UK SRS Guide: Requirements, Who Reports, and the 2027 Timeline

What are the UK Sustainability Reporting Standards?

The UK Sustainability Reporting Standards, known as UK SRS, are the UK's endorsed versions of the global sustainability disclosure standards written by the International Sustainability Standards Board. The Department for Business and Trade published two of them on February 25, 2026: UK SRS S1, covering general sustainability-related financial disclosure, and UK SRS S2, covering climate. Both are voluntary as published. Neither has an effective date, because the government removed the effective-date clauses on purpose and left the timing to whoever mandates them. The Financial Conduct Authority has proposed the first mandate, covering listed issuers for accounting periods beginning on or after January 1, 2027. Gravity builds the emissions inventory and evidence trail these standards require, and exports the same inventory to SECR, CSRD, California and CDP.

There is no UK SRS filing portal and no separate submission. The disclosures go inside the annual financial report and are published at the same time as the financial statements. And publication of the standards did not change anyone's existing obligations. Streamlined Energy and Carbon Reporting (SECR) and the 2022 climate-related financial disclosure regulations still apply exactly as they did before February 2026, and they will keep applying until something replaces them.

UK SRS key facts at a glance

What is UK SRS and where did it come from?

UK SRS is the UK's answer to a question every major economy has been asked since 2023: what do you do with the ISSB standards. The International Sustainability Standards Board, the body created by the IFRS Foundation to write a global baseline for sustainability disclosure, published IFRS S1 and IFRS S2 in June 2023. It also absorbed the Task Force on Climate-related Financial Disclosures, which had been the reference point for UK climate reporting since 2021. The TCFD no longer exists as a standard-setting body, and its recommendations are now part of IFRS S2.

That left the UK with rules anchored to a framework that had been superseded. The government set up a formal endorsement process, published exposure drafts of UK SRS S1 and S2 in June 2025, and consulted until September 17, 2025. It received 209 responses. Eighty-eight percent of respondents agreed the government should endorse the standards. The final versions arrived on February 25, 2026.

The UK's approach was to change as little as possible. Departing from the global baseline creates work for companies that report in more than one jurisdiction, and the purpose of the ISSB baseline is that one set of disclosures can be reused across countries. The UK made six amendments. Two of them change what a company has to produce. The rest change the timing and who decides it.

What changed in 2026

Three things are happening at once, and they are at different stages.

Published and available now

• UK SRS S1 and UK SRS S2, published February 25, 2026. Any entity can use them, in whole or in part, voluntarily. There is no legal obligation attached to publication.
• The government response to the exposure draft consultation, published the same day, setting out each amendment and the reasoning.
• The sustainability assurance oversight decision. The government confirmed it will establish a voluntary, opt-in register of sustainability assurance providers operated by the Financial Reporting Council, with an interim non-legislative version targeted for mid-2026 and statutory footing to follow when parliamentary time allows.

Proposed, not yet final

• FCA CP26/5, published January 30, 2026, consultation closed March 20, 2026. This is the proposal to require listed issuers to report against UK SRS from accounting periods beginning on or after January 1, 2027, and to delete the existing TCFD-aligned listing rules. The FCA aims to publish a policy statement in autumn 2026. Until it does, nothing in the proposal binds anyone.

Still in progress

• Mandatory application beyond listed companies. The government has said it will consult on changes to the Companies Act 2006 as part of the Modernising Corporate Reporting programme, announced October 22, 2025 and expected to consult during 2026. That is the vehicle that would bring in large private companies, and it is also where the future of SECR and the 2022 climate disclosure regulations will be decided.
• Transition plan requirements. The Department for Energy Security and Net Zero consulted between June 25, 2025 and September 17, 2025 on requiring UK-regulated financial institutions and FTSE 100 companies to publish credible transition plans. No government response has been published as of August 2026.

Who has to comply with UK SRS?

Right now, compliance is voluntary. No company in the UK is currently required to report against UK SRS.

