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Your complete UK SRS S2 disclosures checklist

Every disclosure UK SRS S2 asks for, the paragraph it comes from, and the evidence to keep ready. Plus what to say if you can't meet a requirement yet.

Work through it on this page, or start a free trial and track each requirement in Drova.

UK SRS S2 framework in Drova: clause compliance result, control effectiveness, tasks, and the Governance clauses

TL;DR

  • UK SRS S2 is the UK's climate disclosure standard, issued by the Secretary of State for Business and Trade in February 2026 and based on IFRS S2.
  • From accounting periods beginning on or after 1 January 2027, the FCA's listing rules require in-scope listed companies to report against UK SRS S2, or explain which requirements they haven't met, why, and the steps they're taking or plan to take. For calendar-year companies, first reports are published in 2028.
  • This checklist lists every UK SRS S2 disclosure area with its paragraph references, a fill-in template and the evidence to keep ready.
  • Section 07 covers comply or explain: what an explanation has to say, what doesn't need explaining, and how to state the reliefs.

The checklist

What this checklist covers

UK SRS S2 sets out what a company discloses about its climate-related risks and opportunities: how they are governed, how they shape strategy, how they are managed, and how they are measured. This page lists every disclosure area in UK SRS S2, the paragraphs each comes from, and the evidence to keep ready behind it, organised into the sections of a first-year report.

Work through each section and tick what you can already evidence. Whatever is left unticked is your work plan, and section 07 explains what to say about it.

The checklist is written in our own words. Always work from the published standard on GOV.UK when you prepare your disclosures, and take appropriate legal, accounting and assurance advice before you finalise them.

Before you start

Who reports under UK SRS S2, and from when?

Listed companies, through the FCA's listing rules. The FCA's final rules (Policy Statement PS26/19, September 2026) apply to five listing categories:

  • equity shares in commercial companies
  • equity shares in the transition category
  • secondary listings of international commercial companies
  • certificates representing certain securities (depositary receipts)
  • non-equity shares and non-voting equity shares

Out of scope: closed-ended investment funds, open-ended investment companies, shell companies, debt and debt-like securities, securitised derivatives, and warrants, options and other miscellaneous securities. Investment entities and shell companies are also excluded from the transition and non-equity share categories.

From when. The rules apply to accounting periods beginning on or after 1 January 2027. For calendar-year companies, first reports are published in 2028. A company with a year starting 1 April, for example, reports on the year from 1 April 2027 to 31 March 2028.

Comply or explain. In-scope companies report in line with UK SRS, or explain in their annual financial report which UK SRS S2 requirements they have not met, why, and any steps they are taking or plan to take. (Under UK SRS S1, explanations are framed by the sustainability risks and opportunities not reported on.) Section 07 covers what a good explanation looks like.

Reliefs in the first years. Scope 3 emissions can be left out for the first year (periods beginning in 2027), and companies can report on climate only, rather than all sustainability topics, for the first two years. A company using a relief says so in its annual financial report. The Scope 3 relief ends for periods beginning on or after 1 January 2028, and the climate-only relief for periods beginning on or after 1 January 2029. No comparative figures are needed for the first period you report, including the first period you report on something a relief previously covered; comparatives are needed from the period after that.

Everyone else. For other companies, UK SRS is voluntary for now. The government has said it will consider how UK SRS should be reflected in the Companies Act 2006.

The Companies Act rules still apply. Separately, the Companies Act 2006 already requires certain companies, listed or not, to make climate-related financial disclosures in their strategic report. The listing rules don't replace that duty. The government has said companies can use their UK SRS S2 disclosures to meet it.

Not sure whether you're in scope? See who must comply with UK SRS.

01

Basis of preparation

Paragraphs: UK SRS S2 Appendix C (C1-C6); UK SRS S1 as it relates to climate (S2 C2), including the parts the FCA's guidance says may be relevant: conceptual foundations 10-24, general requirements 60-71, statement of compliance 72-73B, and judgements, uncertainties and errors 74-86 (UKLR 6.6.6AG, which also lists S1 31, 49, 50, 52 and 53, and Appendices A, B and D).

