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.
| Consultation | Owner | Window | Outcome | Status |
|---|---|---|---|---|
| UK SRS exposure drafts | DBT | 25 Jun – 17 Sep 2025 | UK SRS S1 and S2, 25 Feb 2026 | Closed |
| Assurance oversight regime | DBT | Alongside the exposure drafts | A voluntary, opt-in regime | Closed |
| Transition plan requirements | DESNZ | 25 Jun – 17 Sep 2025 | No outcome published | Awaiting outcome |
| CP26/5 — listing rules | FCA | 30 Jan – 20 Mar 2026 | PS26/19, 30 Sep 2026 | Closed |
| Draft TN 803.1 (in PMB 66) | FCA | 30 Sep – 28 Oct 2026 | Guidance to be finalised before 1 Jan 2027 | Open |
| Modernising corporate reporting | DBIST | 7 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.
| Provision | Proposed | Final, 25 February 2026 |
|---|---|---|
| Climate-first relief (UK SRS S1) | Extended from one year to two — the TAC’s recommendation, carried into the exposure drafts | No time limit at all (¶E3); timing left to legislation or FCA rules (¶E5) |
| Scope 3 relief (UK SRS S2) | One year from initial application | No time limit (¶C4); timing left to UK law (¶C6) |
| GICS classification for financed emissions | Remove the requirement — a TAC recommendation | Withdrawn: 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 compliance | Not in the exposure drafts | S1 ¶¶73A and 73B added |
| Financed emissions | Not in the exposure drafts | S2 ¶B59A added: explain why, if impracticable |
| ISSB’s December 2025 amendments to IFRS S2 | Not yet issued | Built 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.
| Provision | CP26/5 proposed | PS26/19 final |
|---|---|---|
| Basis for UK SRS S2 | Mandatory, except Scope 3 | Comply or explain (¶1.2) |
| UKLR 14 and 15 | A statement naming the home-country standards used | Comply or explain against UK SRS (¶1.7) |
| Start | Periods beginning on or after 1 January 2027 | Kept (¶3.12) |
| Scope 3 and S1 non-climate reliefs | One year and two years | Kept (¶3.14) |
| Early adopters | No reliefs | Keep the reliefs (¶3.19) |
| Which S1 paragraphs apply with S2 | Drafted as a rule, “must apply” | Guidance: UKLR 6.6.6A G, “is reminded” |
| Assurance | A statement of whether it was obtained; not mandatory | Kept “as consulted on”: UKLR 6.6.6R(8)(d) |
| Transition plans | A statement of whether one is published | Kept; no duty to have one: UKLR 6.6.6R(8)(e) |
| Population | Around 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.
| Question in CP26/5 | Support reported in PS26/19 |
|---|---|
| Proposed scope | 94 of 110 respondents |
| Replacing the TCFD-aligned rules | Over 90% |
| Comply or explain (Question 4) | Over two thirds of those answering directly |
| UK SRS S1 on comply or explain | 78 of 113 |
| Assurance transparency | Over 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.
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.
- Department for Business and TradeExposure drafts of UK SRS — consultation and outcome
“The government proposes 6 minor amendments”; “The consultation received 209 responses.”
- Department for Business and TradeGovernment response to the consultation on UK SRS (web version)
¶1.6 the 209 responses; ¶1.7 who responded; ¶1.17 68% (125 of 184).
- Department for Business and TradeConsultation response (PDF), Annex A
Every final difference from IFRS; carries no count.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
The consultation “ran from 25 June 2025 to 17 September 2025, alongside a consultation on … assurance”.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication
The final standards, 25 February 2026.
- Department for Business and TradeUK SRS S1 (PDF), ¶¶73A, 73B, E1–E5
- Department for Business and TradeUK SRS S2 (PDF), ¶¶12, 23, 32, 37, B59A, C1–C6
- Department for Business and TradeLetter to the FCA, 5 January 2026 (PDF)
The reliefs’ time references to go; the compliance statement to be clarified.
- Department for Business and TradeAssurance of sustainability reporting — government response
The parallel consultation: a voluntary, opt-in oversight regime.
- Department for Energy Security and Net ZeroClimate-related transition plan requirements — implementation routes
Same window, 25 June to 17 September 2025; no outcome published.
- Financial Conduct AuthorityCP26/5 (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.
- Financial Conduct AuthorityCP26/5 consultation page
Opened 30 January 2026, closed 20 March 2026.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
The final rules, 30 September 2026.
- Financial Conduct AuthorityPS26/19 (PDF), chapter 2 and Appendix 1
The feedback, question by question, and the made rules.
- Financial Conduct AuthorityPrimary Market Bulletin 66
Consults on draft TN 803.1 until 28 October 2026, with three questions.
- Financial Conduct AuthorityDraft Technical Note 803.1
The guidance under consultation.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
7 September to 30 November 2026.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document (PDF)
¶¶147–150, 154–155: the CFD review, SECR’s location, a promised SECR and ESOS consultation, and UK SRS.
- Financial Reporting CouncilUK Sustainability TAC issues final recommendations, 18 December 2024
The origin of the two-year relief and the GICS proposals.
- IFRS FoundationISSB issues targeted amendments to IFRS S2, December 2025