UK SRS compliance checker

The scope question

UK SRS mandatory application is introduced through FCA CP26/5, which proposes requiring companies with securities listed on the FCA's Official List in specific UK Listing Rules (UKLR) categories to comply with UK SRS S1 and S2.

The scope determination has two branches, not one binary in/out: companies in UKLR categories 6, 16, or 22 would report against UK SRS from the first reporting year beginning on or after 1 January 2027, while companies in UKLR categories 14 or 15 would instead make a signposting statement about the overseas standards they follow.

UK SRS standards themselves were published by the Department for Business and Trade on 25 February 2026.

They are available for voluntary adoption immediately — mandatory application depends on the FCA finalising CP26/5 rules.

The consultation closed in mid-2026; final rules are expected to confirm the January 2027 mandatory date.

This page takes you through the scope determination process in five steps: listing status, UKLR category, mandatory date, what compliance requires, and what private or AIM-listed companies should watch.

Step 1 — Are you listed on a UK regulated market?

UK SRS mandatory application under FCA CP26/5 applies to companies whose securities are admitted to the FCA's Official List and traded on a UK regulated market — primarily the Main Market of the London Stock Exchange.

The key question is whether your company has securities listed under the UK Listing Rules (UKLR).

Common cases that are in scope at Step 1:

• Companies with equity shares (ordinary shares, preference shares) listed on the Main Market of the London Stock Exchange under UKLR Category 6, the commercial companies category
• Companies with a secondary listing on the Main Market under UKLR Category 14, the secondary listing category
• Companies with depositary receipts admitted under UKLR Category 15, the depositary receipts category
• Companies with non-equity shares or non-voting equity shares listed under UKLR Category 16, or in the transition category under UKLR Category 22

Common cases that are NOT in scope at Step 1:

• Companies admitted solely to AIM — AIM is a multilateral trading facility, not a regulated market; AIM-listed companies are not admitted to the FCA's Official List under UKLR
• Companies traded on AQUIS Exchange only
• Unlisted private companies (pending MCR Strand 2)
• Companies listed on overseas markets only (e.g. NYSE, NASDAQ) with no UK Main Market listing

Step 2 — Which UKLR category applies?

Not all UKLR-listed companies face the same proposed obligation under FCA CP26/5.

The consultation covers five UKLR categories — "with some variation depending on the category".

Three would carry a full UK SRS reporting duty; two would instead make a signposting statement.

Full UK SRS reporting duty proposed — UK SRS S2 climate disclosure mandatory (excluding Scope 3), with Scope 3 and UK SRS S1 non-climate content on a comply-or-explain basis:

• UKLR Category 6 — the commercial companies category
• UKLR Category 16 — the non-equity shares and non-voting equity shares category
• UKLR Category 22 — the transition category

No UK SRS reporting duty proposed — CP26/5 states plainly that it is "not proposing disclosures aligned with UK SRS (including for transition plans)" for these two categories.

Instead, companies would make a statement naming the overseas climate and sustainability standards they follow, or a nil statement if they follow none:

• UKLR Category 14 — the secondary listing category
• UKLR Category 15 — the depositary receipts category

Sustainability-assurance requirements are proposed to apply across all five categories, even though only three would carry a UK SRS reporting duty.

CP26/5's cost-benefit analysis estimates around 600 listed companies affected in total: 515 in Categories 6, 16 and 22 would be required to comply with the UK SRS proposals, and the remaining 89, in Categories 14 and 15, would instead disclose which overseas standards they follow.

Companies in UKLR categories covering debt securities only (bonds, notes) or specialist segments not listed above should review the FCA's final CP26/5 rules when published.

The scope of the consultation proposal as of the first half of 2026 is as described above, but final rules — not yet published — may refine the category list.

Step 3 — When does your obligation start?

FCA CP26/5 proposes that UK SRS S1 and S2 become mandatory for UKLR-listed companies in scope for reporting years beginning on or after 1 January 2027.

For a company with a 31 December year-end, the first mandatory reporting year would be 2027 (with reports published in spring 2028).

For a company with a 31 March year-end, the first mandatory reporting year would begin 1 April 2027 (with reports published in summer 2028).

This mandatory date applies only once the FCA has finalised CP26/5 and issued final rules.

The FCA's policy statement confirming final rules was expected in Autumn 2026.

Companies should monitor FCA publications and confirm the mandatory date in the final rules before committing to specific implementation timelines based solely on the consultation proposal.

Voluntary adoption of UK SRS S1 and S2 is available now from their February 2026 publication date.

Companies that adopt UK SRS voluntarily before the mandatory date gain implementation experience, can refine their materiality assessment process, and can engage their assurance provider earlier.

The UK SRS compliance guide recommends starting preparation at least 18 months before the mandatory reporting year begins.

Step 4 — What does compliance require?

If your company is in scope, UK SRS compliance requires disclosures across four pillars drawn from the ISSB framework and incorporated into UK SRS S1 and S2:

1. Governance

Disclosure of the governance processes, controls, and procedures the company uses to monitor, manage, and oversee sustainability-related risks and opportunities.

