What UK SRS is
In 2023 the International Sustainability Standards Board (ISSB), part of the IFRS Foundation that sets international accounting standards, published two standards: IFRS S1 on sustainability-related financial information in general, and IFRS S2 on climate. The UK government assessed them for use here and published its versions on 25 February 2026:
- UK SRS S1, General requirements. How to report sustainability-related risks and opportunities that could affect a company's cash flows, access to finance or cost of capital, organised around governance, strategy, risk management, and metrics and targets.
- UK SRS S2, Climate-related disclosures. Climate risks and opportunities, climate resilience and scenario analysis, transition plans if the company has one, and greenhouse gas emissions across Scopes 1, 2 and 3, measured with the GHG Protocol.
Like the ISSB standards, UK SRS uses financial materiality: it asks what sustainability matters mean for the company and its investors. That is different from the EU's CSRD, which also asks about the company's impact on people and the environment (double materiality).
How UK SRS differs from the ISSB standards
The government kept changes to a minimum. The main ones are:
- The relief that lets a company report only on climate in its first year was extended to two years.
- The relief allowing sustainability disclosures to be published after the financial statements in year one was removed.
- The effective dates were removed, so that regulators, not the standards, decide when reporting starts.
- A requirement for financial institutions to use a particular industry classification system for financed emissions was removed.
Who has to report, and when
| Who | Status as of October 2026 |
|---|---|
| Any company | May use UK SRS voluntarily now |
| UK listed companies (commercial companies, transition, non-equity shares, secondary listings and depositary receipts categories) | Comply or explain against UK SRS for accounting periods starting on or after 1 January 2027, so first reports in 2028. One year of relief for Scope 3 emissions and two years for wider S1 sustainability disclosures. Final rules: FCA PS26/19, 30 September 2026 |
| Large private companies and LLPs | No requirement yet. The government's Modernising Corporate Reporting consultation asks whether to extend UK SRS to "economically significant" private entities through the Companies Act. It closes on 30 November 2026 |
| SMEs | No requirement and none proposed |
Comply or explain means a listed company either reports in line with UK SRS or explains in its annual report why it has not. The FCA has also consulted on guidance about how much detail an explanation needs.
What happens to TCFD and the existing climate rules
Since 2021, UK listed companies have reported against the TCFD recommendations on a comply or explain basis under FCA rules, and since 2022 the largest companies and LLPs (more than 500 employees and more than £500 million turnover) have made climate-related financial disclosures under the Companies Act. The TCFD itself was wound up in 2023 and handed its work to the ISSB. The FCA's new rules replace its TCFD-based rules for listed companies. The Companies Act climate disclosures remain for now, and the government is reviewing how they fit with UK SRS. A company caught by both can use its UK SRS S2 report to meet the Companies Act requirement, rather than writing two.
What it means for an SME
You will not have to report under UK SRS. But if you supply a listed company or a large private one, expect more questions about your emissions. A company reporting Scope 3 under UK SRS S2 needs data from its value chain, and the GHG Protocol encourages it to use supplier-specific figures where it can. The practical steps are the same as for any customer data request:
- Measure your Scope 1 and 2 emissions and the main Scope 3 categories with the UK government factors.
- Keep the same 12-month period as your financial year, so your figures fit your customers' reporting cycle.
- Publish a Carbon Reduction Plan or similar summary, so you can answer with a link. Our free template gets you started.
- Be ready to allocate your emissions to a customer by revenue or another clear measure.
UK SRS, SECR and the rest
| Requirement | Who | Status |
|---|---|---|
| SECR | Quoted companies, and large unquoted companies and LLPs | In force. DESNZ plans to consult on SECR and ESOS later in 2026 |
| Companies Act climate-related financial disclosures | Companies and LLPs with more than 500 employees and £500m turnover, and certain others | In force, under review |
| UK SRS | Listed companies from 2027 (comply or explain); possibly large private companies later | Voluntary now |
| ESOS | Large undertakings | Phase 4 compliance date 5 December 2027 |
| PPN 006 | Bidders for central government contracts over £5m a year | In force |
Not sure whether SECR applies to you? Our SECR checker takes under a minute.
How Carbon Recycling helps
Carbon Recycling calculates the Scope 1, 2 and 3 figures that UK SRS S2 and your customers' questionnaires ask for, using the GHG Protocol and the UK government factors, with location-based and market-based Scope 2. If you're an SME supplying a listed company, it gives you consistent, traceable figures to send them. We will update this guide when the government decides on private company reporting.