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UK SRSThe UK Sustainability Reporting Standards, ESOS, SECR and TCFD, read against the published text.HUBUK SRS GuideAn independent reference guide to UK SRS, ESG, TCFD, SECR, ESOS and the global standards.YOU ARE HEREGlobal Reporting StandardsSustainability reporting standards worldwide: ISSB, the EU CSRD after Omnibus I, California SB 253 and SB 261, and UK SRS.UK SRS StandardsUK SRS S1 and S2 at the provision: reliefs, comply or explain, and the FCA statements.ESOS QuestESOS Phase 4 in depth: qualification, the audit, sign-off, action plans and penalties, read against the Regulations.SRS EngineeringThe data build behind a UK SRS report: metrics, owners, controls and timing.SRS ReportWhat a UK SRS report contains, how it is assembled, and how to read one.UK SRS ReportAnalysis and commentary: CDP, the DESNZ emission factors, SECR and ESOS, with every figure cited.UK SRS NewsThe cluster's news publication, and what a UK SRS report contains.UK SRS DeliveryTemplates, costs, ESOS delivery guides and readiness assessment.UK SRS FinanceFinanced emissions, PCAF and IFRS S1/S2 for banks, insurers and asset managers.SECRStreamlined Energy and Carbon Reporting: deadlines, thresholds, eligibility and guidance.Carbon CreditsCarbon credit ratings, risk analysis, valuation and market structure.Environmental RegimesThe eight UK environmental reporting regimes, their thresholds, deadlines and regulators.UK SRS ServicesThe services arm: ESOS, SECR, net zero and sustainability consultancy.

Comparison · the standards themselves

UK SRS vs ESRS

UK SRS vs ESRS is a comparison of two texts: the UK’s UK SRS S1 and S2 and the EU’s twelve European Sustainability Reporting Standards, revised by Delegated Regulation (EU) 2026/1563.

They agree on what financial materiality means and disagree on almost everything built on top of it.

This page sets the paragraphs side by side for a group that has to report under both, climate first because that is where most of the work overlaps.

Two texts

Where the two sets come from

UK SRS S1 and S2 are the ISSB’s standards — see the IFRS Sustainability Standards Navigator — endorsed for the UK, with every change listed in Annex A of the government’s response.
Evidence mapRequirements and evidence

Module 01 / 04

Author

Department for Business and Trade
European Commission, on EFRAG’s drafts
UK SRSESRS
AuthorDepartment for Business and TradeEuropean Commission, on EFRAG’s drafts
Built onIFRS S1 and S2, endorsed with UK amendmentsThe EU’s own standards
Legal formStandards for voluntary useAn EU delegated regulation
What makes a company use themFCA Listing Rules: comply or explainThe CSRD: must report if in scope
Current textFebruary 2026Revised, published 21 September 2026
Read the detailed guidance and evidence

UK SRS S1 and S2 are the ISSB’s standards — see the IFRS Sustainability Standards Navigator — endorsed for the UK, with every change listed in Annex A of the government’s response.

The ESRS were drafted by EFRAG, which describes its role as giving technical advice to the Commission from its sustainability reporting hub, and made law by the Commission as Delegated Regulation (EU) 2023/2772.

The ESRS exist because the CSRD requires them; UK SRS exists as a standard first, with rules attached afterwards.

The FCA’s final rules put UK-listed companies on comply or explain against UK SRS for accounting periods beginning on or after 1 January 2027; the consultation had proposed mandatory UK SRS S2.

How the two regimes compare as law is on UK SRS vs CSRD.

Structure

Two standards against twelve

UK SRS organises disclosure around four pillars inherited from the TCFD: governance, strategy, risk management, and metrics and targets.
StandardRequirements and evidence

Module 01 / 04

S1 — general requirements and core content

ESRS 1 (rules) and ESRS 2 (general disclosures)
UK SRSNearest ESRS
S1 — general requirements and core contentESRS 1 (rules) and ESRS 2 (general disclosures)
S1 — any other material sustainability risk or opportunityE2–E5, S1–S4, G1, where material
S2 — climateE1
S1 ¶25: governance, strategy, risk management, metrics and targetsESRS 1 reporting areas; ESRS 2 GOV, SBM, IRO; GDR-P, A, M, T
Read the detailed guidance and evidence

UK SRS organises disclosure around four pillars inherited from the TCFD: governance, strategy, risk management, and metrics and targets.

ESRS organises it by reporting area across twelve standards, with ESRS 2 carrying the disclosures every company makes and each topical standard applying only if material, as revised ESRS 1 sets out.

UK SRS S1 has no topical standards: any sustainability matter other than climate is reported under S1’s general requirements, where it is financially material.

