Consultation
The government response records its submitted responses.
UK SRS S1 and S2 · the pair
UK SRS s1 and s2 timeline
UK SRS S1 supplies general requirements and UK SRS S2 applies them to climate-related disclosures.
The pair
Two standards, one of them the other’s frame
UK SRS S1 supplies general requirements and UK SRS S2 applies them to climate-related disclosures.
Two standards, one reportRequirements and evidence
Module 01 / 03
S1 foundation
Define material information and connected reporting.
Module 02 / 03
S2 content
Explain climate risks, opportunities, strategy and metrics.
Module 03 / 03
Report
Present the disclosures as a coherent package.
Read the detailed guidance and evidence
UK SRS S1 and S2 were issued together on 25 February 2026: UK SRS S1 is the framework for any sustainability topic, and UK SRS S2 is that framework applied to climate.
Neither works alone, and the seams between them — the compliance statement, the reliefs, the renumbered appendix — are where most published summaries go wrong.
Under the FCA’s final rules, listed companies in scope report against both on a comply-or-explain basis, with S2 arriving first.
UK SRS S1 answers how any sustainability-related financial disclosure is made; UK SRS S2 answers what a climate disclosure contains.
S1 covers the objective and scope, the conceptual foundations — materiality at ¶¶17–19, connected information at ¶¶21–24 — the core content at ¶25, and where and when disclosures appear (UK SRS S1).
S2 fills that structure with climate: physical and transition risks, scenario analysis, and greenhouse gas emissions across Scopes 1, 2 and 3.
Both are derived from the ISSB’s IFRS S1 and IFRS S2, and both carry a notice that they “have not been prepared or endorsed by the International Sustainability Standards Board”.
They were issued by the Secretary of State for Business and Trade, through the Department for Business and Trade, and published on GOV.UK alongside the government response.
The standards one at a time are on UK SRS S1 and UK SRS S2, and on the sister reference’s UK SRS S1 and UK SRS S2; the primer is what is UK SRS.
| UK SRS S1 | UK SRS S2 | |
|---|---|---|
| Full title | General Requirements for Disclosure of Sustainability-related Financial Information | Climate-related Disclosures |
| Based on | IFRS S1 (June 2023) | IFRS S2, as the ISSB amended it in December 2025 |
| Transition appendix | Appendix E, E1–E5 | Appendix C, C1–C6 |
| UK-only paragraphs | 73A, 73B, E5 | B59A, C6 |
| Effective date | None | None |
By the numbers
The pair in six figures
Response counts and reporting dates should retain their primary-source context rather than imply a count of final UK amendments.
A number needs an owner
Comparison
Annex A maps the final differences without a total.
Application
The FCA instrument sets the relevant dates and reliefs.
Read the detailed guidance and evidence
209
Responses to the exposure-draft consultation, 25 June to 17 September 2025
Government response ¶1.6
125 of 184
Respondents (68%) who agreed the four TAC amendments
Government response ¶1.17
0
Effective dates in either standard
Annex A; UK SRS S1 ¶E2
4
Areas of core content: governance, strategy, risk management, metrics and targets
UK SRS S1 ¶25
1 year
FCA relief for Scope 3, from initial application
PS26/19 ¶3.14
2 years
FCA relief for UK SRS S1 non-climate matters
PS26/19 ¶3.14
Of the 209 responses, 170 came through the online survey and 39 by email, and 199 came from organisations (government response ¶1.6).
The four TAC amendments were the ones the Technical Advisory Committee recommended in its final recommendations, published on 18 December 2024.
Interlock
Four things S2 borrows from S1
The climate standard depends on S1 rather than duplicating its general reporting requirements.
General rules are sharedRequirements and evidence
Module 01 / 03
Materiality
Apply the same investor-focused materiality basis.
Module 02 / 03
Connection
Connect climate information with the financial statements.
Module 03 / 03
Presentation
Apply the general location, timing and compliance rules.
Read the detailed guidance and evidence
The two-standard design only works because four things are defined once, in S1, and inherited by S2.
UK SRS S1 ¶E2 makes the dependence formal: an entity applies UK SRS S2 at the same time as UK SRS S1.