A company applies UK SRS S2 at the same time as UK SRS S1, as far as S1 relates to climate (S2 C2). That brings in S1's ground rules: the climate disclosures cover the same reporting entity and period as the financial statements, are published at the same time, connect to the financial statements, and say how they were prepared, including the judgements and uncertainties behind them.


Required disclosures


  • A statement of compliance with UK SRS S2 (S1 72-73B), or, if you don't meet every requirement, the explanation in section 07 (UKLR 6.6.6R(7A)(b))
  • The financial statements the disclosures relate to, for the same reporting entity and period (S1 20, 22, 64)
  • How the climate disclosures connect to each other and to the financial statements, with consistent data and assumptions (S1 21, 23)
  • Significant judgements made in preparing the disclosures (S1 74-76)
  • Measurement uncertainty affecting the amounts reported (S1 77-82)
  • Corrections of material prior period errors, if any (S1 83-86)
  • Any relief you use, stated (S2 C3-C5; S1 73A; UKLR TP 16)

Disclosure text (fill in)

  • If you meet every requirement: In producing the climate-related financial disclosures made in this report, we have met all the requirements of UK SRS S2. If you use the Scope 3 relief, add: We have used the relief in UK SRS S2 paragraph C4 and UKLR TP  , so these disclosures do not include Scope 3 greenhouse gas emissions.
  • If you explain: Our report includes climate-related financial disclosures prepared in accordance with UK SRS S2 requirements, except in relation to   (paragraph  ). This opens an explanation, not a statement of compliance: complete it with the reasons and steps in section 07.
  • (Both adapted from the FCA's illustrative examples 1 and 2, draft TN 803.1 Annex 2.)
  • These disclosures relate to the financial statements of   for the period   to  
  • Where the disclosures sit in the annual financial report:  
  • Significant judgements:  
  • Main sources of measurement uncertainty:  
  • Reliefs relied on, and the listing-rule reference:  
  • Prior period errors corrected (if any):  

Evidence to keep ready

7 items

Basis of preparation

02

Governance

Paragraphs: UK SRS S2 5-7, including 6(a)(i)-(v) and 6(b)(i)-(ii).

Governance disclosures show who is accountable for climate-related risks and opportunities, how that oversight works in practice, and how climate is built into strategy, major decisions, risk management and target-setting. If you govern all sustainability matters together, you can describe that once rather than repeating it for climate (S2 7).


2.1 Board or committee oversight


Paragraphs: S2 6(a)(i)-(v)

What to disclose: the body or person responsible for oversight, named, and:

  • how climate responsibilities appear in its terms of reference, mandates, role descriptions and related policies (6(a)(i))
  • how it decides whether it has, or will build, the skills to oversee your climate strategy (6(a)(ii))
  • how, and how often, it is informed about climate-related risks and opportunities (6(a)(iii))
  • how it takes climate into account when overseeing strategy, major transactions and risk management, including any trade-offs it has weighed (6(a)(iv))
  • how it oversees target-setting and monitors progress, including whether and how climate metrics feed into remuneration policies (6(a)(v); see sections 05 and 06)


Disclosure text (fill in)


  • Oversight of climate-related risks and opportunities sits with   (body or individual).
  • Climate responsibilities are set out in   (terms of reference, mandate or policy).
  • The   receives climate updates from  ,   times a year. Matters covered this period:  
  • When overseeing strategy, major transactions and risk management this period, the   considered  , including the trade-off between   and  .
  • The   approves our climate-related targets and reviews progress   (how often). Climate metrics   (are / are not) included in remuneration policies:  


2.2 Skills and competence


Paragraphs: S2 6(a)(ii)


Disclosure text (fill in)


  • The   assesses whether it has the skills to oversee our climate strategy by  . Where gaps exist, we are building them through   (training, appointments, external advisers).


