UK SRS scope · thresholds

UK SRS thresholds: a listing category, not a company size

UK SRS thresholds do not exist in the form most people search for: there is no turnover, balance sheet or headcount test.

Under the FCA’s final rules of 30 September 2026, scope is set by where a company is listed: five UK Listing Rules categories are in, six are out.

Companies in scope report against UK SRS S1 and S2 on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

Check your category Compare the other tests

Quick answer

Who is in scope, category by category

The only UK SRS scope test is the listing category of a company’s securities.

PS26/19 paragraph 3.6 names five categories, from commercial companies in UKLR 6 to the transition category in UKLR 22.

Paragraph 3.7 excludes six others, including investment funds, shells and listed debt.

Because the test is the category, a small company listed in UKLR 6 is in scope and a very large private company is not.

AIM is not a category at all: section 385 of the Companies Act defines a quoted company by the Official List and named overseas markets, and AIM is neither.

The rules take effect for accounting periods beginning on or after 1 January 2027; the dated sequence is on UK SRS deadline.

The rules were made through the FCA Handbook, in the UK Listing Rules sourcebook that replaced the old LR.

PS26/19 ¶3.6 (in) and ¶3.7 (out).
Category	What is listed	FCA rules
UKLR 6	Equity shares — commercial companies	In
UKLR 14	Equity shares — international commercial companies, secondary listing	In
UKLR 15	Certificates representing certain securities (depositary receipts)	In
UKLR 16	Non-equity shares and non-voting equity shares	In
UKLR 22	Equity shares — transition category	In
UKLR 11 and 12	Closed-ended investment funds; open-ended investment companies	Out
UKLR 13	Shell companies	Out
UKLR 17, 18, 19	Debt and debt-like securities; securitised derivatives; warrants, options and other miscellaneous securities	Out

The count

How many companies? The final rules do not say

PS26/19 contains no total count of companies in scope.

The consultation paper estimated, from the Official List as of January 2025, that around 600 listed companies would be affected.

It split them into two routes, and the final rules merged the routes: the 89 issuers with only a secondary listing or depositary receipts now report on the same comply-or-explain basis as everyone else.

So a figure quoted as the number that “must comply” describes a consultation route that no longer exists.

If a number is needed, the honest one is the consultation’s estimate, labelled as such.

~600

Listed companies CP26/5 estimated would be affected — the consultation’s estimate

CP26/5 Annex 2 ¶43

Secondary-listing and depositary-receipt issuers, now under the same requirements

PS26/19 ¶4.35

Other tests

Three tests people mistake for UK SRS thresholds

Searches for UK SRS thresholds usually find one of three other regimes, each with a real size test.

SECR’s is an exemption test in Schedule 7 paragraph 20B: a large unquoted company escapes only by meeting two or more of turnover not more than £36 million, balance sheet not more than £18 million, not more than 250 employees.

ESOS uses Schedule 1: at least 250 employees, or turnover over £44 million and a balance sheet over £38 million.

The Companies Act climate disclosures use section 414CA: more than 500 employees, together with traded, banking, insurance or AIM status or turnover above £500 million.

None of the three is the Companies Act small-company test in section 382, and none moved when SI 2024/1303 raised the size limits from 6 April 2025 — SECR’s table is its own.

Set your figures in the check beside this text; each answer names the provision it reads.

The SECR edge cases are on SECR thresholds.

The UK regime check · your figures

Turnover£mBalance sheet total£mEmployeespeople

A quoted company (Companies Act 2006 s.385)A traded, banking, insurance or AIM companyListing

AppliesSECRIn, as a large unquoted company: you meet at most one of the three “not more than” limits, so the exemption does not apply.SI 2008/410 Sch 7 Part 7A, ¶20B
AppliesESOS Phase 4A large undertaking: at least 250 employees, or turnover over £44m and balance sheet over £38m. Qualification is judged on 31 December 2026; notification is due by 5 December 2027.SI 2014/1643 Sch 1 ¶1(a), ¶1A; reg 4
Does not applyClimate-related financial disclosureNeeds more than 500 employees and either a traded, banking, insurance or AIM company, or turnover above £500m.Companies Act 2006 ss.414CA–414CB
Does not applyFCA listing rules (UK SRS)No listing, no FCA duty. UK SRS stays voluntary for you.FCA PS26/19 ¶3.6; GOV.UK UK SRS guidance

Indicative, not advice.

Group aggregation, LLPs, overseas parents and how size carries across financial years are on each regime’s own page.

Nothing you enter leaves your browser.

