UK SRS reporting guidance · the mechanics
UK SRS reporting guidance: where it sits, when it is due, what it says
This UK SRS reporting guidance deals with the mechanics: where each disclosure may be placed, when it must be published, and which statements the annual report carries under the FCA’s final rules.
The standards themselves are voluntary for any entity.
For a listed company in UKLR 6, 14, 15, 16 or 22 they apply on a comply-or-explain basis from accounting periods beginning on or after 1 January 2027.
Location
Where UK SRS disclosures may sit
UK SRS disclosures are not a free-standing document.
UK SRS S1 ¶60 makes them part of an entity’s general purpose financial reports, the same family of reports as the financial statements.
Paragraph 62 lets them share a location with information required by regulators, as long as they stay clearly identifiable and are not obscured by the additional material.
Paragraph 63 lets information be included by cross-reference to another report the entity publishes.
The conditions sit in Appendix B: the cross-referenced material must be available on the same terms and at the same time, and the complete set must not become less understandable (B45).
Whatever is brought in by cross-reference becomes part of the disclosures and must meet the standards in full (B46).
For listed companies the FCA turned this into a statement: the annual financial report says where the disclosures can be found, noting that they may be cross-referenced as B45 to B47 allow (UKLR 6.6.6R(8)(c)).
In its response to feedback the FCA kept the requirement for climate disclosures and explanations, Scope 3 included, to be in the annual report, with cross-referencing only where UK SRS S1 permits it.
Choose the location in the panel and it returns the rule that governs it, the FCA statement, and whether the directors’ safe harbour in section 463 applies.
The directors’ side of that choice is worked through on UK SRS for boards.
Placement check · one disclosure at a time
- PermittedInside the general purpose financial reportsUK SRS disclosures are part of general purpose financial reports; they may share a location with other required information if they stay clearly identifiable.UK SRS S1 ¶¶60–62
- Final ruleState where the disclosures can be foundThe annual financial report says where the UK SRS disclosures are; cross-reference to another published report is allowed under UK SRS S1 B45–B47.UKLR 6.6.6R(8)(c); FCA response after PS26/19 ¶2.24
- Safe harbour appliesDirectors’ liability for this statement is limited by s.463A director is liable only to the company, and only on knowledge, recklessness or dishonest concealment. It does not touch civil penalties or criminal offences.CA 2006 s.463(1)–(4), (6); DBT response Ch.3; MCR consultation ¶160
- Companies ActClimate-related financial disclosures in the non-financial and sustainability information statementA company within s.414CA must include them; UK SRS S2 is confirmed as a national reporting framework, so S2 disclosures can meet the duty without duplicating them.CA 2006 s.414CB(A1), (6); DBT UK SRS response Ch.3
Indicative, not advice.
Location, cross-reference and liability are legal questions for your advisers; this tool only points to the provision.
Nothing you enter leaves your browser.
The annual report map
Which part of the annual report carries what
The standard does not prescribe section headings, so this is a map of where each pillar usually lands and the provision that allows it — not a template the regulator has issued.
| Annual report section | UK SRS content that commonly lands here | The provision that governs it |
|---|---|---|
| Strategic report — business model and strategy | Effects on the business model and value chain (S2 ¶13); response in strategy and decision-making, including any transition plan (S2 ¶14) | CA 2006 s.414A; UK SRS S1 ¶¶60–62 |
| Strategic report — principal risks | Risk management: how climate risks are identified, assessed, prioritised and monitored (S2 ¶25) | UK SRS S2 ¶¶24–26; S1 ¶62 on shared locations |
| Strategic report — resilience and outlook | Scenario analysis and the resilience assessment (S2 ¶22) | UK SRS S2 ¶22 and B1–B18 |
| Non-financial and sustainability information statement | Climate-related financial disclosures; UK SRS S2 may be named as the framework used | CA 2006 s.414CB(A1), (2A), (6) |
| Corporate governance report | Governance: the body overseeing climate risks and management’s role (S2 ¶6) | UK SRS S1 ¶63 cross-reference; UK Corporate Governance Code 2024 |
| Metrics section or KPI pages | Scope 1, 2 and 3 emissions, cross-industry metrics, targets (S2 ¶¶29–36) | UK SRS S2 ¶¶27–37 |
| Notes to the financial statements | Where climate affects carrying amounts, estimates or going concern — connected information | UK SRS S1 ¶¶21–24, B39–B44 |
| A separate sustainability report | Any of the above, brought in by cross-reference | UK SRS S1 ¶63, B45–B47; UKLR 6.6.6R(8)(c) |
The Companies Act route
The NFSIS and section 414CB(6)
The NFSIS is the non-financial and sustainability information statement, a part of the strategic report that sections 414CA and 414CB of the Companies Act 2006 require.
