Quick Answer — Who Is In Scope?
If · ListingListed on a UK market?
If · SizeLarge under SECR — 2 of 3?
If · EnergyESOS qualification?
The Three Threshold Tests
Listing-based threshold (primary route to scope)
FCA CP26/51 proposes scope based on UK listing category under the UK Listing Rules:
Premium-listed Main Market companies: approximately 500 companies in proposed mandatory scope from 1 January 20271.
This covers FTSE All-Share constituents and other companies meeting premium listing requirements.
Standard-listed companies: Subject to final FCA policy statement (autumn 2026)1.
CP26/5 does not definitively include or exclude this category.
AIM companies: Not in proposed mandatory scope1.
AIM remains outside UK SRS requirements under current FCA proposals.
Specialist Fund Segment: Not in proposed mandatory scope1.
Size-based threshold (NOT applicable to UK SRS)
UK SRS does NOT use Companies Act size tests.
This differs fundamentally from SECR thresholds which use the £36 million turnover / £18 million balance sheet / 250 employees tests.
This is a key clarification — UK SRS scope is determined purely by listing status, not financial size.
A small company inside one of those UKLR categories would be in scope; a large private company would not (under initial proposals).
Voluntary adoption (any organisation)
Any UK entity may voluntarily adopt UK SRS S1 or UK SRS S22 from 25 February 20262.
Voluntary adopters do not receive the transitional reliefs available to mandatory reporters — such as the first-year Scope 3 carve-out available under UK SRS S22.
What in-scope companies are — and aren't — required to do
Listed companies whose accounting period begins before 1 January 2027 have a choice under CP26/5 paragraph 8.101: continue applying the existing TCFD-aligned rules for that reporting period, or voluntarily apply the UK SRS-aligned requirements early.
Neither choice carries a penalty.
The FCA does not propose to mandate publication of a climate transition plan1.
In-scope companies must state in their annual report whether they have published a transition plan and where it can be found, or explain why no plan has been published.
Third-party assurance over UK SRS disclosures is also not proposed as mandatory1.
Companies that obtain assurance voluntarily must disclose the assurance level, standard used, and provider. ISSA (UK) 50007
, published by the FRC on 12 November 2025 and effective for engagements covering periods beginning on or after 15 December 20267, is the applicable UK standard for voluntary engagements.
UK SRS S2 has been designated a national reporting framework under Companies Act 2006 section 414CB(2A)3.
The FRC has confirmed6 that an entity applying UK SRS S2 — whether mandatorily or voluntarily — does not need to separately satisfy the existing climate-related financial disclosure requirements in section 414CB(1)-(5), provided its use of UK SRS S2 is clearly referenced in the Non-Financial and Sustainability Information Statement (NFSIS).
UK SRS vs SECR vs CSRD Thresholds
| Framework | Threshold basis | Approx. in scope | Status | Authority |
|---|---|---|---|---|
| UK SRS S2 | Listed status (premium) | approximately 500 UK companies | Proposed 2027 | FCA |
| SECR | Listed OR 2/3 size tests | ~11,900 UK companies | In force since 2019 | Companies House |
| CSRD (EU) | EU presence + size + revenue | ~10,000 EU companies | Phased FY2024+ | European Commission |
| IFRS S1/S2 | Jurisdiction adoption | Varies by country | Global baseline | ISSB |
This comparison shows UK SRS as the most targeted framework — applying to fewer companies than SECR but with more comprehensive disclosure requirements than current TCFD-aligned rules.
Are private companies in scope?
Not in initial CP26/5 proposed scope. FCA CP26/51 applies only to listed companies under FCA jurisdiction.
The Government's Modernising Corporate Reporting (MCR) programme4 may extend UK SRS to large private companies through future consultation — likely targeting companies meeting SECR size thresholds or similar.
Private companies can adopt UK SRS voluntarily from 25 February 20262.
Cross-link: UK SRS for Private Companies.
One open question the MCR consultation will need to resolve: whether a wholly-owned subsidiary of a UK parent that already reports UK SRS should separately report itself.
