UK SRS Consultation Timeline 2025-2026 — Government Response & Implementation
The UK Sustainability Reporting Standards consultation process represents one of the most comprehensive stakeholder engagement exercises in UK corporate reporting history.
1Running from June to September 2025, the consultation attracted responses from across the business, finance, and civil society sectors, ultimately shaping the final standards published in February 2026.
Stakeholder Engagement
Consultation Timeline
The UK SRS consultation followed a structured timeline designed to allow comprehensive stakeholder input while maintaining the government's commitment to implementation by 2027.
1The consultation period of approximately 8 weeks ran from 25 June to 17 September 2025, alongside a parallel consultation on the development of an oversight regime for assurance of sustainability-related financial disclosures.
3The Financial Conduct Authority coordinated closely with DBT throughout this period, with FCA officials participating in stakeholder roundtables and technical working groups to ensure alignment between the final standards and their proposed implementation rules.
1Following the consultation closure on 17 September 2025, DBT undertook a comprehensive review of all submissions, conducting additional targeted engagement with key respondent groups including the Investment Association, the CBI, and major audit firms to clarify technical implementation points.
Response Demographics & Participation
| Response Category | Count | Percentage | Key Contributors |
|---|---|---|---|
| Total responses | 209 | 100% | All stakeholders |
| Organisations | 199 | 95% | Companies, audit firms, associations |
| Individuals | 10 | 5% | Independent experts |
| Online platform | 170 | 81% | Government survey tool |
| Direct email | 39 | 19% | Detailed submissions |
Major Respondent Categories
Financial Services
Major banks, asset managers, and insurance companies provided detailed technical feedback on proposed requirements, particularly financed emissions and investment disclosure obligations.
Manufacturing & Energy
Substantial input on Scope 3 emissions reporting and transition planning requirements, highlighting implementation challenges and data availability concerns.
Professional Services
Audit firms, consultancies, and trade associations contributed expertise on assurance, methodology, and cross-sector implementation considerations.
2The consultation received 209 responses in total, representing one of the highest response rates for a UK corporate reporting consultation.
Of these responses, 170 were submitted through the government's online survey platform while 39 were sent directly to the Department for Business and Trade by email.
2The demographic breakdown shows 199 responses from organisations and 10 from individuals, indicating the predominantly institutional nature of stakeholder engagement.
Organisational respondents included listed companies, audit firms, professional services providers, trade associations, environmental groups, and academic institutions.
Analysis of the response distribution reveals significant engagement from the financial services sector, with major banks, asset managers, and insurance companies providing detailed technical feedback on the proposed requirements.
1Manufacturing and energy companies also provided substantial input, particularly regarding Scope 3 emissions reporting and transition planning requirements.
Key Changes Made Following Consultation
Major Changes Following Consultation
Transitional Relief Flexibility
Removed time-specific references, leaving application to government regulations and FCA rules based on stakeholder feedback about implementation timing.
Financed Emissions Guidance
Added specific requirements to address financial sector concerns about investment-related emission disclosure obligations and calculation methodologies.
ISSB December 2025 Updates
Incorporated latest ISSB amendments including GICS requirement removal and derivatives exclusion from Scope 3 Category 15 calculations.
1The government made several significant modifications to the exposure drafts based on consultation feedback.
Most notably, DBT removed time-specific references about the application of transitional reliefs contained in UK SRS S1 and S2, with the application and availability of these reliefs now left to government regulations, FCA rules, or rules made by other relevant authorities.
2New requirements for financed emissions explanations were added to address concerns from financial sector respondents about the clarity of investment-related emission disclosure obligations.
This addition provides specific guidance for banks, insurers, and asset managers on how to approach financed emissions calculations and disclosure.
1The final standards also incorporate amendments made by the International Sustainability Standards Board (ISSB) in December 2025, including the removal of the Global Industry Classification Standard (GICS) requirement and the exclusion of derivatives from Scope 3 Category 15 (Investments) calculations.
Technical amendments were made to enhance clarity around climate scenario analysis requirements, with additional guidance provided on the selection and application of scenarios based on feedback from preparers about implementation challenges.
FCA Implementation Consultation
3Following publication of the final UK SRS on 25 February 2026, the Financial Conduct Authority launched Consultation Paper CP26/5 on 30 January 2026, setting out proposals for UK SRS-aligned reporting requirements to be applied to companies with shares listed in the UK.
4The FCA consultation proposes a phased implementation approach, with mandatory reporting taking effect from 1 January 2027. The consultation period runs until 20 March 2026, allowing stakeholders approximately 7 weeks to provide detailed feedback on the proposed rules.
3Key aspects of the FCA's proposals include mandatory application of both UK SRS S1 and S2 for Premium Listed companies, with specific rules for investment trusts and other specialist listing categories. The FCA also proposes specific requirements for assurance and audit of sustainability disclosures.
4The FCA aims to finalise its rules and publish a policy statement in autumn 2026, providing listed companies with approximately three months to prepare for mandatory implementation from 1 January 2027.
Next Steps & Future Consultations
5While the UK SRS are now available for voluntary use following their publication in February 2026, the government has indicated that a consultation on Modernising Corporate Reporting (MCR) is expected later in 2026 to address mandatory UK SRS reporting requirements for private entities.
The MCR consultation will likely address scope and threshold questions for private companies, building on the framework established for listed companies through the FCA process.
1DBT has indicated this consultation will consider the interaction between UK SRS requirements and existing reporting obligations under the Companies Act 2006 and related regulations.
5Additional technical guidance is expected to be published by both DBT and FCA throughout 2026 to support implementation, including sector-specific guidance for financial services, extractive industries, and real estate sectors where stakeholders identified particular implementation challenges during the consultation.
How many organisations responded to the UK SRS consultation?
The government received 209 responses total: 199 from organisations and 10 from individuals. Of these, 170 responses were submitted through the online survey platform and 39 were sent directly to DBT by email. The consultation ran for approximately 8 weeks from 25 June to 17 September 2025.
When did the government publish its response to the UK SRS consultation?
The Department for Business and Trade published the government response to the UK SRS consultation on 25 February 2026, alongside the final UK SRS S1 and S2 standards. The response document addresses feedback received during the consultation period and explains key changes made to the exposure drafts.
What is the FCA's role in UK SRS implementation?
The FCA launched Consultation Paper CP26/5 on 30 January 2026, proposing UK SRS-aligned reporting requirements for companies with shares listed in the UK. The FCA consultation runs until 20 March 2026, with implementation planned for 1 January 2027. The FCA aims to finalise rules and publish a policy statement in autumn 2026.
What major changes were made following the consultation feedback?
Key changes include removal of time-specific references about transitional reliefs (left to regulations and FCA rules), addition of financed emissions explanation requirements, and incorporation of ISSB December 2025 amendments such as removal of the Global Industry Classification Standard (GICS) requirement.
When will UK SRS become mandatory for listed companies?
UK SRS implementation for listed companies is planned for 1 January 2027, subject to the FCA finalising its rules following CP26/5 consultation. The standards are currently available for voluntary use. A separate consultation on Modernising Corporate Reporting (MCR) for private entities is expected later in 2026.