---
title: "UK SRS explained: what the UK Sustainability Reporting Standards require of insurers"
source_url: https://abgalis.com/regulation/uk-srs
canonical: https://abgalis.com/regulation/uk-srs
description: "UK SRS S1 and S2 in full: issued 25 February 2026, voluntary, no effective date. Scope, the FCA's unpublished policy statement, the UK-only financed-emissions paragraph B59A, and why UK SRS and SS5/25 are parallel regimes rather than one."
publisher: Abgalis Limited
author: Abgalis Research
date_published: 2026-08-22
date_modified: 2026-08-22
keywords: ["UK SRS", "UK SRS S1", "UK SRS S2", "IFRS S1", "IFRS S2", "ISSB", "FCA CP26/5", "financed emissions", "B59A", "SS5/25", "Companies Act section 414CB", "TCFD", "climate disclosure"]
retrieved: 2026-08-22
content_signal: search=yes, ai-input=yes, ai-train=no
citation: "Abgalis Research, 'UK SRS explained: what the UK Sustainability Reporting Standards require of insurers', Abgalis Limited, https://abgalis.com/regulation/uk-srs"
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  May be quoted and cited in AI-generated answers with attribution to the author named
  above and a link to source_url. Not licensed for model training or fine-tuning
  (ai-train=no; Art. 4 reservation, EU Directive 2019/790).
---

Regulation · UK SRS

# UK SRS explained: what the UK Sustainability Reporting Standards require of insurers

**UK SRS S1 — *General Requirements for Disclosure of Sustainability-related Financial
Information*** — and **UK SRS S2 — *Climate-related Disclosures*** were issued by the
**Secretary of State for Business and Trade on 25 February 2026**, following a consultation
that opened on 25 June 2025, closed on 17 September 2025 and drew **209 responses**.

As at the date of this page, **no UK entity is required to report against either standard.**

That sentence is the whole of the difference between this page and most of what has been
written about UK SRS, so it is worth being precise about why it is true.

---

## Is UK SRS mandatory?

**No. Not for any entity, in any sector, today.**

The government's own guidance is unambiguous: the standards are *"available for voluntary
use, by any entity that chooses to do so."* The government response puts it the same way —
the decision was to *"endorse the 2 IFRS Sustainability Disclosure Standards and therefore
issue UK SRS S1 and UK SRS S2 for voluntary use in the UK."*

The confusion is caused by the word **endorse**. In this context endorsement describes a
completed technical assessment of the ISSB standards, resulting in UK versions being issued.
It is not adoption into law. Headlines reading "the UK has endorsed UK SRS" are accurate and
are routinely read as meaning something they do not say.

**Mandation, if it comes, will come from the FCA — and it has not come yet.** The FCA
consulted in **CP26/5, *Aligning listed issuers' sustainability disclosures with international
standards***, published 30 January 2026 and closed 20 March 2026. As at today the FCA's own
sustainability reporting page still describes the operative requirement as the
**TCFD-aligned rules**, and states that the regulator intends *"to publish a Policy Statement
in autumn 2026, with the rules coming into force from January 2027."*

Until that policy statement is published, three things follow. Nothing is mandatory. The
proposed scope could change — CP26/5 was published four weeks *before* the final standards.
And the earliest possible first mandated reporting period is one beginning on or after
1 January 2027, with the first reports landing in 2028.

## Who issued UK SRS — and did the FRC?

**The Secretary of State for Business and Trade issued them. The FRC did not.**

This matters because the misattribution is common enough to appear in vendor material. The
FRC's own FAQ page is explicit that it does not issue UK SRS. What the FRC does is **host the
UK Sustainability Disclosure Technical Advisory Committee (TAC)**, which made the technical
recommendations, and sit on the Policy and Implementation Committee.

The standards themselves carry a DBT copyright notice recording that they are reproduced and
distributed by the Secretary of State with the permission of the IFRS Foundation, within the
United Kingdom only.

## Which entities are in scope?

**The standards themselves impose no entity scope at all.** Because they are voluntary, any
entity may apply them, in whole or in part. Scope will be set by whoever mandates them.