The Government's consultation response5 records strong respondent support for an exemption where the parent already reports UK SRS or an equivalent international standard such as ESRS5, though no exemption is yet confirmed.
Are overseas companies in scope?
Only UK-incorporated companies with UK listings are in proposed scope under FCA CP26/51.
Foreign companies with secondary listings in London are not currently proposed for UK SRS scope — they remain subject to their home jurisdiction requirements only.
UK subsidiaries of foreign groups would be subject to UK SRS only if they themselves are listed in one of those UKLR categories.
Consolidated group reporting follows standard consolidation principles under Companies Act 2006 section 414CB3.
Cross-link: UK SRS for Overseas Companies.
When thresholds change
2027: UK SRS S2 proposed mandatory (subject to FCA Policy Statement autumn 20261).
2029: UK SRS S1 proposed comply-or-explain for the same scope as S21.
Future MCR consultation: The Modernising Corporate Reporting programme4 may extend scope to large private companies.
Timing and criteria to be confirmed through separate Government consultation.
Standard-listed companies remain subject to final FCA policy clarification1.
What are the UK SRS thresholds?
UK SRS thresholds are based on UK listing status, not company size.
FCA CP26/5 proposes mandatory UK SRS S2 for approximately 500 in-scope listed companies from 1 January 2027.
UK SRS does not use the Companies Act size tests that apply to SECR.
Does UK SRS apply to private companies?
Not in the initial scope.
FCA CP26/5 applies only to listed companies.
The Government's Modernising Corporate Reporting programme may extend UK SRS to large private companies through future consultation, but timing is unconfirmed.
How is UK SRS different from SECR thresholds?
SECR uses Companies Act size tests (£36m turnover OR £18m balance sheet OR 250 employees) affecting ~11,900 companies.
UK SRS uses listing status only, affecting approximately 500 in-scope listed companies.
Completely different threshold basis.
Will UK SRS scope expand?
Possibly.
The Government's Modernising Corporate Reporting programme is reviewing corporate reporting requirements including potential extension of sustainability reporting to large private companies.
Future expansion would require separate consultation.
Are AIM companies in UK SRS scope?
No. FCA CP26/5 proposes scope limited to UKLR categories 6, 14, 15, 16 and 22 on the Main Market.
AIM companies are not included in mandatory scope, though they can adopt UK SRS voluntarily from 25 February 2026.
When do UK SRS thresholds apply from?
Proposed from 1 January 2027 for UK SRS S2 (climate), and 1 January 2029 for UK SRS S1 (general sustainability) on comply-or-explain basis.
Subject to FCA Policy Statement expected autumn 2026.
What happens if my accounting period begins before 1 January 2027?
CP26/5 paragraph 8.10 gives listed companies a choice: continue applying the existing TCFD-aligned rules for that reporting period, or voluntarily apply the new UK SRS-aligned requirements early.
There is no penalty for choosing either path.
Do in-scope companies have to publish a climate transition plan?
No. The FCA has explicitly chosen not to mandate publication of transition plans.
CP26/5 requires only a statement confirming whether a transition plan has been published and where, or the reasons why not.
Is third-party assurance required for UK SRS disclosures?
No. The FCA does not propose to mandate third-party assurance over UK SRS disclosures.
Companies that obtain assurance voluntarily must disclose the assurance level, standard, and provider.
ISSA (UK) 5000, the FRC's UK sustainability assurance standard, is available for voluntary engagements from 15 December 2026.
Does UK SRS S2 replace the existing section 414CB climate disclosure requirements?
Effectively yes.
The FRC has confirmed UK SRS S2 is designated a national reporting framework under section 414CB(2A) of the Companies Act 2006.
An entity applying UK SRS S2 does not need to separately satisfy section 414CB(1)-(5), provided its use is clearly referenced in the Non-Financial and Sustainability Information Statement (NFSIS).
Are wholly-owned subsidiaries of a UK parent exempt from separate UK SRS reporting?
Not yet decided.
The Government's consultation response records strong support for an exemption where the parent company already reports UK SRS or an equivalent standard such as ESRS, but this is one of the open questions the MCR private-company consultation will resolve.
