UK Sustainability Reporting Standards — FAQ

The UK Sustainability Reporting Standards (UK SRS) are the UK government's endorsed versions of the ISSB's global baseline standards — IFRS S1 and IFRS S2. They were published on 25 February 2026 by the Department for Business and Trade. UK SRS S1 covers general sustainability-related financial disclosures and UK SRS S2 covers climate-related disclosures. Both incorporate four UK-specific amendments to the original ISSB standards.

UK SRS S1 and S2 are the UK's national adoptions of IFRS S1 and IFRS S2 respectively. They follow the ISSB global baseline with four minor UK-specific amendments. Companies reporting under UK SRS will be substantially aligned with the global ISSB framework, which supports international comparability.

The four UK-specific amendments tailor the ISSB global baseline to the UK regulatory context. They were recommended by the UK Technical Advisory Committee (TAC) in December 2024 and adopted by the Department for Business and Trade when UK SRS was published in February 2026. The amendments address UK-specific reporting requirements within the Strategic Report framework.

UK SRS S2 (climate disclosures) becomes mandatory from 1 January 2027 for approximately 515 primary-listed companies. Scope 3 emissions disclosure moves to comply-or-explain from 1 January 2028. UK SRS S1 (general sustainability disclosures) moves to comply-or-explain from 1 January 2029. This timeline is set out in FCA CP26/5.

Yes. Both UK SRS S1 and S2 are available for voluntary use immediately following their publication on 25 February 2026. However, voluntary adoption requires a full statement of compliance — companies cannot cherry-pick individual disclosures. It is an all-or-nothing early adoption.

FCA CP26/5 is the Financial Conduct Authority's consultation paper setting out proposed rules for mandatory sustainability reporting by UK-listed companies. The consultation closed on 20 March 2026. The FCA is expected to publish final rules in Autumn 2026, confirming the mandatory timeline for UK SRS S2 from January 2027.

The initial scope covers approximately 515 primary-listed companies on the UK market. This includes commercial companies under UKLR6, non-equity shares under UKLR16, and transition category companies under UKLR22. Excluded are closed-ended investment funds, shell companies, debt securities issuers, and securitised derivatives issuers.

The Government has signalled its intention to extend UK SRS to economically significant private companies and LLPs through Companies Act amendments. However, the thresholds and timelines for this extension have not yet been confirmed. Private companies should begin monitoring developments and preparing their data collection processes.

Companies with secondary listings and depositary receipt categories are subject to different rules. They are required to disclose their home jurisdiction sustainability reporting requirements rather than comply with UK SRS directly.

UK SRS S2 requires climate-specific disclosures covering governance, strategy, risk management, and metrics and targets. This includes scenario analysis, transition plan disclosures, and Scope 1, Scope 2, and Scope 3 greenhouse gas emissions. Companies must also show the connection between climate risks and their financial statements.

Scope 3 greenhouse gas emissions disclosure is subject to a one-year transitional relief. From 1 January 2028, Scope 3 disclosure moves to a comply-or-explain basis. Companies must either disclose their Scope 3 emissions or explain why they have not. This reflects the practical challenges of Scope 3 data collection across value chains.

Under UK SRS S2, companies must disclose their climate transition plan or explain why they have not published one. The disclosure should cover the company's targets, actions, and progress toward reducing greenhouse gas emissions and managing climate-related risks in line with their stated strategy.

The TCFD (Task Force on Climate-related Financial Disclosures) was disbanded in October 2023, with monitoring responsibilities transferred to the ISSB. UK SRS S2 replaces the TCFD-aligned Listing Rules from January 2027. While UK SRS builds on the same four-pillar framework (Governance, Strategy, Risk Management, Metrics and Targets), it significantly expands the requirements — including mandatory scenario analysis, explicit Scope 3 obligations, and a formal statement of compliance.

Key material changes include: mandatory (not recommended) scenario analysis, explicit Scope 3 emissions disclosure obligations, required connectivity between climate disclosures and financial statements, a formal statement of compliance (not just alignment), and significantly expanded metrics and targets requirements. Companies currently reporting under TCFD should conduct a gap analysis against UK SRS S2.

UK SRS S2 is confirmed as a national reporting framework under s414CB of the Companies Act. Disclosures made within the Strategic Report benefit from s463 liability protections. This means directors are protected from civil liability for statements in the Strategic Report unless they knew a statement was untrue or misleading, or were reckless as to whether it was.

UK SRS disclosures are made within the Strategic Report, which forms part of a company's Annual Report and Accounts. This is a statutory filing requirement. The placement within the Strategic Report is what triggers s463 liability protections under the Companies Act.

Assurance is not yet mandated for UK SRS disclosures, but it is expected. Companies will be required to disclose the assurance status of their sustainability reporting. The FRC has been asked to establish an interim register of sustainability assurance practitioners by mid-2026. The assurance standard ISSA (UK) 5000 becomes effective for periods beginning on or after 15 December 2026.

ISSA (UK) 5000 is the assurance standard for sustainability information. It becomes effective for sustainability information reported for periods beginning on or after 15 December 2026. It establishes the framework for how sustainability assurance practitioners will assess and report on the quality of UK SRS disclosures.

Streamlined Energy and Carbon Reporting (SECR) obligations remain in place alongside UK SRS. Companies subject to both regimes will need to comply with each. UK SRS sits alongside — and in some areas supersedes — existing SECR requirements, but SECR has not been repealed.

UK SRS uses a four-pillar disclosure framework inherited from TCFD but significantly expanded: Governance (how the organisation governs sustainability risks and opportunities), Strategy (the actual and potential impacts on business model and strategy), Risk Management (processes for identifying, assessing, and managing sustainability risks), and Metrics and Targets (the metrics and targets used to assess and manage relevant risks and opportunities).

Companies should: (1) conduct a gap analysis of current TCFD reporting against UK SRS requirements, (2) assess Scope 3 data collection readiness, (3) review governance structures for sustainability oversight, (4) evaluate systems and controls for connectivity between sustainability and financial reporting, (5) consider assurance readiness, and (6) brief the board and CFO on the timeline and resource requirements.