UK SRS · requirements
UK SRS requirements: what a report must contain
The UK SRS requirements are the disclosures in two standards: UK SRS S1 for sustainability-related risks generally, and UK SRS S2 for climate.
Both are organised under the same four areas — governance, strategy, risk management, and metrics and targets.
For listed companies, the FCA’s final rules add a comply-or-explain frame and three short statements.
Structure
Four areas, two standards
Every UK SRS requirement sits in one of four areas, and both standards use the same four.
UK SRS S1 paragraph 25 lists them: governance, strategy, risk management, and metrics and targets, the last including “progress towards any targets the entity has set or is required to meet by law or regulation”.
UK SRS S1 sets the general requirements and applies to every sustainability topic; UK SRS S2 sets the climate requirements that sit inside that frame.
The four areas come from the TCFD, and their history is on the four pillars of UK SRS and UK SRS vs TCFD.
The standards are voluntary for any entity; who must report against them is on UK SRS thresholds.
| Core content area | UK SRS S1 | UK SRS S2 |
|---|---|---|
| Governance | UK SRS S1 ¶¶26–27 | UK SRS S2 ¶¶5–7 |
| Strategy | UK SRS S1 ¶¶28–42 | UK SRS S2 ¶¶8–23 |
| Risk management | UK SRS S1 ¶¶43–44 | UK SRS S2 ¶¶24–26 |
| Metrics and targets | UK SRS S1 ¶¶45–53 | UK SRS S2 ¶¶27–37 |
UK SRS S1
UK SRS S1: the general requirements
UK SRS S1 decides what is in scope of a report before anything is written.
Paragraph 3 requires disclosure of all sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s cash flows, its access to finance or cost of capital over the short, medium or long term.
Paragraph 18 makes information material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users of general purpose financial reports make on the basis of those reports.
The test is not “enterprise value”, a phrase that appears in neither standard.
The disclosures cover the same reporting entity as the financial statements, and paragraphs 21 to 24 require them to connect to those statements, with consistent data, assumptions and currency.
Paragraph 62 allows the disclosures to sit alongside other information if they are clearly identifiable, and paragraph 63 allows cross-reference to another report on the conditions in B45 to B47.
The UK removed IFRS S1’s first-year option to publish the disclosures after the financial statements, and its effective date; the materiality judgement is worked through on UK SRS S1.
The tests S1 turns on
| Paragraph | What it sets |
|---|---|
| ¶3 | Risks and opportunities that could affect cash flows, access to finance or cost of capital |
| ¶18 | Material if omitting, misstating or obscuring it could influence primary users’ decisions |
| ¶B19 | No quantitative threshold for materiality |
| ¶20 | Same reporting entity as the financial statements |
| ¶¶21–24 | Connected information, including currency and assumptions |
| ¶¶60–63 | Location; cross-reference permitted |
| ¶¶72–73A | The statement of compliance |
UK SRS S2
UK SRS S2: the climate disclosures
UK SRS S2 asks four things before it asks for a number.
Paragraph 10 of UK SRS S2 requires an entity to describe its climate-related risks and opportunities, classify each risk as physical or transition, say over which time horizon each could occur, and explain how it defines short, medium and long term.
The last two limbs are the ones most often left out, and the fourth ties the horizons to the entity’s own planning horizons.
Paragraph 22 requires a climate resilience assessment using scenario analysis: the implications for strategy, the significant uncertainties, and the capacity to adapt, plus the inputs and assumptions used.
The depth of scenario analysis scales with the entity’s circumstances; the practice is on climate scenario analysis under UK SRS.
UK SRS S2’s body paragraphs keep the IFRS S2 numbering, so a reference to paragraph 22 means the same text in both; the appendices were renumbered, and there the standard must always be named.
The whole standard is on UK SRS S2.
Metrics
The seven cross-industry metric categories, paragraph 29
Every entity reporting under UK SRS S2 discloses information on all seven categories, alongside any industry-based metrics it chooses to consider.
| Paragraph | Category | What is disclosed |
|---|---|---|
| 29(a) | Greenhouse gases | Absolute gross Scope 1, 2 and 3 in tCO₂e; Scope 2 location-based; Scope 3 categories; financed emissions for asset management, banking and insurance |
| 29(b) | Transition risks | Amount and percentage of assets or business activities vulnerable to them |
| 29(c) | Physical risks | Amount and percentage of assets or business activities vulnerable to them |
| 29(d) | Opportunities | Amount and percentage of assets or business activities aligned with them |
| 29(e) | Capital deployment | Capital expenditure, financing or investment deployed towards climate risks and opportunities |
| 29(f) | Internal carbon prices | Whether and how a carbon price is used in decisions, and the price per tonne |
| 29(g) | Remuneration | Whether and how climate is factored into executive pay, and the percentage linked to it |
Greenhouse gases come first and carry the most detail: absolute gross Scope 1, 2 and 3 emissions, measured under the GHG Protocol Corporate Standard unless a jurisdictional authority or exchange requires otherwise.