Section 414CB(A1) is the limb that imposes the duty: the statement “must contain the climate-related financial disclosures of the company”.
Subsection (2A) defines what those disclosures are, in eight items from governance to key performance indicators.
Subsection (6) lets a company that publishes the information through a national, EU-based or international reporting framework name that framework instead of repeating the information.
The government confirmed in its response on UK SRS, Chapter 3, that UK SRS S2 is a national reporting framework for section 414CB(6), so companies reporting under S2 need not duplicate their disclosures.
That confirmation covers S2, not S1.
The modernising corporate reporting consultation says the climate-related financial disclosure requirements are under a post-implementation review due by spring 2027, and it proposes nothing about their future.
The scope test is at section 414CA; the wider scope question is on UK SRS thresholds.
Who must include climate-related financial disclosures
| Section 414CA reaches | Condition |
|---|---|
| Traded, banking and insurance companies, and AIM companies | More than 500 employees |
| High turnover companies | Turnover above £500 million and more than 500 employees |
Timing
When the first report is due, year-end by year-end
UK SRS S1 ¶64 is short and absolute: the disclosures are reported at the same time as the related financial statements and cover the same period.
IFRS S1 gave a first-year relief to publish later; the UK removed it (Annex A, IFRS S1 ¶E4).
For a listed company the clock is the annual financial report, which DTR 4.1.3R requires to be public at the latest four months after the year-end.
The FCA’s rules apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028 (PS26/19 ¶3.12).
A company with a year starting part-way through 2026 may keep the TCFD-aligned rules for that year, or adopt UK SRS early and still use the same reliefs (¶3.19).
The reliefs, and how long each lasts
The FCA gives two: one year of non-disclosure of Scope 3 emissions under UK SRS S2, and two years of climate-only reporting under UK SRS S1 (¶3.14).
A company using either states that it is doing so, and no further explanation is required during the relief period (¶3.20).
The standards add two of their own: no comparatives in the first period (UK SRS S2 ¶C1, S1 ¶E1), and another GHG measurement method in the first period if it was used immediately before (S2 ¶C3).
When a relief ends, nothing becomes mandatory — the disclosure moves into the ordinary comply-or-explain limb (¶¶3.23–3.24).
The dated sequence, from TAC advice to first reports, is on the UK SRS timeline, and the date for each listing category is on UK SRS deadline.
First-report planner · listed company in scope
- Period 1First UK SRS period: 1 January 2027 to 31 December 2027Report against UK SRS S1 and S2 or explain. No comparatives are needed for the first period in which UK SRS is applied. Scope 3 relief available; UK SRS S1 non-climate relief available; another GHG measurement method allowed only if this is the first period of application and it was used immediately before.PS26/19 ¶¶3.12, 3.14, 3.16; UK SRS S1 ¶E1; UK SRS S2 ¶¶C1, C3
- PublishAnnual financial report public by the end of April 2028UK SRS disclosures are reported at the same time as the financial statements and for the same period — the delayed-reporting relief in IFRS S1 ¶E4 does not exist in UK SRS S1.DTR 4.1.3R; UK SRS S1 ¶64; Annex A (IFRS S1 ¶E4 removed)
- Period 21 January 2028 to 31 December 2028The Scope 3 relief has expired: disclose Scope 3 or explain. Comparatives now required for amounts disclosed in the prior period.PS26/19 ¶3.23; UK SRS S1 ¶70
- Period 31 January 2029 to 31 December 2029The UK SRS S1 climate-first relief has expired: comply or explain on everything. Nothing becomes mandatory when a relief ends.PS26/19 ¶3.24
- Assurance, if obtainedISSA (UK) 5000 is effective for every period aboveIt applies to engagements on periods beginning on or after 15 December 2026, earlier application permitted. Obtaining assurance is not required; the annual report states whether it was obtained.ISSA (UK) 5000 ¶15; UKLR 6.6.6R(8)(d)
Assumes twelve-month periods ending on a month-end.
A shortened or extended period moves the dates: the test is the first period beginning on or after 1 January 2027.
Indicative, not advice; nothing you enter leaves your browser.
