UK SRS vs IFRS S1 and S2

The Relationship Between UK SRS and the ISSB Standards

UK SRS S1 and S2 are the UK's national adoptions of IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate-related Disclosures) respectively. The UK Technical Advisory Committee (TAC), chaired by the FRC, recommended endorsement of the ISSB standards with four minor amendments tailored to the UK regulatory context. The Department for Business and Trade adopted these recommendations when it published UK SRS on 25 February 2026.

The amendments are deliberately narrow. The TAC's stated objective was to maintain maximum alignment with the global baseline to support international comparability and minimise the reporting burden for companies operating across jurisdictions. A company that complies with UK SRS will be substantially aligned with IFRS S1 and S2.

Where UK SRS Is Identical to IFRS S1 and S2

The vast majority of UK SRS is identical to the ISSB standards. This includes the four-pillar disclosure framework (Governance, Strategy, Risk Management, Metrics and Targets), the definition of materiality, the connectivity principle between sustainability and financial reporting, the climate scenario analysis requirements, the Scope 1, 2, and 3 emissions disclosure requirements, and the transition plan disclosure obligations. The disclosure requirements within each pillar, the guidance on identifying material sustainability topics, and the general approach to presentation and timing are all carried over without modification.

The Four UK-Specific Amendments

1. Removal of the First-Year Publication Delay

IFRS S1 includes a transitional relief allowing companies, in their first year of adoption, to publish sustainability disclosures after their financial statements rather than at the same time. UK SRS removes this relief. Companies adopting UK SRS must publish sustainability disclosures simultaneously with their annual report from year one. The rationale is that UK SRS disclosures are made within the Strategic Report, which is an integral part of the annual report — a delayed publication would be inconsistent with the statutory filing framework.

2. SASB Reference Changed from Mandatory to Permissive

IFRS S1 paragraph 55 directs companies to consider SASB Standards and the CDSB Framework when identifying material sustainability topics and associated disclosures, using the word “shall.” UK SRS amends this to “may” — companies may consider SASB Standards but are not required to do so. This change reflects the UK TAC's view that while SASB Standards can be a useful reference, making them a mandatory consideration could create confusion given their US-centric industry classifications and the existence of other credible sector-specific guidance.

3. Reporting Period Timing Alignment

UK SRS clarifies how the sustainability reporting period aligns with the financial reporting period under UK Companies Act requirements. This ensures that the period covered by sustainability disclosures in the Strategic Report matches the financial year of the annual report, which is a requirement of the statutory filing framework. In practice, this alignment already existed for most UK companies but the amendment removes any ambiguity.

4. Connectivity with Companies Act Reporting

UK SRS establishes an explicit connection between sustainability disclosures and the Companies Act reporting framework. UK SRS S2 is confirmed as a national reporting framework under s414CB of the Companies Act. This means sustainability disclosures made within the Strategic Report benefit from s463 liability protections — directors are shielded from civil liability unless statements are knowingly untrue or reckless. This amendment is arguably the most practically significant of the four, as it directly affects the legal exposure of company directors making UK SRS disclosures.

What This Means for Multi-Jurisdictional Reporting

Companies reporting under UK SRS and simultaneously subject to sustainability reporting requirements in other ISSB-aligned jurisdictions — such as Australia (ASRS), Singapore, Japan, or Nigeria — will find substantial overlap. The four UK amendments are narrow enough that a company complying with UK SRS can make a credible claim of alignment with the ISSB global baseline. However, companies also subject to the EU Corporate Sustainability Reporting Directive (CSRD) face a more complex interoperability question, as CSRD uses double materiality while UK SRS (like IFRS S1) uses single materiality focused on enterprise value.

The practical implication is that for most global companies, UK SRS compliance does not require a separate reporting workstream from ISSB compliance. The incremental effort is in understanding the four amendments and ensuring disclosures are placed within the Strategic Report as required by the Companies Act framework.