UK regimes on the UK sustainability regulation timeline.

2026What happenedWhat it settled
5 JanDBT writes to the FCARelief time limits to come out of the standards
30 JanCP26/5 publishedThe FCA’s proposal, including mandatory S2
25 FebUK SRS S1 and S2 publishedThe final text; voluntary for all
7 SepCorporate reporting consultationNo UK SRS proposal for private companies
24–30 SepRules made and publishedComply or explain from 2027
25 SepFCA 2026/59 in forceProduct-level TCFD reports replaced

Decisions before 1 January 2027

Six decisions, each tied to a provision

For a company listed in UKLR 6, 14, 15, 16 or 22.

None is a regulator’s deadline in 2026 except the guidance comments; each is a choice the first report will show.

From PS26/19 and its Appendix 1.
DecisionThe choiceWhere it is set
A period that begins in 2026Stay on the TCFD-aligned rules, or adopt UK SRS early and keep the reliefsPS26/19 ¶3.19; UKLR TP 16
The Scope 3 reliefUse it for the first period and state that you are, or report Scope 3 anywayPS26/19 ¶¶3.14, 3.20, 3.22
The UK SRS S1 non-climate reliefUse it for up to two periods, stating its use, or report beyond climate from the startPS26/19 ¶3.14
Where the disclosures sitIn the annual financial report, or cross-referred from itUKLR 6.6.6R(8)(c); UK SRS S1 ¶¶B45–B47
AssuranceObtain it or not; either way, say whichUKLR 6.6.6R(8)(d)
Transition planSay whether one is published and where, or why notUKLR 6.6.6R(8)(e); not for UKLR 14 and 15

Using a relief is not an explanation: the company states that it is using it, and the explain rules are not engaged while it runs (PS26/19 ¶3.20).

A company that relies on the climate-first relief cannot claim compliance with UK SRS S1 at all, under UK SRS S1 ¶73A.

Where the disclosures sit also decides the directors’ protection: the government response confirms that section 463 covers UK SRS disclosure placed in the strategic report.

A structured look at the gaps between current reporting and the standards is on the UK SRS gap analysis, and the board’s part in these choices on UK SRS for boards.

The rest of the year

The dates left in 2026, and what each one is

The FCA holds a webinar on 19 October 2026 to explain the new requirements (PS26/19).

It is consulting until 28 October 2026 on draft Technical Note 803.1, the guidance on what complying and explaining should look like, and aims to finalise it before 1 January 2027 (PMB 66).

The government’s Modernising corporate reporting consultation closes on 30 November 2026; it says only that the government will consider how UK SRS should be reflected in the Companies Act.

ISSA (UK) 5000 takes effect for periods beginning on or after 15 December 2026, so it is in effect for any engagement over a 2027 period that uses it; assurance itself remains optional, and so does the choice of standard, as covered on UK SRS assurance.

The FCA has promised updated information on its supervisory approach in the second half of 2027, and says it is working closely with the FRC, whose Corporate Reporting Review examines annual reports.

  1. 19 Oct
    FCA webinar on the new requirements
  2. 28 Oct
    Comments close on draft TN 803.1

    To primarymarketbulletin@fca.org.uk.

  3. 30 Nov
    Modernising corporate reporting closes

    Nothing in it changes UK SRS.

  4. 15 Dec
    ISSA (UK) 5000 effective

    For periods beginning on or after.

  5. 31 Dec
    ESOS Phase 4 qualification date

    A different regime, the same week.

  6. 1 Jan 2027
    Rules in force; first periods begin

Data

What the first period needs measured, and what it does not

The first period is the first to be measured: for a 31 December year-end, calendar 2027, reported by 30 April 2028 under DTR 4.1.3R.

2026 is not a required comparative year: UK SRS S1 ¶E1 and UK SRS S2 ¶C1 keep the first-period relief, and PS26/19 ¶3.16 confirms it is available.

UK SRS S2 ¶29(a) asks for absolute gross Scope 1, 2 and 3 emissions, with location-based Scope 2, and ¶B32 for the 15 Scope 3 categories of the GHG Protocol to be considered.

A company that measured its emissions by a different method immediately before may keep that method for one year (PS26/19 ¶3.16; UK SRS S2 ¶C3).

Banks, insurers and asset managers that cannot estimate financed emissions for the same period as their accounts must explain why, under UK SRS S2 ¶B59A.

The tools that collect this data are compared on sustainability software; the IFRS Foundation’s own supporting materials explain the underlying ISSB requirements.

No comparative year

UK SRS S1 ¶E1 and UK SRS S2 ¶C1 keep the relief from comparatives in the first period.

A December year-end company’s first report covers 2027 alone.

People and controls

Governance and controls, in the FCA’s own list

The FCA has published its own list of what listed companies should do before the rules start, and it is more useful than any generic roadmap because it is the supervisor’s.

PMB 66 sets out nine steps, from understanding the requirements and the proposed technical note to engaging investors on what they expect.

It also reminds companies of Listing Principle 1, which requires adequate procedures, systems and controls, and of DTR 4.1.8R on principal risks and uncertainties.

The full list, read against the rule text, is on the FCA’s UK SRS rules, and the practical programme on UK SRS compliance.

Six of the nine steps in PMB 66; all nine are on the FCA rules page.
PMB 66 stepIn short
2Identify financially material risks and opportunities
3Review governance arrangements
6Develop the data, metrics and targets
7Establish internal controls and review processes
8Build capabilities and provide training
9Engage with investors

Checklist

What the first report must contain, line by line

Drawn from the rule text, not from practice.

