UK SRS FAQ 2026

What are UK SRS?

UK Sustainability Reporting Standards (UK SRS) are comprehensive sustainability disclosure standards published 25 February 2026 by the Department for Business and Trade.

UK SRS consists of two standards:

• UK SRS S1: General requirements for sustainability disclosures
• UK SRS S2: Climate-related disclosures

Are UK SRS mandatory in 2026?

No. UK SRS are currently voluntary for all organisations. The FCA has proposed making UK SRS S2 proposed mandatory from 1 January 2027 for certain listed companies, but this is subject to final policy statements.

Who will need to comply with UK SRS?

Proposed Scope (From 2027)

FCA CP26/5 proposes mandatory UK SRS S2 for:

• Premium-listed companies on London Stock Exchange Main Market
• Standard-listed companies (subject to final FCA policy)
• Approximately 515 primary-listed companies in total

Not in Scope (Currently)

• Unquoted companies — not proposed for mandatory UK SRS
• Private companies — remain outside scope
• LLPs — not subject to listing requirements
• AIM companies — not in initial scope

When do UK SRS requirements start?

Current Timeline

• 25 February 2026: UK SRS published (voluntary)
• 1 January 2027: UK SRS S2 proposed mandatory for listed companies
• TBD: FCA Policy Statement on final implementation

First Reporting Cycles

Companies subject to mandatory UK SRS S2 from 2027 would typically report:

• Financial year 2027: First UK SRS S2 disclosures
• Filed in 2028: As part of 2027 annual reports

How do UK SRS interact with SECR?

SECR Continues

• SECR remains mandatory for quoted companies and large unquoted companies/LLPs
• Scope largely unaffected — most SECR companies are unquoted
• Requirements unchanged — six core SECR disclosures continue

Quoted Companies Face Dual Requirements

From 2027, quoted companies may be subject to both:

• SECR: Six core energy and emissions disclosures in directors' report
• UK SRS S2: Comprehensive climate framework in sustainability report

Government Review Promised

The government committed to "consider how the SECR requirements interact with UK SRS with a view to reducing unnecessary duplication where possible".

What's the difference between UK SRS and IFRS S1/S2?

Similarities

• Based on IFRS S1/S2 — UK SRS built on ISSB standards
• Four pillar structure — governance, strategy, risk management, metrics
• Climate focus — S2 standards address climate-related disclosures

UK-Specific Adaptations

• UK legal framework — aligned with UK company law
• UK market focus — tailored for UK capital markets
• UK transition approach — phased implementation for UK listed companies

Do private companies need UK SRS?

Not currently proposed. UK SRS S2 proposed mandatory implementation is proposed only for listed companies. However:

Supply Chain Considerations

• Customer requirements — listed companies may require supplier disclosures
• Voluntary adoption — private companies may adopt UK SRS competitively
• Future scope expansion — government may extend scope over time

SECR Remains Primary Framework

Large unquoted companies and LLPs remain subject to SECR only, which provides:

• Streamlined requirements — six core disclosures
• Established framework — in force since 2019
• No immediate change — continues unchanged

What are the penalties for UK SRS non-compliance?

No Penalties Yet Specified

• FCA enforcement — likely to follow listing rule enforcement approach
• Market oversight — stock exchange monitoring and sanctions
• Auditor requirements — external assurance obligations

Contrast with SECR

SECR penalties follow Companies House late filing rules. UK SRS penalties are expected to follow FCA enforcement mechanisms for listed companies.

Should we start preparing for UK SRS now?

Quoted Companies: Yes

• Gap analysis — assess current SECR vs UK SRS S2 requirements
• Data systems — expand beyond SECR scope to full climate framework
• Governance preparation — establish climate oversight processes
• 2027 readiness — build comprehensive disclosure capabilities

Large Unquoted Companies: Monitor

• SECR focus — maintain robust existing compliance
• Supply chain watch — monitor customer ESG requirements
• Voluntary consideration — assess competitive advantage of early adoption
• System flexibility — design SECR processes with potential UK SRS expansion

What about Scope 3 emissions under UK SRS?

UK SRS S2 Requirements

• Scope 3 mandatory — where material and data available
• Value chain emissions — upstream and downstream activities
• Industry guidance — sector-specific metrics expected

SECR Comparison

• Scope 3 not required under SECR
• Voluntary disclosure — some companies include Scope 3 in SECR
• UK SRS broader — comprehensive value chain approach

How are UK SRS enforced?

FCA Oversight (Proposed)

• Listing rule compliance — part of ongoing listing obligations
• Thematic reviews — periodic FCA assessment of disclosure quality
• Enforcement action — censure, fines, or other regulatory sanctions

External Assurance

• Independent verification — third-party assurance expected
• Audit integration — likely integration with statutory audit process
• Professional standards — assurance standards under development

What's the best approach for transition planning?

For Quoted Companies

1. 2026: Continue SECR, begin UK SRS gap analysis
2. Late 2026: Finalise UK SRS implementation plan
3. 2027: Implement dual SECR-UK SRS reporting
4. Ongoing: Monitor integration opportunities

For Large Unquoted Companies

1. Primary focus: Robust SECR compliance
2. Market monitoring: Track customer ESG demands
3. Voluntary assessment: Consider UK SRS competitive advantage
4. Future preparation: Flexible systems for potential scope extension

The key message for 2026 is that SECR remains the primary mandatory framework while UK SRS provides an optional pathway for enhanced sustainability disclosure. Quoted companies should prepare for dual compliance from 2027, while unquoted companies should monitor developments while maintaining SECR focus.