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.
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.
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.
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.
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.
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.
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.
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.
| 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.
No. As at 22 August 2026 no UK entity is required to report against UK SRS S1 or UK SRS S2. The government's guidance states the standards are available for voluntary use by any entity that chooses to do so. Mandation, if it comes, would come from the FCA, which consulted in CP26/5 (30 January 2026, closed 20 March 2026) and has said it intends to publish a policy statement in autumn 2026 with rules coming into force from January 2027. That policy statement has not been published, and the FCA's own reporting-requirements page still describes the TCFD-aligned rules as operative.
The Secretary of State for Business and Trade issued them on 25 February 2026, following a consultation that opened on 25 June 2025, closed on 17 September 2025 and received 209 responses. The FRC did not issue them - a common misattribution. The FRC hosts the UK Sustainability Disclosure Technical Advisory Committee, which made the technical recommendations, and sits on the Policy and Implementation Committee.
It has no effective date. The government deliberately removed the effective-date clauses from both standards to avoid confusion with the introduction of any reporting requirements. Application will be set by future UK regulation or legislation if and when reporting requirements are introduced. A consequence is that for voluntary adopters the transitional reliefs - climate-first, first-year measurement method, and Scope 3 - have no fixed reference period.
The standards themselves impose no entity scope, because they are voluntary. The FCA's proposed scope in CP26/5 covers listed issuers in UKLR categories 6, 14, 15, 16 and 22, excluding closed-ended investment funds, open-ended investment companies, shell companies, debt and debt-like securities, securitised derivatives and warrants. There is no insurer-specific scoping and no scoping by PRA authorisation, so a UK insurer is in scope only if it is itself listed. Lloyd's managing agents, mutuals and unlisted UK subsidiaries are captured by none of it. Large private companies are deferred to the Modernising Corporate Reporting programme.
Less than commentary suggests. The government's comparison annex states that where requirements are not listed, there are no differences. The divergences are: references to the SASB Standards and IFRS S2 industry-based guidance softened from 'shall refer to and consider' to 'may' (UK SRS S1 paragraphs 55(a) and 58(a); UK SRS S2 paragraphs 12, 23 and 32); a new UK-only paragraph B59A on financed emissions; removal of the effective dates; removal of the IFRS S1 relief permitting sustainability information to be published later than the financial statements; and new compliance-statement mechanics at UK SRS S1 paragraphs 73A and 73B. There is no divergence on materiality or on the core content architecture.
B59A is a UK-only addition with no IFRS S2 equivalent. It requires an entity that cannot disclose in line with the financed-emissions requirements at paragraph B59 to explain why. It was added in response to consultation feedback, and 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. For insurers it is a documentation and evidence obligation rather than a data obligation, and the paragraph most likely to be tested under assurance.
No, but it does not exclude them either. The ISSB's December 2025 amendments, carried into UK SRS S2, permit an entity to limit its Scope 3 Category 15 measure to financed emissions only, because established methodologies for insurance-associated emissions are lacking. Underwriting-portfolio emissions therefore sit outside the requirement but remain disclosable voluntarily and remain subject to the general materiality judgements in S1. Describing them as 'excluded' overstates the position.
Yes. 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 this covers the investment portfolio: disaggregation by industry and asset class, gross exposure, the percentage of exposure included in the calculation, and the methodology used. The UK-only paragraph B59A then requires an explanation wherever the entity cannot disclose in line with those requirements.
They are parallel regimes, not one. UK SRS contains no reference to Solvency, underwriting, the SFCR, the RSR or the ORSA beyond the financed-emissions provisions, and CP26/5 proposes no such link. From the other direction, PS25/25 records that the PRA chose not to introduce new disclosure expectations, reaffirming instead that firms should engage with wider disclosure initiatives. UK SRS is a corporate reporting stream under DBT, the FCA and the Companies Act; SS5/25 is a prudential risk-management stream under the PRA carried by the ORSA. They share underlying climate risk analytics and nothing else.
It can. 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, so a company reporting in accordance with UK SRS S2 need not 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. This matters because SI 2022/31 remains in force and expressly captures authorised insurance companies and companies carrying on insurance market activity above 500 employees - so a UK insurer may already have a mandatory duty independent of the voluntary 2026 standards.
Developments on this and related instruments are tracked in regulatory updates.
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