Materiality is financial in both: information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions of primary users, and ¶B19 sets no numerical threshold.
The FCA’s guidance at UKLR 6.6.6A G names the S1 paragraphs that a listed company is “reminded” to apply to its climate disclosures: ¶¶10–24, ¶¶31, 49, 50, 52 and 53, and ¶¶60–71 (PS26/19 Appendix 1).
The consultation had drafted that list as a rule; the made provision is guidance.
The UK also removed the IFRS S1 relief that let a first-year reporter publish its sustainability disclosures after its financial statements, so the pair is always published together (Annex A).
The materiality test is worked through on UK SRS S1 materiality, and the contrast with the EU’s approach on double materiality — which is not a UK amendment, as UK SRS vs IFRS S1 and S2 explains.
| Set in UK SRS S1 | What UK SRS S2 does with it |
|---|---|
| Materiality, ¶¶17–19 | Uses the same financial-materiality test for climate; there is no separate threshold |
| Connected information, ¶¶21–24 | Ties anticipated financial effects back to the financial statements |
| Core content, ¶25 | Fills governance, strategy, risk management, and metrics and targets with climate |
| Location and timing, ¶¶60–69 | Publishes the climate disclosures with the financial statements, not after |
The structure
The four areas, and where each sits in S1
Governance, strategy, risk management, and metrics and targets provide the organising structure for both standards.
A familiar structureRequirements and evidence
Module 01 / 03
Oversight
Who monitors the risks and opportunities?
Module 02 / 03
Response
How do strategy and risk processes address them?
Module 03 / 03
Measurement
Which metrics and targets show performance?
Read the detailed guidance and evidence
Both standards share one structure: governance, strategy, risk management, and metrics and targets.
The structure comes from the TCFD’s recommendations, whose task force disbanded on 12 October 2023; UK SRS S1 carries it as the frame for any topic.
S2’s metrics include absolute gross emissions across three scopes, with Scope 3 measured against the fifteen categories of the GHG Protocol’s value-chain standard.
The pillars across both standards are covered on the UK SRS four pillars and the four pillars of sustainability reporting, the framework itself on TCFD and what is TCFD, and the switch from it on UK SRS vs TCFD.
Scenario work sits on climate scenario analysis under UK SRS, and the Scope 3 method on Scope 3 under UK SRS.
| Area | UK SRS S1 | What S2 adds for climate |
|---|---|---|
| Governance | ¶¶26–27 | Board and management oversight of climate risks and opportunities |
| Strategy | ¶¶28–42 | Climate risks and opportunities, resilience and scenario analysis |
| Risk management | ¶¶43–44 | How climate risks are identified, assessed and managed |
| Metrics and targets | ¶¶45–53 | Scope 1, 2 and 3 emissions and climate targets |
Divergence
What the UK changed from IFRS, and why there is no count
The final UK changes must be read from Annex A rather than counted from the six consultation proposals.
Annex A controls the comparisonRequirements and evidence
Module 01 / 03
References
Check the softened references to industry guidance.
Module 02 / 03
Application
Check removed dates and the role of application rules.
Module 03 / 03
Statements
Check the UK compliance and financed-emissions wording.
Read the detailed guidance and evidence
| Provision | IFRS | UK SRS | Direction |
|---|---|---|---|
| Industry-based guidance (SASB) | S1 ¶¶55(a), 58(a); S2 ¶¶12, 23, 32: “shall refer to and consider” | “may refer to and consider”; S2 ¶37 keeps “shall” | Permissive |
| Effective date | S1 ¶¶E1–E2; S2 ¶¶C1–C2 | Removed; S1 ¶E2 keeps “apply S2 at the same time” | Permissive |
| Publishing after the financial statements | S1 ¶E4 allows it in year one | Removed | Stricter in effect |
| Climate-first relief | S1 ¶E5, first year only | S1 ¶E3, no time limit; ¶E5 subjects it to UK law | Permissive |
| Scope 3 relief | S2 ¶C4(b), first year only | S2 ¶C4, no time limit; ¶C6 subjects it to UK law | Permissive |
| GHG measurement method relief | S2 ¶C4(a), first year | S2 ¶C3, still the first year only | Same |
| Comparatives in year one | S1 ¶E3; S2 ¶C3 | Kept as S1 ¶E1 and S2 ¶C1 | Same |
| Statement of compliance | — | S1 ¶¶73A–73B added | New |
| Financed emissions | S2 ¶B59 | S2 ¶B59A added: explain why, if impracticable | Stricter |
| ISSB’s December 2025 amendments | Added to IFRS S2 later | Built into UK SRS S2 from the start | The ISSB’s, not the UK’s |
Of the six proposals, four came from the TAC and two from the government’s Policy and Implementation Committee (consultation page).