This includes the role of the board, board committees, and management.

Under UK SRS S1, governance disclosures must describe how the board considers sustainability matters in its decision-making and oversight.

2. Strategy

Disclosure of the sustainability-related risks and opportunities that could reasonably be expected to affect the entity's prospects, and how they affect the business model, value chain, strategy, and financial planning.

UK SRS S2 climate strategy requirements include scenario analysis (paragraph 22) to assess resilience of the strategy under different climate scenarios, and transition plan disclosure (paragraph 14(a)(iii)).

3. Risk management

Disclosure of the processes used to identify, assess, prioritise, and monitor sustainability-related risks and opportunities, and how these processes are integrated into the overall risk management framework.

4. Metrics and targets

Disclosure of specific metrics and targets used to measure and manage sustainability-related risks and opportunities.

For climate under UK SRS S2, this includes Scope 1, Scope 2, and Scope 3 greenhouse gas emissions where material, cross-industry climate-related metrics (physical and transition risks), and industry-specific metrics where applicable.

Cross-industry climate metrics are specified in UK SRS S2 paragraphs 29-36.

Disclosures must sit within the Strategic Report under the Companies Act 2006 framework.

The materiality assessment required by UK SRS S1 paragraph 17 determines which disclosures must be made — not all four pillars will have material content for every company in every year.

Step 5 — Private company? What to watch

Large private companies, including those backed by private equity, family-owned businesses above significant size thresholds, and large AIM-listed companies, are not currently in mandatory UK SRS scope.

The UK government's MCR (Modernising Corporate Reporting) programme includes MCR Strand 2, which is expected to consult on extending UK SRS to companies beyond the UKLR-listed population.

The MCR Strand 2 consultation was expected during 2026 but had not been published at the time of writing (June 2026).

The consultation is expected to address which private companies would be in scope, what thresholds would apply, and what transition period would be available.

Until Strand 2 legislation is enacted, private companies have no mandatory UK SRS obligation.

Private companies that proactively adopt UK SRS — either voluntarily or in preparation for mandatory scope — should be aware that:

• UK SRS S1 and S2 are available for voluntary adoption now, with no restrictions on voluntary use
• SECR (Streamlined Energy and Carbon Reporting) under SI 2018/1155 continues to apply to large private companies meeting the two-of-three size thresholds — SECR is a separate and continuing obligation
• Large private companies above the ESOS qualification criteria must comply with ESOS Phase 4 by 5 December 2027 — this is a separate requirement from UK SRS
• Building UK SRS-aligned capability now (data infrastructure, materiality process, governance framework) reduces preparation time if and when mandatory scope is extended

UKLR category scope table

The table below summarises UK SRS mandatory scope by UKLR category and listing type, under FCA CP26/5 proposals.

What UK SRS compliance requires in practice

For companies confirming they are in mandatory scope, the UK SRS compliance guide provides a detailed seven-step implementation pathway.

The key elements every in-scope company must address are:

• Materiality assessment — identifying which sustainability topics are financially material to the company's investors and creditors under UK SRS S1 paragraph 17
• Governance framework — documenting board and management oversight of sustainability matters
• Data infrastructure — establishing systems to capture Scope 1, 2, and 3 emissions data, physical and transition risk metrics, and other material sustainability metrics
• Scenario analysis — for climate under UK SRS S2 paragraph 22, assessing strategy resilience under at least two climate scenarios
• Transition plan — if the company has a transition plan, it must be disclosed; absence of a transition plan is also disclosed
• Assurance engagement — under ISSA (UK) 5000, published by the FRC in November 2025, UK SRS disclosures require third-party assurance
• Strategic Report integration — sustainability disclosures must be included in the Strategic Report and aligned with financial statements

Companies typically need 12-18 months of preparation before first mandatory reporting.

The critical path activities are establishing data collection systems (particularly for Scope 3 emissions), conducting a credible materiality assessment, and engaging an assurance provider early enough for the assurer to design their procedures.

Assurance requirements

UK SRS disclosures must be assured under the ISSA (UK) 5000 standard, published by the FRC in November 2025.

ISSA (UK) 5000 is the UK's adaptation of the International Standard on Sustainability Assurance 5000 for the UK regulatory context.

The assurance requirement is part of the FCA CP26/5 framework for in-scope UKLR-listed companies.

Assurance under ISSA (UK) 5000 is required because investors and creditors rely on UK SRS disclosures for resource allocation decisions — the same rationale that drives statutory audit of financial statements.

The assurance engagement provides independent verification that material sustainability-related financial disclosures are free from material misstatement.

Companies should engage their assurance provider early — at least 12 months before the first mandatory reporting year begins.

Assurance providers need to design their procedures around the company's specific materiality assessment, data systems, and disclosure scope.

Last-minute assurance engagement risks delays to the annual report publication timeline.

Frequently asked questions