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UK Sustainability Reporting Standards 2025 · the draft year

UK Sustainability Reporting Standards in 2025: the draft year

The UK Sustainability Reporting Standards of 2025 were drafts: the government consulted on exposure drafts of UK SRS S1 and S2 from 25 June to 17 September 2025.

The final standards came on 25 February 2026, so no UK SRS obligation of any kind applied in 2025.

What 2025 did produce was the consultation that shaped them, three decisions around them, and the ISSB’s own changes that the final UK text absorbed.

The name

There is no “UK SRS 2025” — there were 2025 drafts

People searching for the UK Sustainability Reporting Standards 2025 usually want one of two things: the drafts, or what they had to report in 2025.

The drafts were published on 25 June 2025 by the Department for Business and Trade, and the final UK SRS S1 and S2 on 25 February 2026, with no effective date.

What UK companies had to report in 2025 came from regulations that already existed, set out beside this section.

The listing-rule climate disclosures in force in 2025 were still TCFD-aligned; the rules that replace them were made in 2026 and published in PS26/19.

The full set of UK obligations by instrument is on ESG reporting requirements in the UK.

What bound UK organisations during 2025.
In 2025Status
SECRIn force since 1 April 2019
Companies Act climate disclosuresFinancial years from 6 April 2022
FCA TCFD-aligned listing rulesIn force
ESOS Phase 4Running, from 6 December 2023
FCA SDR, anti-greenwashing ruleIn force since 31 May 2024
UK SRS S1 and S2Exposure drafts only

Month by month

2025, from exposure draft to amended IFRS S2

The year began with the Technical Advisory Committee’s advice already in hand: its final recommendations, published on 18 December 2024, backed endorsing IFRS S1 and S2 with minor amendments.

On 25 June 2025 the government opened three consultations together: the UK SRS exposure drafts, an oversight regime for assurance, and transition plan requirements; all three closed on 17 September.

On 15 July the government decided not to take a UK Green Taxonomy forward.

On 21 October a Written Ministerial Statement announced the Modernisation of Corporate Reporting programme and said “a broad consultation will be delivered in 2026”.

On 12 November the FRC issued ISSA (UK) 5000, effective for periods beginning on or after 15 December 2026, and on 3 December the PRA’s SS5/25 replaced its 2019 climate-risk expectations.

In December the ISSB issued targeted amendments to IFRS S2, which the UK built into UK SRS S2 before publication.

  1. Dec 2024
    TAC recommends endorsement

    Agreed 5 December, published 18 December.

  2. 25 Jun
    Three consultations open

    Exposure drafts, assurance oversight, transition plans.

  3. 15 Jul
    Green taxonomy not taken forward
  4. 17 Sep
    All three close
  5. 21 Oct
    Modernisation of Corporate Reporting announced

    WMS HCWS973.

  6. 12 Nov
    ISSA (UK) 5000 issued

    For voluntary use by assurers.

  7. 3 Dec
    PRA SS5/25 commences
  8. Dec
    ISSB amends IFRS S2

    Later built into UK SRS S2.

The consultation

What the 2025 consultation proposed, and who answered

The consultation page put it in one line: “The government proposes 6 minor amendments to the standards for application in a UK context” (DBT).

Four of the six were the TAC’s recommendations and two came from the government’s Policy and Implementation Committee.

The TAC’s included extending the climate-first relief from one year to two and revising the requirement to use GICS when breaking down financed emissions.

Among online respondents who gave an organisation type, listed companies and representative bodies were the most common, followed by unlisted companies and investors (¶1.7).

The DBT’s letter to the FCA of 5 January 2026 described “more than 200 responses”; the final count on the outcome page is 209.

How the ISSB texts behind the drafts fit together is on IFRS S1 and S2, and on the IFRS Foundation’s navigator.

Government response ¶¶1.6, 1.17 (DBT).
RespondentsCount
Total209
Online survey170
Email to DBT39
Organisations199
Individuals10
Agreed the four TAC amendments125 of 184 (68%)

What the proposals became

Two proposals fell away, four provisions arrived

The 2025 proposals did not all survive into February 2026.

The two-year climate-first relief was replaced by no time limit at all, and the Scope 3 relief lost its one-year limit too, leaving timing to legislation or FCA rules.

The GICS proposal was withdrawn because the ISSB made the same change itself in December 2025.

Four provisions not in the drafts were added: UK SRS S1 ¶¶73A and 73B on the statement of compliance and on UK law, ¶E5, and UK SRS S2 ¶B59A on financed emissions (Annex A).

Each proposal against its final form is set out on the UK SRS consultations, and the final pair on UK SRS S1 and S2.

Why “six amendments” is not a count of the final standards

Six was the number proposed in June 2025.

The final differences are mapped in Annex A of the government response, which carries no total.

Publication

What the drafts became on 25 February 2026

The final UK SRS S1 and UK SRS S2 were published with the government response on 25 February 2026, issued by the Secretary of State for Business and Trade.

They carry no effective date, and the government’s guidance says they are “available for voluntary use, by any entity that chooses to do so”.

The response also confirms UK SRS S2 as a national framework for section 414CB(6) of the Companies Act, and that section 463’s protection applies to UK SRS disclosure in the strategic report.

What came after

After 2025: comply or explain, from 2027

The FCA consulted on listing rules in January 2026, in CP26/5 (consultation page), and published its final rules on 30 September 2026 in PS26/19.

Companies listed in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reporting in 2028.

The rule text is on the FCA’s UK SRS rules, the dated sequence on the UK SRS timeline, and the year that followed 2025 on UK SRS in 2026; the regulator itself is at fca.org.uk.