The ESRS topics outside climate — pollution, water, biodiversity, circularity, the four groups of people, business conduct — have no dedicated UK counterpart.

What each ESRS standard covers is on ESRS explained, standard by standard.

Materiality

The same financial test, and one test the UK does not have

The interoperability guidance of EFRAG and the IFRS Foundation says the definition of financial materiality in ESRS is aligned with the definition of materiality in IFRS S1.
Evidence mapRequirements and evidence

Module 01 / 04

Materiality

The interoperability guidance of EFRAG and the IFRS Foundation says the definition of financial materiality in ESRS is aligned with the definition of materiality in IFRS S1.

At the provision

UK SRS S1 ¶18

Material if it “could reasonably be expected to influence decisions that primary users of general purpose financial reports make”.

Revised ESRS 1 ¶23

Material if it could influence decisions of primary users (a), or of other users about the undertaking’s impacts, risks and opportunities (b).

Read the detailed guidance and evidence

The interoperability guidance of EFRAG and the IFRS Foundation says the definition of financial materiality in ESRS is aligned with the definition of materiality in IFRS S1.

Revised ESRS 1 ¶47 tests financial materiality by effects on development, financial position, performance, cash flows, access to finance or cost of capital — close to UK SRS S1 ¶3.

What UK SRS lacks is the impact perspective, and ESRS 1 ¶4 names the readers it serves: investors and lenders, and also business partners, trade unions, civil society and NGOs.

So a group that has done the UK SRS assessment has done roughly the financial half of the ESRS one.

UK SRS S1 also sets no numerical threshold for materiality (¶B19), and revised ESRS 1 says quantitative scoring is not necessarily required.

The two concepts are explained on double materiality.

Climate

UK SRS S2 against ESRS E1, paragraph by paragraph

Climate is where a group reporting under both saves most work, and where the small differences cost most if missed.

Inventory boundaryRead all decisions below

Module 01 / 03

Inventory boundary

For Scope 1 and 2, disclose the consolidated-group and other-investee split within the chosen inventory boundary.
UK SRS S2 (DBT, 25 February 2026); revised ESRS E1 from the 3 July 2026 delegated act as rendered on EFRAG’s Knowledge Hub.
DisclosureUK SRS S2Revised ESRS E1
Transition planInformation about any plan the entity has (¶14(a)(iv))Key features of the plan (¶12); if none, say so and whether and when one will be adopted (¶13)
Scenario analysisRequired, to assess climate resilience (¶22)Disclosures prescribed “if climate-related scenario analysis is used” (¶17, AR 6)
Scope 1Absolute gross (¶29(a)(i))Absolute gross, with the share from the EU ETS (¶30(a)(i))
Scope 2Location-based required; market-based permitted (¶29(a)(v), ¶B30–B31)Location-based and market-based (¶30(a)(ii))
Scope 3All fifteen categories considered; disclose which are included (¶B32)Each significant category, as a total and per category (¶30(a)(iii))
Boundary splitScope 1 and 2 split between the consolidated accounting group and other investees within the chosen emissions boundary (¶29(a)(iv))Scope 1 and 2 split between the consolidated group and other emissions (¶30(c))
Biogenic CO₂—Reported separately from Scope 1 (¶31)
TargetsState whether gross or net (¶36(c))Gross targets: no removals, credits or avoided emissions (AR 12)
Carbon creditsPlanned use to meet a net target (¶36(e))Removals and credits disclosed separately (E1-9)
Financed emissionsExplain if impracticable for the same period (¶B59A, UK only)Within Scope 3 category 15, with an intensity-target exemption for financial institutions (AR 13)

Scope 2 is the difference that most often catches a dual reporter: UK SRS S2 is satisfied by one location-based number, and ESRS E1 is not.

Scenario analysis runs the other way: UK SRS S2 requires it, and ESRS E1 prescribes what to disclose only where a company uses it.

Neither standard makes a company have a transition plan; ESRS makes the absence visible in the report, and the FCA’s rules ask a UK-listed company whether it has published one and, if not, why.

Both count emissions gross, so an offset never reduces a reported inventory under either.

UK SRS S2 in full is on UK SRS S2, and the ISSB original on IFRS S2.

Who uses which

Who reports under each, and when both apply

UK SRS reaches a company because of where its shares are listed; ESRS reaches it because of how big its EU operations are.
DisclosureRequirements and evidence

Module 01 / 04

Voluntary use

Available to any entity
A separate voluntary standard, DR (EU) 2026/1560, for undertakings outside mandatory reporting
UK SRSESRS
Voluntary useAvailable to any entityA separate voluntary standard, DR (EU) 2026/1560, for undertakings outside mandatory reporting
Required forComply or explain: UKLR 6, 14, 15, 16, 22CSRD scope: >1,000 employees and >€450m
FromAccounting periods from 1 January 2027Financial years from 1 January 2027
UK group reachedDirectly, by listingThrough an EU subsidiary or branch
Read the detailed guidance and evidence

UK SRS reaches a company because of where its shares are listed; ESRS reaches it because of how big its EU operations are.