Two fell away: removing the GICS classification requirement, because the ISSB made that change itself in its December 2025 amendments, and extending the climate-first relief to two years, which became no time limit at all.
Paragraphs 73A, 73B, B59A and E5 were added after the consultation, following the DBT’s letter to the FCA of 5 January 2026, which said the time references on the reliefs would go and the compliance statement would be clarified.
The transition appendices were renumbered as a result: IFRS S1 ¶E3 is UK SRS S1 ¶E1, ¶E5 is ¶E3 and ¶E6 is ¶E4, so a paragraph reference lifted from IFRS material may point at the wrong UK paragraph.
The SASB change matters because the ISSB maintains the SASB Standards and IFRS S2 ties its industry guidance to them; the UK made reference to them optional.
Contemporary law-firm commentary on the final texts, from Linklaters and DLA Piper, groups the differences in its own ways; neither is a source for a count.
The side-by-side comparison with the ISSB texts is on UK SRS vs IFRS S1 and S2, and the global originals on IFRS S1, IFRS S2, IFRS S1 and S2, the ISSB and IFRS.
The compliance statement
Paragraph 73A: one relief costs you the S1 statement
Using climate-first relief restricts a UK SRS S1 compliance claim while the standards specify the permitted S2 position.
The claim has conditionsRequirements and evidence
Module 01 / 03
S1 claim
Paragraph 73A prevents an S1 compliance assertion when using E3.
Module 02 / 03
Relief disclosure
State use of the relevant reliefs.
Module 03 / 03
S2 claim
Check the remaining S2 requirements before asserting compliance.
Read the detailed guidance and evidence
UK SRS S1 gained two paragraphs with no IFRS equivalent, and they decide what a company may say about itself.
¶73A: an entity using the climate-only relief in ¶E3 “may not assert compliance with UK SRS S1 and must disclose its use of the relief”, but using ¶E3 or S2’s ¶¶C3–C4 “is not prevented from asserting compliance with UK SRS S2, so long as they disclose the use of the relief/s” (Annex A).
So a company reporting on climate alone can state that it complies with UK SRS S2, and cannot state that it complies with UK SRS S1.
¶73B makes the whole of UK SRS S1 subject to “any regulation or legislation set out in the Companies Act, by the Financial Conduct Authority, or by any other UK regulatory or government entity”.
The FCA’s rules sit on top: its draft Technical Note 803.1, still proposed guidance, says a company that explains a gap cannot make an unreserved statement of compliance with the standard concerned.
The listing rules themselves require no separate compliance statement; what they require is set out on the FCA’s UK SRS rules.
| If you use… | Claim UK SRS S1? | Claim UK SRS S2? |
|---|---|---|
| S1 ¶E3 — climate only | No; disclose the relief instead | Yes, if the relief is disclosed |
| S2 ¶C3 — measurement method | Not affected | Yes, if disclosed |
| S2 ¶C4 — Scope 3 | Not affected | Yes, if disclosed |
| No relief | Yes | Yes |
Financed emissions
Paragraph B59A: the one place the UK asks for more
UK SRS S2 paragraph B59A adds an explanation where reliable same-period financed emissions are impracticable to estimate.
Explain financed-emissions gapsRequirements and evidence
Module 01 / 03
Same period
Assess the reporting-period alignment of the emissions information.
Module 02 / 03
Impracticability
Document why reliable estimation is impracticable.
Module 03 / 03
Explanation
Provide the required explanation rather than silently omitting the disclosure.
Read the detailed guidance and evidence
Every other UK change is a relaxation or a clarification; B59A is an added duty.
