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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.

The two explain limbs, side by side

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.

Source: UK SRS S2 (DBT, 25 February 2026), read in full 30 September 2026; Annex A of the consultation response for the UK amendments.
UK SRS S2 requirementWhy a TCFD report may not meet itParagraph
Skills and competencies of the oversight bodyS2 asks how the body decides whether the skills exist or will be developed¶6(a)(ii)
Time horizons tied to planning horizonsShort, medium and long term must be defined and linked to strategic planning¶10(d)
Current and anticipated financial effectsQuantitative where possible; otherwise the reasons¶¶15–21
Scenario analysis inputs and assumptionsA structured list: scenarios and sources, range, alignment with the latest international agreement, time horizons, scope¶22(b)
Cross-industry metricsAmounts and percentages of assets vulnerable to transition and physical risk, aligned with opportunities, and capital deployed¶29(b)–(e)
Internal carbon priceWhether and how one is used, and the price per tonne¶29(f)
RemunerationThe percentage of executive remuneration linked to climate considerations¶29(g)
Industry-based metricsMetrics associated with the business model; the SASB guidance is “may” in the UK¶¶32, 12
Targets and carbon creditsHow each target is set and reviewed, and any planned use of carbon credits¶¶33–36
Financed emissionsFor 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)

Source: UK SRS S2 ¶¶29(a), C3.
ItemRequirement
StandardGHG Protocol Corporate Standard (2004)
Scope 2Location-based, with contractual instruments information
Scope 3Categories from the Scope 3 Standard (2011)
First-period reliefAnother 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

Source: FCA PS26/19 ¶¶3.14, 3.18, 3.20, 3.23, 3.24; UK SRS S1 ¶E1, S2 ¶C1. Nothing becomes mandatory when a relief ends: it moves into comply or explain.
Period (from initial application)What must be disclosed or explainedWhat can be stated as relief
Period 1All of UK SRS S2 except Scope 3; S1 climate-related informationScope 3 (one year); S1 beyond climate (two years); no comparatives
Period 2All of UK SRS S2, Scope 3 included; S1 climate-related informationS1 beyond climate
Period 3 onwardsAll of UK SRS S1 and S2None 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

  1. Confirm which regime you are reporting under: the FCA’s rules, voluntary UK SRS, or the Companies Act climate disclosures alone.
  2. List your climate risks and opportunities (S2 ¶10) and, for S1, your other sustainability-related risks and opportunities.
  3. Test each S2 requirement with the checklist on this page, recording evidence for every “can disclose now”.
  4. Decide which reliefs you will state, and remove those items from the explain list.
  5. For each remaining gap, write the reason and the step; the S2 limb sets no deadline for the steps, but they must be real.
  6. Check the draft explanations against the final version of TN 803.1 once the FCA publishes it.
  7. 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.

Checked against 16 sources fromFinancial Conduct AuthorityDepartment for Business and TradeFinancial Reporting CouncilIFRS FoundationTask Force on Climate-related Financial DisclosuresGHG Protocol
  1. Financial Conduct Authority
    PS26/19 — 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.

  2. Financial Conduct Authority
    PS26/19 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.

  3. Financial Conduct Authority
    Draft Technical Note 803.1 (Primary Market Bulletin 66)

    Proposed guidance on proportionate explanations; comments by 28 October 2026.

  4. Financial Conduct Authority
    CP26/5 consultation page

    The consultation the final rules answer.

  5. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 (25 February 2026)

    The publication page for both standards; voluntary for any entity.

  6. Department for Business and Trade
    UK SRS S1 — ¶¶21–24 connected information, ¶¶60–73B location, timing, comparatives and compliance, ¶¶77–86, Appendix E

    Read in full 30 September 2026.

  7. Department for Business and Trade
    UK SRS S2 — ¶¶5–37, Appendix B and Appendix C

    Read in full 30 September 2026.

  8. Department for Business and Trade
    UK SRS consultation response, Annex A — the S1 and S2 difference tables

    IFRS S1 ¶E4 removed; ¶B59A added; reliefs untimed except ¶C3.

  9. Department for Business and Trade
    Government 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.

  10. Financial Reporting Council
    Sustainability Reporting Developments: FAQs (last updated 26 February 2026)
  11. IFRS Foundation
    IFRS S1 — General Requirements for Disclosure of Sustainability-related Financial Information

    The international baseline UK SRS S1 adopts with amendments.

  12. IFRS Foundation
    IFRS S2 — Climate-related Disclosures
  13. Task Force on Climate-related Financial Disclosures
    Recommendations of the TCFD (2017) — the four thematic areas and eleven recommended disclosures
  14. GHG Protocol
    Corporate Standard (2004)

    The measurement basis UK SRS S2 ¶29(a) requires for Scope 1 and 2.

  15. GHG Protocol
    Corporate Value Chain (Scope 3) Standard (2011)
  16. Financial Reporting Council
    ISSA (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.

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