What the annual report says
The statements the FCA’s rules require
The made rule is UKLR 6.6.6R, with equivalents in UKLR 14, 15, 16 and 22. It asks for disclosures or an explanation, then three statements.
| Limb | What it asks | Who it applies to |
|---|---|---|
| (7A) UK SRS S2 | Climate disclosures under UK SRS S2 — or a summary of the requirements not met, the reasons, and any steps taken or planned | All five categories |
| (7B) UK SRS S1 | Other sustainability disclosures under UK SRS S1 — or the risks and opportunities not disclosed and the reasons | All five categories |
| (8)(c) Location | Where the disclosures can be found; cross-reference as S1 B45–B47 allows | All five categories |
| (8)(d) Assurance | Whether third-party assurance was obtained and, if so, the provider, what was assured and to what level, the standards, and where the report is | All five categories |
| (8)(e) Transition plan | Whether a climate-related transition plan is published and where — or why not | UKLR 6, 16 and 22 only |
| Relief statement | That a Scope 3 or climate-first relief is being used — no further explanation | Any company using a relief |
The two “explain” limbs are shaped differently: for S2 the explanation works requirement by requirement, for S1 it works risk by risk (UKLR 6.6.6R(7A)(b), (7B)(b)).
The S2 limb asks for the steps a company is taking or plans to take, but sets no timeframe for them.
What a proportionate explanation contains is the subject of draft Technical Note 803.1, out for comment until 28 October 2026 through Primary Market Bulletin 66.
It is proposed guidance, not a final rule.
A separate test governs the word “compliance”: UK SRS S1 ¶72 allows an explicit and unreserved statement of compliance only when every requirement is met.
A company using the climate-first relief may not assert compliance with UK SRS S1, but may still assert compliance with UK SRS S2 if it discloses its use of the reliefs alongside (¶73A).
A calculator that works these statements out for one company and one period is on the UK SRS compliance calculator.
Connected information
Tying the disclosures to the accounts
UK SRS S1 ¶20 requires the disclosures to be for the same reporting entity as the related financial statements.
Paragraphs 21 to 24 then require the connections to be visible to a reader, not just true in the working papers.
The connection that matters most is between the climate narrative and the numbers in the accounts: impairment tests, useful lives, provisions and going concern.
Where the disclosures use an assumption the accounts do not, a reader should be able to see the difference and why it exists.
The practical consequence is organisational: the finance team that prepares the accounts and the team that prepares the climate disclosures need a shared set of assumptions before either document is drafted.
Periods, events and errors
Paragraph 65 expects a 12-month period but allows a 52-week year; paragraph 66 sets out what to say when a period is longer or shorter.
Paragraphs 67 and 68 deal with information received after the year-end but before the disclosures are authorised: update for conditions that existed at the date, and disclose later events that could influence users.
Paragraph 70 requires comparatives for all amounts after the first period, and paragraphs 83 to 86 deal with correcting prior-period errors.
How materiality decides what goes in at all is on UK SRS S1 materiality, and the paragraph-by-paragraph content of the general requirements is on UK SRS S1.
¶21 — connections between risks, between pillars, and across to the financial statements.
¶22 — name the financial statements the disclosures relate to.
¶23 — use data and assumptions consistent with the financial statements, to the extent possible.
¶24 — use the same presentation currency.
Interim, tagging and assurance
Three questions the standards answer narrowly
Interim reporting
UK SRS S1 ¶69 says the standard does not mandate which entities provide interim sustainability disclosures, how often, or how soon after the period end.
If a company is required, or chooses, to publish interim UK SRS disclosures, B48 applies: they update the latest annual set, focus on new information, and may be more condensed.
The FCA’s rules sit in the annual financial report provisions of UKLR 6.6, so the obligation they create is annual.
Digital tagging
The IFRS Foundation publishes the IFRS Sustainability Disclosure Taxonomy so that companies can tag information prepared under ISSB Standards and make it machine-readable.
The Foundation says in terms that the taxonomy neither introduces new requirements nor affects a company’s compliance with its standards.
UK SRS contains no tagging requirement of its own; any tagging duty comes from the electronic-format rules for the annual financial report, which your advisers should confirm.
Assurance
No UK law or rule requires sustainability disclosures to be assured.
The FCA asks only for a statement of whether assurance was obtained, and if so over what, by whom, to what level and under which standards (UKLR 6.6.6R(8)(d)).
Where assurance is commissioned, ISSA (UK) 5000 is effective for periods beginning on or after 15 December 2026, which covers every period the FCA’s rules reach.
The assurance statement, the levels and the standard are on UK SRS assurance.
Inside the company
The preparation process and who signs it off
UK SRS disclosures inside the strategic report are approved with it.
The strategic report is required by section 414A and must be approved by the board and signed on its behalf.
The FRC’s Guidance on the Strategic Report, re-issued in February 2026, sets out its expectations for a coherent narrative rather than a set of appended disclosures.