Side by side

UK SRS, SECR, ESOS and CSRD: five tests compared

Each test as its instrument writes it; the EU row reaches a UK group only through its EU undertakings.
Regime	Who it reaches	Size test	Status on 30 September 2026
FCA listing rules (UK SRS)	Listing category: UKLR 6, 14, 15, 16, 22	No size test	Final; accounting periods from 1 January 2027
SECR	Quoted companies; large unquoted companies and LLPs	Exempt on two or more of £36m / £18m / 250 ("not more than")	In force since 1 April 2019
Companies Act climate disclosures	Traded, banking, insurance, AIM, or turnover above £500m	And more than 500 employees	Financial years from 6 April 2022
ESOS	UK large undertakings and their group members	At least 250 employees, or over £44m turnover and over £38m balance sheet	Phase 4 qualification 31 December 2026
EU CSRD	EU undertakings; third-country groups via Art 40a	Above €450m and 1,000 employees, both	EU law; financial years from 2027

The FCA rules are the narrowest population and the only one with no size test.

The EU line is included because it is often mistaken for a UK threshold: Directive (EU) 2026/470 applies to undertakings above €450 million net turnover and 1,000 employees, both.

A UK company can sit inside several of these at once, and reports under each.

Inside scope

What an in-scope company must do, and what it need not

Inside scope, nothing is mandatory in the strict sense: every limb is comply or explain.

The made rule asks for UK SRS S2 disclosures or a statement summarising what was not met, the reasons, and the steps planned.

Two reliefs apply from initial application: one year’s non-disclosure of Scope 3 emissions and two years’ non-disclosure of UK SRS S1 non-climate matters, stated but not explained.

Paragraph 3.19 lets a company whose period begins before 1 January 2027 stay on the TCFD-aligned rules or adopt early, keeping the same reliefs.

The FCA says it is not requiring transition plans; the Scope 3 detail is on Scope 3 under UK SRS.

Assurance is a statement, not a duty; the FRC’s ISSA (UK) 5000 is available for voluntary engagements from periods beginning on or after 15 December 2026 (¶15).

A company that is also in the Companies Act climate regime can use UK SRS S2 to meet it, because the government response confirmed UK SRS S2 as a section 414CB(6) national framework.

What each standard asks for is on UK SRS S1 and UK SRS S2.

UKLR 6.6.6R(7A), (7B), (8)(d)–(e); PS26/19 ¶3.14.
Item	Under the final rules
UK SRS S2 climate disclosures	Disclose, or say what is missing, why, and the steps planned
UK SRS S1 other sustainability matters	Disclose the risks and opportunities, or explain; two-year relief
Scope 3 emissions	One-year relief, then comply or explain
Transition plan	Say whether one is published and where, or why not
Assurance	Say whether obtained; if so, provider, scope, level and standard

Outside scope

Private and overseas companies at the edge of scope

A private company has no UK SRS duty, and no threshold for one has been proposed.

The Modernising corporate reporting consultation, open until 30 November 2026, says only that the government will consider how UK SRS belongs in the Companies Act; the detail is on private companies and UK SRS.

Any entity may still use the standards: the FRC notes that a voluntary user can rely on the reliefs without time limits, which voluntary UK SRS reporting explains.

Incorporation does not decide scope; the listing category does.

An overseas company with a secondary listing in UKLR 14, or depositary receipts in UKLR 15, is now inside the rules on the same comply-or-explain basis as a UK issuer.

The FCA says such a company may rely on home-jurisdiction reporting where it aligns with UK SRS outcomes, and explain where it does not; the detail is on overseas companies and UK SRS.

The dates

When the position changes

The scope itself is fixed by the rules; what changes over time is how much a company in scope must say.

For accounting periods beginning between 1 January 2028 and 1 January 2029, the Scope 3 relief has gone and those emissions move to comply or explain.

From 1 January 2029 the climate-first relief has gone too, so the whole of UK SRS S1 is on comply or explain.

When a relief expires nothing becomes mandatory; it becomes something to disclose or explain.

The FCA’s guidance on what a proportionate explanation looks like is still a draft, with comments due by 28 October 2026.

30 Jan 2026
CP26/5 published
Consultation closed 20 March 2026.
25 Feb 2026
UK SRS S1 and S2 published
Voluntary for any entity.
24 Sep 2026
Listing rules instrument made
30 Sep 2026
PS26/19 published
28 Oct 2026
Comments due on draft TN 803.1
Proposed guidance on comply or explain.
30 Nov 2026
MCR consultation closes
1 Jan 2027
Rules in force
Accounting periods beginning on or after.
2028
First reports under the rules
From 1 Jan 2028
Scope 3 relief expired for new periods
PS26/19 ¶3.23.
From 1 Jan 2029
S1 relief expired for new periods
PS26/19 ¶3.24.

Frequently asked

Questions people ask

What are the UK SRS thresholds?

There are no size thresholds.

Under the FCA's final rules (PS26/19, 30 September 2026) scope is set by listing category: companies listed in UKLR 6, 14, 15, 16 and 22 must report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

A company outside those categories has no UK SRS duty, however large it is, and a company inside them is in scope however small.

Who is in scope of UK SRS?

Companies with securities listed in five UK Listing Rules categories: commercial companies (UKLR 6), international commercial companies with a secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity shares and non-voting equity shares (UKLR 16) and the transition category (UKLR 22).

Closed-ended investment funds, open-ended investment companies, shell companies, debt, securitised derivatives and miscellaneous securities are excluded.

