Update, 6 October 2026: the FCA published its final rules in PS26/19 on 30 September 2026. They apply comply or explain across all of UK SRS, including S2 climate disclosures, which the consultation had proposed to make mandatory. The dates below (periods from 1 January 2027, Scope 3 relief for one year, S1 relief for two years) are confirmed. Read what the final rules require and how to write a defensible explanation.
The UK’s sustainability reporting standards have been finished for six months and almost nobody has started. That is not negligence, it is a rational response to an unfinished sentence: the standards exist, but the rule that makes them binding does not. It is expected this autumn.
Which makes now the useful moment to understand them, rather than the moment after the announcement when every consultant in London is quoting you a readiness assessment.
Where things actually stand
The Department for Business and Trade published the final UK SRS S1 and UK SRS S2 on 25 February 2026. They are available for voluntary use by any entity today, and a handful of companies have already adopted them early.
The binding step sits with the Financial Conduct Authority. Its consultation, CP26/5, ran from 30 January to 20 March 2026 and proposed replacing the current TCFD-aligned listing rules with UK SRS. The FCA has said it aims to publish the final Policy Statement in autumn 2026. As of today it has not.
Everything below the standards themselves is therefore still a proposal. It is a well-signalled proposal that has already been through consultation, which is not the same thing as a rule.
The distinction that matters most: this is ISSB, not ESRS
If your team spent 2024 and 2025 building for CSRD, the single most important thing to understand about UK SRS is that it did not come from the same place.
UK SRS S1 and S2 are endorsed versions of IFRS S1 and IFRS S2, the ISSB standards, with only limited UK amendments. They are not derived from the ESRS. The practical consequences are real:
- Materiality is single, not double. ISSB asks what could reasonably be expected to affect an entity’s prospects – cash flows, access to finance, cost of capital. It does not ask you to report impacts on people and planet that are not financially material. Your CSRD double materiality assessment is useful input, but it is not the same assessment.
- The audience is investors, explicitly and narrowly. That changes the register of the disclosure and often the level of aggregation.
- There is no ESRS datapoint list to work through. ISSB is principles-based with industry-specific metrics drawn from SASB. Teams used to filling in a defined set of datapoints find this harder, not easier, because judgement is now load-bearing.
The overlap is nonetheless substantial at the data layer. Emissions are emissions; governance narrative is largely reusable; scenario analysis carries over. It is the framing, materiality boundary and reporting location that differ. We covered the mechanics of that mapping in more detail in our piece on how TCFD and CSRD requirements line up for UK companies.
Who is in scope
The FCA’s proposals apply to listed issuers in five UK Listing Rules categories: commercial companies (UKLR 6), secondary listings (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16), and the transition category (UKLR 22).
That is roughly 515 companies. For context, post-Omnibus CSRD now catches around 5,000 companies across the entire EU, so neither regime is the mass-market obligation the 2023 architecture implied.
If you are a private UK company, you are not in the FCA’s population. You may still receive UK SRS-shaped questions from listed customers and from lenders, which is a different problem with the same answer.
The timetable, as proposed
- UK SRS S2 (climate): accounting periods beginning on or after 1 January 2027. For a December year end, that means the report published in 2028.
- Scope 3 emissions: a one-year transitional relief, applying on a comply-or-explain basis for periods beginning on or after 1 January 2028.
- UK SRS S1 (wider sustainability): a two-year relief, comply-or-explain for periods beginning on or after 1 January 2029.
Read that phasing carefully, because it is the opposite of how most companies sequence their work. Climate lands first and hardest. Scope 3, the hardest data problem in the standard, gets one extra year and then arrives on comply-or-explain, which in practice means “report it or write a paragraph explaining a gap to your investors”. Neither is a reason to defer the work; both are a reason to sequence it properly.
What happens to your TCFD disclosures
If you have been reporting under the FCA’s TCFD-aligned rules, you are not starting from zero. IFRS S2 was built on the TCFD’s four pillars, and governance, strategy, risk management, and metrics and targets survive intact as the structure of the disclosure.
What is genuinely new is the level of specificity:
- Industry-based metrics. S2 points to SASB-derived metrics for your sector. TCFD left this open; S2 does not.
- Scope 3 across all fifteen categories, with the measurement approach and inputs disclosed, rather than a partial inventory with a footnote.
- Connectivity with the financial statements. The assumptions behind your climate disclosure are expected to be consistent with the ones behind your accounts. Asset lives are the classic exposure.
- Transition plans. The FCA is not proposing to mandate one. It is proposing that you disclose whether you have published one and where it can be found, or why you have not – which is a harder question to answer blandly than it looks.
The assurance line most readers skipped
CP26/5 does not mandate third-party assurance. It proposes something quieter: that in-scope companies state in the annual financial report whether they obtained assurance, from whom, over which disclosures, to what level, against which standard, and where the report sits.
A visible blank is a disclosure in itself. Once one FTSE 250 peer names a provider and a standard, the field fills in fast. Anyone who watched limited assurance arrive in Europe will recognise the shape of it – and the preparation it demands is the same as we set out in our guide to what limited assurance actually tests: documentation, traceability and controls, not recalculated totals.
SECR has not gone anywhere
Worth saying plainly, because the UK SRS coverage tends to imply otherwise. Streamlined Energy and Carbon Reporting still applies to all UK quoted companies and to large unquoted companies and LLPs meeting the familiar size test. That population is an order of magnitude larger than the FCA’s 515, and nothing in UK SRS removes the obligation. If you are a large private company, SECR remains your binding UK requirement and UK SRS is, for now, context.
What to do before the Policy Statement lands
- Establish whether you are in one of the five UKLR categories. Ten minutes, and it determines everything else.
- Re-run materiality on a single-materiality basis if your existing assessment was built for CSRD. Do not assume the answer transfers.
- Baseline Scope 3 now, not in 2028. The relief is on the reporting date, not on the data collection, and purchased goods and services cannot be built in a quarter.
- Check connectivity between your climate assumptions and the assumptions in your financial statements. Fix the inconsistencies while nobody is examining them.
- Decide your assurance position early. If you intend to say “assured”, the provider needs to see your controls well before the reporting period, not after it.
- Read the Policy Statement when it appears and re-check the dates. Consultation feedback moves timetables, and these are still proposals.
The companies that will find UK SRS straightforward are not the ones with the most disclosure experience – they are the ones that can show where each number came from. Horizon ESG helps UK reporting teams collect data once and keep source, method, factor version and owner attached to every figure, so the same evidence base serves UK SRS, SECR, ISSB and customer data requests without a rebuild each cycle. If you are still choosing a platform, our comparison of eight ESG reporting platforms sets out which ones cover ISSB properly rather than treating it as a CSRD add-on. See how it works for UK reporting, or book a free demo.
Leave a Reply