UK SRS S1
The general requirements standard, read paragraph by paragraph.
What UK SRS S1 requires, by paragraph.
UK SRS S1 runs to 86 numbered paragraphs and five appendices, and every requirement sits in one of thirteen blocks.
Most explanations of this Standard paraphrase it. This one gives you the paragraph, so you can check.
The requirement itself is one sentence
¶25 says an entity shall disclose about governance, strategy, risk management, and metrics and targets.
Everything before ¶25 tells you what to disclose about; everything after tells you where, when and how.
Who must apply it, and when.
Nobody, at present, by force of law. That is not a gap in the Standard; it was built that way.
Why the effective date was removed rather than set
The government deleted the effective-date provisions so that timing could be fixed later by legislation or by the FCA.
Any table showing UK SRS S1 as “effective from” a date is inventing that date.
The Standards contain the machinery to be mandated, and no mandate.
What is proposed, and by whom
The FCA has consulted on requiring listed companies to report against UK SRS S1 on a comply-or-explain basis.
CP26/5 ¶3.9 puts the non-climate limb at accounting periods beginning on or after 1 January 2029.
A proposal in a closed consultation is not a rule.
The consultation closed on 20 March 2026; the FCA aims to publish its Policy Statement in autumn 2026, and it is still unpublished.
Where the four pillars came from.
UK SRS S1 is the UK-endorsed version of IFRS S1, and IFRS S1 inherited its architecture from the TCFD.
Governance, strategy, risk management, and metrics and targets have carried through every step unchanged.
If you have reported under TCFD, the skeleton is already familiar. The materiality test is not.
What endorsement changed, and what it did not
Endorsement changed the effective dates, the reliefs and two references. It did not touch ¶25.
Compliance with UK SRS is not automatically compliance with the ISSB’s Standards, and the copyright notice says so.
The UK SRS S1 materiality test, in its own words.
UK SRS S1 applies single, financial materiality. Two paragraphs carry the whole test.
¶3 sets what the disclosures are about; ¶18 sets when a piece of information is material.
What ¶3 actually says
The Standard requires disclosure about 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.
That triple is the reach test, and it is the sentence most explainers replace with a phrase that does not appear in the Standard.
“Enterprise value” is not the test. The phrase appears nowhere in UK SRS S1.
What ¶18 adds
Information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions primary users make on the basis of general purpose financial reports.
Primary users are existing and potential investors, lenders and other creditors, and no one else.
There is no threshold, and that is deliberate
¶B19 states that the Standard does not specify any thresholds for materiality, nor predetermine what would be material in a particular situation.
A vendor offering you a materiality percentage is offering you their judgement, not the Standard’s.
Governance, strategy, risk, metrics.
¶25 names the four. ¶¶26–53 set out what each requires.
Governance gets two paragraphs. Strategy gets fifteen.
The pillar most first attempts under-serve
Metrics and targets asks for progress, not only the target — and progress is what a first report lacks.
Connected information: four paragraphs, four duties.
¶¶21–24 require the sustainability disclosures and the financial statements to be readable as one set of information.
This is where a report assembled by a separate team, on a separate timetable, usually fails.
The heading is “Connected information”
The word “connectivity” does not appear in UK SRS S1 at all, though a great deal of commentary uses it.
If you are searching the PDF for the requirement, search for the Standard’s heading rather than the commentary’s word.
Same reporting entity, same data, same assumptions, same currency — and an explanation where the two overlap.
Where this lands in UK law
The government has confirmed UK SRS S2 as a national reporting framework for section 414CB(6) of the Companies Act 2006.
S1 has no such confirmation, which is one more reason its status differs from its sibling’s.
Where the disclosures go, and when they are due.
¶¶60–63 govern location; ¶¶64–69 govern timing.
One IFRS S1 paragraph was deleted outright in endorsement.
The deletion worth knowing about
IFRS S1 ¶E4 let first-year disclosures follow the accounts. Annex A records it as removed.
A UK reporter publishes both together from year one, with no grace.
The UK SRS S1 reliefs, one by one.
Appendix E runs E1 to E5, is titled “Application and transition”, and carries the same authority as the rest of the Standard.
It contains no effective date, and two of its reliefs carry no time limit at all.
The climate-only relief has no expiry
¶E3 permits an entity to disclose only about climate-related risks and opportunities, and applies the Standard only so far as it relates to climate.
The exposure draft proposed a two-year limit. The final Standard removed the reference to the first annual reporting period entirely.
Any source telling you the climate-first relief lasts two years is reading the exposure draft.
And it costs you the S1 compliance statement
¶73A is explicit: an entity using ¶E3 is not permitted to assert compliance with UK SRS S1, and shall disclose its use of the provision instead.
The same paragraph preserves the right to assert compliance with UK SRS S2, provided the use is disclosed alongside the statement.
Permitted, or prohibited. There is no third statement.
How UK SRS S1 differs from IFRS S1.
Annex A of the government’s consultation response maps every difference, and it has six rows.
Annex A also states its own scoping rule: where requirements are not in the table, there are no differences between the two.
The count you will see elsewhere describes a proposal
The June 2025 consultation proposed six amendments for a UK context. Two of those did not survive to publication.
The GICS proposal was withdrawn because the ISSB made the change itself in December 2025, and the two-year relief was replaced by removing the limit.
Two of the six were abandoned. Four new provisions appeared.
¶73A, ¶73B, ¶B59A and ¶E5 were added after the consultation closed.
