UK SRS deadline · one answer per listing category
The UK SRS deadline: your date, by listing category
The UK SRS deadline depends on one fact about you: which UK Listing Rules category, if any, your shares sit in.
Five categories report against UK SRS on a comply-or-explain basis from the first accounting period beginning on or after 1 January 2027, under the FCA’s final rules.
Everyone else — private companies, AIM companies, funds, LLPs, charities — has no UK SRS deadline, and the standards stay voluntary.
Your answer
One answer per category, and one for everyone else
Pick your listing category and year-end, and the panel returns your first period, your relief years, the statements you owe and when your first report is public.
The five categories in scope are named at PS26/19 ¶3.6: UKLR 6, 14, 15, 16 and 22.
The six left out are named at ¶3.7: closed-ended funds (UKLR 11), open-ended investment companies (UKLR 12), shell companies (UKLR 13), and debt, securitised derivatives and miscellaneous securities (UKLR 17, 18 and 19).
All five in-scope categories are on one basis: report against UK SRS, or explain.
The one difference between them is the transition-plan statement, which applies to UKLR 6, 16 and 22 but not to secondary listings and depositary receipts.
International issuers in UKLR 14 and 15 may rely on home-country reporting where it “aligns with the outcomes of UK SRS”, and explain where it falls short (PS26/19).
Whether your company is listed at all, and in which category, is the test on UK SRS scope; the Companies Act duties that may bind you anyway are on UK SRS regulations.
Your listing category · your year-end
- Final ruleFirst period: 1 January 2027 to 31 December 2027Report against UK SRS S1 and S2, or explain what is missing, why, and the steps you plan. Comply or explain — not mandatory.PS26/19 ¶3.12; UKLR 6.6.6R(7A), (7B) or the category equivalent
- ReliefScope 3 — first period onlyState that you are using the relief. No further explanation is needed until the period starting 1 January 2028.PS26/19 ¶3.14, ¶3.20
- ReliefUK SRS S1 non-climate matters — first two periodsState the use of the relief. Comply or explain on everything from the period starting 1 January 2029.PS26/19 ¶3.14, ¶3.24
- PublicationFirst report: within four months of 31 December 2027The disclosures go in the annual financial report, which is public within four months of the year-end.DTR 4.1.3R
- Final ruleTransition-plan statementSay whether you have published a climate transition plan, and where; if not, why not. There is no duty to have one.UKLR 6.6.6R(8)(e)
- Final ruleAssurance statementSay whether third-party assurance was obtained; if so, the provider, what was assured, the level and the standards used. Assurance itself is not required.UKLR 6.6.6R(8)(d)
Assumes twelve-month periods ending on a month-end.
A shortened or extended period moves the dates: the test is always the first period beginning on or after 1 January 2027.
Indicative, not advice; nothing you enter leaves your browser.
Category by category
The deadline for each category, side by side
| Category | UK SRS duty | First period | Transition-plan statement |
|---|---|---|---|
| UKLR 6 — commercial companies | Comply or explain | First beginning on or after 1 Jan 2027 | Yes |
| UKLR 14 — secondary listing | Comply or explain; home reporting may be relied on | First beginning on or after 1 Jan 2027 | No |
| UKLR 15 — depositary receipts | Comply or explain; home reporting may be relied on | First beginning on or after 1 Jan 2027 | No |
| UKLR 16 — non-equity and non-voting equity shares | Comply or explain | First beginning on or after 1 Jan 2027 | Yes |
| UKLR 22 — transition | Comply or explain | First beginning on or after 1 Jan 2027 | Yes |
| UKLR 11, 12, 13, 17, 18, 19 | None | — | — |
| AIM, unlisted, private, LLP | None — UK SRS voluntary | — | — |
The statements owed by every in-scope company — where the disclosures sit, and whether assurance was obtained — are the same in every category and are read limb by limb on the FCA’s UK SRS rules.
Assurance is not required by any category: the rule asks only whether it was obtained, and if it was, by whom, over what and to which standard — ISSA (UK) 5000, which the FRC lists among its assurance standards, is effective for periods beginning on or after 15 December 2026.
