Preparing for UK SRS: what companies need to do now

For the UK's largest listed companies, sustainability reporting is about to change shape. The UK Sustainability Reporting Standards (UK SRS) were published by the Department for Business and Trade on 25 February 2026, and the Financial Conduct Authority has consulted on aligned changes to the Listing Rules. Under the FCA's proposals, mandatory climate disclosures (UK SRS S2) will apply to accounting periods beginning on or after 1 January 2027, with Scope 3 emissions and broader UK SRS S1 disclosures applying on a comply-or-explain basis from 1 January 2028 and 1 January 2029 respectively. A final policy statement is expected this autumn.

While we do not expect the timetable to slip, meaningful preparation needs to be underway by the summer, and most companies are not yet where they need to be.

What the rules cover

UK SRS is intended to become the UK's primary sustainability disclosure framework, aligned with the ISSB's IFRS S1 and S2, and incorporating the targeted amendments the ISSB made to IFRS S2 in December 2025. Over time it will consolidate and, in part, supersede the current patchwork of TCFD-aligned listing rules, SECR, and the climate-related disclosure requirements in the Companies Act. The change brings the UK in line with a growing number of major capital markets, including Japan, Singapore, Hong Kong, and Australia, who have adopted or are moving towards ISSB-aligned standards.

The single most substantive change is the broadening of scope. UK sustainability reporting has historically been about emissions: TCFD looked at climate, SECR at energy and carbon. UK SRS S1 extends the lens to all material sustainability matters, including biodiversity and ecosystem dependencies, water availability, workforce risks, human rights, supply chain resilience and resource scarcity. The regime is deliberately light-touch on its face - investor-focused single materiality, comply-or-explain for Scope 3 and the wider S1 matters, transition reliefs on newer disclosures, and no mandatory assurance at the outset. For companies already running TCFD-aligned disclosure, the conceptual ground is familiar. The challenge is extending it across the wider S1 perimeter.

How to prepare

Preparation splits into four workstreams running in parallel.

Gap assessment

Companies should run a structured comparison of current disclosures under TCFD, SECR, and the Companies Act against SRS requirements, identifying where it is already compliant, where it holds the data but needs to reformat or recontextualise it, and where there is nothing at all. This output drives every other decision.

Data infrastructure

 Most companies' ESG data sits scattered across spreadsheets, supplier emails, plant logs, and procurement records. Under UK SRS, it needs to be auditable to the standard of financial information: methodologies documented and consistent year-on-year, internal controls in place, evidence trails traceable. The most demanding element is often value-chain data, typically Scope 3 emissions from purchased goods and services, which for most companies is the largest emissions line and the hardest to capture.

Governance

UK SRS requires disclosure of how the board oversees sustainability, and the disclosure must match the boardroom reality. Companies whose sustainability function has sat in corporate affairs, distant from finance and risk, likely have most ground to make up.

Assurance readiness

The FCA has not proposed mandatory assurance at the outset. Instead, in-scope companies will simply disclose whether their UK SRS disclosures have been externally assured. However, ISSA (UK) 5000, the relevant sustainability assurance standard, is effective for engagements on information reported for periods beginning on or after 15 December 2026, and investors will draw their own conclusions about a 'no assurance' line in an annual report.