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UK SRS consultation · proposed against final

The UK SRS consultations: what was proposed, and what became final

Two UK SRS consultations built the regime: the government’s on the exposure drafts in 2025, and the FCA’s on listing rules, CP26/5, in 2026.

Both are closed, and both finished somewhere different from where they started — the standards lost their relief deadlines, and the listing rules lost the word “mandatory”.

This page sets each proposal beside its final form, and names the two related consultations still open.

The consultations

Six consultations, two of them still open

Two built UK SRS; two ran alongside and shaped its edges; two are open now.

Dates and outcomes are the owners’ own.

The assurance oversight consultation drew 99 responses over twelve weeks, for scale beside the exposure drafts’ 209.
ConsultationOwnerWindowOutcomeStatus
UK SRS exposure draftsDBT25 Jun – 17 Sep 2025UK SRS S1 and S2, 25 Feb 2026Closed
Assurance oversight regimeDBTAlongside the exposure draftsA voluntary, opt-in regimeClosed
Transition plan requirementsDESNZ25 Jun – 17 Sep 2025No outcome publishedAwaiting outcome
CP26/5 — listing rulesFCA30 Jan – 20 Mar 2026PS26/19, 30 Sep 2026Closed
Draft TN 803.1 (in PMB 66)FCA30 Sep – 28 Oct 2026Guidance to be finalised before 1 Jan 2027Open
Modernising corporate reportingDBIST7 Sep – 30 Nov 2026—Open

Three of these shared the window of 25 June to 17 September 2025, which is why a date alone never tells you which consultation a document belongs to.

The exposure drafts themselves grew out of the Technical Advisory Committee’s final recommendations, agreed on 5 December 2024 and published on 18 December 2024.

The dated sequence around them is on the UK SRS timeline, and what 2025 itself produced on UK SRS in 2025.

The standards

The exposure drafts against the final standards

The June 2025 consultation said the government “proposes 6 minor amendments”.

Two of them did not survive and four provisions were added, so the table is organised by provision, not by a count.

From the consultation page, the TAC recommendations and Annex A, which says “Where requirements in the standards are not included in the table, there are no differences between the two.”
ProvisionProposedFinal, 25 February 2026
Climate-first relief (UK SRS S1)Extended from one year to two — the TAC’s recommendation, carried into the exposure draftsNo time limit at all (¶E3); timing left to legislation or FCA rules (¶E5)
Scope 3 relief (UK SRS S2)One year from initial applicationNo time limit (¶C4); timing left to UK law (¶C6)
GICS classification for financed emissionsRemove the requirement — a TAC recommendationWithdrawn: the ISSB removed it itself in December 2025
Industry-based (SASB) guidance“shall” to “may”, including in S2 ¶37“may” in S2 ¶¶12, 23, 32 and S1 ¶¶55(a), 58(a); ¶37 back to “shall”
Statement of complianceNot in the exposure draftsS1 ¶¶73A and 73B added
Financed emissionsNot in the exposure draftsS2 ¶B59A added: explain why, if impracticable
ISSB’s December 2025 amendments to IFRS S2Not yet issuedBuilt into UK SRS S2

The largest change was announced before publication: the DBT’s letter to the FCA of 5 January 2026 said the government would remove “specific time-references about when the reliefs would apply” and leave timing to regulations or FCA rules.

That is why CP26/5, published on 30 January 2026, still described the exposure drafts’ one- and two-year reliefs as built into UK SRS: it was written, as it said itself, on the draft standards.

Of the 184 respondents who answered the question, 68% (125) agreed with the four amendments the TAC had recommended (government response ¶1.17).

The ISSB’s own December 2025 changes to IFRS S2 are the ISSB’s, absorbed into UK SRS S2, not amendments the UK made.

The final texts are on UK SRS S1 and UK SRS S2, published on GOV.UK.

The listing rules

CP26/5 against PS26/19

The FCA kept its dates and its reliefs, and changed the obligation around them.