The listing categories themselves are defined in the UK Listing Rules, at UKLR 1.1.
Mandatory or not
The proposal was mandatory; the rule is comply or explain
Most published deadline pages still describe CP26/5, which proposed mandatory UK SRS S2 climate disclosures from 1 January 2027 for companies in three of the five categories.
The consultation ran from 30 January to 20 March 2026 (consultation page), and the Policy Statement that answers it, PS26/19, was published on 30 September 2026.
The date survived; the word “mandatory” did not.
PS26/19 ¶1.7 brought UK SRS S2 into line with the comply-or-explain basis already proposed for UK SRS S1 and Scope 3, and put UKLR 14 and 15 on the same footing as the rest.
CP26/5 estimated that around 600 listed companies would be affected; the final rules give no total, and the consultation’s split into 515 and 89 describes routes that no longer exist.
The instrument was made on 24 September 2026 and comes into force on 1 January 2027 (Appendix 1).
The FCA’s product-level SDR regime for asset managers is a separate set of rules, covered on FCA sustainability disclosure requirements.
“Our final rules adopt a comply or explain approach across the UK SRS.”
What the deadline asks
What “comply or explain” asks for on the day
Comply or explain is not an exemption: a company either publishes the disclosure or publishes the reason it has not.
For UK SRS S2, the explanation lists the unmet requirements, the reasons, and any steps the company is taking or plans to take (UKLR 6.6.6R(7A)(b)).
The old TCFD-aligned rule asked for a timeframe; the new UK SRS S2 limb does not.
For UK SRS S1, the explanation works at the level of the undisclosed risk or opportunity, not requirement by requirement.
The FCA’s draft guidance, Technical Note 803.1, says an explanation “can be a short, proportionate explanation” but “should not omit material information”; it is out for comment until 28 October 2026 (PMB 66).
In the same draft, a company that explains cannot also make an unreserved statement of compliance with the standard; the standard itself sets a similar limit, since UK SRS S1 ¶73A bars a compliance claim by a company using the climate-first relief.
What a full disclosure contains is set out on UK SRS requirements, and how a first-time preparer gets there on UK SRS compliance.
| Standard | If you do not disclose in full, say |
|---|---|
| UK SRS S2 | Which requirements are not met; why; the steps you are taking or plan to take |
| UK SRS S1 | Which risks or opportunities are not covered; why; and what you plan |
| Neither | No separate compliance statement is required by the listing rules |
The reliefs, as dates
The two reliefs, by the period your year starts
The reliefs count from initial application, which is the start of the first annual reporting period beginning on or after 1 January 2027 but before 1 January 2028 (PS26/19 ¶3.18).
Scope 3 is relieved for one year and UK SRS S1 non-climate matters for two (¶3.14).
A company using either states that it is doing so in its annual financial report; no explanation is required while the relief runs (¶3.20).
When a relief ends, the disclosure moves onto comply or explain, like everything else in UK SRS; it does not become compulsory.
The standards’ own reliefs have no time limit — UK SRS S2 ¶C4 for Scope 3 and UK SRS S1 ¶E3 for climate-first — so the periods above bind only listed companies in scope (UK SRS S2; FRC).
Measuring Scope 3 before the relief year ends is covered on Scope 3 under UK SRS.
| Period begins | Scope 3 | UK SRS S1 non-climate |
|---|---|---|
| Before 1 Jan 2027 | Old TCFD-aligned rules, or early adoption with reliefs | Old rules, or early adoption |
| 1 Jan 2027 – 31 Dec 2027 | Relief: state its use | Relief: state its use |
| 1 Jan 2028 – 31 Dec 2028 | Comply or explain | Relief: state its use |
| 1 Jan 2029 onwards | Comply or explain | Comply or explain |
The dates that already bind
Publication and filing: the deadlines that already exist
UK SRS adds no filing deadline of its own; it rides on two that exist already.
The listing rule puts the disclosures in the annual financial report, and DTR 4.1.3R requires a listed issuer to make that report public at the latest four months after its year-end.