2.3 Management's role


Paragraphs: S2 6(b)(i)-(ii)

What to disclose:

  • whether day-to-day responsibility is delegated to a named management role or committee, and how the board oversees that role or committee (6(b)(i))
  • whether management uses controls and procedures to support climate oversight, and if so how they connect with other internal functions (6(b)(ii))


Disclosure text (fill in)


  • Management responsibility for climate-related risks and opportunities is delegated to   (role or committee), which reports to   (board or committee)   (how often).
  • Controls and procedures supporting climate oversight:  . These are integrated with   (for example internal audit, finance, risk).

Evidence to keep ready

8 items

Governance

Evidence ready from the start

Every section pairs the disclosures with the evidence to keep ready. It's also what an assurance provider would ask for, if you choose to seek assurance. If you need to get moving on UK SRS S2, start a free trial today.

UK SRS S2 selected as a framework in Drova

03

Strategy

Paragraphs: UK SRS S2 8-23 (9-14 risks and opportunities, business model and value chain, strategy and decision-making; 15-21 financial effects; 22 climate resilience; 23 metrics to consider), with S2 B1-B18 (scenario analysis) and UK SRS S1 31 (time horizons).

Strategy disclosures show which climate-related risks and opportunities could affect your prospects, where they sit in your business, what you are doing about them, what they mean for your numbers, and how resilient your strategy is across different climate futures.


3.1 Climate-related risks and opportunities


Paragraphs: S2 10-12

What to disclose:

  • each climate-related risk and opportunity that could reasonably be expected to affect your prospects (10(a))
  • for each risk, whether it is a physical or a transition risk (10(b))
  • for each risk and opportunity, the time horizon over which its effects could occur: short, medium or long term (10(c))
  • how you define short, medium and long term, and how those definitions link to your planning horizons (10(d); S1 31)

Identify them using reasonable and supportable information available without undue cost or effort (S2 11). You may consider the industry-based disclosure topics in the Industry-based Guidance on Implementing IFRS S2 (S2 12).


Disclosure text (fill in)


  • We define short term as  , medium term as   and long term as  . These match   (our planning cycle, capital allocation horizon).
  • Risk:   · physical (acute / chronic) or transition (policy, legal, technology, market, reputation) · time horizon  
  • Opportunity:   · time horizon  


3.2 Business model and value chain


Paragraphs: S2 13

What to disclose:

  • the current and anticipated effects of climate-related risks and opportunities on your business model and value chain (13(a))
  • where in your business model and value chain they are concentrated, for example by geography, facility or type of asset (13(b))


Disclosure text (fill in)


  • Climate-related risks and opportunities currently affect our business model and value chain by  , and we expect  
  • They are concentrated in   (regions, sites, asset types, supplier groups).


3.3 Strategy, decision-making and transition plan


Paragraphs: S2 14

What to disclose:

  • how you have responded, and plan to respond, in your strategy and decision-making (14(a)), including:
    • current and anticipated changes to your business model and resource allocation (14(a)(i))
    • direct mitigation and adaptation efforts, such as changes to processes, equipment, sites, workforce or products (14(a)(ii))
    • indirect mitigation and adaptation efforts, such as working with customers and suppliers (14(a)(iii))
    • any climate-related transition plan, including its key assumptions and dependencies (14(a)(iv))
    • how you plan to achieve any climate-related targets, including emissions targets and any targets you are required to meet by law or regulation (14(a); 14(a)(v); see section 06)
  • how you are resourcing, and plan to resource, those activities (14(b))
  • quantitative and qualitative information on progress against plans disclosed in earlier periods (14(c))

For most listing categories, the listing rules also ask whether you have published a transition plan, and where (section 07). The FCA says you may use the IFRS Foundation's guidance on transition plan disclosures if you publish one (UKLR 6.6.7AG).