Annex A is the authoritative mapping of the final differences, and it carries no count.
The change most often stated backwards
Effective dates were removed, not replaced with UK ones. The phrase “effective date” appears nowhere in the final Standard.
Nor is comply-or-explain a UK SRS amendment: it is the FCA’s proposed rule, and the Standard contains no such mechanism.
Single materiality, and what that excludes.
UK SRS S1 asks one question: could this affect the entity?
The EU regime asks that question and a second one: does the entity affect people and the environment?
A matter can be immaterial under UK SRS S1 and reportable under the ESRS on the same facts.
Why the distinction bites
A group reporting on both sides needs one assessment for investors and a wider one for impact, and cannot substitute either.
The right sentence names the paragraphs on both sides rather than reaching for a phrase that appears in neither.
Who checks a UK SRS S1 disclosure.
Nobody is obliged to, because the disclosure itself is not obliged.
A standard to assure against is not a duty to be assured.
What a voluntary reporter usually does
Most take no external assurance and say so plainly, which beats implying a check that did not happen.
The non-climate half of the Standard.
UK SRS S1 covers every sustainability-related risk and opportunity meeting its test, not only climate.
S2 then adds climate-specific requirements on top of the S1 frame.
Where the topic-level guidance is still forming
The ISSB agreed a proposed way forward on nature-related disclosures in May 2026.
Until topic standards follow, non-climate matters are disclosed against S1’s general requirements alone, using ¶¶54–59 to find guidance.
Where first attempts go wrong.
The common failures are not effort failures. They are paragraph failures.
A report can be long, careful and still miss a limb the Standard states in one line.
The most expensive mistake is claiming compliance you are not permitted to claim.
The one to check first
If you used the climate-only route, read ¶73A before the compliance statement is drafted.
It is a short paragraph and it decides the wording of the most quoted sentence in the report.
What you may actually claim.
¶¶72–73 set the statement of compliance. ¶73A tells you when you may not make it.
Answer for the reliefs you have used, and the permitted wording is derived rather than guessed.
The trap, stated once more
Climate-only disclosure under ¶E3 removes the right to assert compliance with UK SRS S1.
It does not remove the right to assert compliance with UK SRS S2, provided the use of the provision is disclosed.
A great many published statements make the claim that ¶73A forbids.
And a claim is subordinate to UK law
¶73B subjects the application of the Standard to the Companies Act, to the FCA, and to any other UK body able to enact reporting requirements.
That paragraph is why the reliefs could safely be made untimed: someone retained the power to re-time them.
The shape of the Standard.
Thirteen blocks, 86 numbered paragraphs, two UK additions and five appendices.
Reading it takes an afternoon, which is less time than most summaries of it will cost you.
It is 45 pages. Almost nobody writing about it has opened it.
If you read only three things
Read ¶3 for what the Standard is about, ¶25 for what it asks, and ¶73A for what you may say afterwards.
Read ¶3, ¶25 and ¶73A.
Then open the PDF.
Every claim on this page, and its paragraph.
Nothing here is asserted without the provision that carries it.
Where a position is proposed rather than made, the page says which document proposes it and whether it has been finalised.
A misread figure is named, not left standing.
Where a widely-repeated number is wrong, the page names the document being misread.
What this page does not cover.
UK SRS S2 has its own page, and the climate-specific requirements are set out there rather than here.
Sector guidance, the ISSB’s industry-based material and the Modernising Corporate Reporting programme are named but not treated in depth.
No clients, no certifications, no accreditations, no awards.
Nothing here is advice on your own circumstances.
UK SRS S1: questions readers ask.
Every claim, and where it came from.
Every claim on this page is cited inline to the paragraph of the Standard that carries it, or to the instrument that does.
Each entry says what kind of document it is — the Standard itself, a government response, a regulator’s consultation, a standard-setter’s text, or a labelled secondary source.
Where a document is superseded or proposed rather than made, it says so.
- UK SRS S1 — General Requirements for Disclosure of Sustainability-related Financial Information
- GOV.UK — UK SRS S1 and UK SRS S2, publication page
- GOV.UK — UK Sustainability Reporting Standards guidance
- Companies Act 2006 section 414CB
- FCA CP26/5 — consultation page
- FCA CP26/5 — the paper
- IFRS S1 — General Requirements (the source standard)
- DBT — UK SRS consultation response, Annex A
- Government response to the UK SRS consultation — web version
- SASB Standards
- Directive (EU) 2022/2464 — the CSRD
- ISSA (UK) 5000 — Sustainability Assurance Standard
- ISSB — proposed way forward on nature-related disclosures
- Companies Act 2006
- uksrs.org.uk — the UK SRS S1 fact record
- uksrs.org.uk — the UK SRS S2 fact record
- UK SRS S2 — Climate-related Disclosures
- FRC — Sustainability Reporting Developments: FAQs
- Companies Act 2006 section 414CA
- SI 2022/31
- IFRS S2 — Climate-related Disclosures
- TCFD — Final Recommendations
- DBT — UK SRS exposure drafts consultation
- EFRAG — sustainability reporting standards
- Commission Delegated Regulation (EU) 2023/2772 — the ESRS
- IFRS Foundation — the ISSB
- Companies Act 2006 section 414C
- SI 2018/1155 — SECR
- FRC — Assurance Standards
- FRC — ISSA (UK) 5000 issued
Carried over, so no citation is lost
The fact record from which every entry is drawn is the cluster’s reference at uksrs.org.uk.