Who must comply with UK SRS?

The current position: voluntary, available to all

The Department for Business and Trade published the final UK SRS S1 and S2 on 25 February 20262. Both standards are available for immediate voluntary reporting by any UK entity.

The DBT consultation response confirms that an entity may apply UK SRS requirements "in whole or in part, as they see fit"3 — there is no minimum scope of application for voluntary reporters, although the standards do require an entity claiming compliance to apply UK SRS S1 and UK SRS S2 together where both are relevant2.

The DBT received 209 responses3 to the consultation. Financial and insurance services made up the largest single sector at 25% of respondents, with 45% of respondents already reporting under SECR and 35% under TCFD-aligned Companies Act rules3 — context that explains why voluntary adoption is concentrated among entities already carrying climate-related reporting obligations.

In scope from 1 January 2027: the FCA's proposals

The FCA published CP26/51 on 30 January 20261. The consultation closed on 20 March 20261; a final Policy Statement is expected in autumn 20261 with rules taking effect from UK SRS deadline1.

Paragraph 3.4 of CP26/51 names five UK Listing Rule categories9 that would fall within the new regime: UKLR 6 (Commercial Companies, the largest category), UKLR 14 (Secondary Listings), UKLR 15 (Depositary Receipts), UKLR 16 (Non-Equity Shares), and UKLR 22 (Transition Category, former Standard listing segment following the 2024 regime overhaul)1.

The five UKLR categories — two-tier treatment

Listed companies in UKLR categories 6, 14, 15, 16, and 22 fall within the CP26/5 scope1, split into two tiers of treatment.

Full UK SRS S2 reporting (mandatory)

UKLR 6, UKLR 16, and UKLR 221 companies face mandatory S2 climate standard reporting from accounting periods beginning on or after 1 January 20271, with supply chain emissions and S1 non-climate disclosures applying on comply-or-explain basis initially under the transitional reliefs.

Transparency regime only

UKLR 14 (Secondary Listings) and UKLR 15 (Depositary Receipts)1 face no direct UK SRS reporting requirement. These companies must disclose home-jurisdiction standards followed and voluntary frameworks used.

The rationale1 is that primary-listed jurisdictions are the appropriate locus of reporting obligations; the UK does not seek to duplicate or override them.

The transitional reliefs

Two reliefs are built into UK SRS itself2 and would apply through the FCA's rules1.

Scope 3 one-year deferral

Companies may defer mandatory Scope 3 requirements for one year from initial application, under CP26/5 paragraphs 3.9 and 8.61. Scope 3 becomes mandatory on a comply-or-explain basis from implementation timeline1.

UK SRS S1 two-year deferral

Companies may defer UK SRS S1 non-climate reporting for up to two years, with S1 non-climate becoming mandatory on a comply-or-explain basis from 1 January 20291. The foundational elements of S1 — materiality, value chain scope, financial-statement connectivity2 — apply from January 2027 alongside S2 because S2 cannot be applied without them.

Special provision for pre-2027 accounting periods

Under paragraph 8.10 of CP26/51, listed companies whose accounting period begins before 1 January 2027 may either continue to apply the existing TCFD-aligned rules and guidance for that reporting period, or voluntarily apply the new UK SRS-aligned requirements early1.

The FCA's consultation does not finalise these arrangements. The Policy Statement expected in autumn 20261 will confirm the final scope and the precise wording of the rules.

Companies should plan for the proposed timetable but monitor the final rules for changes.

Transition plans and assurance: what the FCA is not requiring

Two areas where the FCA has explicitly stopped short of mandating something are worth noting because they often appear in commentary as if they were already in scope.

Transition plans are not mandated

The FCA's position in CP26/51 is that mandating the production of climate-related transition plans is a matter for Government policy1. The FCA's proposal is more limited: in-scope companies must include a statement in their annual report confirming whether they have published a climate-related transition plan and where it can be found, or the reasons why no plan has been published1.

Assurance is not mandated

The FCA does not propose to require third-party assurance over UK SRS disclosures at this stage1. Where companies obtain assurance voluntarily, they would be required to disclose the assurance level obtained, the assurance standard used, and the identity of the assurance provider1.

The FRC published ISSA (UK) 50008 as the UK assurance standard for sustainability disclosures, but its use is voluntary unless mandated separately.

Private companies: the MCR programme

UK SRS does not yet apply to private companies on a mandatory basis. The Government has confirmed in the DBT consultation response, paragraph 1.163, that the question of mandatory UK SRS reporting by private entities will be addressed through the Modernising Corporate Reporting (MCR) programme, announced in October 20254.

A consultation on MCR is expected later in 20263.

The two strands of MCR

The first strand, set out in a Written Ministerial Statement on 21 October 20254, is a set of immediate legislative changes intended to remove reporting obligations from up to 51,000 companies4 — exempting medium-sized private companies from the Strategic Report requirement, exempting wholly-owned subsidiaries where their disclosure is included in a UK parent's annual report, and removing the Directors' Report requirement4. The Government estimates these reforms will save UK businesses around £230 million per year in administrative costs4.

The second strand, which is the relevant one for UK SRS scope, is a broader consultation on corporate reporting framework alignment3. Within that consultation, the Government will consider whether to extend UK SRS reporting requirements to "economically significant private entities" through amendments to the Companies Act 20063.

Open questions for MCR

The DBT consultation response notes several issues3 that the MCR consultation will need to resolve:

• Defining 'economically significant' — paragraph 1.61 of the DBT response records that 'a notable number of respondents asked that the phrase be clearly defined.' There is no published definition at present.
• Subsidiaries of reporting parents — paragraph 1.67 records strong respondent support for an exemption where a parent company already reports against UK SRS or an equivalent international standard (such as ESRS).
• Proportionality and phasing — paragraph 1.68 records that 'proportionality is the priority for consultation respondents' and that a phased approach with longer preparation period is expected for private entities not currently in scope of similar requirements.

NFSIS and SECR integration

UK SRS does not replace the existing climate-related reporting regime under section 414CA of the Companies Act 20066 — the Non-Financial and Sustainability Information Statement (NFSIS).

However, the FRC has confirmed in its FAQ updated 26 February 20265 that the Government has designated UK SRS S2 as a national reporting framework under section 414CB(2A) of the Companies Act 20067. The practical effect: an entity using UK SRS S2 does not need to separately satisfy the climate-related financial disclosure requirements in section 414CB(1)-(5)7, provided the use of UK SRS S2 is clearly referenced in the NFSIS5. This applies whether UK SRS S2 is applied on a mandatory or voluntary basis5.

SECR continues to operate alongside UK SRS. The Government has indicated it will consider how energy and emissions data reported under UK SRS interacts with SECR, with a view to reducing unnecessary duplication, but the SECR Regulations remain in force. The UK SRS guidance hub10 provides implementation guidance for entities considering early voluntary application.

Quick-reference table

Frequently asked questions