**The FCA's proposed scope** in CP26/5 covers listed issuers in the commercial companies
category (UKLR 6), secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity and
non-voting equity shares (UKLR 16) and the transition category (UKLR 22). Closed-ended
investment funds, open-ended investment companies, shell companies, debt and debt-like
securities, securitised derivatives and warrants are excluded. The FCA describes the scope as
maintaining focus on the listed companies already subject to its TCFD-aligned rules.

**For insurers, read that carefully.** There is **no insurer-specific scoping** and no scoping
by PRA authorisation. A UK insurer is in scope only if it is itself listed in one of those
categories. Lloyd's managing agents, mutuals, and unlisted UK subsidiaries of overseas groups
are captured by nothing here.

**Large private companies are not in scope of anything yet.** The government response defers
that question to the *Modernising Corporate Reporting* programme, promising a consultation.
We have not been able to find that consultation published.

## When does UK SRS take effect?

**It has no effective date. That was deliberate.**

The government response records the fourth of its four amendments as *"the removal of the
'effective date' clauses from UK SRS to avoid any confusion with the introduction of any
reporting requirements."* The comparison annex states that the effective date was removed
from UK SRS S2, meaning entities can apply the standard when they choose, unless required by
UK law or regulation. The FRC's FAQ says the same: application will be set out in future UK
regulation or legislation, *if and when* reporting requirements are introduced.

**A practical consequence follows that is easy to miss.** The transitional reliefs — the
climate-first relief in UK SRS S1, and the first-year measurement-method and Scope 3 reliefs
in UK SRS S2 — were retained, but their fixed reference periods were removed. For a
*voluntary* adopter there is therefore no clock running on them. For a *mandated* adopter,
the relief periods will be whatever the mandating regulator sets. The FCA has proposed
comply-or-explain treatment for Scope 3 and for non-climate sustainability matters, with
transitional deferrals and no comparatives required in the first period — but that is a
proposal in an unpublished policy statement, not a rule.

> If you see "UK SRS is mandatory from 2027" in a gap-analysis template or a vendor
> deck, it is describing a consultation, not a requirement.

## Where does UK SRS diverge from IFRS S1 and S2?

**Less than commentary suggests, and in a small, closed set of places.** The comparison annex
states that where requirements are not listed in it, there are no differences between the two.
There is no divergence on materiality, on the definition of scope, or on the core content
architecture.

The differences that exist are these.

| Change | Where | What it does |
|---|---|---|
| **SASB softened** | UK SRS S1 §§55(a), 58(a); UK SRS S2 §§12, 23, 32 | *"shall refer to and consider"* becomes ***"may*** *refer to and consider"* for the SASB Standards and the IFRS S2 industry-based guidance |
| **Financed-emissions explanation** | **UK SRS S2 §B59A — new, UK only** | An entity that cannot disclose in line with the financed-emissions requirements must explain why |
| **Effective dates removed** | UK SRS S1 and S2 | No commencement written into either standard |
| **Delayed publication relief removed** | UK SRS S1 | The IFRS S1 relief allowing sustainability information to be published later than the financial statements was deleted |
| **Compliance-statement mechanics** | UK SRS S1 §§73A, 73B — new | Using the climate-first relief means an entity cannot assert compliance with UK SRS S1, and must disclose that it used the provision |

On the SASB softening, the government's stated reasons were that the material had not been
through ISSB-equivalent due process and that a mandatory reference risked creating audit and
assurance expectations. Around 70% of respondents agreed. The government flagged the point
for review once the ISSB completes its internationalisation of the SASB material.

**One divergence that was consulted on largely evaporated.** The proposal to remove the
mandatory GICS requirement was overtaken by the ISSB's own December 2025 amendments, which
permit an entity to select a suitable classification system. No GICS row appears in the final
comparison annex. It is not a live UK divergence.

**UK SRS S2 is built on the amended IFRS S2.** The ISSB's *Amendments to Greenhouse Gas
Emissions Disclosures*, issued 11 December 2025, were incorporated. Note the asymmetry this
creates: those amendments are not internationally effective until periods beginning on or
after 1 January 2027, but they are in UK SRS S2 from issue.

