UK SRS by the numbers
Nine canonical figures that anchor the UK Sustainability Reporting Standards regime — every figure pinned to a primary source.
The framing on this page sits behind every other reference page on the site.
Methodology and source pinning: every figure on this page is verified against the primary regulator publication.
Figures conventionally cited but not pinned to clearly accessible primary sources (population estimates, jurisdictional adoption counts, practitioner consensus on preparation timelines) are NOT included — these vary over time and across sources.
UK SRS S1 and S2 overview
The UK Sustainability Reporting Standards (UK SRS) consist of two standards:
UK SRS S11 establishes the General Requirements for Disclosure of Sustainability-related Financial Information.
UK SRS S21 sets out the Climate-related Disclosures specifically.
Both were published by the Department for Business and Trade1 on 25 February 2026 alongside the Government Response to the consultation2.
The relationship between the two standards is fundamental:
S1 is the framework; S2 is its first application.
UK SRS S11 establishes the materiality principles, four-pillar architecture, the Connected information requirement, and disclosure framework that apply to ALL sustainability topics.
UK SRS S21 then applies these principles specifically to climate-related risks and opportunities.
Future topic-specific standards (S3, S4, etc.) — if and when ISSB issues them and the UK adopts — would follow the same pattern, applying S1's framework to additional sustainability themes.
How UK SRS S1 and S2 work together
The two-standard architecture allows entities to start with climate (using UK SRS S21) while building capabilities for broader sustainability reporting under UK SRS S11.
Three coordination mechanisms operate between the standards:
- Materiality framework — UK SRS S1 [1] defines the financial materiality concept; UK SRS S2 [1] applies it to climate-specific risks and opportunities; both use the same threshold (information that could reasonably be expected to affect cash flows, access to finance, or cost of capital)
- Four-pillar architecture — both standards organise disclosure across Governance, Strategy, Risk Management, and Metrics and Targets [7]; the pillar structure is inherited from TCFD and retained in both UK SRS S1 and S2
- Connected information — UK SRS S1 [1] paragraphs 21-24, headed 'Connected information', establish that sustainability disclosure must be connected to the financial statements; UK SRS S2 [1] applies the same requirement to climate-related anticipated financial effects, requiring connection to financial reporting on cash flows and balance sheet items
Under FCA CP26/53, in-scope listed companies disclose information about their climate-related risks and opportunities in accordance with UK SRS S2.
They must apply the specific provisions in UK SRS S1 as relevant to those climate-related disclosures.
UK SRS S2 (excluding Scope 3 emissions) is proposed mandatory from 1 January 2027.
Broader UK SRS S1 application is on a comply-or-explain basis from 1 January 2029.
Sequencing — start with S2, build to S1
For most UK entities approaching UK SRS, the practical sequencing is to start with UK SRS S2 (climate)1 and build capability over time for broader UK SRS S1 (general sustainability)1 coverage.
Reasons for this sequencing:
- TCFD continuity — most large UK companies have existing TCFD-aligned [7] climate disclosure; the four-pillar architecture and content overlap substantially with UK SRS S2
- Mandatory before voluntary — UK SRS S2 is proposed mandatory under CP26/5 [3] from 1 January 2027; UK SRS S1 is comply-or-explain from 1 January 2029
- Climate is the materiality starting point — climate-related risks typically pass the financial materiality threshold for most companies; non-climate sustainability topics require materiality assessment under UK SRS S1 [1]
- Data infrastructure — climate emissions data infrastructure (Scope 1/2/3 [8]) is more mature than broader sustainability metrics for most entities
- Assurance availability — ISSA (UK) 5000 [10] applies to both, but practitioner experience is greater on climate disclosure
The two-standard approach allows entities to manage capability development progressively.
Beginning with climate disclosure under UK SRS S21 and expanding to broader sustainability topics under UK SRS S11 over multiple reporting cycles.
The MCR Strand 2 consultation2 expected during 2026 may set timelines for broader application to private companies.
Four-pillar architecture across both standards
UK SRS S11 and UK SRS S21 share the TCFD four-pillar architecture7.
The table summarises how each standard applies the pillars:
| Pillar | UK SRS S1 | UK SRS S2 |
|---|---|---|
| Governance | Oversight of sustainability-related risks and opportunities (paragraphs 5-7) | Climate-specific governance arrangements (paragraphs 5-8) |
| Strategy | Impact on business model and value chain (paragraphs 8-22) | Climate risks and opportunities in strategy, scenario analysis, transition plans (paragraphs 9-22) |
| Risk Management | Process for identifying and assessing sustainability risks (paragraphs 23-28) | Climate risk management integration (paragraphs 23-28) |
| Metrics and Targets | Performance measurement and progress monitoring (paragraphs 29-44) | Climate metrics including GHG emissions, cross-industry metrics, climate-related targets (paragraphs 29-37) |
Each pillar requires disclosure of current state and forward-looking information1.