Disclosure text (fill in)


  • In response to   (risk or opportunity), we have   and plan to  
  • Resources allocated:   (budget, capital expenditure, people)
  • Our climate-related transition plan   (is set out in   / we do not currently have one). Key assumptions:   Dependencies:  
  • Progress against the plans we disclosed last period:  


3.4 Financial position, performance and cash flows


Paragraphs: S2 15-21

What to disclose, in quantitative and qualitative terms:

  • how climate-related risks and opportunities affected your financial position, performance and cash flows this period (16(a))
  • which of those risks and opportunities create a significant risk that the reported value of assets or liabilities in your financial statements will need a material adjustment in the next reporting period (16(b))
  • how you expect your financial position to change over the short, medium and long term, taking into account your investment and disposal plans, including plans you are not yet contractually committed to, and your planned sources of funding (16(c))
  • how you expect financial performance and cash flows to change over the short, medium and long term (16(d))

How to approach it:

  • A single amount or a range is fine (S2 17).
  • For anticipated effects, use reasonable and supportable information available without undue cost or effort, and an approach that matches your skills, capabilities and resources (S2 18).
  • You need not give a figure if the effects are not separately identifiable, or the measurement uncertainty is so high the figure would not be useful (S2 19). For anticipated effects only, you also need not give one if you lack the skills, capabilities or resources (S2 20).
  • If you don't give a figure, you must say why, describe the effects in words, including which figures in your financial statements are or are likely to be affected, and give a combined figure with other climate risks and other factors unless that would not be useful (S2 21). Doing this meets the standard. The FCA's draft guidance (TN 803.1) says no further explanation is needed under the listing rules (see section 07).


Disclosure text (fill in)


  • In the period,   (risk or opportunity) affected   (line item) by   (amount or range).
  • Assets and liabilities at significant risk of a material adjustment next year:  
  • Over the   term, we expect   (financial position, performance, cash flows) to change by  , given   (investment plans, funding sources).
  • Where we have not quantified an effect: we have not provided a figure for   because  . The items in our financial statements that   (have been / are likely to be) affected are  . Combined effect:   (or why a combined figure would not be useful).


3.5 Climate resilience and scenario analysis


Paragraphs: S2 22, B1-B18

What to disclose:

  • your assessment of climate resilience at the reporting date (22(a)), including:
    • what it means for your strategy and business model, and how you would respond (22(a)(i))
    • the significant areas of uncertainty in the assessment (22(a)(ii))
    • your capacity to adjust over the short, medium and long term: the money you could draw on, how far you could change the use of existing assets or retire them, and what your current and planned climate investment does for your resilience (22(a)(iii))
  • how and when you carried out the scenario analysis (22(b)), including:
    • inputs: which scenarios and their sources, whether they cover a diverse range, whether they relate to transition or physical risks, whether one is aligned with the latest international agreement on climate change, why they are relevant, the time horizons, and the scope of operations covered (22(b)(i))
    • key assumptions about climate policy, macroeconomic trends, national or regional variables, energy use and mix, and technology (22(b)(ii))
    • the reporting period in which the analysis was carried out (22(b)(iii))

How to approach it:

  • Scenario analysis is required, using an approach that suits your circumstances (S2 22). A simpler, qualitative approach is acceptable where it fits. A company with a high degree of exposure to climate risk and access to the necessary skills, capabilities or resources must use a more advanced quantitative approach (S2 B17).
  • You can run the analysis on your strategic planning cycle, for example every three to five years, so the 22(b) disclosures may stay the same in some years. The resilience assessment in 22(a) is updated every reporting date (S2 B18).


Disclosure text (fill in)


  • We assessed our climate resilience using   (qualitative narratives / quantitative analysis), carried out in   (reporting period).
  • Scenarios used:   (name and source), covering   (transition / physical risks), including   (scenario aligned with the latest international agreement on climate change). We chose them because  
  • Time horizons:   Scope of operations covered:  
  • Key assumptions:   (policy, macroeconomic, regional, energy, technology)
  • Implications for our strategy and business model:   Significant uncertainties:  
  • Our capacity to adjust:   (financial resources, assets, planned investment)


3.6 Metrics to consider


Paragraphs: S2 23

In preparing 3.2 to 3.5, refer to and consider the cross-industry metric categories (S2 29), and you may consider the industry-based metrics (S2 32). See section 05.