For companies under the UK Corporate Governance Code 2024, Provision 29 has applied since financial years beginning on or after 1 January 2026.
It asks the board to declare the effectiveness of material controls, and the FRC says those controls extend to narrative and ESG reporting.
The Code itself deliberately contains no sustainability reporting requirement; the FRC says one would have duplicated the Companies Act and listing rules.
The FRC’s sustainability reporting FAQs record that voluntary users may use the UK SRS reliefs without a time limit.
The board’s own questions are on UK SRS for boards, and a requirement-by-requirement gap review is on UK SRS gap analysis.
- PlanningScope, reliefs and locations agreed
Which limbs you will comply with, which you will explain, which reliefs you will state.
- Year-endData closed with the accounts
Same entity, same period, consistent assumptions — S1 ¶¶20–24, 64.
- DraftingDisclosures and statements drafted
Including the (7A)/(7B) explanations and the (8)(c)–(e) statements.
- ApprovalBoard approves the strategic report
CA 2006 s.414D; Provision 29 declaration where the Code applies.
- ≤ 4 monthsAnnual financial report public
DTR 4.1.3R.
What is still moving
Open consultations and draft guidance
| Item | Status on 1 October 2026 | Source |
|---|---|---|
| Draft TN 803.1 — what an explanation should contain | Consultation; comments by 28 October 2026 | FCA PMB 66 |
| FCA webinar on the final rules | 19 October 2026 | PS26/19 page |
| FCA supervisory information for the first season | Second half of 2027 | PS26/19 page |
| Modernising corporate reporting | Consultation, closes 30 November 2026; government “will consider” how UK SRS is reflected in the Companies Act | DBIST |
| Climate-related financial disclosure PIR | Due to be completed by spring 2027 | MCR ¶148 |
| Directors’ report | Proposed for abolition; no instrument laid | HCWS973 |
The modernising corporate reporting programme was announced by Written Ministerial Statement HCWS973 on 21 October 2025.
The September 2026 consultation proposes a simpler strategic report and the abolition of the directors’ report; it does not propose UK SRS requirements for any company.
It restates that the section 463 safe harbour covers only UK SRS disclosures inside the strategic report unless section 463 is widened (¶160).
A private company’s position is set out on private companies and UK SRS.
Sustainability reporting guidelines
A preparation checklist, in the order the rules bite
These are the sustainability reporting guidelines a UK listed company works to, reduced to the order in which each provision bites.
- Confirm scope: your listing category decides whether the FCA’s rules apply at all — see UK SRS thresholds and the FCA’s UK SRS rules.
- Identify your first period beginning on or after 1 January 2027, and whether you will adopt early (PS26/19 ¶¶3.12, 3.19).
- List what the standards require — UK SRS requirements and UK SRS S2 — and mark what you can disclose now.
- Decide which reliefs you will use and draft the relief statements (¶¶3.14, 3.20).
- Draft the (7A) and (7B) explanations for what remains: requirements for S2, risks and opportunities for S1.
- Map every disclosure to a location and test each cross-reference against S1 B45–B47.
- Reconcile the assumptions with the financial statements (S1 ¶¶21–24).
- Decide whether to commission assurance; either way, draft the (8)(d) statement.
- Draft the (8)(e) transition-plan statement if you are in UKLR 6, 16 or 22.
- Take the whole set through the board with the strategic report, within the DTR 4.1.3R four months.
The same steps, as a longer programme, are on the UK SRS compliance guide; the frameworks behind them are compared on sustainability reporting frameworks.
For the wider picture of what UK companies report and why, see sustainability reporting, and for the standards as a pair, the UK SRS hub.
Software that collects the data and drafts disclosures is compared on sustainability software.
If you want to talk your placement or timing through, you can book a free 15-minute call.
Frequently asked
Questions people ask
Where do UK SRS disclosures go in the annual report?
UK SRS S1 makes the disclosures part of general purpose financial reports and lets them share a location with other required information, provided they stay clearly identifiable (¶¶60–62).
For a listed company in scope of the FCA’s rules, the annual financial report must say where the UK SRS disclosures can be found, and cross-reference to another report is allowed as UK SRS S1 B45–B47 permits (UKLR 6.6.6R(8)(c)).
Most companies place them in the strategic report, because that is where the s.414CB climate disclosures already sit and where the s.463 safe harbour applies.
Can UK SRS disclosures be published after the financial statements?
No. UK SRS S1 ¶64 requires the disclosures to be reported at the same time as the related financial statements and for the same period.
IFRS S1 ¶E4 allowed a first-year delay; the UK removed it.
Cross-referenced material must also be available on the same terms and at the same time (B45(a)).
Do I need a separate sustainability report?
