REGULATORY TIMELINE

Key UK SRS dates and milestones

25 Feb 2026
Standards published
UK SRS S1 and S2 available for voluntary adoption
1 Jan 2027
S2 proposed mandatory
Climate reporting for listed companies (subject to Policy Statement)
1 Jan 2028
Scope 3 comply-explain
Value chain emissions with explain option
1 Jan 2029
S1 comply-explain
General sustainability disclosures

The proposed-mandatory dates depend on the FCA Policy Statement

The dates shown above for the Effect track are proposed, not yet legally binding. They depend on the FCA's autumn 2026 Policy Statement on CP26/5.

UK SRS itself contains no effective date clauses.

Those come from the FCA for SRS compliance companies, or from future Government consultation for private companies.

For the complete regulatory framework underlying these timelines, see our UK SRS regulations guide.

The standards published 25 February 2026 are available for voluntary adoption immediately.

For the complete publication timeline and context, see UK SRS 2026 publication details.

IMPLEMENTATION ROADMAP

Complete UK SRS implementation timeline

Comprehensive timeline from publication through voluntary adoption to full mandatory compliance

Regulatory timeline

From consultation to compliance

The path from DBT standards to mandatory reporting. Each milestone links to its primary source.

  1. Nov 2025
    ISSA (UK) 5000 published by FRC
    FRC β€” ISSA (UK) 5000
  2. Jan 2026
    FCA publishes CP26/5
    FCA β€” CP26/5
  3. Feb 2026
    DBT publishes final UK SRS S1 and S2
    DBT β€” UK SRS S1 and S2
  4. Mar 2026
    CP26/5 consultation closes
    FCA β€” CP26/5
  5. Autumn 2026
    FCA Policy Statement expected
    FCA CP26/5 paragraph 1.11
  6. Dec 2026
    ISSA (UK) 5000 effective
    FRC β€” ISSA (UK) 5000
  7. Jan 2027
    UK SRS S2 mandatory (proposed)
    FCA CP26/5 paragraphs 3.7–3.8
  8. Jan 2028
    Scope 3 comply-or-explain
    FCA CP26/5 paragraphs 3.9, 8.6
  9. Jan 2029
    UK SRS S1 comply-or-explain
    FCA CP26/5 paragraph 3.9

What happens when CP26/5 is finalised

The FCA's CP26/5 consultation closed on 20 March 2026.

The Policy Statement, expected autumn 2026, will confirm or modify the proposed rules.

The 1 January 2027 effective date applies to accounting periods beginning on or after that date β€” not to reports published after that date.

When the first mandatory reports appear

Financial year-endFirst proposed-mandatory periodFirst report published (typical)
31 December1 Jan 2027 to 31 Dec 2027Spring 2028 (March–April)
31 March1 Apr 2027 to 31 Mar 2028Summer 2028 (June–August)
30 June1 Jul 2027 to 30 Jun 2028Autumn 2028
30 September1 Oct 2027 to 30 Sep 2028Winter 2028–29

For a typical FTSE 350 company with December year-end, this gives an 18-month window from publication (February 2026) to first report.

Most of that goes to data systems, materiality assessment, scenario analysis, and assurance preparation.

The Scope 3 transitional treatment

FCA CP26/5 proposes who must comply can omit Scope 3 emissions in their first year of mandatory reporting S2 climate standard (paragraphs 3.9 and 8.6).

From accounting periods beginning on or after 1 January 2028, Scope 3 reporting moves to comply-or-explain across all 15 GHG Protocol categories where material.

This recognises the data challenges in value chain emissions reporting while maintaining disclosure expectations.

S1 and S2 Integration Timeline

S1 Foundation Elements (2027)

Materiality definitions, value chain scope, and financial connectivity apply immediately with S2 because S2 cannot operate without them

S2 Climate Focus (2027)

Complete four-pillar climate reporting including governance, strategy, risk management, and metrics & targets

Scope 3 Enhancement (2028)

Value chain emissions across 15 GHG Protocol categories move from relief to comply-or-explain

S1 Broader Sustainability (2029)

General sustainability disclosures beyond climate move to comply-or-explain for listed companies

UK SRS S1 timeline

The conceptual foundation elements of S1 standard β€” definitions of materiality, scope of value chain, financial-statement connectivity β€” apply from January 2027 alongside UK SRS S2 because S2 requirements cannot be applied without them.

The broader general sustainability disclosures move to comply-or-explain from January 2029 under FCA CP26/5.

This creates a logical implementation timeline sequence: climate first (SRS S2), then broader sustainability (SRS S1), with foundational concepts applying throughout.

Timeline Implementation Checklist

Voluntary adoption phase (Now - 2027)

Begin voluntary UK SRS S1/S2 application to test systems and build capability before mandatory requirements

Policy Statement monitoring (Autumn 2026)

Track FCA Policy Statement for final mandatory dates, scope, and any modifications to CP26/5 proposals

S2 mandatory preparation (2027)

Complete climate reporting implementation including governance, strategy, risk management, and metrics

Scope 3 readiness (2028)

Prepare for comply-or-explain Scope 3 disclosure across material GHG Protocol categories

S1 broader sustainability (2029)

Implement general sustainability disclosures beyond climate on comply-or-explain basis

Assurance engagement

Plan ISSA (UK) 5000 assurance provider engagement and trial assurance processes


Frequently asked questions

When does UK SRS become mandatory?

UK SRS S2 is proposed mandatory for accounting periods beginning on or after 1 January 2027, under FCA CP26/5.

The FCA's final Policy Statement is expected autumn 2026.

UK SRS itself contains no effective date clauses.

Is UK SRS available now?

Yes, for voluntary use.

The standards were published by DBT on 25 February 2026 and are available immediately for voluntary adoption.

Proposed mandatory application for listed companies is subject to the FCA's CP26/5 proposals.

What is the Scope 3 carve-out?

FCA CP26/5 proposes that companies can omit Scope 3 emissions in the first year of proposed mandatory reporting.

From accounting periods beginning 1 January 2028, Scope 3 moves to comply-or-explain across all 15 GHG Protocol categories where material.

When are the first proposed mandatory reports published?

For companies with December year-ends β€” typical for FTSE 350 β€” the first proposed mandatory accounting period begins 1 January 2027 and the first report typically publishes in spring 2028.

Year-ends in March, June, or September produce later first reports through 2028 and into 2029.

When does UK SRS S1 become mandatory?

Under CP26/5, UK SRS S1 (broader sustainability) moves to comply-or-explain for accounting periods beginning 1 January 2029.

The conceptual foundation elements of S1 β€” materiality definitions, value-chain scope, financial-statement connectivity β€” apply from January 2027 alongside S2.

How does ISSA (UK) 5000 fit the timeline?

The FRC published ISSA (UK) 5000, the UK sustainability assurance standard, on 12 November 2025.

It becomes effective on 15 December 2026, giving assurance providers time to align with the new framework before UK SRS S2 proposed mandatory disclosures begin.

UK SRS timeline implementation in practice