UK SRS · regulators
UK SRS regulations: the regulators, their rules and their powers
UK SRS regulations, in the strict sense, are the FCA’s: one listing rules instrument, made on 24 September 2026.
The standards come from the government, the rules that apply them from the FCA, and review of the reports that contain them from the FRC.
Each has different powers, and none has a sustainability-specific fine.
The bodies
Five bodies, five different jobs
A UK SRS report touches several regulators because it sits in an annual report governed by company law and, for listed companies, by listing rules.
| Body | What it governs | Its powers |
|---|---|---|
| Financial Conduct Authority | The listing rules requiring UK SRS reporting or an explanation | Supervision; penalties under FSMA s.91 |
| Department for Business and Trade (now BIST) | The standards themselves; the Companies Act route | Guidance power only under s.414CB(10); no enforcement role |
| Financial Reporting Council | Review of annual reports; ISSA (UK) 5000 | Court application under CA 2006 s.456, authorised by SI 2021/465 |
| Companies House | Filing of accounts and reports | Late-filing civil penalties under s.453 |
| Environment Agency | ESOS — not UK SRS | Civil penalties under SI 2014/1643 Part 8 |
The FCA is the only body that has made UK SRS reporting a requirement, and only for listed companies.
The government owns the standards and could make them a Companies Act requirement; it says in the Modernising corporate reporting consultation only that it “will consider” doing so.
The FRC neither wrote UK SRS nor enforces it as such; its reach is the annual report and the assurance standard.
Who these rules reach is on UK SRS thresholds, and the private-company position on private companies and UK SRS.
The FCA
The FCA: listing rules made under FSMA
The FCA regulates UK SRS reporting through the listing rules, which it makes under the Financial Services and Markets Act 2000.
The UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026 amends UKLR 6.6, 14.3, 15.3, 16.3 and 22.2 and the ESG sourcebook, and comes into force on 1 January 2027.
The main rule sits in the UK Listing Rules at UKLR 6.6.6R, and the ESG sourcebook already shows a future version from that date.
The basis is comply or explain throughout: the Policy Statement says the rules “adopt a comply or explain approach across the UK SRS”.
The guidance on what a proportionate explanation looks like is still a draft, with comments due by 28 October 2026.
The consultation’s page, CP26/5, still carries the pre-decision wording; the Policy Statement governs.
The FCA’s approach is set out further on the UK SRS timeline.
- 30 Jan 2026CP26/5 published
Closed 20 March 2026.
- 24 Sep 2026Instrument made by the FCA Board
- 30 Sep 2026PS26/19 published
- 19 Oct 2026FCA webinar
- 28 Oct 2026Draft TN 803.1 comments due
- 1 Jan 2027Rules in force
- H2 2027Supervisory information
The FRC
The FRC: review and assurance, not standard-setting
The FRC’s role in UK SRS is narrower than its name suggests.
It published the final recommendations of the UK Sustainability Technical Advisory Committee on 18 December 2024, which fed the government’s endorsement; the standards themselves were published by the Department for Business and Trade.
It reviews annual reports, and SI 2021/465 authorises it to apply to court under section 456 for a defective strategic report to be revised.
It issued ISSA (UK) 5000 for sustainability assurance engagements; no UK entity is required to commission one, and no register of sustainability assurance providers is in operation.
Its sustainability FAQ notes that new ISSB standards would not automatically apply in the UK; the ISSB’s own set is on its Standards Navigator.
The assurance side is on UK SRS assurance.
Its Corporate Reporting Review procedures say it keeps a £2 million legal costs fund, and that it and its predecessors have resolved every case voluntarily, without a court order.
The government
The government: owner of the standards and the Companies Act
The Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026.
Since 20 July 2026 GOV.UK has also carried the department as the Department for Business, Innovation, Science and Trade; the standards’ publisher, on the date they were published, was DBT.
The standards were published as standards, not made as a statutory instrument, and their effective dates were removed so that timing could be set by regulation.
The government’s Companies Act powers are real but unused: section 414CB(10) lets the Secretary of State issue guidance on the climate disclosures, not change them.