The standards themselves impose no obligation

UK SRS S1 and S2 are standards, not law. Publishing a standard does not create a duty to apply it. The government removed the effective-date clauses from both standards specifically so that the question of who reports and from when would be answered by regulators and by legislation rather than by the standards themselves.

The FCA route: listed issuers

The FCA's proposal is the first and, so far, only route to a mandate. Under CP26/5, the full UK SRS requirements would apply to issuers in three UK Listing Rules categories: commercial companies (UKLR 6), non-equity shares and non-voting equity shares (UKLR 16), and the transition category (UKLR 22). The FCA estimates approximately 515 companies fall into those categories.

A further group would get lighter treatment. Issuers with a secondary listing (UKLR 14) and depositary receipt issuers (UKLR 15), approximately 89 companies, would face transparency requirements rather than the full standard, on the basis that their primary listing jurisdiction already asks them for sustainability disclosure.

If you are a UK-listed commercial company, assume you are in scope and plan on that basis. The consultation asked how the rules should work, not whether to make them.

Overseas parents and subsidiaries

A UK-incorporated subsidiary of a US or EU parent is not included in the FCA proposal unless it is itself listed in one of those categories. That is true today. It is also the exposure most likely to change, because the Modernising Corporate Reporting consultation is where a size-based threshold applied to UK companies generally would appear, and a size-based threshold does not depend on who owns you.

Multinationals with a UK listing and an EU footprint have a second consideration. UK SRS disclosures are built on the same underlying emissions inventory as CSRD disclosures, and the assurance market that serves both is being regulated in parallel. The FRC's voluntary register of sustainability assurance providers was designed in part so that UK-based providers satisfy the requirements CSRD places on assurance, which removes a friction UK-headquartered groups had been hitting.

Who is not included yet

• Private companies of any size, including very large ones
• AIM-quoted companies, which are outside the UKLR categories in the FCA proposal
• Limited liability partnerships
• UK subsidiaries of overseas groups that are not themselves listed

For all four groups, the position today is that no requirement exists, and the consultation that could create one is expected during 2026.

What you still have to do today

UK SRS changed nothing about existing UK obligations. As of August 2026:

• SECR still requires quoted companies and large unquoted companies and LLPs to report UK energy use, scope 1 and 2 emissions, an intensity ratio and energy efficiency actions in the annual report. See our SECR reporting guide for the thresholds.
• The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 still require TCFD-aligned disclosure in the strategic report from companies with more than 500 employees that are traded, banking, insurance or AIM companies, and from other large companies with more than 500 employees and turnover above £500 million.
• FCA listing rule TCFD requirements still apply to listed companies until the FCA replaces them, which is the purpose of CP26/5.

UK SRS deadlines: what happens when

The reliefs are optional deferrals, not exemptions. A company that takes the scope 3 deferral has bought one year, not permission to skip scope 3.

Explaining still requires the analysis. Under the FCA proposal, a company that does not make a required disclosure has to identify the specific UK SRS S2 paragraphs it did not comply with, explain why, and describe the steps and timeframes for making the disclosure in future. Writing that explanation credibly requires knowing what you would have had to disclose.

The first mandatory report is published in 2028, but the data collection starts in January 2027. Emissions data cannot be reconstructed retroactively with any quality. If the rules are confirmed in autumn 2026, the systems have to be live for the financial year that starts weeks later.

Disclosures are published with the financial statements from year one. IFRS S1 allows first-year reporters to publish sustainability information later than their financial statements. The UK removed that relief, so the sustainability reporting close now runs to the same deadline as the financial reporting close.

What you have to report under UK SRS S2

UK SRS S2 is the climate standard and it accounts for most of the work. It organises disclosure under four headings that anyone who has done TCFD reporting will recognise.

Governance (paragraphs 5 to 7). Which body or individual oversees climate-related risks and opportunities, how their responsibilities are set, how their skills are assessed, how often they are informed, and how management monitors and controls the work.

Strategy (paragraphs 8 to 23). The climate-related risks and opportunities that could reasonably affect the company's prospects, the effects on the business model and value chain, the strategic response including any transition plan, the current and anticipated financial effects across short, medium and long term, and a climate resilience assessment supported by scenario analysis.