It applies to entities with financed emissions — in practice banks, insurers and asset managers — that cannot estimate those emissions reliably for the same period as their accounts (UK SRS S2).
The FRC restates it: such an entity “is required to explain why, which includes explaining the measurement approach taken”.
One published methodology for measuring financed emissions is that of the Partnership for Carbon Accounting Financials.
The sector view is on UK SRS for financial services.
Annex A, on B59A
Added “to require entities to explain why they have not been able to disclose in line with the financed emissions requirements … if they have determined that it is impracticable to reliably estimate financed emissions for the same reporting period as the related financial statements.”
When each applies
When each standard bites, and for whom
The listing rules set the ordinary sequence for climate disclosures, Scope 3 and wider sustainability matters.
- From 2027 periods01
Climate reporting begins with relevant S1 requirements and available reliefs.
- From 2028 periods02
Scope 3 relief has expired.
- From 2029 periods03
S1 non-climate relief has also expired.
Read the detailed guidance and evidence
For a voluntary user, both standards apply whenever it chooses, with reliefs that have no time limit in the text.
For a company listed in UKLR 6, 14, 15, 16 or 22, the FCA’s rules set the order: UK SRS S2, and the parts of S1 it depends on, from the first accounting period beginning on or after 1 January 2027.
The non-climate part of UK SRS S1 can wait two years from that first period, and Scope 3 one year, while the company states that it is using the relief.
Every limb is comply or explain; nothing in either standard becomes compulsory when a relief ends.
The consultation had proposed a mandatory UK SRS S2; the final rules dropped it and brought secondary listings and depositary receipts in, with the categories defined in UKLR 1.1.
UK SRS S2 is also confirmed as a national reporting framework for section 414CB(6) of the Companies Act, the climate duty that followed the government’s 2021 consultation.
Assurance of either standard is optional; if obtained, ISSA (UK) 5000 is effective for periods beginning on or after 15 December 2026, and the listing rules ask only what was obtained.
The regime’s full sequence is on the UK SRS timeline, and your own first period on the UK SRS deadline; the regulator’s own pages are on the FCA site.
A listed company with a December year-end
- 25 Feb 202601
Both standards available
Voluntary; untimed reliefs.
- 1 Jan 202702
UK SRS S2 and the S1 parts it needs
Comply or explain; Scope 3 and S1 non-climate reliefs available.
- 1 Jan 202803
Scope 3 relief spent
Scope 3 on comply or explain.
- 1 Jan 202904
S1 relief spent
All of UK SRS on comply or explain.
Around the pair
Where the pair meets the rest of the reference
Treat the programme as connected evidence and decisions rather than independent paragraph-writing tasks.
- 1
Scope and materiality
Identify the reporting route and material topics.
- 2
Data and analysis
Build emissions, scenarios, metrics and supporting judgements.
- 3
Review and publish
Map evidence, approve disclosures and retain the record.
Read the detailed guidance and evidence
Scope and the law
UK SRS hub · UK SRS scope · Private companies · Are reports mandatory? · UK SRS regulations · UK SRS requirements · The FCA’s rules · Compliance calculator
Doing the work
UK SRS compliance · Gap analysis · Assurance · ISSA (UK) 5000 · Transition plans · ESG governance · Sustainability software · Carbon management software
Energy and carbon regimes
SECR and UK SRS · SECR thresholds · SECR deadline · SECR exemptions · Is SECR mandatory? · ESOS and UK SRS · ESOS vs SECR
ESOS in detail
ESOS hub · ESOS Phase 4 · Is ESOS mandatory? · ESOS compliance · Energy audits · Action plan · Penalties · Phase 3 vs 4
The EU and ESG
European standards · ESRS · UK SRS vs ESRS · CSRD for UK companies · The CSRD · ESG hub · What is ESG · ESG pillars · ESG vs CSR · ESG reporting requirements
Frameworks and advice
Sustainability reporting · Frameworks · TCFD requirements · ISO 14001 · Sustainability consultancy · Carbon consultancy · Net zero consultancy · CSRD consultancy · CSRD software
For the UK regime in depth, the sister reference is UK Sustainability Reporting Standards, including its guide to the pair and its UK SRS thresholds page.
