What UK SRS requires
The UK SRS requirements live in two standards published by the Department for Business and Trade on 25 February 2026 for voluntary use1: UK SRS S1, covering general sustainability-related financial disclosures, and UK SRS S2, covering climate.
Both are the UK-endorsed versions of the IFRS Foundation’s IFRS S14 and IFRS S25.
The test that decides what must be disclosed is not “enterprise value” but the effect on cash flows, access to finance or cost of capital — single (financial) materiality, judged by influence on the decisions of primary users of general purpose financial reports6.
A company must report the sustainability and climate risks and opportunities that could reasonably be expected to affect its prospects over the short, medium and long term10.
Two further requirements govern where and when the information appears.
Disclosures must form part of the general purpose financial reports, published at the same time and for the same period as the financial statements — UK SRS S1’s “Connected information” requirement6.
The core disclosure requirements
Both standards are built on the same four pillars, inherited from the Task Force on Climate-related Financial Disclosures5.
Each pillar has an objective and a set of specific disclosures6.
UK SRS S1 applies them to all material topics; UK SRS S2 applies them to climate1.
| Pillar | The requirement, in one line | Go deeper |
|---|---|---|
| Governance | Disclose who oversees sustainability and climate matters, and the controls used. | Four pillars → |
| Strategy | Disclose the effect on business model, strategy and financial planning — including scenario analysis. | Scenario analysis → |
| Risk management | Disclose how risks and opportunities are identified, assessed and integrated. | Four pillars → |
| Metrics & targets | Disclose Scope 1, 2 and 3 emissions, cross-industry metrics and any targets. | Scope 3 → |
For the paragraph-by-paragraph disclosure list under each pillar — including every governance, strategy, risk and metric requirement — see our dedicated four pillars reference5.
This page stays at the level of the requirement categories so you can see the whole obligation at once.
Greenhouse gas & emissions requirements
The most data-intensive requirement sits in the metrics pillar.
UK SRS S2 requires absolute gross greenhouse gas emissions in tonnes of CO₂ equivalent, classified by Scope 1, Scope 2 and Scope 35, measured using the GHG Protocol8.
Scope 3 — value-chain emissions across the 15 GHG Protocol categories — is required where material, and the entity must disclose which categories it includes8.
See our practitioner guide to Scope 3 under UK SRS.
Financial institutions face an additional requirement to disclose financed emissions, with a UK-specific explanation provision (paragraph B59A) added in the final standard3.
Scenario analysis & transition plan requirements
Two strategy-pillar requirements deserve singling out because they drive the most work.
First, climate scenario analysis is a hard requirement, not a recommendation, where climate risk is material — and at least one scenario must align with the latest international agreement on climate change5.
Second, where a company has a climate transition plan, it must disclose the plan’s targets, actions and the resources and assumptions it depends on5.
Who must meet the requirements — and when
The standards are voluntary today9.
Mandatory application is being phased in through the FCA’s CP26/5 proposals, which would replace the TCFD-aligned Listing Rules for accounting periods beginning on or after 1 January 20272.
| Requirement | Who | From | Basis |
|---|---|---|---|
| UK SRS S2 climate (excluding Scope 3) | 515 primary-listed companies of ~600 affected (UKLR 6, 16, 22) | FY beginning on/after 1 Jan 2027 | Mandatory (proposed) |
| Scope 3 emissions | Same in-scope companies | FY beginning on/after 1 Jan 2028 | Comply-or-explain (proposed 1-year relief) |
| UK SRS S1 (non-climate) | Same in-scope companies | FY beginning on/after 1 Jan 2029 | Comply-or-explain (proposed 2-year relief) |
| Signposting statement only, not UK SRS | 89 companies listed only in secondary listing or depositary receipts categories (UKLR 14, 15) | FY beginning on/after 1 Jan 2027 | State home-jurisdiction standard (proposed) |
For a calendar-year reporter, a 2027 start means the first UK SRS-aligned report appears in 20282.
Use our who must comply and UK SRS timeline references to check your own position.
Overseas issuers with a UK secondary listing, and UK subsidiaries of foreign parents, face scope questions the table above doesn't capture — see our overseas companies and UK SRS guide for the three common scenarios.
How UK SRS departs from IFRS S1 and S2
UK SRS is near-identical to IFRS S1 and S210.