Risk management (paragraphs 24 to 26). How climate risks and opportunities are identified, assessed, prioritised and monitored, and how that process connects to overall risk management.

Metrics and targets (paragraphs 27 to 37). Cross-industry metrics, industry-based metrics, and the targets the company has set with progress against them.

Greenhouse gas measurement

The cross-industry metrics in paragraph 29 are where the data work concentrates. Companies disclose absolute gross scope 1, scope 2 and scope 3 emissions in tonnes of CO2 equivalent, measured using the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (2004) unless a jurisdictional or exchange requirement says otherwise. Scope 2 must be disclosed on a location-based basis, with information about contractual instruments where they are relevant. Companies also disclose the measurement approach, inputs and assumptions, including which emission factors were used and any changes to them.

Scope 3 requires disclosing which of the 15 categories in the Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Standard are included. Financial institutions get a specific accommodation: for asset management, commercial banking and insurance activities, a company may limit its category 15 disclosure to financed emissions, with derivatives excluded, provided it explains the limitation.

The other cross-industry metrics

Beyond emissions, paragraph 29 asks for the amount and percentage of assets or business activities vulnerable to transition risk, vulnerable to physical risk, and aligned with climate-related opportunities. It asks for capital deployed towards climate-related risks and opportunities. It asks whether an internal carbon price is used in decision-making and what that price per tonne is. And it asks whether climate is factored into executive remuneration and what percentage of current-period executive pay is linked to it.

Most companies have never produced these figures, and they require input from finance and human resources rather than sustainability alone.

Industry metrics and SASB

UK SRS S2 requires industry-based metrics. Companies may refer to the ISSB's Industry-based Guidance on Implementing IFRS S2, which is derived from the SASB standards, to work out which apply. The UK changed the language here from mandatory consideration to permissive, which is one of the six amendments discussed below.

Transition plans

UK SRS S2 does not require a company to have a transition plan. It requires a company that has one to disclose it, including the key assumptions it rests on and the dependencies it relies on, along with resourcing and progress against previously disclosed plans. The FCA proposal adds a lighter obligation on top: state whether and where a transition plan has been published, or why one has not been.

What UK SRS S1 adds

UK SRS S1 is the framework standard. It sets the objective, which is disclosing sustainability-related risks and opportunities that could reasonably be expected to affect the company's prospects, meaning its cash flows, access to finance or cost of capital. It uses the same four-pillar structure as S2 and applies it to sustainability topics beyond climate.

S1 also sets rules about process rather than content.

Same entity, same time, same report. Disclosures cover the same reporting entity as the financial statements, use consistent data and assumptions, and are published at the same time as the financial statements as part of the general purpose financial report.

Comparatives. Comparative information for the preceding period is required for all amounts disclosed, and for narrative information where it aids understanding. The FCA has proposed waiving comparatives for the first reporting period, which is a relief in the listing rules rather than in the standard.

The compliance statement. A company can make an explicit and unreserved statement of compliance with UK SRS only if it complies with every requirement. Narrow exemptions exist for information prohibited by law and for commercially sensitive information about opportunities. A company using the transition relief to report only on climate cannot claim full compliance with UK SRS S1, though it can still claim compliance with UK SRS S2.

Sources of guidance. Where no specific standard covers a risk or opportunity, companies may refer to SASB disclosure topics, the CDSB Framework application guidance on water and biodiversity, and, where they do not conflict with UK SRS, GRI and the European Sustainability Reporting Standards. Companies must identify which sources they applied.

How UK SRS differs from IFRS S1 and S2

The UK made six amendments.

