UK SRS gap analysis · requirement by requirement
UK SRS gap analysis: every gap becomes a sentence
A UK SRS gap analysis used to be a planning exercise; under the FCA’s final rules it produces text that goes into the annual report.
A listed company in scope that does not meet a UK SRS S2 requirement must summarise it, give the reasons, and say what it is doing about it.
This page lists the requirements and turns your gaps into the skeleton of that statement.
Why first
Why the gap analysis comes before the drafting
The FCA’s final rules put all of UK SRS on a comply-or-explain basis for listed companies in UKLR 6, 14, 15, 16 and 22, for periods beginning on or after 1 January 2027 (PS26/19).
The explanation is not a general statement of intent.
For UK SRS S2 it is a summary of the specific requirements not met (UKLR 6.6.6R(7A)(b)), so the company needs a list of requirements and a status against each.
For UK SRS S1 it works by risk and opportunity rather than requirement, so the company needs its list of sustainability-related risks and opportunities first.
The FCA explained its reasoning: where issuers do not provide financially material information under UK SRS, a proportionate explanation of their reasoning and judgement can itself be useful to investors (¶1.3).
What proportionate means is the subject of draft Technical Note 803.1, which is out for comment until 28 October 2026 and is not final.
Scope — whether the FCA’s rules reach you at all — is on UK SRS thresholds; a voluntary reporter has no explain duty but the same compliance-statement rule.
UK SRS S2 — UKLR 6.6.6R(7A)(b): (i) a summary of the requirements not met; (ii) the reasons; (iii) any steps taken or planned.
UK SRS S1 — UKLR 6.6.6R(7B)(b): (i) the risks or opportunities for which disclosures are missing; (ii) the reasons; and a further limb to check in the Handbook text.
The checklist
UK SRS S2, sixteen requirements to test
The checklist groups UK SRS S2 into sixteen testable requirements across its four pillars.
The pillars are the TCFD’s: governance from ¶5, strategy from ¶8, risk management from ¶24, metrics and targets from ¶27 of UK SRS S2.
Mark each row as something you can disclose now, in part, or not yet.
The panel counts the open items by pillar and drafts the three parts of the (7A)(b) statement, with a placeholder for your reasons and steps.
If this is your first period and you intend to use the Scope 3 relief, tick the box: a Scope 3 gap then becomes a relief statement rather than an explanation.
The sixteen rows summarise the standard; they are not every sub-paragraph, and ¶22 alone has more than a dozen disclosure items.
The full text of each requirement is set out on UK SRS S2, and the pillars side by side on the four pillars.
UK SRS S2 gap checklist · sixteen requirements
- ClearGovernance
- ClearStrategy
- ClearRisk management
- ClearMetrics and targets
Skeleton of the comply-or-explain statement
The sixteen rows summarise UK SRS S2; they are not every sub-paragraph.
The FCA’s guidance on what a proportionate explanation contains is in draft (TN 803.1).
Nothing you enter leaves your browser.
If you report under TCFD today
Common gaps for TCFD-aligned reporters
The FCA says its new rules replace the TCFD-aligned disclosures (PS26/19 ¶1.10).
The structure carries over; these requirements are where TCFD reports most often fall short of UK SRS S2.
| UK SRS S2 requirement | Why a TCFD report may not meet it | Paragraph |
|---|---|---|
| Skills and competencies of the oversight body | S2 asks how the body decides whether the skills exist or will be developed | ¶6(a)(ii) |
| Time horizons tied to planning horizons | Short, medium and long term must be defined and linked to strategic planning | ¶10(d) |
| Current and anticipated financial effects | Quantitative where possible; otherwise the reasons | ¶¶15–21 |
| Scenario analysis inputs and assumptions | A structured list: scenarios and sources, range, alignment with the latest international agreement, time horizons, scope | ¶22(b) |
| Cross-industry metrics | Amounts and percentages of assets vulnerable to transition and physical risk, aligned with opportunities, and capital deployed | ¶29(b)–(e) |
| Internal carbon price | Whether and how one is used, and the price per tonne | ¶29(f) |
| Remuneration | The percentage of executive remuneration linked to climate considerations | ¶29(g) |
| Industry-based metrics | Metrics associated with the business model; the SASB guidance is “may” in the UK | ¶¶32, 12 |
| Targets and carbon credits | How each target is set and reviewed, and any planned use of carbon credits | ¶¶33–36 |
| Financed emissions | For asset managers, banks and insurers; a UK-only duty to explain a different period | ¶¶B59–B63A, B59A |
The TCFD recommendations set four thematic areas and eleven recommended disclosures; UK SRS S2, like IFRS S2, turns them into specific requirements.