Private companies

The private-company route: announced in 2025, proposed nowhere since

The October 2025 statement promised a broad consultation on corporate reporting in 2026, and it came on 7 September 2026.

The Modernising corporate reporting consultation says the government will consider how UK SRS should be reflected in the Companies Act 2006, and proposes no threshold, mechanism or date for private companies.

Private companies can use UK SRS voluntarily now, as any entity can.

If your plan dates from 2025

Updating a 2025 plan to the final rules

Plans written against the 2025 drafts, or against the FCA’s January 2026 consultation, now need four corrections.

The practical programme against the final rules is on UK SRS compliance, and the data tools on sustainability software.

A 2025 plan may sayThe position now
UK SRS S2 mandatory from 2027Comply or explain (PS26/19)
Reliefs of one and two years in the standardsUntimed in the standards; timed by the FCA for listed companies
Secondary listings only signpostComply or explain like the rest
Private-company threshold comingNone proposed

Frequently asked

UK SRS in 2025: the questions asked

What are the UK Sustainability Reporting Standards 2025?

There is no standard of that name.

In 2025 the government consulted on exposure drafts of UK SRS S1 and S2, from 25 June to 17 September 2025.

The final standards were published on 25 February 2026.

“UK SRS 2025” usually means those drafts, or the consultation on them.

Was UK SRS mandatory in 2025?

No. Nothing in UK SRS applied to anyone in 2025: the standards were still drafts.

They were published for voluntary use in February 2026, and the FCA’s listing rules apply only to accounting periods beginning on or after 1 January 2027, on a comply-or-explain basis.

What sustainability reporting was mandatory in the UK in 2025?

Regulations, not standards: SECR for quoted companies and large unquoted companies and LLPs; the Companies Act climate-related financial disclosures for the largest companies; the FCA’s TCFD-aligned listing rules for listed companies; ESOS Phase 4, then running; and, for FCA-regulated investment firms, the SDR rules including the anti-greenwashing rule.

How many responses did the 2025 UK SRS consultation receive?

209: 170 through the online survey and 39 by email, 199 from organisations and 10 from individuals.

Of the 184 who answered the question on the TAC’s four recommended amendments, 125 (68%) agreed.

What changed between the 2025 drafts and the final standards?

The two-year climate-first relief and the one-year Scope 3 relief lost their time limits, leaving timing to legislation or FCA rules.

A proposed change on GICS classification was withdrawn because the ISSB made it in December 2025.

Paragraphs 73A, 73B, B59A and E5 were added.

Annex A of the government response lists every final difference.

Why are the standards called 2025 if they were published in 2026?

They are not, officially.

The consultation ran in 2025 and the final texts are dated February 2026.

Search engines and some commentary attach 2025 to the drafts; the government’s own title is simply UK SRS S1 and UK SRS S2.

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 21 sources fromDepartment for Business and TradeDepartment for Energy Security and Net ZeroHM GovernmentUK ParliamentDepartment for Business, Innovation, Science and TradeFinancial Reporting Council
  1. Department for Business and Trade
    Exposure drafts of UK SRS — consultation and outcome

    “The government proposes 6 minor amendments”; the consultation received 209 responses.

  2. Department for Business and Trade
    UK Sustainability Reporting Standards — guidance

    The consultation “ran from 25 June 2025 to 17 September 2025, alongside a consultation on … assurance”.

  3. Department for Business and Trade
    Government response to the consultation on UK SRS (web version)

    ¶1.6 the 209 responses; ¶1.7 who responded; ¶1.17 68% (125 of 184); Chapter 3 s.414CB(6) and s.463.

  4. Department for Business and Trade
    Consultation response (PDF), Annex A

    The final differences from IFRS; no count.

  5. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2

    Published 25 February 2026.

  6. Department for Business and Trade
    Letter to the FCA, 5 January 2026 (PDF)

    “More than 200 responses” — written before the final count of 209.

  7. Department for Business and Trade
    Assurance of sustainability reporting — government response

    The parallel 2025 consultation.

  8. Department for Energy Security and Net Zero
    Climate-related transition plan requirements

    Same window; no outcome published.

  9. HM Government
    UK Green Taxonomy: consultation response

    Not taken forward, 15 July 2025.

  10. UK Parliament
    Written Ministerial Statement HCWS973, 21 October 2025

    “A broad consultation will be delivered in 2026.”

  11. Department for Business, Innovation, Science and Trade
    Modernising corporate reporting — consultation, 7 September to 30 November 2026
  12. Financial Reporting Council
    UK Sustainability TAC issues final recommendations, 18 December 2024

    Commissioned May 2024; agreed 5 December 2024.

  13. Financial Reporting Council
    ISSA (UK) 5000 (PDF)

    Issued 12 November 2025; effective for periods beginning on or after 15 December 2026.

  14. Prudential Regulation Authority
    SS5/25 — climate-related risks

    Commenced 3 December 2025.

  15. IFRS Foundation
    ISSB issues targeted amendments to IFRS S2, December 2025
  16. IFRS Foundation
    IFRS Sustainability Standards Navigator
  17. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    The 2026 outcome: comply or explain from periods beginning on or after 1 January 2027.

  18. Financial Conduct Authority
    PS23/16 — SDR and investment labels

    Anti-greenwashing rule applying from 31 May 2024.

  19. legislation.gov.uk
    SI 2018/1155 (SECR)
  20. legislation.gov.uk
    Companies Act 2006, section 414CB
  21. legislation.gov.uk
    SI 2014/1643, regulation 4 (ESOS)
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