Scope 3 disclosure names the categories included, from the fifteen in the Scope 3 Standard; the detail is on Scope 3 under UK SRS.
Internal carbon prices are a metric, not a strategy item: paragraph 29(f) is framed “whether and how”, so an entity that uses none still has something to say.
For financial institutions, paragraph B59A requires an explanation where financed emissions cannot be estimated for the same period as the financial statements.
UK text
Where the UK requirements differ from IFRS
UK SRS is IFRS S1 and IFRS S2 endorsed with a short list of changes.
Annex A of the government response says that where a requirement is not in its table, “there are no differences between the two”, so the table is complete.
It gives no count, and a count of UK “amendments” is not something the government published for the final standards.
The FRC summarises B59A: an entity unable to disclose financed emissions in line with UK SRS S2 must explain why, including the measurement approach taken.
The line-by-line comparison is on UK SRS vs IFRS S1 and S2, and against the EU set on UK SRS vs CSRD.
| Change | Direction |
|---|---|
| SASB and industry guidance: "shall" to "may" | Permissive |
| Effective dates removed | Timing left to law or regulation |
| Climate-first and Scope 3 reliefs untimed | Permissive |
| First-year late publication (IFRS S1 ¶E4) | Not carried over |
| Financed-emissions explanation, ¶B59A | Stricter |
Listed companies
What the FCA adds for listed companies
From accounting periods beginning on or after 1 January 2027, a company listed in UKLR 6, 14, 15, 16 or 22 meets the requirements above or explains, under a frame the FCA wrote.
| Rule | What the annual financial report contains |
|---|---|
| UKLR 6.6.6R(7A) | UK SRS S2 disclosures, or a summary of the requirements not met, the reasons, and the steps planned |
| UKLR 6.6.6R(7B) | UK SRS S1 disclosures on identified risks and opportunities, or an explanation |
| UKLR 6.6.6R(8)(c) | Where the disclosures are; cross-reference permitted under UK SRS S1 ¶¶B45–B47 |
| UKLR 6.6.6R(8)(d) | Whether assurance was obtained; if so, the provider, what was assured and to what level, and the standards |
| UKLR 6.6.6R(8)(e) | Whether a climate-related transition plan is published, and where, or why not |
| UKLR 6.6.6A G | Guidance on which UK SRS S1 paragraphs are relevant to the climate disclosures |
None of it is mandatory in the strict sense: PS26/19 paragraph 1.2 says the rules “adopt a comply or explain approach across the UK SRS”.
The consultation had proposed mandatory UK SRS S2 disclosures, excluding Scope 3; the final rules did not adopt that.
The clause-by-clause reading is on UK SRS rules analysed, the FCA’s wider approach on the FCA and UK SRS, and the dates on the UK SRS timeline.
Overseas issuers in UKLR 14 and 15 follow a parallel limb, covered on overseas companies and UK SRS.
Not required
Transition plans and assurance: statements, not duties
Two things are often listed as UK SRS requirements and are not.
No UK entity must have a climate transition plan; a listed company says whether it has published one, and the FCA says it is not requiring them.
The planning side is on transition plans under UK SRS.
No UK entity must obtain assurance; a listed company says whether it did.
The FRC issued ISSA (UK) 5000 for engagements that are commissioned, covered on ISSA (UK) 5000 and UK SRS assurance.
The FCA’s Sustainability Disclosure Requirements are rules for investment products and their managers, with four labels only qualifying funds may use.
People searching for “sustainability disclosure requirements” usually mean one or the other; the SDR is covered on FCA sustainability disclosure requirements.
In practice
Turning the requirements into a work plan
Most first reports are organised around the four areas, with the metrics collected first because they take longest.
A limb-by-limb checklist is on UK SRS compliance, and the government’s own starting point on GOV.UK links both standards and the government response.
The government’s guidance page remains the short statement of who may use the standards.
The professional bodies have published commentary, such as the ICAEW’s overview; the standards themselves are the text to rely on.
The sister reference site keeps its own UK SRS material at uksrs.org.uk.
Frequently asked
Questions people ask
What are the UK SRS requirements?
UK SRS S1 requires disclosure of all sustainability-related risks and opportunities that could reasonably be expected to affect an entity's cash flows, access to finance or cost of capital, organised under four core content areas: governance, strategy, risk management, and metrics and targets.