A UK-listed group with a large EU subsidiary can owe both from 2027: comply or explain in its UK annual report, and an ESRS statement from the subsidiary.

Under the FCA’s explain limb for UK SRS S2, a company summarises the requirements it has not met, why, and what it plans to do.

A group that maps its ESRS climate work to UK SRS S2 can therefore explain the gaps rather than build a second process — but it has to do the mapping.

How the EU regime reaches a UK business is on CSRD for UK companies.

Dual reporting

One data platform, two presentations

A group that owes both usually ends up with one data platform and two reports, with the impact assessment and the non-climate topical standards carried as ESRS-only work.
Evidence mapRequirements and evidence

Module 01 / 04

Boundary

A group that owes both usually ends up with one data platform and two reports, with the impact assessment and the non-climate topical standards carried as ESRS-only work.
What cannot be shared

The impact half of the ESRS materiality assessment.

The market-based Scope 2 figure, if the UK report does not already carry it.

The ESRS-only topics a group finds material.

The ESRS 2 Appendix A table of datapoints from other EU law.

Read the detailed guidance and evidence

A group that owes both usually ends up with one data platform and two reports, with the impact assessment and the non-climate topical standards carried as ESRS-only work.

The interoperability guidance is the starting map for climate, with two warnings on its face: it is not a formal statement of equivalence, and it maps the 2023 ESRS.

Paragraph numbers moved in the revision, so a mapping built on the 2023 text needs re-keying against the revised annex.

Two commentaries on the process difference, useful as reading rather than as sources for any figure: Deloitte’s Heads Up on the ESRS double materiality assessment and an ISSB-versus-ESRS process analysis.

Dates

The dates, in both jurisdictions

UK SRS S1 and S2 were published on 25 February 2026, and the ESRS revision was published on 21 September 2026.
Evidence mapRequirements and evidence

Module 01 / 04

Key point 01

UK SRS S1 and S2 were published on 25 February 2026, and the ESRS revision was published on 21 September 2026.
Read the detailed guidance and evidence

UK SRS S1 and S2 were published on 25 February 2026, and the ESRS revision was published on 21 September 2026.

Both bite on the year beginning 1 January 2027: accounting periods under the FCA’s rules, financial years under the revised ESRS.

Under the FCA rules, Scope 3 relief lasts one year and the UK SRS S1 non-climate relief two, after which those topics are comply or explain, not mandatory.

For financial year 2026 an EU reporter may use the 2023 ESRS, the revised set, or the 2023 set with eight named reliefs, and must say which.

The EU dates are set out on the European Sustainability Reporting Standards.

Frequently asked

Questions people ask

What is the main difference between UK SRS and ESRS?

Materiality.

UK SRS S1 treats information as material if it could reasonably be expected to influence the decisions of investors, lenders and other creditors, judged by effects on cash flows, access to finance or cost of capital.

ESRS applies double materiality: information is reported if it is material from the impact perspective, the financial perspective, or both.

The ESRS financial definition is aligned with the ISSB’s; the impact perspective has no UK SRS equivalent.

How many standards does each have?

UK SRS has two: UK SRS S1 on general requirements and UK SRS S2 on climate.

ESRS has twelve: ESRS 1 and ESRS 2, which are cross-cutting, and ten topical standards covering climate, pollution, water, biodiversity, resource use, own workforce, value-chain workers, affected communities, consumers and business conduct.

Can UK SRS disclosures satisfy ESRS?

Only in part.

Climate is where most information carries across, but ESRS E1 asks for things UK SRS S2 does not require, such as a market-based Scope 2 figure alongside the location-based one, and it applies double materiality to decide which other topics are reported.

UK SRS compliance does not discharge an ESRS obligation, and the reverse is also true.

Does ESRS require scenario analysis?

Not in terms.

Revised ESRS E1 requires a company to describe how it identifies and assesses climate risks, and sets out what it must disclose if it uses climate scenario analysis.

UK SRS S2 paragraph 22 requires climate-related scenario analysis to assess climate resilience.

Do UK SRS and ESRS require a transition plan?

Neither requires a company to have one.

UK SRS S2 paragraph 14(a)(iv) asks for information about any climate-related transition plan the entity has.

