UK SRS legislation: which laws carry it, and which do not

There is no Act of Parliament or statutory instrument that makes UK SRS compulsory.

UK SRS S1 and S2 are standards published by the Department for Business and Trade on 25 February 2026, voluntary for any entity.

The one binding requirement to use them is in FCA listing rules — the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026 — made under the Financial Services and Markets Act 2000, which puts companies listed in five categories on a comply-or-explain basis from 1 January 2027.

The Companies Act 2006 and regulations made under it: the strategic report (section 414A), the non-financial and sustainability information statement and climate-related financial disclosures (sections 414CA and 414CB, inserted for climate by SI 2022/31), and SECR in the directors' report (SI 2008/410 Schedule 7, inserted by SI 2018/1155).

ESOS is separate energy legislation, SI 2014/1643, now amended under the Energy Act 2023.

The non-financial and sustainability information statement.

Section 414CA of the Companies Act 2006 requires it in the strategic report of companies with more than 500 employees that are traded, banking, insurance or AIM companies, or have turnover above £500 million.

Section 414CB sets its contents: environmental, employee, social, human rights and anti-corruption matters for traded, banking and insurance companies, and the eight climate-related financial disclosures in subsection (2A), which also reach AIM and high-turnover companies.

A company outside scope may include one voluntarily.

It is a safe harbour for directors.

A director is liable to the company for an untrue or misleading statement, or an omission, in the strategic report or directors' report only if the director knew the statement to be untrue or misleading, was reckless as to whether it was, or knew the omission to be dishonest concealment of a material fact.

The government's September 2026 consultation says that unless section 463 is expanded, only UK SRS disclosures included in the strategic report are covered.

The small companies exemption from the strategic report.

A company entitled to prepare accounts under the small companies regime, or that would be but for being a member of an ineligible group, is not required to prepare a strategic report — and so is outside the non-financial and sustainability information statement and the climate-related financial disclosures.

Late filing of accounts and reports brings a civil penalty on the company under section 453, from £150 to £1,500 for a private company and £750 to £7,500 for a public one.

Section 451 also makes it an offence for each director not to file on time, with a defence of having taken all reasonable steps.

Nothing 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.

It gives no mechanism, threshold or date, and it does not propose changes to the existing climate-related financial disclosures, which are under a post-implementation review due by spring 2027.

Yes.

The government confirmed in February 2026 that UK SRS S2 is a national reporting framework for the purposes of section 414CB(6), so a company reporting under UK SRS S2 does not need to duplicate its section 414CB(2A) disclosures.