The UK amendments are listed in Annex A: most relax the IFRS text, such as making the industry guidance “may” rather than “shall”, while ¶B59A on financed emissions adds a duty.
A full comparison is on UK SRS vs TCFD.
If you are starting from SECR or nothing
Common gaps for first-time reporters
A company whose climate reporting today is SECR alone will find gaps in every pillar, not just metrics.
SECR sits in the directors’ report and reports energy use and emissions; it asks nothing about governance, strategy, scenario analysis or targets.
Even the emissions data may need work: UK SRS S2 ¶29(a) requires measurement under the GHG Protocol Corporate Standard, with Scope 3 categories drawn from the Scope 3 Standard.
In the first period a company may use another method if it used it immediately before (S2 ¶C3), so SECR methodology can bridge one year.
UK SRS S1 ¶64 then requires the disclosures to cover the same period as the financial statements and be published at the same time, which may move data collection earlier.
How SECR and UK SRS fit together is on SECR and UK SRS; Scope 3 in detail is on Scope 3 under UK SRS.
Measurement basis, UK SRS S2 ¶29(a)
| Item | Requirement |
|---|---|
| Standard | GHG Protocol Corporate Standard (2004) |
| Scope 2 | Location-based, with contractual instruments information |
| Scope 3 | Categories from the Scope 3 Standard (2011) |
| First-period relief | Another method if used immediately before (¶C3) |
UK SRS S1
The materiality and beyond-climate gap
UK SRS S1 asks for disclosure of every sustainability-related risk and opportunity that could reasonably be expected to affect the entity’s prospects, not only climate (¶¶3, 17–19).
The FCA lets listed companies report climate only under S1 for two years from initial application (PS26/19 ¶3.14).
After that, the S1 limb works risk by risk: the annual report names the risks or opportunities for which disclosures are missing, with the reasons.
So the S1 gap analysis starts with an identification exercise, not a disclosure checklist.
UK SRS S1 permits reference to the SASB Standards when identifying risks and opportunities, and in the UK that reference is optional (Annex A).
The FRC’s FAQs note that voluntary reporters may use the reliefs without time limit; listed companies may not.
The materiality judgement is covered on UK SRS S1 materiality; the international text is IFRS S1.
Governance and assurance readiness
Two gaps that are not about data
Governance
UK SRS S2 ¶6 asks which body or individual oversees climate risks and opportunities, how the responsibility appears in terms of reference, how the body decides it has the skills, how often it is informed, and how it oversees targets and remuneration.
Each of these is a fact about how the company is run, and a gap is closed by changing the process, not by writing better prose.
The board’s side is on UK SRS for boards.
Assurance readiness
Assurance is not required, but a listed company must say whether it obtained it and over what.
If you plan to commission it, ISSA (UK) 5000 is effective for periods beginning on or after 15 December 2026, and data that cannot be traced to source will fail an engagement at either level.
The FCA’s statement and the standard are on UK SRS assurance.
Order of work
Prioritising, by the order the reliefs expire
| Period (from initial application) | What must be disclosed or explained | What can be stated as relief |
|---|---|---|
| Period 1 | All of UK SRS S2 except Scope 3; S1 climate-related information | Scope 3 (one year); S1 beyond climate (two years); no comparatives |
| Period 2 | All of UK SRS S2, Scope 3 included; S1 climate-related information | S1 beyond climate |
| Period 3 onwards | All of UK SRS S1 and S2 | None under the FCA’s rules |
The expiry dates give a natural order: close the S2 gaps that cannot be relieved first, Scope 3 next, then the S1 risks beyond climate.
A gap that will still be open when its relief ends needs an explanation that year, with steps.
The dates for your own year-end are worked out on UK SRS reporting guidance.
How to run it
Seven steps to a finished gap analysis
- Confirm which regime you are reporting under: the FCA’s rules, voluntary UK SRS, or the Companies Act climate disclosures alone.
- List your climate risks and opportunities (S2 ¶10) and, for S1, your other sustainability-related risks and opportunities.
- Test each S2 requirement with the checklist on this page, recording evidence for every “can disclose now”.
- Decide which reliefs you will state, and remove those items from the explain list.
- For each remaining gap, write the reason and the step; the S2 limb sets no deadline for the steps, but they must be real.
- Check the draft explanations against the final version of TN 803.1 once the FCA publishes it.
- Take the gap list to the board with the plan to close it.
The longer programme is on the UK SRS compliance guide, and the statements for one period are worked out by the UK SRS compliance calculator.
Where a public body is buying this kind of support, the contract is advertised as a tender; rfp.quest tracks UK public-sector tenders.
You can also book a free 15-minute call to talk through your gap list.
Frequently asked
Questions people ask
What is a UK SRS gap analysis?
