What do the UK SRS mean for companies?

The UK’s sustainability reporting regime is now final.

On 30 September 2026 the Financial Conduct Authority (FCA) published rules requiring listed companies to report against the UK Sustainability Reporting Standards (UK SRS) for accounting periods beginning on or after 1 January 2027.The first reports are due in 2028. The rules replace the FCA’s climate disclosure requirements based on the Task Force on Climate-related Financial Disclosures (TCFD).

For listed companies, this means moving from a climate-only framework to one that covers sustainability more broadly. It also means deciding, requirement by requirement, what to disclose and what to explain.

What are the UK Sustainability Reporting Standards?

The Department for Business and Trade published the standards in February 2026. They are the UK’s version of IFRS S1 and IFRS S2 from the International Sustainability Standards Board (ISSB), with minor changes to fit the UK context. 

There are two standards. UK SRS S1 covers sustainability-related risks and opportunities in general, and UK SRS S2 covers climate, including Scope 1, 2 and 3 greenhouse gas emissions.

Who is affected?

The rules apply to commercial and transition companies, issuers of non-equity and non-voting shares, international companies with a secondary listing and depositary receipt issuers. Investment funds, shell companies and debt issuers are out of scope.

Comply or explain, across the board

The FCA had proposed making climate disclosures mandatory. Instead, the final rules apply comply or explain to everything. A company that falls short must say which requirements it hasn’t met, why, and what it plans to do. Explanations can be grouped, but they must be specific to the company. The FCA’s draft guidance on what a good explanation looks like is open for comment until 28 October 2026.

Transitional reliefs ease the start: one year for Scope 3 emissions and two years for non-climate UK SRS S1 disclosures. A company using a relief must say so but doesn’t need to explain why.

Our view

The FCA’s flexibility moves the burden onto companies. “Data not yet available” won’t satisfy an investor who can see a peer disclosing the same metric, so treat the explanation as a disclosure in its own right. Groups with large EU operations should also map now where the UK SRS and the European Sustainability Reporting Standards (ESRS) overlap, rather than building two separate reporting processes.

What to do now

Start with a gap analysis of your current sustainability disclosures against UK SRS. Then identify the sustainability risks and opportunities UK SRS S1 will require you to report. Decide your comply or explain position for each requirement, and use the Scope 3 relief year to build supplier data.