From CP26/5 and PS26/19.
ProvisionCP26/5 proposedPS26/19 final
Basis for UK SRS S2Mandatory, except Scope 3Comply or explain (¶1.2)
UKLR 14 and 15A statement naming the home-country standards usedComply or explain against UK SRS (¶1.7)
StartPeriods beginning on or after 1 January 2027Kept (¶3.12)
Scope 3 and S1 non-climate reliefsOne year and two yearsKept (¶3.14)
Early adoptersNo reliefsKeep the reliefs (¶3.19)
Which S1 paragraphs apply with S2Drafted as a rule, “must apply”Guidance: UKLR 6.6.6A G, “is reminded”
AssuranceA statement of whether it was obtained; not mandatoryKept “as consulted on”: UKLR 6.6.6R(8)(d)
Transition plansA statement of whether one is publishedKept; no duty to have one: UKLR 6.6.6R(8)(e)
PopulationAround 600 listed companies affected (Annex 2 ¶43)No count given

The consultation ran from 30 January to 20 March 2026 (consultation page); the FCA’s old news story announcing it no longer resolves, and the consultation page is its record.

The rule as made, limb by limb, is on the FCA’s UK SRS rules.

Who said what

The responses, in the owners’ own figures

The government’s figures for the exposure drafts are exact: 209 responses, 170 by online survey and 39 by email, 199 from organisations and 10 from individuals (¶1.6).

Among online respondents who gave an organisation type, listed companies and representative bodies were the most common, followed by unlisted companies and investors (¶1.7).

The FCA gives no single total for CP26/5, only question-by-question counts, reproduced beside this section.

Some respondents published their own letters: Norges Bank Investment Management asked for mandatory Scope 3 or a sunset date, and the PRI asked for a phased move towards mandatory disclosure.

Both also asked that secondary-listed and depositary-receipt issuers report against UK SRS, which the final rules adopted; the move to mandatory disclosure was not adopted.

PS26/19 ¶¶2.7, 2.13, 2.17, 2.28, 2.47 (PS26/19). No single total is published.
Question in CP26/5Support reported in PS26/19
Proposed scope94 of 110 respondents
Replacing the TCFD-aligned rulesOver 90%
Comply or explain (Question 4)Over two thirds of those answering directly
UK SRS S1 on comply or explain78 of 113
Assurance transparencyOver 90%

Still open

What you can still respond to, and how

The FCA is consulting on draft Technical Note 803.1, which sets out what it expects when a listed company complies with UK SRS and when it explains, alongside an update to TN 801.4 and the deletion of TN 802.3 (PMB 66).

Comments close on 28 October 2026, and the FCA aims to finalise the guidance before the rules come into force on 1 January 2027.

The government’s Modernising corporate reporting consultation closes on 30 November 2026.

On UK SRS it says the government “will consider how UK SRS should be reflected in the Companies Act 2006”, and proposes nothing more (¶¶154–155).

It makes no proposals on the Companies Act climate disclosures, whose post-implementation review is due by spring 2027 (¶¶147–148).

It would move where SECR sits in the annual report, not who must report (¶149), and says a separate consultation on SECR and ESOS is intended later in 2026 (¶150).

The standards remain available for voluntary use by anyone in the meantime.

Draft TN 803.1 — the FCA’s three questions

1. Do you agree with the proposed expectations for complying?

2. Do you agree with the proposed expectations for explaining?

3. Do you agree with the proposed guidance for international companies?

By 28 October 2026 to primarymarketbulletin@fca.org.uk (PMB 66).

Frequently asked

UK SRS consultations: the questions asked

What was the UK SRS consultation?

Two consultations built UK SRS.

The Department for Business and Trade consulted on exposure drafts of UK SRS S1 and S2 from 25 June to 17 September 2025 and published the final standards on 25 February 2026.

The FCA consulted on listing rules in CP26/5 from 30 January to 20 March 2026 and published its final rules, PS26/19, on 30 September 2026.

How many responses did the UK SRS consultation receive?

The exposure-draft consultation received 209 responses: 170 through the online survey and 39 by email, 199 from organisations and 10 from individuals.

The FCA published no single total for CP26/5; PS26/19 gives counts question by question.

Is the UK SRS consultation still open?

The two that built UK SRS are closed.

Two related consultations are open: the FCA’s draft Technical Note 803.1 on comply or explain, with comments by 28 October 2026, and the government’s Modernising corporate reporting consultation, which closes on 30 November 2026.