The UK government consulted on six proposed amendments in June 2025; the final Standards differ from IFRS S1 and S2 as set out in Annex A of the government response, which carries no overall count3.
| UK amendment | Effect on the requirements |
|---|---|
| Effective date removed | No fixed start date in the standard; timing is set by UK legislation or FCA rules, so reliefs are not time-limited within the text. |
| Climate-first exception carries no time limit | UK SRS S1 ¶E3 permits an entity to disclose climate-related information only, for as long as it chooses — not a mandated S2-before-S1 phasing order. |
| SASB “shall” → “may” | Use of SASB industry-based metrics becomes optional, not mandatory. |
| Delayed-reporting relief removed | Sustainability disclosures must be published with the financial statements, in step with the Standard’s "Connected information" requirements (¶¶21–24). |
| Financed emissions clarified (B59A) | A UK explanation requirement is added for financial institutions reporting financed emissions. |
The most consequential for reporting teams is the removal of the delayed-reporting relief: sustainability disclosures must now be published with the accounts, not afterwards3.
Assurance requirements
UK SRS does not yet require external assurance.
Under CP26/5 the FCA proposes a disclose-or-explain approach: a company must state whether its disclosures have been assured and give details2.
To support quality, the FRC published ISSA (UK) 5000, a voluntary UK sustainability assurance standard, in November 20257.
It covers both limited and reasonable assurance and is effective for engagements covering periods beginning on or after 15 December 20267.
See our UK SRS assurance and ISSA (UK) 5000 references.
How the requirements compare to other frameworks
Companies already reporting under the old TCFD-aligned Listing Rules are not starting from zero — but the UK SRS requirements are tighter5.
| Area | TCFD (old Listing Rules) | UK SRS requirement |
|---|---|---|
| Quantified financial effects | Encouraged | Required, with limited relief where measurement is highly uncertain |
| Scenario analysis | Recommended | Required where climate risk is material |
| Scope 3 emissions | Recommended where material | Required where material (comply-or-explain with relief) |
| Same-time publication (“Connected information”) | Not required | Required — same time and period as the accounts (UK SRS S1 ¶¶21–24) |
For the detail, compare UK SRS vs TCFD and UK SRS vs CSRD.
The ICAEW’s overview is a useful practitioner summary of the same shift10.
Frequently asked questions
What are the UK SRS requirements?
UK SRS requirements are the disclosure rules in two standards: UK SRS S1 (general sustainability-related financial disclosures) and UK SRS S2 (climate-related disclosures).
Both require information across four pillars — governance, strategy, risk management, and metrics and targets — about the sustainability and climate risks and opportunities that could reasonably affect a company’s cash flows, access to finance or cost of capital.
DBT published the standards on 25 February 2026 for voluntary use.
What must a UK SRS report actually contain?
At minimum: governance of sustainability and climate matters; the strategic and financial effects of material risks and opportunities (including climate scenario analysis); the processes used to manage them; and metrics and targets, including Scope 1, 2 and 3 greenhouse gas emissions measured on the GHG Protocol.
The information must form part of the general purpose financial reports and be published at the same time as the financial statements.
Is Scope 3 a UK SRS requirement?
Yes, where material — but with relief.
UK SRS S2 requires Scope 1, 2 and 3 emissions.
Under the FCA’s CP26/5 proposals, Scope 1 and 2 are required from the first reporting period, while Scope 3 is comply-or-explain with a one-year transitional relief, becoming required for accounting periods beginning on or after 1 January 2028.
Who has to meet the UK SRS requirements?
The standards do not set scope.
Under the FCA’s proposed Listing Rules (CP26/5), 515 primary-listed companies — of around 600 affected overall — in UK Listing Rules categories 6, 16 and 22 would be required to comply with UK SRS S2 for accounting periods beginning on or after 1 January 2027.
The remaining 89, listed only in the secondary listing or depositary receipts categories (UKLR 14, 15), would instead make a signposting statement about the overseas or voluntary standards they follow, not a UK SRS disclosure.
A separate consultation on large private companies is expected.
How are the UK SRS requirements different from IFRS S1 and S2?
UK SRS is near-identical to IFRS S1 and S2.
The UK government consulted on six proposed amendments in June 2025, but the final Standards don’t map one-to-one onto that list: the fixed effective date is removed; the climate-first exception (UK SRS S1 paragraph E3) carries no time limit; SASB references move from “shall” to “may”; the relief to publish sustainability disclosures after the financial statements is removed; and a UK financed-emissions explanation (paragraph B59A) is added.
GICS classification was never a UK amendment — the ISSB itself dropped that requirement globally in December 2025, before UK SRS was finalised.
The government response’s Annex A is the authoritative map of the final differences and carries no overall count.
Do the UK SRS requirements include mandatory assurance?
Not yet.
Under CP26/5 the FCA proposes a disclose-or-explain approach — companies must state whether disclosures are assured.
The FRC published ISSA (UK) 5000, a voluntary UK sustainability assurance standard, in November 2025, effective for engagements covering periods beginning on or after 15 December 2026.