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
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Author
Module 02 / 04
Built on
Module 03 / 04
Legal form
Module 04 / 04
What makes a company use them
| UK SRS | ESRS | |
|---|---|---|
| Author | Department for Business and Trade | European Commission, on EFRAG’s drafts |
| Built on | IFRS S1 and S2, endorsed with UK amendments | The EU’s own standards |
| Legal form | Standards for voluntary use | An EU delegated regulation |
| What makes a company use them | FCA Listing Rules: comply or explain | The CSRD: must report if in scope |
| Current text | February 2026 | Revised, 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
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S1 — general requirements and core content
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S1 — any other material sustainability risk
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S2 — climate
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S1 ¶25: governance, strategy, risk managemen
| UK SRS | Nearest ESRS |
|---|---|
| S1 — general requirements and core content | ESRS 1 (rules) and ESRS 2 (general disclosures) |
| S1 — any other material sustainability risk or opportunity | E2–E5, S1–S4, G1, where material |
| S2 — climate | E1 |
| S1 ¶25: governance, strategy, risk management, metrics and targets | ESRS 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
Module 01 / 04
Materiality
Module 02 / 04
Materiality · 2
Module 03 / 04
Key point 03
Module 04 / 04
Boundary
At the provision
Material if it “could reasonably be expected to influence decisions that primary users of general purpose financial reports make”.
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.
Module 01 / 03
Inventory boundary
Module 02 / 03
Scope 2 information
Module 03 / 03
Version mapping
| Disclosure | UK SRS S2 | Revised ESRS E1 |
|---|---|---|
| Transition plan | Information 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 analysis | Required, to assess climate resilience (¶22) | Disclosures prescribed “if climate-related scenario analysis is used” (¶17, AR 6) |
| Scope 1 | Absolute gross (¶29(a)(i)) | Absolute gross, with the share from the EU ETS (¶30(a)(i)) |
| Scope 2 | Location-based required; market-based permitted (¶29(a)(v), ¶B30–B31) | Location-based and market-based (¶30(a)(ii)) |
| Scope 3 | All fifteen categories considered; disclose which are included (¶B32) | Each significant category, as a total and per category (¶30(a)(iii)) |
| Boundary split | Scope 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) |
| Targets | State whether gross or net (¶36(c)) | Gross targets: no removals, credits or avoided emissions (AR 12) |
| Carbon credits | Planned use to meet a net target (¶36(e)) | Removals and credits disclosed separately (E1-9) |
| Financed emissions | Explain 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
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Voluntary use
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Required for
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From
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UK group reached
| UK SRS | ESRS | |
|---|---|---|
| Voluntary use | Available to any entity | A separate voluntary standard, DR (EU) 2026/1560, for undertakings outside mandatory reporting |
| Required for | Comply or explain: UKLR 6, 14, 15, 16, 22 | CSRD scope: >1,000 employees and >€450m |
| From | Accounting periods from 1 January 2027 | Financial years from 1 January 2027 |
| UK group reached | Directly, by listing | Through 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
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Boundary
Module 02 / 04
Key point 02
Module 03 / 04
Key point 03
Module 04 / 04
Materiality
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
Module 01 / 04
Key point 01
Module 02 / 04
Reporting period
Module 03 / 04
Scope 3
Module 04 / 04
Reliefs
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.
- Stage 0101
Applicability and timing
Check the entity, group, jurisdiction and reporting year against the current instrument.
- Stage 0202
Materiality
Document the assessment needed for the applicable reporting standard.
- Stage 0303
Value-chain requests
Scope the information requests and any applicable supplier protection.
- Stage 0404
Disclosure pack
Connect the applicable datapoints to controlled records and responsible owners.
- Stage 0505
Review and assurance
Check the applicable legal assurance route and implementation dates.
- 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.
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.
- Department for Business and TradeUK SRS S1 and UK SRS S2, 25 February 2026
- Department for Business and TradeUK SRS S1 — ¶3, ¶18, ¶B19
Financial materiality; primary users; no numerical threshold.
- Department for Business and TradeUK 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.
- Department for Business and TradeExposure drafts of UK SRS: government response, Annex A
Every UK difference from IFRS S1 and S2.
- Financial Conduct AuthorityPS26/19 (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.
- Financial Conduct AuthorityCP26/5 — the consultation the final rules replaced
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — the revised ESRS
Published 21 September 2026; applies to financial years from 1 January 2027.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — ESRS Set 1, Article 1 and Annex I
- EUR-LexDirective (EU) 2022/2464 — the CSRD
- EFRAGRevised ESRS 1 General requirements (¶2, ¶4, ¶23–24, ¶47)
Double materiality; users; information materiality; financial materiality.
- EFRAGRevised ESRS 2 General disclosures (IRO-1, IRO-2)
- EFRAGRevised 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.
- EFRAGSustainability reporting — the standard-setter’s hub
- EFRAG and IFRS FoundationESRS–ISSB Standards Interoperability Guidance, 2 May 2024 (IFRS copy)
Introduction and §1.1: the financial-materiality definition is aligned; the regimes are not.
- EFRAG and IFRS FoundationESRS–ISSB Standards Interoperability Guidance (EFRAG copy)
- IFRS FoundationIFRS Sustainability Standards Navigator
- IFRS FoundationIFRS S1 General Requirements
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