A free 15-minute call to talk through where your company sits is on book a call; who writes this reference is on about and contact, and every section is listed on all sections.
Frequently asked
UK SRS S1 and S2: the questions asked
What are UK SRS S1 and S2?
UK SRS S1 sets the general requirements for disclosing sustainability-related financial information: materiality, connected information, the four areas of core content, where and when disclosures are published, and the statement of compliance.
UK SRS S2 applies that framework to climate.
Both were issued by the Secretary of State for Business and Trade on 25 February 2026, based on the ISSB’s IFRS S1 and S2.
How do UK SRS S1 and S2 work together?
UK SRS S1 is the framework and UK SRS S2 its first topic.
Paragraph E2 of UK SRS S1 says an entity applies UK SRS S2 at the same time as UK SRS S1.
S2 relies on S1 for its materiality test, its link to the financial statements and its general requirements, and the FCA’s guidance at UKLR 6.6.6A G lists the S1 paragraphs a listed company applies when it makes S2 disclosures.
Are UK SRS S1 and S2 mandatory?
No. Both are voluntary standards.
Companies listed in UKLR 6, 14, 15, 16 and 22 must report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, under the FCA’s final rules in PS26/19.
The consultation had proposed making UK SRS S2 mandatory; the final rules did not.
How many UK amendments are there to IFRS S1 and S2?
No authoritative count exists.
The June 2025 consultation proposed six amendments; two did not survive into the final standards and four further provisions were added.
Annex A of the government response maps every difference and carries no total.
Is single materiality a UK amendment?
No. IFRS S1 and S2 and UK SRS S1 and S2 all use financial materiality.
The contrast with double materiality is between the ISSB-based standards and the EU’s ESRS, not between UK SRS and IFRS.
What does paragraph 73A of UK SRS S1 do?
It is a UK-only paragraph on the statement of compliance.
An entity using the climate-only relief in UK SRS S1 paragraph E3 may not assert compliance with UK SRS S1 and must disclose its use of the relief instead.
Using that relief or the UK SRS S2 reliefs in paragraphs C3 and C4 does not prevent an entity asserting compliance with UK SRS S2, provided it discloses the reliefs used.
What is paragraph B59A of UK SRS S2?
A paragraph the UK added.
Where an entity determines it is impracticable to estimate financed emissions reliably for the same reporting period as its financial statements, B59A requires it to explain why.
It is the one place UK SRS asks for more than IFRS S2.
Which comes first, UK SRS S1 or S2?
Under the FCA’s rules, UK SRS S2 and the parts of UK SRS S1 that climate disclosure needs apply from the first accounting period beginning on or after 1 January 2027.
The rest of UK SRS S1 — non-climate risks and opportunities — has two years’ relief, so it is addressed on a comply-or-explain basis from periods beginning on or after 1 January 2029.
Fictional example
One risk, two standards working together
A fictional climate risk uses S1’s general reporting rules and S2’s climate-specific requirements together.
A fictional climate disclosureRequirements and evidence
Module 01 / 03
S1 materiality
Explain why the risk matters to financial prospects.
Module 02 / 03
S2 detail
Explain exposure, response, resilience and relevant metrics.
Module 03 / 03
Connection
Link assumptions to strategy and financial information.
Read the detailed guidance and evidence
This is a fictional disclosure-planning illustration, not an assessed report.
Preparation
Build a connected reporting package
A connected report can cross-refer shared governance and risk-management information while retaining clear climate-specific detail.
Avoid duplicate explanationsRequirements and evidence
Module 01 / 03
Shared process
Explain the common oversight and risk-management process.
Module 02 / 03
Specific risk
Show how that process addresses climate.
Module 03 / 03
Evidence location
Make the reader’s route between disclosures clear.
Read the detailed guidance and evidence
This is editorial presentation advice supporting the standards’ connected-information requirements.
Prepare the evidence
UK SRS s1 and s2 timeline: from a requirement to a reporting pack
Use this preparation sequence alongside the detailed requirements on this page.
An editorial workflow, not a statutory schedule.
- Stage 0101
Applicability
Record the listing category or voluntary reporting decision.