A comparison of what your company can disclose now against each requirement of UK SRS S1 and S2.
Under the FCA’s final rules its output is practical: for a listed company in scope, every UK SRS S2 requirement not met must be summarised in the annual financial report, with the reasons and the steps planned (UKLR 6.6.6R(7A)(b)).
What must the explanation contain?
For UK SRS S2: a summary of the requirements not met, the reasons, and any steps being taken or planned to make them in future.
For UK SRS S1: the sustainability-related risks or opportunities for which disclosures are missing, and the reasons.
The S2 limb asks for steps but sets no timeframe.
Draft FCA guidance (TN 803.1) on what a proportionate explanation contains is out for comment until 28 October 2026.
Do I need to explain a Scope 3 gap in the first year?
Not if you use the relief.
The FCA’s rules give one year of non-disclosure of Scope 3 from initial application.
A company using it states that it is doing so and needs give no further explanation during the relief period (PS26/19 ¶¶3.14, 3.20).
What are the most common gaps for TCFD reporters?
UK SRS S2 keeps the TCFD’s four pillars but adds specific requirements that TCFD reports often lack: the cross-industry metrics in ¶29(b)–(g) such as capital deployment and internal carbon price, climate-linked remuneration, a structured scenario-analysis disclosure under ¶22, industry-based metrics, and, for banks, insurers and asset managers, the financed-emissions paragraphs.
Is a UK SRS gap analysis the same as a CSRD gap analysis?
No. UK SRS is built on financial materiality — risks and opportunities that could affect the entity’s prospects.
The EU’s ESRS use double materiality, adding the company’s impacts on people and the environment.
A CSRD gap analysis therefore covers more topics and datapoints.
Should the gap analysis cover UK SRS S1 as well as S2?
Yes, though the timing differs.
Under the FCA’s rules a company may report climate-only under UK SRS S1 for two years from initial application.
After that, it discloses or explains for each sustainability-related risk or opportunity beyond climate.
Can I say my report complies with UK SRS if there are gaps?
No. UK SRS S1 ¶72 allows an explicit and unreserved statement of compliance only where every requirement is met.
A company using the climate-first relief may not assert compliance with UK SRS S1, but may assert compliance with UK SRS S2 if all its requirements are met, disclosing the reliefs alongside (¶73A).
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 (30 September 2026)
Final rules: comply or explain against UK SRS, UKLR 6, 14, 15, 16 and 22, periods from 1 January 2027.
- Financial Conduct AuthorityPS26/19 PDF — ¶¶1.2, 1.7, 1.10, 2.44–2.51, 3.6–3.24 and Appendix 1 (UKLR 6.6.6R(7A), (7B), (8)(c)–(e))
The made rule text and the reliefs.
- Financial Conduct AuthorityDraft Technical Note 803.1 (Primary Market Bulletin 66)
Proposed guidance on proportionate explanations; comments by 28 October 2026.
- Financial Conduct AuthorityCP26/5 consultation page
The consultation the final rules answer.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 (25 February 2026)
The publication page for both standards; voluntary for any entity.
- Department for Business and TradeUK SRS S1 — ¶¶21–24 connected information, ¶¶60–73B location, timing, comparatives and compliance, ¶¶77–86, Appendix E
Read in full 30 September 2026.
- Department for Business and TradeUK SRS S2 — ¶¶5–37, Appendix B and Appendix C
Read in full 30 September 2026.
- Department for Business and TradeUK SRS consultation response, Annex A — the S1 and S2 difference tables
IFRS S1 ¶E4 removed; ¶B59A added; reliefs untimed except ¶C3.
- Department for Business and TradeGovernment response to the consultation on UK SRS — Chapter 3 (s.414CB(6); s.463)
UK SRS S2 confirmed as a national reporting framework; the s.463 safe harbour follows the strategic report.
- Financial Reporting CouncilSustainability Reporting Developments: FAQs (last updated 26 February 2026)
- IFRS FoundationIFRS S1 — General Requirements for Disclosure of Sustainability-related Financial Information
The international baseline UK SRS S1 adopts with amendments.
- IFRS FoundationIFRS S2 — Climate-related Disclosures
- Task Force on Climate-related Financial DisclosuresRecommendations of the TCFD (2017) — the four thematic areas and eleven recommended disclosures
- GHG ProtocolCorporate Standard (2004)
The measurement basis UK SRS S2 ¶29(a) requires for Scope 1 and 2.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard (2011)
- Financial Reporting CouncilISSA (UK) 5000 — ¶¶9, 10, 11, 15, 18, 20, 34, 87, 190, 198
Issued 12 November 2025; effective for periods beginning on or after 15 December 2026; binds by representation.