• The first-year publication timing relief was removed. IFRS S1 lets first-time reporters publish sustainability disclosures later than their financial statements in year one. UK SRS does not.
• The climate-first relief was extended, then untimed. IFRS S1 lets a company report only on climate in its first year. The UK extended this to two years in the exposure draft, then removed the time references entirely in the final standard, so voluntary users can rely on it indefinitely. If a mandate arrives, the mandating regulator sets the limit. The FCA has proposed two years.
• Effective dates were removed. Both standards were stripped of effective-date clauses, leaving implementation timing to future regulation.
• SASB consideration became optional. "Shall consider" became "may refer to and consider" in UK SRS S1.
• Reliance on reliefs must be disclosed. A company using a relief has to say so in its compliance statement rather than leaving readers to infer it.
• The ISSB's December 2025 amendments were incorporated, which remove the requirement to use the Global Industry Classification Standard when disaggregating financed emissions and allow alternative classification systems, and which give financial institutions relief where financed emissions cannot be estimated for the same period as the financial statements.

For a company already reporting under IFRS S1 and S2 elsewhere, the measurement work is close to identical. The differences are about when you publish and what you can defer, not what you measure.

Assurance under UK SRS

UK SRS does not require assurance, and the FCA has not proposed requiring it. What the FCA has proposed is a disclosure about assurance: whether third-party assurance was obtained, and where it was, the provider's name, which disclosures were covered and at what level, the standard used, and where to find the report.

The market infrastructure is being built ahead of any mandate. The government confirmed in early 2026 that it will establish a voluntary, opt-in oversight regime for sustainability assurance providers, operated by the Financial Reporting Council, with an interim non-legislative register targeted for mid-2026 covering firms first and individual practitioners later. Statutory underpinning follows when parliamentary time allows, a timeline that lengthened when the government decided not to proceed with the Audit Reform Bill.

Assurance itself is voluntary. The disclosure about whether you obtained it is not. Build the evidence trail on the assumption it will be tested, because a figure you cannot support is an exposure whether or not anyone is currently required to check it.

What will UK SRS cost

The FCA published a cost benefit analysis with CP26/5. It estimates approximately £286 million in total costs to affected firms across the appraisal period, against approximately £519 million in benefits to UK-based equity investors, giving a net present value of roughly £234 million over ten years.

The internal split is the more useful number for budgeting. The FCA apportions costs as roughly 60 percent to UK SRS S1 non-climate disclosure, 32 percent to UK SRS S2 climate disclosure excluding scope 3, and 8 percent to scope 3 emissions. Scope 3 is expensive per tonne of effort, but it is a smaller share of the total than the non-climate disclosure in S1, which most companies have never built a process for.

The FCA also assumes 71 percent of issuers are not currently aligned with the standards, and expects most of them to use the explain side of comply or explain in the early years.

How to prepare for UK SRS

1. Settle your scope question in writing

Determine whether you fall into UKLR 6, 16 or 22, whether you are in the lighter secondary listing or depositary receipt population, or whether you are outside the FCA proposal entirely. Write the conclusion down with the reasoning. If you are outside it, write down what would change that, because the Modernising Corporate Reporting consultation is the thing that would, and it is expected during 2026.

2. Gap your current TCFD reporting against UK SRS S2

You are not starting from zero. Map what you already disclose under the listing rules or the 2022 regulations against the four pillars and paragraph 29. The gaps cluster predictably: the asset and activity exposure percentages, capital deployed, internal carbon price, and the executive remuneration percentage. Those four require finance and human resources involvement.

3. Close scope 1 and 2 first, and make them auditable

Location-based scope 2 is required. Utility data has to be complete, and every figure needs an emission factor with a version and a document behind it. Everything else depends on this.

4. Map scope 3 categories now, even with the deferral

The deferral buys a year of reporting, not a year of preparation. Determine which of the 15 categories are relevant, identify which suppliers and data sources you need, and get the first estimate on paper. A company that starts scope 3 in 2028 to report in 2029 is starting too late.

5. Move sustainability reporting onto the financial reporting close

Disclosures must be published at the same time as the financial statements, and the UK removed the year-one relief. Run a dry run against your actual reporting calendar and find out where it breaks before it matters.

6. Build the inventory once

The scope 1, 2 and 3 inventory that supports UK SRS is the same inventory that supports SECR, CSRD, California and CDP. The disclosure formats differ. The underlying data does not. Building it separately for each regime duplicates the same collection work three or four times and produces figures that do not reconcile.