Evidence to keep ready

11 items

Strategy

04

Risk management

Paragraphs: UK SRS S2 24-26, including 25(a)(i)-(vi), 25(b) and 25(c).

Risk management disclosures show how you find, assess, prioritise and monitor climate-related risks and opportunities, and how that fits into your wider risk management. If you manage sustainability risks on an integrated basis, describe that once rather than repeating it for climate (S2 26).


4.1 Processes for climate-related risks


Paragraphs: S2 25(a)(i)-(vi)

What to disclose, about the processes and related policies you use to identify, assess, prioritise and monitor climate-related risks:

  • the inputs and parameters, such as data sources and the operations covered (25(a)(i))
  • whether and how scenario analysis informs how you identify risks (25(a)(ii))
  • how you assess the nature, likelihood and size of their effects, for example qualitative factors or quantitative thresholds (25(a)(iii))
  • whether and how you prioritise climate risks against other types of risk (25(a)(iv))
  • how you monitor them (25(a)(v))
  • whether and how the processes changed since the previous period (25(a)(vi))


Disclosure text (fill in)


  • We identify climate-related risks using   (data sources), covering   (operations, sites, value chain).
  • Scenario analysis   (informs / does not currently inform) how we identify climate-related risks:  
  • We assess likelihood and impact using   (criteria, thresholds, rating scale).
  • Climate-related risks are prioritised   (alongside / separately from) other risks by  
  • We monitor them through   (owner, frequency, reporting).
  • Changes since last period:   (or none)


4.2 Processes for climate-related opportunities


Paragraphs: S2 25(b)


Disclosure text (fill in)


  • We identify, assess, prioritise and monitor climate-related opportunities by  . Scenario analysis   (informs / does not currently inform) this:  


4.3 Integration with overall risk management


Paragraphs: S2 25(c)


Disclosure text (fill in)


  • Climate-related risks and opportunities are   (fully / partly) integrated into our enterprise risk management through   (risk register, risk appetite, reporting to  ).

Evidence to keep ready

7 items

Risk management

05

Metrics

Paragraphs: UK SRS S2 27-32, including 29(a)(i)-(vi), 29A-29C, 29(b)-(g), with S2 B19-B65; UK SRS S1 49-50 and 52-53 (how metrics are defined and kept consistent); S2 C3-C4 (reliefs).

Metrics disclosures show your performance on climate: your greenhouse gas emissions, how exposed your assets and activities are, how much capital you put towards climate, and the industry metrics that matter for your business.


5.1 Greenhouse gas emissions


Paragraphs: S2 29(a)

What to disclose:

  • absolute gross Scope 1, Scope 2 and Scope 3 emissions for the period, in metric tonnes of CO2 equivalent (29(a)(i))
  • measured using the Greenhouse Gas Protocol Corporate Standard (2004), unless a jurisdictional authority or an exchange you are listed on requires a different method (29(a)(ii))
  • your measurement approach, inputs and assumptions, why you chose them, and any changes in the period with the reasons (29(a)(iii)), including:
    • whether you use the equity share or a control approach to set your boundary, and why (B27)
    • the emission factors you use (B29)
    • where you use value chain data for a different period from yours, the effect of significant events between those dates and your reporting date (B19(c))
  • Scope 1 and 2 split between your consolidated group and other investees, such as associates and joint ventures (29(a)(iv))
  • location-based Scope 2, plus any information on contractual instruments users need to understand your Scope 2 figure (29(a)(v))
  • for Scope 3, the categories included, using the Greenhouse Gas Protocol's 15 categories (29(a)(vi)(1))
  • for Scope 3, how far your figures rely on data from specific activities in your value chain, and how far on verified data (B55-B56). In the rare case that Scope 3 is impracticable to estimate, say how you are managing those emissions instead (B57)
  • if you are in asset management, commercial banking or insurance, additional information on financed emissions (29(a)(vi)(2); B58-B63A)