UK SRS S2 applies the same structure to climate: climate-related risks and opportunities, climate resilience and scenario analysis, and seven cross-industry metric categories including absolute gross Scope 1, 2 and 3 greenhouse gas emissions.
What are the four pillars of UK SRS?
Governance, strategy, risk management, and metrics and targets.
UK SRS S1 paragraph 25 sets them out as the core content an entity must disclose, and UK SRS S2 follows the same four areas for climate-related matters.
They are inherited from the TCFD recommendations through IFRS S1 and S2.
What greenhouse gas emissions does UK SRS S2 require?
Absolute gross Scope 1, Scope 2 and Scope 3 emissions for the reporting period, in tonnes of CO2 equivalent, measured under the GHG Protocol Corporate Standard unless a jurisdictional authority or exchange requires another method.
Scope 2 is disclosed location-based with information on contractual instruments; Scope 3 disclosure names the categories included and, for asset management, commercial banking or insurance, covers financed emissions.
Is materiality under UK SRS based on enterprise value?
No. The phrase does not appear in UK SRS S1 or S2.
UK SRS S1 paragraph 3 asks for information about risks and opportunities that could reasonably be expected to affect the entity's cash flows, access to finance or cost of capital, and paragraph 18 makes information material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions of primary users of general purpose financial reports.
What does the FCA require listed companies to disclose under UK SRS?
For accounting periods beginning on or after 1 January 2027, a company in scope makes UK SRS S2 climate disclosures or states which requirements it has not met, why, and the steps it plans; makes UK SRS S1 disclosures on the risks and opportunities it has identified or explains; and states where the disclosures are, whether it obtained assurance and whether it has published a transition plan.
All of it is comply or explain.
Is UK SRS the same as the FCA's Sustainability Disclosure Requirements?
No. The Sustainability Disclosure Requirements are FCA rules for investment products and the firms that manage them, including four sustainability labels that only qualifying funds may use.
UK SRS are company reporting standards.
The two share a word, not a population.
Does UK SRS require a transition plan?
No. UK SRS S2 asks for information about climate-related targets and how an entity is responding to climate risks, but creates no duty to have a transition plan.
Listed companies under the FCA rules say whether they have published one and where, or why not.
How does UK SRS S2 differ from IFRS S2?
In a few places, all listed in Annex A of the government's response.
References to the industry-based guidance at paragraphs 12, 23 and 32 say "may" rather than "shall"; the effective date was removed; the Scope 3 relief lost its time limit; and paragraph B59A was added, requiring an explanation where financed emissions cannot be disclosed for the same period — the one place UK SRS is stricter than IFRS.
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.
- Department for Business and TradeUK SRS S1 — General requirements (PDF), ¶¶3, 18, 20–25, 60–63, 72–73B, B19
The scope test, materiality, reporting entity, connected information, core content, location, compliance statement.
- Department for Business and TradeUK SRS S2 — Climate-related disclosures (PDF), ¶¶10, 22, 29, B59A, Appendix C
Risks and opportunities, climate resilience, the seven metric categories, financed emissions.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
Voluntary for any entity.
- Department for Business and TradeExposure drafts of UK SRS: government response, Annex A (PDF)
Every difference from IFRS S1 and S2, and the rule that there are no others.
- Department for Business and TradeGovernment response to the consultation on UK SRS (web version)
- IFRS FoundationIFRS S2 Climate-related Disclosures, December 2025 text (HTML)
The body paragraphs UK SRS S2 carries under the same numbers.
- IFRS FoundationIFRS S1 General Requirements
- IFRS FoundationIFRS S2 Climate-related Disclosures
- GHG ProtocolA Corporate Accounting and Reporting Standard (2004)
The default measurement basis named in ¶29(a).
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The fifteen Scope 3 categories.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
- Financial Conduct AuthorityPS26/19 (PDF), Appendix 1 — UKLR 6.6.6R(7A), (7B), (8)(c)–(e); UKLR 6.6.6A G
What a listed company must disclose or explain from 1 January 2027.
- Financial Conduct AuthorityCP26/5 (PDF)
The consultation the rules finalise.
- Financial Conduct AuthorityPS23/16: Sustainability Disclosure Requirements and investment labels
The SDR — a different regime, for investment products.
- Financial Reporting CouncilSustainability reporting developments: frequently asked questions
On ¶B59A: an entity unable to disclose financed emissions must explain why.
- Financial Reporting CouncilFRC takes steps to support quality and consistency in the assurance of sustainability reporting
ISSA (UK) 5000, 12 November 2025.