Revised ESRS E1 asks for the key features of a transition plan and, if the company has none, requires it to say so and whether and when it expects to adopt one.

Separately, the FCA’s rules ask a UK-listed company whether it has published a transition plan and, if not, why.

Which Scope 2 figure do UK SRS and ESRS require?

UK SRS S2 requires location-based Scope 2 and permits a market-based figure as additional information.

Revised ESRS E1 requires gross Scope 2 on both the location-based and market-based methods.

A group reporting under both needs both figures for ESRS.

Is UK SRS stricter than IFRS anywhere?

In one place.

UK SRS S2 paragraph B59A requires an entity to explain why it could not disclose financed emissions for the same reporting period as its financial statements, where it has found that impracticable.

Every other UK difference from IFRS S1 and S2 is permissive.

Prepare the evidence

UK SRS vs ESRS: 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.

  1. Stage 0101

    Applicability and timing

    Check the entity, group, jurisdiction and reporting year against the current instrument.

  2. Stage 0202

    Materiality

    Document the assessment needed for the applicable reporting standard.

  3. Stage 0303

    Value-chain requests

    Scope the information requests and any applicable supplier protection.

  4. Stage 0404

    Disclosure pack

    Connect the applicable datapoints to controlled records and responsible owners.

  5. Stage 0505

    Review and assurance

    Check the applicable legal assurance route and implementation dates.

  6. Stage 0606

    Publication

    Resolve the report location, format and filing requirements for the entity.

Read the applicable instrument: UK SRS S1 and UK SRS S2, 25 February 2026

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.

View the preparation diagramUK SRS vs ESRS: evidence preparation sequenceUK SRS vs ESRS: evidence preparation sequence
  1. Prepare01

    Create the traceable pack

    Keep the input records, calculation files and narrative together.

  2. Challenge02

    Resolve questions before publication

    Record the assumptions challenged and any limitations still unresolved.

  3. Retain03

    Make the next cycle reproducible

    Keep the approved version and the actions carried forward.

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 17 sources fromDepartment for Business and TradeFinancial Conduct AuthorityEUR-LexEFRAGEFRAG and IFRS FoundationIFRS Foundation
  1. Department for Business and Trade
    UK SRS S1 and UK SRS S2, 25 February 2026
  2. Department for Business and Trade
    UK SRS S1 — ¶3, ¶18, ¶B19

    Financial materiality; primary users; no numerical threshold.

  3. Department for Business and Trade
    UK SRS S2 — ¶14(a)(iv), ¶22, ¶29(a), ¶36(c), ¶36(e), ¶B30–B32, ¶B59A, ¶C4

    Transition plan if one exists; scenario analysis; gross emissions; location-based Scope 2; Scope 3 categories considered.

  4. Department for Business and Trade
    Exposure drafts of UK SRS: government response, Annex A

    Every UK difference from IFRS S1 and S2.

  5. Financial Conduct Authority
    PS26/19 (PDF) — ¶3.6, ¶3.12, ¶3.14 and Appendix 1 (UKLR 6.6.6R(7A), (8)(e))

    Comply or explain for listed companies; the explain limb; the transition-plan statement.

  6. Financial Conduct Authority
    CP26/5 — the consultation the final rules replaced
  7. EUR-Lex
    Commission Delegated Regulation (EU) 2026/1563 — the revised ESRS

    Published 21 September 2026; applies to financial years from 1 January 2027.

  8. EUR-Lex
    Commission Delegated Regulation (EU) 2023/2772 — ESRS Set 1, Article 1 and Annex I
  9. EUR-Lex
    Directive (EU) 2022/2464 — the CSRD
  10. EFRAG
    Revised ESRS 1 General requirements (¶2, ¶4, ¶23–24, ¶47)

    Double materiality; users; information materiality; financial materiality.

  11. EFRAG
    Revised ESRS 2 General disclosures (IRO-1, IRO-2)
  12. EFRAG
    Revised ESRS E1 Climate change (¶12–13, ¶17, ¶30–31, AR 6, AR 12)

    Transition plan; scenario analysis “if used”; Scope 2 on both methods; gross targets.

  13. EFRAG
    Sustainability reporting — the standard-setter’s hub
  14. EFRAG and IFRS Foundation
    ESRS–ISSB Standards Interoperability Guidance, 2 May 2024 (IFRS copy)

    Introduction and §1.1: the financial-materiality definition is aligned; the regimes are not.

  15. EFRAG and IFRS Foundation
    ESRS–ISSB Standards Interoperability Guidance (EFRAG copy)
  16. IFRS Foundation
    IFRS Sustainability Standards Navigator
  17. IFRS Foundation
    IFRS S1 General Requirements
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