With quantitative metrics where possible and qualitative explanation where quantification is not yet feasible.
The Connected information requirement1 (¶¶21–24) requires that the disclosures align with financial statement timing, scope, and recognition principles.
For detailed coverage of each pillar across both standards, see UK SRS Four Pillars.
For the individual standards, see UK SRS S1 Materiality and UK SRS S2 Deep Dive.
UK amendments to IFRS S1 and S2
The UK SRS1 retains close alignment with IFRS S14 and IFRS S25 with UK-specific amendments.
The government's June 2025 consultation proposed six; two did not survive to the final Standards and four further provisions were added afterwards, so Annex A of the Government Response — which maps the final differences — carries no summary count.
The six items below are grouped for navigation, not asserted as an official total.
Verified against the Government Response to the UK SRS Consultation2 and Linklaters' analysis11.
Amendment 1 — SASB Industry-based Guidance: "shall" → "may"
Paragraphs 12, 23, and 32 of IFRS S25 state that entities "shall refer to and consider" the applicability of the Industry-based Guidance on Implementing IFRS S2 (the SASB Industry-based Guidance).
In each corresponding paragraph of UK SRS S21, "shall" has been amended to "may"2.
Practical effect2: UK SRS S2 entities are expected to disclose industry-relevant metrics but are NOT required to use the SASB-based guidance specifically.
The amendment provides flexibility for UK entities to use alternative industry-relevant metrics where appropriate.
Amendment 2 — Removal of effective dates and time references
UK SRS S11 and UK SRS S21 do not contain effective date provisions.
Time references for temporary reliefs have also been removed11.
Rationale and effect2:
- Effective dates will be set when mandatory reporting requirements are introduced — via FCA Listing Rules [3] for listed entities; via Companies Act 2006 [14] amendments under MCR Strand 2 [2] for private entities
- Standards are available for voluntary use immediately without effective-date complications
- Time references for temporary reliefs (non-climate reporting relief, Scope 3 relief) have been removed; the standards no longer specify duration of relief application
- Reliefs may be re-introduced with specific durations when mandatory reporting requirements are introduced
Amendment 3 — Compliance statement provisions
UK SRS S11 includes provisions limiting the ability to make compliance statements OR requiring that additional information is included in compliance statements when an entity is relying on reliefs11.
The compliance-statement provisions are carried by two new paragraphs of UK SRS S1 with no IFRS S1 equivalent — 73A and 73B2.
Paragraph 73A names three reliefs and then treats them asymmetrically:
- Paragraph E3 of UK SRS S1 — the climate-first relief, permitting an entity to disclose information on climate-related risks and opportunities only. An entity using it is NOT permitted to assert compliance with UK SRS S1, and shall disclose use of the provision instead
- Paragraphs C3 and C4 of UK SRS S2 — the Scope 3 reliefs. Neither is affected by the UK SRS S1 restriction
- None of the three prevents an entity asserting compliance with UK SRS S2, provided it discloses its use of them alongside its statement of compliance
Paragraph 73B subordinates all of this to any regulation or legislation made under the Companies Act14, so a future mandate can narrow the reliefs but not widen them.
Practical effect: an entity reporting climate only can state that it complies with UK SRS S2, but cannot state that it complies with UK SRS S11.
Amendment 4 — Removal of delayed sustainability reporting relief
UK SRS1 removes the IFRS S14 ability for entities to report sustainability disclosures AFTER they have published their financial statements.
Sustainability disclosure must be published WITH the financial statements11.
Rationale2:
- Connected information — the requirement that sustainability disclosure connect to the financial statements calls for same-time publication
- Existing UK climate-related financial disclosure requirements under Companies Act 2006 section 414CB [14] already require same-time publication with the annual report
- TCFD disclosure under existing FCA Listing Rules [9] (LR 9.8, to be replaced) requires publication with the annual financial report
- UK entities are well-positioned for same-time publication given existing reporting infrastructure
This amendment strengthens the Connected information requirement and aligns UK SRS1 with existing UK reporting practice.
Amendment 5 — Paragraph B59A (financed emissions reporting flexibility)
UK SRS S21 includes a new paragraph B59A that allows financial institutions to report financed emissions from a DIFFERENT reporting period than the entity's own emissions11.
It is widely summarised as a permission.
It is better read as a conditional one, because the paragraph carries both a gate and a price.
The gate: B59A applies where the institution determines it is impracticable to reliably estimate financed emissions for the same reporting period as its own emissions1.
The price: an institution relying on it shall disclose three things1:
- The reasons why measuring financed emissions for the same reporting period is impracticable
- The measurement approach, inputs and assumptions used for the financed emissions it does report
- Its plan to be able to report financed emissions for the same reporting period, including timelines
That third requirement is what separates B59A from a permanent relief — it is closer to comply-or-explain with a dated remediation commitment.