Every line is a provision.

From PS26/19 Appendix 1 and DTR 4.1.
ItemProvision
UK SRS S2 disclosures — or which requirements are unmet, why, and the steps plannedUKLR 6.6.6R(7A)
UK SRS S1 disclosures beyond climate — or which risks and opportunities are undisclosed, and whyUKLR 6.6.6R(7B)
A statement of any relief used (Scope 3; S1 non-climate)PS26/19 ¶3.20
Where the disclosures can be foundUKLR 6.6.6R(8)(c)
Whether assurance was obtained; if so, provider, scope, level, standards and report locationUKLR 6.6.6R(8)(d)
Whether a transition plan is published and where, or why not (UKLR 6, 16, 22)UKLR 6.6.6R(8)(e)
All of it in an annual financial report public within four months of the year-endDTR 4.1.3R

For every entity outside the five categories, none of this applies and the standards stay voluntary; what they contain is on what is UK SRS.

The sister reference, UK Sustainability Reporting Standards, keeps its own view of the year.

Frequently asked

UK SRS in 2026: the questions asked

What happened to UK SRS in 2026?

The FCA consulted on listing rules in CP26/5 from 30 January to 20 March.

The government published UK SRS S1 and S2 on 25 February for voluntary use.

The FCA made its final rules on 24 September and published them as PS26/19 on 30 September: listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

Is UK SRS mandatory in 2026?

No. Nobody is required to report under UK SRS in 2026.

The FCA’s rules come into force on 1 January 2027 and apply to accounting periods beginning on or after that date, on a comply-or-explain basis.

A listed company may adopt early for a period beginning in 2026 and keep the transitional reliefs.

Do companies need 2026 data for their first UK SRS report?

Not as comparatives.

UK SRS S1 paragraph E1 and UK SRS S2 paragraph C1 keep the relief from giving comparative information in the first period, and PS26/19 leaves it in place.

A company may still want 2026 data as a baseline for targets, but the first report does not require it.

What should a listed company decide before 1 January 2027?

Whether a period that begins in 2026 stays on the TCFD-aligned rules or adopts UK SRS early; whether to use the Scope 3 and UK SRS S1 reliefs; where the disclosures will sit in the annual financial report; whether to obtain assurance; and what it will say about a transition plan.

It can also comment on the FCA’s draft guidance until 28 October 2026.

What UK SRS dates are left in 2026?

The FCA webinar on 19 October, the close of comments on draft TN 803.1 on 28 October, the close of the Modernising corporate reporting consultation on 30 November, and ISSA (UK) 5000 taking effect for periods beginning on or after 15 December.

What is SRS 2026?

Usually a search for the UK Sustainability Reporting Standards as they stood in 2026: UK SRS S1 and S2, published on 25 February 2026, and the FCA’s final rules of 30 September 2026.

There is no separate standard called SRS 2026.

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.

Checked against 19 sources fromFinancial Conduct AuthorityDepartment for Business and TradeDepartment for Business, Innovation, Science and TradeFinancial Reporting CouncilIFRS FoundationGHG Protocol
  1. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    Published 30 September 2026; webinar 19 October 2026.

  2. Financial Conduct Authority
    PS26/19 (PDF), ¶¶3.12–3.24 and Appendix 1

    Timing, initial application, the reliefs, early adoption; UKLR 6.6.6R(7A), (7B), (8).

  3. Financial Conduct Authority
    CP26/5 (PDF)

    The January 2026 consultation the rules finalise.

  4. Financial Conduct Authority
    Primary Market Bulletin 66

    Nine preparation steps; draft TN 803.1 for comment by 28 October 2026; early adopters may use the reliefs.

  5. Financial Conduct Authority
    Draft Technical Note 803.1

    Proposed guidance on complying and explaining.

  6. Financial Conduct Authority
    FCA Handbook, DTR 4.1

    Annual financial report public within four months (4.1.3R).

  7. Financial Conduct Authority
    Handbook Notice 144

    FCA 2026/59, in force 25 September 2026.

  8. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2

    Published 25 February 2026.

  9. Department for Business and Trade
    UK Sustainability Reporting Standards — guidance

    Voluntary for any entity.

  10. Department for Business and Trade
    UK SRS S1 (PDF), ¶¶E1, E3, 73A, B45–B47
  11. Department for Business and Trade
    UK SRS S2 (PDF), ¶¶29(a), B32, B59A, C1, C3, C4
  12. Department for Business and Trade
    Letter to the FCA, 5 January 2026 (PDF)
  13. Department for Business and Trade
    Government response to the consultation on UK SRS (web version), Chapter 3

    Section 463 applies to UK SRS disclosure in the strategic report.

  14. Department for Business, Innovation, Science and Trade
    Modernising corporate reporting — consultation

    Closes 30 November 2026.

  15. Financial Reporting Council
    ISSA (UK) 5000 (PDF)

    Effective for periods beginning on or after 15 December 2026.

  16. Financial Reporting Council
    Corporate Reporting Review — overview

    The FRC reviews annual reports; the FCA says it is working closely with it.

  17. IFRS Foundation
    Supporting materials for the IFRS Sustainability Disclosure Standards
  18. GHG Protocol
    Corporate Value Chain (Scope 3) Standard
  19. legislation.gov.uk
    Companies Act 2006, section 463
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