- Stage 0202
Period and boundary
Set the reporting entity and period before collecting disclosures.
- Stage 0303
Materiality
Document the financial materiality judgements behind the disclosures.
- Stage 0404
Governance and strategy
Connect oversight, strategy and risk management to the reporting evidence.
- Stage 0505
Metrics and reliefs
Record methods, estimates, targets and any relief actually used.
- Stage 0606
Connected publication
Reconcile the disclosure pack with the annual report and approval record.
Read the applicable instrument: UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
A practical brief
An evidence pack, with a clear review trail
Ask for a pack that lets the next reviewer retrace the scope decision, follow the evidence and understand the limitations.
This describes a useful handover; it does not certify compliance or establish that a vendor or adviser delivers it.
Trace the answerScope → evidence → review
Module 01 / 04
Applicability record
Write down the entity, reporting route and relevant period, including why the route applies.
Module 02 / 04
Evidence register
Attach each reported figure or statement to its source, method, version and limitations.
Module 03 / 04
Review trail
Name the preparer, reviewer, open questions and decisions taken before publication.
Module 04 / 04
Usable handover
Retain the working files and unresolved actions so the next reporting cycle can reuse the evidence.
View the preparation diagram
- Prepare01
Create the traceable pack
Keep the input records, calculation files and narrative together.
- Challenge02
Resolve questions before publication
Record the assumptions challenged and any limitations still unresolved.
- Retain03
Make the next cycle reproducible
Keep the approved version and the actions carried forward.
Continue your research
Related guides, one question at a time
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 20 sources fromDepartment for Business and TradeFinancial Conduct AuthorityFinancial Reporting CouncilIFRS FoundationTCFDGHG Protocol
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026, “issued by the Secretary of State for Business and Trade”.
- Department for Business and TradeUK SRS S1 — General requirements (PDF), ¶¶17–25, 60–73B, Appendix E
Materiality, connected information, core content, statement of compliance, application and transition.
- Department for Business and TradeUK SRS S2 — Climate-related disclosures (PDF), ¶¶12, 23, 32, B59A, Appendix C
The SASB “may”, the financed-emissions explanation and the untimed Scope 3 relief.
- Department for Business and TradeConsultation response (PDF), Annex A — the mapping of every difference from IFRS
“Where requirements in the standards are not included in the table, there are no differences between the two.” No count.
- Department for Business and TradeGovernment response to the consultation on UK SRS (web version)
¶1.6: 209 responses; ¶1.17: 68% (125 of 184) agreed the four TAC amendments; Chapter 3: s.414CB(6) and s.463.
- Department for Business and TradeExposure drafts of UK SRS — consultation page
“The government proposes 6 minor amendments” — the June 2025 count of proposals.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
Voluntary for any entity.
- Department for Business and TradeLetter to the FCA, 5 January 2026 (PDF)
Why the reliefs lost their time limits, and why ¶73A exists.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Comply or explain across UK SRS; the reliefs’ periods (¶3.14).
- Financial Conduct AuthorityPS26/19 (PDF), Appendix 1 — UKLR 6.6.6R(7A), (7B) and UKLR 6.6.6A G
The paragraphs of UK SRS S1 a company is “reminded” to apply with S2.
- Financial Conduct AuthorityDraft Technical Note 803.1
Proposed guidance: explaining and an unreserved compliance statement do not go together.
- Financial Reporting CouncilSustainability reporting developments: frequently asked questions
On B59A and on untimed reliefs for voluntary users.
- Financial Reporting CouncilUK Sustainability TAC issues final recommendations, 18 December 2024
- IFRS FoundationIFRS S1 General Requirements
- IFRS FoundationIFRS S2 Climate-related Disclosures
- IFRS FoundationISSB issues targeted amendments to IFRS S2, December 2025
Absorbed into UK SRS S2; the ISSB’s changes, not the UK’s.
- IFRS FoundationSASB Standards
Maintained by the ISSB.
- TCFDRecommendations of the Task Force on Climate-related Financial Disclosures
The four areas: governance, strategy, risk management, metrics and targets.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
- legislation.gov.ukCompanies Act 2006, section 414CB
UK SRS S2 a national framework for s.414CB(6).