Financed emissions:

  • You may limit Category 15 to financed emissions, and leave out emissions from derivatives. If you do, say what you treated as a derivative and which financial activities you left out (29A-29B).
  • If Category 15 is in your Scope 3 figure, disclose the Category 15 total and the financed-emissions subtotal (29C).
  • Asset managers: financed emissions split by Scope 1, 2 and 3; the assets under management behind each figure; the share of total assets under management covered, with any exclusions explained; and your method, including how you attribute emissions to the size of each holding (B61).
  • Banks and insurers: financed emissions split by Scope 1, 2 and 3 for each industry and asset class; the gross exposure behind each, with undrawn loan commitments shown separately; the share of gross exposure covered, with any exclusions explained; and your method and attribution (B62-B63). Name the industry classification you used and why it fits, and cover at least loans, project finance, bonds, equity investments and undrawn loan commitments (B62A, B63A).
  • If it is impracticable to estimate financed emissions reliably for the same period as your financial statements, say why, how you estimated what you report, and your plan and timeline to align the periods (B59A).

First-period reliefs:

  • Scope 3. You need not disclose Scope 3, including financed emissions, for accounting periods beginning in 2027 (S2 C4; UKLR TP 16). State that you are using the relief (section 07).
  • Measurement method. For periods beginning in 2027 (or earlier, if you adopt UK SRS early), you may keep a method other than the Greenhouse Gas Protocol, but only if you used it in the period immediately before (S2 C3; UKLR TP 16.6G(4)).


Disclosure text (fill in)


  • Scope 1:   tCO2e · Scope 2 (location-based):   tCO2e · Scope 3:   tCO2e (categories  )
  • Scope 1 and 2 for the consolidated group:   tCO2e; for other investees:   tCO2e
  • Measured using   (method), on   (equity share / control) basis. We chose this approach because  . Changes in the period:  
  • Emission factors used:   (sources)
  • Scope 3 data:   (share or description) measured using activity-specific data;   using verified data
  • Contractual instruments relevant to Scope 2:  
  • Financed emissions (if applicable):   tCO2e, within a Category 15 total of   tCO2e


5.2 Cross-industry metrics


Paragraphs: S2 29(b)-(g), 30-31; B64-B65

What to disclose:

  • how much of your assets or activities are exposed to transition risk, as an amount and a % (29(b))
  • how much are exposed to physical risk, as an amount and a % (29(c))
  • how much are positioned to benefit from climate-related opportunities, as an amount and a % (29(d))
  • how much capital spending, financing or investment went towards climate risks and opportunities (29(e))
  • whether and how you use an internal carbon price in decisions, and the price per tonne (29(f))
  • whether and how executive pay takes climate into account, and what share of this period's executive pay is linked to it (29(g); see 2.1)

For 29(b)-(d), use reasonable and supportable information available without undue cost or effort (S2 30). For 29(b)-(g), refer to B64-B65 (S2 31).


Disclosure text (fill in)


  • Assets or activities vulnerable to transition risks:   (amount) ·  % of  
  • Assets or activities vulnerable to physical risks:   (amount) ·  % of  
  • Assets or activities aligned with climate-related opportunities:   (amount) ·  % of  
  • Capital deployed towards climate-related risks and opportunities:  
  • Internal carbon price:   per tCO2e, used in   (or: we do not apply an internal carbon price in decision-making)
  • Executive remuneration:  % linked to climate-related considerations, through  


5.3 Industry-based metrics


Paragraphs: S2 32

Disclose industry-based metrics associated with your business model, activities or the features of your industry. You may consider the metrics in the Industry-based Guidance on Implementing IFRS S2.