Scope for the existing climate disclosures is in section 414CA, and the government response confirmed UK SRS S2 as a national framework for meeting them.
The strategic report itself dates from SI 2013/1970, SECR from SI 2018/1155, and the current company size limits from SI 2024/1303; the whole statute book is on UK SRS legislation.
Enforcement
What happens on a breach, regulator by regulator
| Failure | Who acts | Power | What it can lead to |
|---|---|---|---|
| A listed company neither reports nor explains as the rule requires | FCA | FSMA s.91(1) | A penalty of such amount as the FCA considers appropriate |
| A director knowingly concerned in that breach | FCA | FSMA s.91(2) | A penalty on the director |
| A strategic report that does not comply with the Companies Act | FRC | CA 2006 s.456 | A court order to revise; costs may fall on approving directors |
| Directors approving a non-compliant report | Prosecution | CA 2006 s.419 | A criminal offence where knowledge or recklessness is shown |
| Accounts and reports filed late | Companies House | CA 2006 s.453 | A civil penalty on the company, set by lateness and company type |
The route that matters for UK SRS is section 91, because the obligation is a listing rule.
Section 91(1) lets the FCA impose a penalty on an issuer that has contravened any provision of listing rules; section 91(2) reaches a director knowingly concerned in the contravention.
Section 206 is a different power: it applies to authorised persons, the firms the FCA regulates, not to companies because they are listed.
How the FCA sets the amount is described in its Decision Procedure and Penalties Manual.
Because the rule is comply or explain, a company that explains in the form the rule asks for is complying; the risk is an explanation that does not meet the rule.
Late filing penalties run from £150 to £1,500 for a private company and £750 to £7,500 for a public one, doubled for a second consecutive late year, as set out in Companies House’s guidance.
Section 463 of the Companies Act is a shield, not a sanction: it limits directors’ liability to the company for statements in the strategic report (s.463).
ESOS is enforced by the Environment Agency under SI 2014/1643, which is why it appears on the ESOS pages rather than here.
Not UK SRS
The other FCA regime: the SDR
The FCA’s Sustainability Disclosure Requirements are rules for investment products and the firms that manage them, not for company reporting.
They include four sustainability labels that a firm may not use unless a fund qualifies, and a fund needs at least 70% of its assets invested in line with its sustainability objective.
A listed company’s UK SRS report and a fund’s SDR label share a regulator and a vocabulary, and nothing else.
The standards’ content is on what is UK SRS and the reporting mechanics on UK SRS reporting guidance.
In practice
What a company should take from this
For a listed company, the regulator to read is the FCA, and the text to read is the made rule.
It is annotated clause by clause on UK SRS rules analysed, and the dates for each cohort are on the UK SRS S1 and S2 timeline.
For a private company, no regulator requires UK SRS; the regimes that do bind it are SECR, ESOS and the Companies Act climate disclosures.
A limb-by-limb checklist is on UK SRS compliance, and the sister reference site keeps its own material at uksrs.org.uk.
Frequently asked
Questions people ask
What are the UK SRS regulations?
The only regulations that require anyone to report against UK SRS are the FCA's: the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, made on 24 September 2026 and published in PS26/19 on 30 September 2026.
It requires companies listed in UKLR 6, 14, 15, 16 and 22 to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
UK SRS S1 and S2 themselves are standards, not regulations.
Who regulates UK SRS?
Three bodies, for different things.
The FCA makes and enforces the listing rules that bring UK SRS into listed companies' annual reports.
The Department for Business and Trade published the standards and owns the Companies Act route; its successor for current purposes is the Department for Business, Innovation, Science and Trade.
The FRC reviews annual reports for compliance with the Companies Act and sets the UK sustainability assurance standard, ISSA (UK) 5000.
What can the FCA do if a listed company breaches the UK SRS rules?
Under section 91 of the Financial Services and Markets Act 2000 the FCA may impose a penalty of such amount as it considers appropriate on an issuer that contravenes the listing rules, and on a director knowingly concerned in the contravention.