The underlying constraint it recognises is real: financial institutions typically receive investee and borrower emissions data 12-18 months after the relevant period.
This amendment is particularly relevant for banks, insurers, asset managers, and other financial institutions in scope of UK SRS S21.
The Partnership for Carbon Accounting Financials (PCAF) methodology is commonly used for financed emissions calculation.
Under the UK Listing Rules9, this amendment provides practical relief for financial institutions subject to mandatory UK SRS S2 disclosure requirements.
See UK SRS for Financial Services for sector-specific coverage.
Amendment 6 — Incorporation of ISSB December 2025 IFRS S2 amendments
The ISSB published targeted amendments to IFRS S26 in December 2025.
UK SRS S21 incorporates these amendments (except the effective date and transition provisions, which are not relevant given UK SRS's own structure under Amendment 2)2.
These are the ISSB's own changes, adopted by the UK rather than authored by it — the same distinction that matters for the GICS classification requirement, which the ISSB removed from IFRS S2 in this same December 2025 round and which UK SRS S2 never separately amended.
The ISSB December 2025 amendments6 cover four targeted topics:
- Allowing an entity to limit the measurement of Category 15 Scope 3 GHG emissions to only "financed emissions" (a narrower scope than the general Category 15 definition)
- Permitting an entity to select an industry-classification system for disaggregating financed emissions (alternative to the IFRS-prescribed approach)
- Expanding the jurisdictional relief from using the GHG Protocol Corporate Standard — applies if an entity (in whole or in part) is required to use a different method for measuring GHG emissions
- Introducing a new jurisdictional relief allowing an entity to use global warming potential (GWP) values other than the values currently required by the GHG Protocol
The UK Sustainability Disclosure Technical Advisory Committee (TAC) reviewed the ISSB amendments in January 2026 and recommended their inclusion in UK SRS S22.
The TAC's written recommendations were sent to DBT on 26 January 2026; UK SRS S2 incorporates the amendments accordingly.
For detailed comparison of UK SRS and IFRS S1/S2 including these amendments, see UK SRS vs IFRS S1/S2.
Mandatory timeline
UK SRS S1 and S21 are available for voluntary use immediately from 25 February 2026.
The path to mandatory application:
- 30 January 2026 — FCA published CP26/5 [3]
- 20 March 2026 — CP26/5 consultation closed; the number of responses has not been published
- Autumn 2026 — FCA Policy Statement expected, finalising UK Listing Rules [9]; no date has been announced beyond "autumn 2026"
- 1 January 2027 — proposed: UK SRS S2 mandatory for UKLR 6, 16 and 22 only (excluding Scope 3); UKLR 14 and 15 are in scope of CP26/5 but would instead make a statement identifying the overseas standards they follow, not report against UK SRS
- 1 January 2028 — proposed: the FCA's Scope 3 deferral (CP26/5 §3.9) would end from this date; Scope 3 remains comply-or-explain even after, under CP26/5 §4.8 — it is not proposed to become straight-mandatory
- 1 January 2029 — proposed: UK SRS S1 comply-or-explain (broader sustainability topics)
- 2026-2028 (anticipated) — MCR Strand 2 consultation [2] and possible Companies Act 2006 [14] amendments to extend application to economically significant private companies; no proposed effective date at all
The two-track timeline — FCA-led for listed companies; DBT-led for private companies — means UK SRS1 mandatoriness expands progressively over multiple years rather than at a single effective date.
See UK SRS Timeline for detailed coverage.
Frequently asked questions
What are UK SRS S1 and S2?
UK SRS S1 [1] is the General Requirements for Disclosure of Sustainability-related Financial Information; UK SRS S2 [1] is the Climate-related Disclosures specifically.
Both were published by the Department for Business and Trade on 25 February 2026 [1].
S1 provides the framework for all sustainability disclosure; S2 applies that framework specifically to climate.
The two standards work together as a coordinated pair.
How are UK SRS S1 and S2 related?
S1 is the framework; S2 is its first application [1].
UK SRS S1 establishes materiality principles, four-pillar architecture, the Connected information requirement (¶¶21–24), and disclosure framework that apply to all sustainability topics.
UK SRS S2 applies these principles specifically to climate-related risks and opportunities.
Both share the TCFD four-pillar architecture [7] (Governance, Strategy, Risk Management, Metrics and Targets) and the financial materiality concept.
What changed between IFRS S1/S2 and UK SRS S1/S2?
The government's June 2025 exposure-draft consultation proposed six amendments; two did not survive to the final Standards (GICS removal — actually the ISSB's own December 2025 change, never a UK amendment — and the two-year non-climate relief, replaced by removing the time limit entirely) and four further provisions were added afterwards.