UK SRS vs SECR and the 2022 climate disclosure regulations: what is the difference?

They ask different questions of the same company, and as of August 2026 all three apply at once.

SECR is an energy reporting scheme with an emissions component. It asks for UK energy use in kWh, scope 1 and 2 emissions, an intensity ratio, and a narrative on energy efficiency actions taken. Its purpose is to drive energy efficiency, and its audience is broad.

The 2022 climate-related financial disclosure regulations ask for TCFD-aligned governance, strategy, risk management and targets disclosure in the strategic report, from companies above 500 employees. Their purpose is investor information about climate risk.

UK SRS asks the 2022 regulations' question at much higher resolution, adds mandatory scope 3, adds the exposure and capital metrics, adds industry-based metrics, and ties the whole thing to the financial statements. Its purpose is the same as the 2022 regulations' purpose. That overlap is why the Modernising Corporate Reporting programme has to resolve what happens to the older regimes, and why the current three-way stack is unlikely to be permanent.

For now, comply with what applies to you and build the data once. Our SECR guide covers the current thresholds and the intensity ratio requirement in detail.

How does UK SRS compare to CSRD, California and CDP?

CSRD asks a broader question. It uses double materiality, which means reporting both how sustainability affects the company and how the company affects the world, across environmental, social and governance topics. UK SRS uses financial materiality alone, in line with the ISSB baseline. CSRD also mandates limited assurance. UK SRS does not. See our CSRD guide for who remains in scope after Omnibus I.

California SB 253 and SB 261 ask a narrower question with harder deadlines. SB 253 requires scope 1, 2 and eventually 3 emissions from companies above $1 billion in revenue doing business in California, with third-party assurance and a fixed filing date. SB 261 requires a climate risk report. Neither asks for the strategy or capital allocation depth UK SRS asks for, and both apply on a nexus test that has nothing to do with where you are listed. Our California climate disclosure guide covers the thresholds and the current litigation position.

CDP is a voluntary questionnaire that has aligned its disclosure with IFRS S2, so a company preparing UK SRS S2 disclosure is most of the way to a CDP response. Our CDP guide covers the current questionnaire.

The same is true across all four. The boundaries differ, the materiality lenses differ, the assurance requirements differ, and the formats differ. The emissions inventory underneath is the same one. Companies that build a single well-evidenced inventory and export it spend a fraction of what companies running parallel processes spend, and they produce consistent numbers, which an assurance provider will check when comparing your CDP response to your annual report. Our guide on choosing the right climate disclosure framework works through the selection question.

How Gravity helps you be ready for January 2027

There are three ways to do this work: in-house, with a consultancy, or with software. Gravity is an integrated energy and carbon management platform that combines software, expert support and a vendor network, and it is built for companies that face more than one disclosure regime at once.

• Automated data collection. Utility bill scanning and utility APIs process large volumes of energy documents without manual entry, which is what makes complete location-based scope 2 achievable on a financial reporting timeline. Supplier engagement and survey tooling collects the value chain activity data that scope 3 categories require and that bills never contain.
• Reporting to the format each regime wants. The platform formats one inventory to the disclosure requirements of UK SRS S2, SECR, CSRD, California and CDP. The scope 1, 2 and 3 figures behind them stay consistent across all of them.
• An evidence trail built for assurance. Data logs, supporting evidence attached to every data point, and documentation held in one place. UK SRS does not require assurance yet and the FCA has not proposed requiring it, but the FCA has proposed that you disclose whether you obtained it.
• Energy efficiency, not only accounting. Energy and cost data surfaces efficiency opportunities ranked by return, and a vendor network helps implement them. That produces the SECR efficiency narrative and the capital deployment metric UK SRS S2 asks for, from the same work.
• Expert assistance. Every customer works with a dedicated Climate Strategist who helps with the judgement calls this regime turns on: which scope 3 categories are relevant, which industry-based metrics apply, and how far a comply-or-explain statement has to go to be credible.

Talk to an expert about getting your inventory ready before the FCA finalises its rules.