## What does UK SRS S2 require of insurers specifically?

Three things, and one widely-misreported absence.

**Financed emissions apply to insurance activities.** UK SRS S2 requires additional
information about financed emissions — part of Scope 3 Category 15 — where an entity's
activities include asset management, commercial banking or **insurance**. For insurers that
means disaggregation by industry and asset class, gross exposure, the percentage of exposure
included in the calculation, and the methodology used. This is the **investment portfolio**.

**§B59A is the UK-only requirement, and it is the one to plan for.** Added in response to
consultation feedback, it requires an entity that cannot disclose in line with the
financed-emissions requirements to **explain why**. The government's stated intent is to
permit use of prior-period data where estimating current-period financed emissions is
impracticable, while requiring the entity to explain its approach. That is a documentation and
evidence obligation, not a data obligation — and it is the paragraph most likely to be tested
by an assurance provider.

**Insurance-associated emissions are not required — but they are not "excluded" either.** The
December 2025 ISSB amendments, carried into UK SRS S2, **permit** an entity to limit its
Scope 3 Category 15 measure to financed emissions only. The ISSB's reasoning was the absence
of established methodologies. Underwriting-portfolio emissions therefore sit outside the
requirement, but they remain disclosable voluntarily and remain subject to the general
materiality judgements in S1.

> The distinction between *permitted to limit* and *excluded* is not pedantry. A firm
> told that insurance-associated emissions have been "removed from UK SRS" may conclude
> that its materiality assessment need not consider them. That is not what the standards
> say.

## Does UK SRS interact with SS5/25 or Solvency UK?

**No. They are parallel regimes, and treating them as one is the most common analytical error
in this area.**

A text search of UK SRS S2 returns no reference to Solvency, to underwriting, or to insurers
other than in the financed-emissions provisions above. There is no interaction with the SFCR,
the RSR or the ORSA written into UK SRS, and none proposed in CP26/5.

From the other direction, the PRA declined to couple them. **PS25/25** records that
respondents *"broadly supported the PRA's approach of not introducing new disclosure
expectations at this time, and instead reaffirming the expectation that firms engage with
wider initiatives on climate-related risk disclosures."*

So: **UK SRS is a corporate reporting stream** — DBT issues, the FCA would mandate, the
Companies Act sits underneath. **SS5/25 is a prudential risk-management stream** — the PRA
supervises, the ORSA carries it. They share underlying climate risk analytics and nothing else.

**One statutory hook does already exist**, and it is useful. The government has confirmed that
UK SRS S2 is a national reporting framework for the purposes of **section 414CB(6) of the
Companies Act 2006**. A company reporting in accordance with UK SRS S2 does not need to
duplicate those disclosures to meet its section 414CB(2A) obligation, provided the other
requirements of section 414CB are met and the use of UK SRS S2 is clearly referenced.

That matters to insurers because the existing mandatory regime has not gone anywhere. **The
Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022, SI
2022/31**, remain in force and expressly capture *authorised insurance companies* and
companies *carrying on insurance market activity* above 500 employees. So a UK insurer may
well have a mandatory climate disclosure duty today, under 2022 regulations, entirely
independently of the voluntary standards issued in 2026 — and can now discharge it using
UK SRS S2 if it chooses.

## What is still undecided?

| Open question | Status |
|---|---|
| **FCA policy statement on CP26/5** | Targeted autumn 2026. Not published. Until it lands, nothing is mandatory |
| **Private and unlisted companies** | Deferred to Modernising Corporate Reporting. Consultation not found published |
| **Transition plan requirements** | DESNZ consulted 25 June – 17 September 2025. Response outstanding. Proposed scope included UK-regulated financial institutions — insurers expressly among them |
| **Mandatory assurance** | The oversight regime for assurance providers is voluntary and opt-in, operated by the FRC. Whether reporters must obtain assurance is separate and undecided |
| **SECR duplication** | DESNZ has said it will consider the interaction. No decision |
| **The SASB softening** | Flagged for review once the ISSB completes internationalisation |

The transition plan file is the one to watch. If DESNZ mandates transition plans for
UK-regulated financial institutions and routes them through UK SRS S2, scope expands well
beyond listed issuers — and unlisted insurers, currently captured by none of this, would be
brought in.

