ESG Quick Guide: UK Sustainability Reporting Standards (UK SRS)

At present, the UK has two main sets of rules for the disclosure of climate change issues by companies – the regime under the Companies Act 2006 (“CA 2006”) and the regime under the UK Listing Rules (“UKLR”). 

In February 2026, the UK government formally endorsed the sustainability disclosure standards developed by the ISSB (IFRS S1 and S2) for voluntary use in the UK, with some minor amendments. This was done via the UK SRS. 

UK SRS S1 sets out the general requirements for sustainability-related disclosures. And UK SRS S2 sets out requirements for climate-related disclosures. 

The UK SRS therefore cover all aspects of sustainability – not just climate change. 

The UK SRS will require (when they become mandatory) new areas of disclosure and will require greater depth of reporting, which will involve additional costs for business.

The UK SRS will require changes to be made to the existing regimes under the CA 2006 and the UKLR. 

The Financial Conduct Authority ("FCA") is already consulting on changes to the UKLR to reflect the UK SRS and the government has said it will consult (on a date TBD) on changes to the CA 2006.

In the meantime, even if an entity did decide to voluntarily disclose against the UK SRS, the existing climate-related reporting regimes (under the CA 2006 and UKLR) continue to apply. 

The government has clarified (in its response to the consultation on the draft UK SRS) that public companies reporting in accordance with UK SRS S2 will meet their legal requirements to disclose climate-related financial information under the CA 2006. 

The UK SRS apply on a voluntary basis initially but the intention is to make this mandatory for certain entities in due course. 

The government published the final versions of the UK SRS on 25 February 2026 (see our blog post). These are now available for voluntary use in the UK. 

The government (Department for Business and Trade / DBT) has said it will consult (on a date TBD) on changes to the CA 2006 to make disclosure in line with the UK SRS mandatory for certain types of companies, including possibly private companies. 

The government has confirmed that its approach will be considered as a part of the broader reporting consultation - known as the Modernising Corporate Reporting ("MCR") programme - that it will be undertaking later this year.  

The FCA is already consulting on changes to the UKLR to make disclosures in line with the UK SRS mandatory for listed companies (see our blog post). That consultation closed on 20 March 2026. The FCA intends to finalise its rules in 2026, with a view to them applying to accounting periods beginning on or after 1 January 2027.

The differences between the IFRS / ISSB standards and the UK SRS are set out in Annex A to the government response document. 

The main differences are as follows: 

• A reporting entity “may” (rather than “shall”) consider the SASB standards when reporting under the UK SRS.
• The removal of timings including for temporary reliefs, although these may be re-introduced when mandatory reporting requirements are introduced.
• The inclusion of provisions either limiting the ability to make compliance statements or requiring that additional information is included in compliance statements when an entity is relying on reliefs.
• Removing the ability for an entity to report sustainability disclosures after it has published its financial statements.
• Allowing financial institutions to report financed emissions from a different reporting period provided that additional disclosures are made (see more detail below).    

For a detailed analysis of the differences between the draft UK SRD and the final UK SRS, see our blog post.

The government consulted on climate transition plans in June 2025 (see our previous blog post), alongside its consultation on the draft UK SRS. 

However, the government has not yet published its response to that consultation so it remains unclear at this stage if transition plans will become mandatory in the UK, and (if so) for which entities and when. We are waiting for the government to announce its next steps on this. 

UK SRS S2 requires disclosure of any climate-related transition plan that an entity has, including key assumptions used to develop such a plan and dependencies on which the plan relies. 

In its consultation on transition plans, the government included questions on whether UK SRS S2 provides sufficient information on transition plans and, if not, it asked what further information respondents would like to see.  

The FCA, in its consultation on changes to the UKLR to reflect the UK SRS, indicated that it does not consider it appropriate at this stage to mandate transition plans in its changes to the UKLR. Instead, the FCA is proposing to replace the existing TCFD-based guidance on transition plan disclosures with:

• a “disclose or explain” requirement, which would require listed companies to include a statement in their annual report explaining whether they have disclosed a climate-related transition plan, and where it can be found. If they have not published a transition plan, the FCA proposes that companies be required to state why not; and
• guidance stating that listed companies that produce a climate-related transition plan may wish to use the IFRS Educational Material, to encourage international comparability.

For more information on transition plans requirements under various disclosure regimes, see our Quick Guide on this. 

In its consultation on the draft UK SRS in June 2025 (see our blog post), the government raised the issue of forward-looking information. 

Reporting on climate and sustainability-related matters will include forward-looking information, including information on the future prospects of the reporting entity, how its strategy will develop over time, and its climate and environmental targets. 

Stakeholders have raised the prospect of legal implications if it later emerges that this information is inaccurate. There could also be implications from any reliance on third-party data, including for example data used to estimate GHG emissions across the value chain.

In section 463 of the CA 2006, there are protective provisions for forward looking information in strategic reports and directors’ reports included in company annual reports. Directors are liable to the company (but not investors) for any loss suffered as a result of any untrue or misleading statement in a report, or any omission, where the director either “knew the statement to be untrue or misleading or was reckless” or knew that the omission was a “dishonest concealment of a material fact”. These provisions should allow for reporting to be made with the best available information and in good faith. 

The UK government said in the consultation on the draft UK SRS that it is considering whether similar provisions should apply to reporting requirements under the UK SRS. Presumably this will be addressed when the government consults on changes to the CA2006 to reflect the UK SRS.

The government has made it clear that any decisions on the UK SRS need to be aligned with the government’s ambition to reduce the costs of regulation for business by 25%. The objective is to ensure that any new sustainability disclosure requirements generate decision-useful information for investors and other stakeholders, while not being overly burdensome for reporting entities to meet.

The Department for Business and Trade announced in October 20204 plans for an “ambitious” consultation in 2025 on further proposals to simplify and modernise the UK’s non-financial reporting framework, which is not limited to sustainability disclosures. Presumably this will be wrapped up as part of the government's MCR programme (discussed above). 

The government has also said it will also consider whether to update current climate disclosure rules for pension schemes, in light of the UK SRS. The Department for Work and Pensions will review the existing regulations, building on evidence provided by The Pensions Regulator. 

The government has said it will consult (on a date TBD) on changes to the CA 2006 to make disclosure in line with the UK SRS mandatory for certain types of companies, including possibly private companies. 

The government has confirmed that its approach will be considered as a part of the broader reporting consultation - known as the Modernising Corporate Reporting ("MCR") programme - that it will be undertaking later this year.  

The FCA is already consulting on changes to the UKLR to make disclosures in line with the UK SRS mandatory for listed companies (see our blog post). That consultation closed on 20 March 2026. The FCA intends to finalise its rules in 2026, with a view to them applying to accounting periods beginning on or after 1 January 2027.

• UK SRS S1 and UK SRS S2 - final versions
• Government response to the consultation on the draft UK SRS
• UK SRS webpage

• UK: Government publishes final versions of UK SRS
• UK SRS: FCA proposes mandatory climate disclosures from 2027, except for Scope 3 emissions, for which it is "comply-or-explain" from 2028
• UK consults on draft UK SRS: implementation of ISSB sustainability disclosure standards
• Quick Guide on ISSB standards
• Quick Guide on UK regime under Companies Act 2006
• Quick Guide on UK regime under Listing Rules
• Other ESG Quick Guides