A UK-incorporated company also files its statutory accounts and reports at Companies House, within six months of the year-end for a public company and nine for a private one (Companies Act 2006 s.442).
Filing late is a civil penalty on the company, set by the table beside this section; it is a penalty for lateness, not for the content of any disclosure.
Where UK SRS disclosure sits matters for directors: the government response confirms that the section 463 safe harbour applies to UK SRS disclosure placed in the strategic report, and the Modernising corporate reporting consultation repeats that it covers only material placed there.
UK SRS S2 is also confirmed as a national framework for section 414CB(6), so a company reporting under it need not duplicate its Companies Act climate disclosures; the Act itself is on legislation.gov.uk.
The same filing clock governs SECR, set out on the SECR deadline.
| Lateness | Private company | Public company |
|---|---|---|
| Up to 1 month | £150 | £750 |
| 1 to 3 months | £375 | £1,500 |
| 3 to 6 months | £750 | £3,000 |
| Over 6 months | £1,500 | £7,500 |
Everyone else
Private companies and everyone else: no date, and none proposed
For a company that is not on the Official List in one of the five categories, the honest answer is that there is no UK SRS deadline.
The Modernisation of Corporate Reporting programme was announced in WMS HCWS973 on 21 October 2025, and its consultation was published on 7 September 2026 and closes on 30 November 2026 (consultation page).
On UK SRS it says only that the government “will consider” how the standards should be reflected in the Companies Act (¶¶154–155).
It proposes no private-company threshold, no mechanism and no date, and no other government document does either.
A date for private companies would have to follow legislation that has not yet been drafted.
The negative is set out in full on private companies and UK SRS.
“The government will consider how UK SRS should be reflected in the Companies Act 2006.”
Modernising corporate reporting ¶155.
No mechanism, threshold or date.
Before any duty
Voluntary and early adoption: no deadline, two routes
UK SRS S1 and S2 have been available since 25 February 2026, and any entity may use them with no deadline and no regulator watching.
A voluntary user may use the standards’ own reliefs without a time limit, in the FRC’s reading, but must disclose that it has done so alongside any statement of compliance.
A listed company whose year does not start in January has a period that begins in 2026 and ends in 2027, and for that period it chooses: keep the TCFD-aligned rules, or adopt UK SRS early.
Early adopters keep the same transitional reliefs (PS26/19 ¶3.19), which reversed the consultation’s proposal; PMB 66 repeats that they may use them.
How the two standards should be named in a voluntary report, and how they fit together, is on voluntary reporting under UK SRS and on the sister reference’s UK SRS S1 and S2.
The move from the old framework is compared on UK SRS vs TCFD, and every page in this cluster is indexed from the UK SRS hub.
Voluntary use: any entity, any time, since 25 February 2026.
Early adoption: a listed company applies the new rules to a period beginning before 1 January 2027, and keeps the reliefs.
Frequently asked
UK SRS deadline: the questions asked
What is the UK SRS deadline?
There is no single one.
For a company listed in UKLR 6, 14, 15, 16 or 22, the FCA’s final rules apply to the first accounting period beginning on or after 1 January 2027, on a comply-or-explain basis, and the first disclosures appear in the annual financial report for that period, published in 2028.
For every other entity there is no UK SRS deadline at all.
Is UK SRS mandatory from 2027?
No. From accounting periods beginning on or after 1 January 2027, listed companies in scope must report against UK SRS or explain what they have not disclosed, why, and what they plan to do about it.
The consultation, CP26/5, proposed mandatory UK SRS S2; PS26/19, published on 30 September 2026, adopted comply or explain across all of UK SRS instead.
Which listed companies are in scope?
Companies with equity shares in the commercial companies category (UKLR 6), international commercial companies with a secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16), and the transition category (UKLR 22).
Closed-ended and open-ended funds, shell companies, and debt, securitised derivative and miscellaneous securities are excluded.
The Policy Statement gives no company count; CP26/5 estimated around 600 would be affected.
When does the Scope 3 relief end?
The relief lasts one year from initial application, which is the start of the first accounting period beginning on or after 1 January 2027.