---

## Where Abgalis fits

The honest position on UK SRS today is that it is a readiness problem, not a compliance
problem, and that the readiness window is defined by an unpublished FCA policy statement.

Two pieces of that readiness are analytical rather than procedural. The financed-emissions
requirement needs portfolio exposure traced by industry and asset class with a documented
methodology — and, under §B59A, a defensible written explanation wherever the data does not
support the calculation. And the climate resilience disclosure needs the same physical and
transition risk analysis that SS5/25 already expects to reach the ORSA.

Abgalis carries all seven risk domains in one continuously updated model, so the scenario work
that supports a prudential judgement and the scenario work that supports a disclosure are the
same work, evidenced once. We would caution against any vendor claim that a tool makes you
"UK SRS compliant" — there is presently nothing to comply with.

Accountability for every regulatory judgement remains with the firm. Abgalis is analytics,
not authority.

---

## Sources

All sources are primary. Consultancy and law-firm commentary was used to locate them and is
not relied on for any statement above.

- **UK SRS S1 and UK SRS S2** — [the standards](https://www.gov.uk/government/publications/uk-sustainability-reporting-standards-uk-srs-s1-and-uk-srs-s2), Secretary of State for Business and Trade, 25 February 2026
- **UK SRS guidance** — [gov.uk](https://www.gov.uk/guidance/uk-sustainability-reporting-standards), last updated 25 February 2026
- **Government response** — [consultation outcome, including the IFRS/UK SRS comparison annex](https://www.gov.uk/government/consultations/exposure-drafts-uk-sustainability-reporting-standards/outcome/government-response-to-the-consultation-on-uk-sustainability-reporting-standards-web-version), 25 February 2026
- **FCA CP26/5** — [Aligning listed issuers' sustainability disclosures with international standards](https://www.fca.org.uk/publications/consultation-papers/cp26-5-sustainability-disclosures), 30 January 2026, closed 20 March 2026
- **FCA sustainability reporting requirements** — [the operative position](https://www.fca.org.uk/firms/climate-change-sustainable-finance/reporting-requirements), last updated 5 June 2026
- **FRC** — [Sustainability Reporting Developments: Frequently Asked Questions](https://www.frc.org.uk/library/standards-codes-policy/accounting-and-reporting/annual-corporate-reporting/sustainability-reporting-developments-frequently-asked-questions/), last updated 26 February 2026
- **ISSB** — [Amendments to Greenhouse Gas Emissions Disclosures (Amendments to IFRS S2)](https://www.ifrs.org/news-and-events/news/2025/12/issb-issues-targeted-amendments-ifrs-s2/), 11 December 2025
- **PS25/25** — [Enhancing banks' and insurers' approaches to managing climate-related risks](https://www.bankofengland.co.uk/prudential-regulation/publication/2025/december/enhancing-banks-and-insurers-approaches-to-managing-climate-related-risks-policy-statement), PRA, 3 December 2025
- **SI 2022/31** — [The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022](https://www.legislation.gov.uk/uksi/2022/31/contents/made)
- **Transition plans** — [DESNZ consultation](https://www.gov.uk/government/consultations/climate-related-transition-plan-requirements), 25 June 2025, closed 17 September 2025, outcome not published

*This page states the position as at 22 August 2026 and will be reviewed when the FCA
publishes its policy statement on CP26/5. Paragraph references to UK SRS appendices follow the
government's published comparison annex.*

---

**Source:** [https://abgalis.com/regulation/uk-srs](https://abgalis.com/regulation/uk-srs) · Abgalis Research, published by Abgalis Limited (England and Wales, no. 17247499)

**Cite as:** Abgalis Research, *UK SRS explained: what the UK Sustainability Reporting Standards require of insurers*, Abgalis Limited. https://abgalis.com/regulation/uk-srs