What changed between the exposure drafts and the final standards?

The time limits on the climate-first and Scope 3 reliefs were removed, leaving timing to legislation or FCA rules.

A proposal to remove the GICS classification requirement was withdrawn because the ISSB made the change itself in December 2025.

Paragraphs 73A and 73B on the statement of compliance, B59A on financed emissions and E5 on UK law were added.

Annex A of the government response maps every final difference and gives no count.

What did the FCA change after CP26/5?

It adopted comply or explain across all of UK SRS instead of mandatory UK SRS S2, brought secondary listings and depositary receipts onto the same basis instead of a signposting statement, let early adopters keep the transitional reliefs, and made its list of UK SRS S1 paragraphs to apply with S2 guidance rather than a rule.

The start date and the length of the reliefs were kept.

How do I respond to the FCA’s draft Technical Note 803.1?

By email to primarymarketbulletin@fca.org.uk by 28 October 2026.

The FCA asks whether respondents agree with its proposed expectations for complying, for explaining, and for international companies, and what they would suggest instead.

Will private companies be consulted on UK SRS?

The Modernising corporate reporting consultation, open until 30 November 2026, says the government will consider how UK SRS should be reflected in the Companies Act 2006. It contains no proposal, threshold or date for private companies.

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 20 sources fromDepartment for Business and TradeDepartment for Energy Security and Net ZeroFinancial Conduct AuthorityDepartment for Business, Innovation, Science and TradeFinancial Reporting CouncilIFRS Foundation
  1. Department for Business and Trade
    Exposure drafts of UK SRS — consultation and outcome

    “The government proposes 6 minor amendments”; “The consultation received 209 responses.”

  2. Department for Business and Trade
    Government response to the consultation on UK SRS (web version)

    ¶1.6 the 209 responses; ¶1.7 who responded; ¶1.17 68% (125 of 184).

  3. Department for Business and Trade
    Consultation response (PDF), Annex A

    Every final difference from IFRS; carries no count.

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

    The consultation “ran from 25 June 2025 to 17 September 2025, alongside a consultation on … assurance”.

  5. Department for Business and Trade
    UK SRS S1 and UK SRS S2 — publication

    The final standards, 25 February 2026.

  6. Department for Business and Trade
    UK SRS S1 (PDF), ¶¶73A, 73B, E1–E5
  7. Department for Business and Trade
    UK SRS S2 (PDF), ¶¶12, 23, 32, 37, B59A, C1–C6
  8. Department for Business and Trade
    Letter to the FCA, 5 January 2026 (PDF)

    The reliefs’ time references to go; the compliance statement to be clarified.

  9. Department for Business and Trade
    Assurance of sustainability reporting — government response

    The parallel consultation: a voluntary, opt-in oversight regime.

  10. Department for Energy Security and Net Zero
    Climate-related transition plan requirements — implementation routes

    Same window, 25 June to 17 September 2025; no outcome published.

  11. Financial Conduct Authority
    CP26/5 (PDF), ¶¶3.4, 7.5, 8.6–8.12 and Annex 2 ¶43

    The FCA’s proposals, including mandatory UK SRS S2 and around 600 companies affected.

  12. Financial Conduct Authority
    CP26/5 consultation page

    Opened 30 January 2026, closed 20 March 2026.

  13. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    The final rules, 30 September 2026.

  14. Financial Conduct Authority
    PS26/19 (PDF), chapter 2 and Appendix 1

    The feedback, question by question, and the made rules.

  15. Financial Conduct Authority
    Primary Market Bulletin 66

    Consults on draft TN 803.1 until 28 October 2026, with three questions.

  16. Financial Conduct Authority
    Draft Technical Note 803.1

    The guidance under consultation.

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

    7 September to 30 November 2026.

  18. Department for Business, Innovation, Science and Trade
    Modernising corporate reporting — consultation document (PDF)

    ¶¶147–150, 154–155: the CFD review, SECR’s location, a promised SECR and ESOS consultation, and UK SRS.

  19. Financial Reporting Council
    UK Sustainability TAC issues final recommendations, 18 December 2024

    The origin of the two-year relief and the GICS proposals.

  20. IFRS Foundation
    ISSB issues targeted amendments to IFRS S2, December 2025
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