Disclosure text (fill in)


  • Industry:   · Metric:   · Value:   · Source of the metric:  


5.4 Defining your metrics


Paragraphs: S1 49-50, 52-53

For any metric taken from another source, name the source (S1 49). For any metric you developed yourself (S1 50), say:

  • how it is defined, including whether you adapted it from another source and how yours differs
  • what kind of metric it is: a total, a ratio to another metric, or a non-numeric rating (such as a traffic-light score)
  • whether a third party validated it, and who
  • how you calculate it, from what inputs, and where the method falls short or rests on key assumptions

Keep definitions consistent over time (S1 52), and label metrics clearly (S1 53).

Evidence to keep ready

14 items

Metrics

This checklist is a snapshot. Drova keeps it live.

Everything above is a point-in-time picture. In Drova, your team tracks each UK SRS S2 requirement's progress and attaches the evidence and controls that support it, all year round, not just at reporting time.

UK SRS S2 Disclosure Report in Drova

06

Targets

Paragraphs: UK SRS S2 33-37, with S2 B66-B71.

Targets disclosures show the climate-related targets you have set, and any you must meet by law or regulation: what each one is, how you set and review it, and how you are doing against it.


6.1 Each target


Paragraphs: S2 33

What to disclose, for each quantitative or qualitative climate-related target, including any emissions target:

  • the metric used to set it (33(a))
  • its objective, for example mitigation, adaptation or alignment with science-based initiatives (33(b))
  • the part of the business it covers (33(c))
  • the period it applies to (33(d)) and the base period progress is measured from (33(e))
  • any milestones and interim targets (33(f))
  • for a quantitative target, whether it is absolute or intensity-based (33(g))
  • how the latest international agreement on climate change, and the commitments jurisdictions have made under it, informed the target (33(h))

If you developed a target's metric yourself, describe it as set out in 5.4 (B67; S1 50).


Disclosure text (fill in)


  • Target:   · Metric:   · Objective:   · Covers:   · Period:   to   · Base period:   · Interim milestones:   · Absolute or intensity:  
  • This target was informed by   (for example the Paris Agreement, currently the latest international agreement on climate change, and the commitments made under it by the jurisdictions you operate in).
  • If you have none: We have not set climate-related targets, and we are not required to meet any by law or regulation.


6.2 Setting, reviewing and monitoring


Paragraphs: S2 34

What to disclose, for each target:

  • whether a third party validated the target and the method behind it (34(a))
  • how you review the target (34(b))
  • the metrics you use to monitor progress (34(c))
  • any revisions, and why (34(d))


Disclosure text (fill in)


  • The target   (was / was not) validated by  . We review it   (how often, by whom). Progress is monitored using  . Revisions this period:   (or none)


6.3 Performance against each target


Paragraphs: S2 35


Disclosure text (fill in)


  • Performance against   this period:   (against a base of  ). Trend and explanation:  


6.4 Greenhouse gas emissions targets


Paragraphs: S2 36

What to disclose, for each emissions target:

  • the greenhouse gases it covers (36(a))
  • which of Scope 1, 2 and 3 it covers (36(b))
  • whether it is a gross or a net target; for a net target, also disclose the associated gross target (36(c))
  • whether it was derived using a sectoral decarbonisation approach (36(d))
  • if you plan to use carbon credits to reach a net target: how much the target depends on them, who will certify them, what kind they are (nature-based or technological, cutting emissions or removing them), and anything else investors need to judge their quality, such as how long the effect lasts (36(e); B70-B71)


Disclosure text (fill in)


  • Gases covered:   · Scopes covered:   · Gross or net:   (gross target associated with our net target:  ) · Sectoral decarbonisation approach:   (yes / no)
  • Planned use of carbon credits:  % of the net target, verified by  , type  , credibility considerations  


6.5 Choosing target metrics


Paragraphs: S2 37

When choosing metrics to set and monitor targets, refer to and consider the cross-industry metrics (S2 29) and industry-based metrics (S2 32), including those in another UK SRS standard, or metrics that otherwise meet UK SRS S1. See section 05.