From the following period Scope 3 is on the same comply-or-explain basis as the rest of UK SRS S2.
While using the relief, a company states that it is doing so and needs give no further explanation.
Is there a UK SRS deadline for private companies?
No. The FCA’s rules apply only to companies on the Official List in the five categories.
No private-company threshold or date has been proposed.
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, and proposes nothing more specific.
What happens to an accounting period that begins before 1 January 2027?
It stays under the TCFD-aligned listing rules in force immediately before 1 January 2027, unless the company chooses to adopt UK SRS early.
Early adopters may use the same transitional reliefs as companies starting in 2027 (PS26/19 ¶3.19).
When is the first UK SRS report due?
The disclosures sit in the annual financial report, which DTR 4.1.3R requires to be made public at the latest four months after the end of the financial year.
For a 31 December year-end, the first period is calendar 2027 and the report is public by 30 April 2028.
How long does a sustainability statement take to complete in the UK?
No regulator publishes a figure for UK SRS.
The rules fix only when the report must be public.
The nearest government measurement is for a different, narrower regime: the evaluation of Streamlined Energy and Carbon Reporting found 94 hours of internal staff time a year.
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.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Published 30 September 2026. Scope (¶3.6), exclusions (¶3.7), timing (¶3.12), initial application (¶3.18), early adopters (¶3.19), reliefs (¶3.14, ¶3.20, ¶3.23, ¶3.24).
- Financial Conduct AuthorityPS26/19 (PDF), Appendix 1 — UKLR 6.6.6R(7A), (7B), (8) and UKLR TP 16 as made
The comply-or-explain limbs and the statements on location, assurance and transition plans.
- Financial Conduct AuthorityCP26/5 (PDF), Annex 2 ¶43
Around 600 listed companies affected — the consultation’s estimate. Its proposal of mandatory UK SRS S2 was not adopted.
- Financial Conduct AuthorityCP26/5 consultation page
Opened 30 January 2026, closed 20 March 2026.
- Financial Conduct AuthorityPrimary Market Bulletin 66
Draft TN 803.1 for comment by 28 October 2026; early adopters may use the reliefs.
- Financial Conduct AuthorityDraft Technical Note 803.1 — UK SRS sustainability disclosures for listed companies
Proposed guidance on what an explanation should contain. Not final.
- Financial Conduct AuthorityFCA Handbook, DTR 4.1.3R
The annual financial report is public within four months of the year-end.
- Financial Conduct AuthorityFCA Handbook, UKLR 6.6 — annual financial report
The rule amended from 1 January 2027; the Handbook flags the future version.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
“Available for voluntary use, by any entity that chooses to do so.”
- Department for Business and TradeUK SRS S1 (PDF), ¶¶E1–E5, 73A
- Department for Business and TradeUK SRS S2 (PDF), ¶¶C1–C6
- Department for Business and TradeGovernment response to the consultation on UK SRS (web version), Chapter 3
UK SRS S2 a national framework for s.414CB(6); s.463 applies to UK SRS disclosure in the strategic report.
- 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), ¶¶154–155, 160
The government “will consider” how UK SRS should be reflected in the Companies Act 2006.
- UK ParliamentWritten Ministerial Statement HCWS973, 21 October 2025
- Financial Reporting CouncilSustainability reporting developments: frequently asked questions
Voluntary users may use the reliefs “without time limits, indefinitely”.
- Financial Reporting CouncilAssurance standards — audit, assurance and ethics
ISSA (UK) 5000, issued 12 November 2025.
- legislation.gov.ukCompanies Act 2006, section 442 — period allowed for filing accounts
Nine months for a private company, six for a public company.
- legislation.gov.ukSI 2008/497, regulation 4(2) — late filing penalties
- legislation.gov.ukCompanies Act 2006, section 414CB
- legislation.gov.ukCompanies Act 2006, section 463
- legislation.gov.ukCompanies Act 2006 — contents
- Department for Energy Security and Net ZeroIndependent evaluation of SECR, 29 January 2026
94 hours of internal staff time a year — for SECR, not UK SRS.
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