Everyone else may use UK SRS voluntarily.

How many companies must report under UK SRS?

The Policy Statement gives no total.

CP26/5, the consultation it finalised, estimated that around 600 listed companies would be affected; that was the consultation's estimate, made on the Official List as of January 2025.

PS26/19 paragraph 4.35 says the 89 secondary-listing and depositary-receipt issuers the FCA identified are subject to the same requirements as domestic listed issuers.

Is UK SRS mandatory from 2027?

No. From accounting periods beginning on or after 1 January 2027, companies in the five listing categories must report against UK SRS S1 and S2 or explain why they have not, on a comply-or-explain basis across both standards.

The consultation had proposed making UK SRS S2 mandatory; the final rules did not.

For every other entity the standards remain voluntary.

Are AIM companies in scope of UK SRS?

No. AIM is not one of the five listing categories: securities admitted to AIM are not admitted to the Official List.

An AIM company can still be caught by the Companies Act climate-related financial disclosures if it has more than 500 employees, and by SECR if it exceeds two of the three SECR size limits.

How do UK SRS thresholds differ from SECR thresholds?

SECR has size limits and UK SRS scope has none.

A large unquoted company is exempt from SECR only if it meets two or more of: turnover not more than £36 million, balance sheet not more than £18 million, not more than 250 employees.

Quoted companies report under SECR at any size.

UK SRS scope under the FCA rules turns only on the listing category.

What happens if my accounting period begins before 1 January 2027?

You may either continue with the TCFD-aligned rules in force immediately before 1 January 2027, or voluntarily apply the UK SRS requirements early.

PS26/19 paragraph 3.19 says an early adopter can use the same transitional reliefs as companies whose periods begin on or after 1 January 2027.

Do in-scope companies have to publish a transition plan or get assurance?

Neither.

A listed company states whether it has published a climate-related transition plan and where, or why not; the FCA says it is not requiring companies to produce one.

On assurance, it states whether third-party assurance was obtained and, if so, the provider, what was assured and to what level, and the standards used.

ISSA (UK) 5000 is available for voluntary engagements covering periods beginning on or after 15 December 2026.

Will UK SRS scope expand to private companies?

Nothing proposes that.

The Modernising corporate reporting consultation, open until 30 November 2026, says only that the government will consider how UK SRS should be reflected in the Companies Act 2006. It gives no threshold and no date.

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.

Checked against 19 sources fromFinancial Conduct AuthorityDepartment for Business and TradeFinancial Reporting Councillegislation.gov.ukDepartment for Business, Innovation, Science and TradeEUR-Lex

Financial Conduct Authority
PS26/19: Aligning listed issuers' sustainability disclosures with international standards
Published 30 September 2026: comply or explain across UK SRS for listed companies.
Financial Conduct Authority
PS26/19 (PDF), ¶¶1.2, 3.6, 3.7, 3.12, 3.14, 3.19, 3.23, 3.24, 4.35 and Appendix 1
The five categories, the six exclusions, timing, reliefs, early adopters, the 89 international issuers; instrument made 24 September 2026.
Financial Conduct Authority
CP26/5 (PDF), Annex 2 ¶43
The consultation’s estimate: around 600 listed companies affected.
Financial Conduct Authority
FCA Handbook — listing, prospectus and disclosure sourcebooks
The former LR sourcebook now opens the Handbook; the listing rules are in UKLR.
Department for Business and Trade
UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026; voluntary for any entity.
Department for Business and Trade
UK SRS S2 (PDF), Appendix C ¶¶C3, C4, C6
The GHG-method and Scope 3 reliefs; their timing left to law or regulation.
Department for Business and Trade
Government response to the consultation on UK SRS (web version)
UK SRS S2 as a national reporting framework for s.414CB(6); Annex A differences.
Financial Reporting Council
Sustainability reporting developments: frequently asked questions
Voluntary users may use the reliefs without time limits.
Financial Reporting Council
Assurance standards — ISSA (UK) 5000
Publication date 12 November 2025.
Financial Reporting Council
ISSA (UK) 5000 (PDF), ¶15
Effective for periods beginning on or after 15 December 2026.
legislation.gov.uk
SI 2008/410 Schedule 7 Part 7A ¶20B (SECR size test)
legislation.gov.uk
SI 2014/1643 Schedule 1 (ESOS large undertaking)
legislation.gov.uk
Companies Act 2006, section 414CA (climate disclosure scope)
legislation.gov.uk
Companies Act 2006, section 414CB(6)
legislation.gov.uk
Companies Act 2006, section 382 (small companies)
The Companies Act size tests, which the FCA rules do not use.
legislation.gov.uk
Companies Act 2006, section 385 (quoted company)
AIM appears nowhere in the definition.
legislation.gov.uk
SI 2024/1303 — the April 2025 size uplift
Department for Business, Innovation, Science and Trade
Modernising corporate reporting — consultation, closes 30 November 2026
EUR-Lex
Directive (EU) 2026/470 (Omnibus I)
CSRD scope: above €450m net turnover and 1,000 employees.