The rules are comply or explain, so a company that explains in the way the rule requires is complying.
The FCA's penalty policy is in its Decision Procedure and Penalties Manual.
Does section 206 of FSMA apply to UK SRS reporting?
Not to listed companies as such.
Section 206 lets a regulator penalise an authorised person — an FCA-regulated firm — for breaching a relevant requirement.
Listing rule breaches by issuers are penalised under section 91.
Does the FRC enforce UK SRS?
Not directly.
The FRC is authorised under section 456 of the Companies Act to apply to court about defective accounts and reports, which can reach sustainability disclosures in a strategic report.
Its operating procedures say every case so far has been resolved voluntarily, without a court order.
The FRC also issued ISSA (UK) 5000, the assurance standard, but assurance is not required.
Is the FCA's comply-or-explain guidance final?
No. The FCA is consulting on draft Technical Note 803.1, in Primary Market Bulletin 66, with comments due by 28 October 2026, and aims to finalise the guidance before the rules come into force on 1 January 2027.
It has also said it will publish supervisory information in the second half of 2027, ahead of the first reporting season.
Are UK SRS regulations the same as the FCA's SDR?
No. The Sustainability Disclosure Requirements (PS23/16) are FCA rules for investment products and their managers, including four sustainability labels.
The UK SRS rules are listing rules for companies.
The same regulator, a different population.
Will new ISSB standards automatically become UK regulations?
No. The FRC's guidance says new ISSB standards would not automatically apply in the UK; each would need endorsement.
And an endorsed standard binds no one until a regulation or rule requires it.
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; webinar 19 October 2026; supervisory information in the second half of 2027.
- Financial Conduct AuthorityPS26/19 (PDF), ¶¶1.2, 1.9, 3.9, 3.10 and Appendix 1
UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, made 24 September 2026; draft TN 803.1 comments by 28 October 2026.
- Financial Conduct AuthorityFCA Handbook — UK Listing Rules (UKLR)
UKLR 6.6, 14.3, 15.3, 16.3, 22.2 amended.
- Financial Conduct AuthorityFCA Handbook — ESG 2.2
The ESG sourcebook cross-reference, future version from 1 January 2027.
- Financial Conduct AuthorityFCA Handbook — Decision Procedure and Penalties Manual (DEPP)
- Financial Conduct AuthorityCP26/5 landing page
- Financial Conduct AuthorityPS23/16: Sustainability Disclosure Requirements and investment labels
- legislation.gov.ukFinancial Services and Markets Act 2000
- legislation.gov.ukFSMA 2000, section 91 — penalties for breach of Part 6 rules
s.91(1) issuers and applicants; s.91(2) directors knowingly concerned.
- legislation.gov.ukFSMA 2000, section 206 — financial penalties
Authorised persons, not issuers as such.
- legislation.gov.ukCompanies Act 2006
ss.419, 453, 456 and 459.
- legislation.gov.ukCompanies Act 2006, section 414CA
- legislation.gov.ukCompanies Act 2006, section 414CB(10)
The Secretary of State may issue guidance — not make rules.
- legislation.gov.ukCompanies Act 2006, section 463
- legislation.gov.ukSI 2021/465 — the FRC authorised for section 456
In force 6 May 2021.
- legislation.gov.ukSI 2013/1970 — the strategic report
- legislation.gov.ukSI 2018/1155 — SECR
- legislation.gov.ukSI 2024/1303 — company size thresholds
- legislation.gov.ukSI 2014/1643 — ESOS
Enforced by the Environment Agency.
- Financial Reporting CouncilCorporate Reporting Review — operating procedures
£2m legal costs fund; all cases resolved voluntarily.
- Financial Reporting CouncilSustainability reporting developments: frequently asked questions
New ISSB standards "would not automatically apply in the UK".
- Financial Reporting CouncilUK Sustainability TAC issues final recommendations, 18 December 2024
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
- Department for Business and TradeGovernment response to the consultation on UK SRS (web version)
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
- Companies HouseLate filing penalties
- IFRS FoundationIFRS Sustainability Standards Navigator