Annex A of the Government Response [2] maps the final differences in full and carries no summary count.
Grouped here for navigation, verified against the Government Response [2] and Linklaters analysis [11]: (1) SASB Industry-based Guidance "shall" → "may" in paragraphs 12, 23, 32 of S2; (2) Removal of effective dates and time references, including for temporary reliefs — the final Standards carry no time limit on the climate-first (S1 ¶E3) or Scope 3 (S2 ¶C4) reliefs at all; (3) Compliance statement provisions, carried by new paragraphs 73A and 73B of UK SRS S1 — 73A names the relief in paragraph E3 of UK SRS S1 and the reliefs in paragraphs C3 and C4 of UK SRS S2, and an entity using the E3 relief may not assert compliance with UK SRS S1; (4) Removal of delayed sustainability reporting relief — must publish with financial statements; (5) New paragraph B59A allowing financial institutions to report financed emissions from a different reporting period where the same period is impracticable; (6) UK SRS S2's incorporation of the ISSB's own December 2025 amendments to IFRS S2 [6], covering financed emissions disaggregation and jurisdictional reliefs — this one is the UK adopting an ISSB-authored change, not a UK amendment.
Note the paragraph numbering: UK SRS S1 Appendix E runs E1 to E5, not E1 to E6.
The UK deleted three paragraphs from IFRS S1's Appendix E and renumbered consecutively, so there is no paragraph E6 in UK SRS S1 and every letter after E1 means something different in the two documents.
Is single vs double materiality one of the UK amendments?
No — this is a common misconception.
IFRS S1 [4] and IFRS S2 [5] both use FINANCIAL materiality (single materiality).
UK SRS S1 [1] and S2 [1] also use financial materiality.
The single vs double materiality distinction is between ISSB-based standards (which include UK SRS and IFRS S1/S2 — all single materiality) and EU CSRD (double materiality).
It is NOT a UK-specific amendment to IFRS S1/S2.
Which standard do I start with — S1 or S2?
For most UK entities, start with UK SRS S2 [1] (climate) and build capability for broader UK SRS S1 [1] over time.
Reasons: TCFD continuity [7]; UK SRS S2 is proposed mandatory from 1 January 2027 under CP26/5 [3]; UK SRS S1 would be comply-or-explain from 1 January 2029, also proposed and not yet confirmed; climate-related risks typically pass materiality threshold for most companies; climate emissions data infrastructure is more mature than broader sustainability metrics.
When does UK SRS become mandatory?
Nobody is required to report under UK SRS today — the Standards themselves carry no effective date.
The FCA has proposed, in CP26/5 [3], that UK SRS S2 become mandatory (excluding Scope 3) for listed companies in the commercial companies, non-equity/non-voting-equity and transition categories (UKLR 6, 16 and 22 only) from accounting periods beginning on or after 1 January 2027, with UK SRS S1 on a comply-or-explain basis from 1 January 2029; UKLR 14 and 15 are in scope of CP26/5 but would instead make a statement identifying the overseas standards they follow, not report against UK SRS.
None of this is settled: the FCA has not published a Policy Statement and has announced no date for one beyond "autumn 2026".
MCR Strand 2 [2] may separately extend application to private companies — consultation expected during 2026, with no proposed effective date at all.
What is paragraph B59A about?
Paragraph B59A is a new paragraph added to UK SRS S2 [1] that allows financial institutions (banks, insurers, asset managers) to report financed emissions from a DIFFERENT reporting period than their own emissions [11].
It is conditional, not a blanket concession: B59A applies where the institution determines it is impracticable to reliably estimate financed emissions for the same reporting period.
An institution relying on it shall then disclose the reasons; the measurement approach, inputs and assumptions used; and its plan to be able to report financed emissions for the same period, including timelines.
The amendment recognises the inherent data lag in financed emissions calculation — financial institutions typically receive investee/borrower emissions data 12-18 months after the relevant period — but it is closer to comply-or-explain with a dated remediation commitment than to a permanent relief.
How do UK SRS S1 and S2 relate to TCFD?
UK SRS S1 [1] and S2 [1] retain the TCFD four-pillar architecture [7] (Governance, Strategy, Risk Management, Metrics and Targets) but enhance the requirements within each pillar substantially.
Under FCA CP26/5 [3], the FCA has proposed that UK SRS S2 supersede TCFD recommendations for in-scope listed companies from 1 January 2027 — proposed, not yet confirmed by a Policy Statement.
Key enhancements: a Scope 3 disclosure requirement on a comply-or-explain basis (TCFD did not require Scope 3 at all, and UK SRS S2 does not make it mandatory either), quantitative scenario analysis (TCFD allowed qualitative), cross-industry climate metrics, anticipated financial effects, connection to the financial statements (the Standards' Connected information requirement).