No. Nothing in UK SRS or the FCA’s rules requires one.
A company may publish one and cross-reference into it, provided it is available at the same time and on the same terms as the annual report and the complete set is not made less understandable (UK SRS S1 ¶63, B45–B46).
What is the NFSIS?
The non-financial and sustainability information statement is the part of the strategic report required by sections 414CA and 414CB of the Companies Act 2006.
Since periods beginning on or after 6 April 2022 it must contain climate-related financial disclosures for companies in scope of s.414CA.
The government has confirmed UK SRS S2 is a national reporting framework for s.414CB(6), so S2 disclosures can meet that duty without duplication.
What reliefs are available in the first year?
Under the FCA’s rules, a one-year relief from disclosing Scope 3 emissions and a two-year relief allowing climate-only reporting under UK SRS S1 (PS26/19 ¶3.14).
UK SRS itself also allows no comparatives in the first period (S1 ¶E1, S2 ¶C1) and another GHG measurement method in the first period if it was used immediately before (S2 ¶C3).
A company using a relief states that it is doing so; no further explanation is needed during the relief period (¶3.20).
Does UK SRS require interim sustainability reporting?
No. UK SRS S1 ¶69 says the standard does not mandate which entities provide interim disclosures, how often or how soon.
If a company is required, or chooses, to publish interim UK SRS disclosures, B48 applies: they update the latest annual set and focus on new information.
Do UK SRS disclosures have to be tagged in iXBRL?
UK SRS itself contains no tagging requirement.
The IFRS Foundation publishes the IFRS Sustainability Disclosure Taxonomy as a tagging vocabulary and says it neither introduces new requirements nor affects compliance with its standards.
Check your annual financial report’s electronic-format obligations with your advisers.
Is sustainability reporting mandatory in the UK?
Some of it is.
SECR, ESOS and the Companies Act climate-related financial disclosures bind companies in their scope.
UK SRS is voluntary for any entity, and from accounting periods beginning on or after 1 January 2027 listed companies in UKLR 6, 14, 15, 16 and 22 must report against it or explain why not.
How do I prepare a sustainability report in the UK?
Establish which regimes bind you, then build the report inside the annual reporting cycle: identify risks and opportunities, map each disclosure to its location, connect the figures to the financial statements, apply any reliefs you are entitled to and draft the statements the rules require.
The checklist on this page follows that order, provision by provision.
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 AuthorityPrimary Market Bulletin 66 — draft Technical Note 803.1, comments by 28 October 2026
Proposed guidance on what a proportionate explanation contains. Not final.
- Financial Conduct AuthorityCP26/5 — the consultation PS26/19 finalises (PDF)
Cited only for what was proposed.
- Financial Conduct AuthorityCP26/5 consultation page
- Financial Conduct AuthorityFCA Handbook, DTR 4.1.3R — annual financial report public within four months
- Financial Conduct AuthorityFCA Handbook — UK Listing Rules
- 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 — ¶¶20–24 (reporting entity, connected information), ¶¶60–73A (location, timing, comparatives, compliance), ¶¶83–86, B45–B48, Appendix E
Read in full 30 September 2026.
- Department for Business and TradeUK SRS S2 — ¶¶C1–C6 (application and transition)
- 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.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation, 7 September to 30 November 2026
¶¶147–161: CFD requirements under review, s.414CB(6), s.463 follows the strategic report.
- UK ParliamentWritten Ministerial Statement HCWS973, 21 October 2025 — modernising corporate reporting
- legislation.gov.ukCompanies Act 2006, s.414A — duty to prepare a strategic report
- legislation.gov.ukCompanies Act 2006, s.414CA — who must include climate-related financial disclosures
Traded, banking, insurance, AIM or over £500m turnover, and more than 500 employees.
- legislation.gov.ukCompanies Act 2006, s.414CB — (A1) the duty, (2A) the eight disclosures, (6) national frameworks
- legislation.gov.ukCompanies Act 2006, s.463 — liability for false or misleading statements in reports
Liability to the company only, and only on knowledge, recklessness or dishonest concealment.
- Financial Reporting CouncilSustainability Reporting Developments: FAQs (last updated 26 February 2026)
- Financial Reporting CouncilGuidance on the Strategic Report (February 2026)
- Financial Reporting CouncilUK Corporate Governance Code 2024 — Provision 29 from 1 January 2026
A board declaration on material controls, including narrative and ESG reporting controls.
- 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.
- IFRS FoundationIFRS Sustainability Disclosure Taxonomy
A tagging vocabulary; it “neither introduces new requirements nor affects a company’s compliance”.
Continue reading
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