Evidence to keep ready

8 items

Targets

07

Comply or explain, and assurance

Rules: UKLR 6.6.6R(7A)(b) and (8)(c)-(e) for commercial companies (applied to overseas commercial companies by UKLR 6.6.17R; equivalents by listing category in the table below); FCA PS26/19 3.20-3.25; FCA draft Technical Note 803.1 (consultation closed 28 October 2026).

The listing rules let you report against UK SRS S2, or explain where you don't. This section covers what an explanation has to say, what doesn't need explaining, how to state the reliefs, and the other statements in-scope companies make: three for most listing categories, two for secondary listings and depositary receipts.


7.1 What an explanation must say


Rules: UKLR 6.6.6R(7A)(b)

If you have not met some UK SRS S2 requirements, your annual financial report needs a statement that sets out:

  1. a summary of the UK SRS S2 requirements you have not met
  2. why you have not made those disclosures
  3. any steps you are taking, or plan to take, to make them in future

How the FCA expects it to read (draft TN 803.1):

  • You don't need a separate explanation for every requirement, but you must clearly identify the requirements not met, for example by heading or paragraph number.
  • The reasons can be short and proportionate, but should not leave out material information.
  • Briefly describe any significant judgements behind your assessment, where needed.
  • If you are taking steps, say so. A timeframe isn't required, but the FCA says it helps if you know one.
  • Clear, concise and cogent: plain language, little room for ambiguity.
  • Specific to your company, not generic.

If you explain for any part of UK SRS S2, you cannot make an unreserved statement of compliance with UK SRS S2 (UK SRS S1 72; draft TN 803.1, Annex 1).


7.2 A short example


Weak: "Due to data limitations, we have not disclosed all metrics. We are working towards full disclosure." It doesn't say which requirements, the reason is generic, and there is no real step.

Stronger: "Our report includes climate-related financial disclosures prepared in accordance with UK SRS S2, except in relation to assets or business activities vulnerable to climate-related physical risks (paragraph 29(c)). We have not yet mapped our 40 distribution sites against physical climate hazards. We are implementing a site-level hazard dataset from our insurer, which will provide this information from the reporting period beginning 1 January 2028."

(Illustrative only: a fictional company.)


7.3 What doesn't need explaining


  • Reliefs you use. Using the Scope 3 relief or the climate-first S1 relief is stated, not explained (PS26/19 3.20, 3.23). See 7.4.
  • The standard's own routes. Where UK SRS S2 itself lets you give a qualitative description instead of a figure, and you follow what it asks (for example S2 paragraph 21 on financial effects, see 3.4), you are meeting the standard. The FCA's draft guidance says no further explanation is needed (draft TN 803.1, Annex 1).
  • Information that isn't material. You need not disclose information a requirement asks for if it isn't material (UK SRS S1 B25). Leaving it out meets the standard, so it is not a gap to explain. If the judgement had a significant effect on what you report, describe it with your other judgements (S1 74-75; section 01).


7.4 Stating the reliefs


Rules: UKLR TP 16; PS26/19 3.20-3.25

  • Scope 3 (periods beginning in 2027). State that you are relying on the transitional provision for your listing category and the relief in UK SRS S2 paragraph C4. You can still make a full statement of compliance with UK SRS S2, with the relief stated alongside it (S1 73A; draft TN 803.1, Annex 2 example 1).
  • Climate-first (periods beginning in 2027 and 2028). State that you are relying on the transitional provision and the relief in UK SRS S1 paragraph E3. If you use it, you cannot state compliance with UK SRS S1 (S1 73A).
  • Measurement method (periods beginning in 2027). If you keep a method other than the Greenhouse Gas Protocol (S2 C3), disclose that alongside your statement of compliance (S2 C5; S1 73A). The figures it produces can be used as comparatives in the next period (S2 C5; PS26/19 3.21).
  • Comparatives. None are needed for the first period you report, including the first period you report on something a relief covered before; they are needed from the period after (PS26/19 3.25).

Transitional provision to cite, by listing category

Listing categoryPeriods beginning in 2027 (Scope 3 and climate-first)Periods beginning in 2028 (climate-first only)
Equity shares (commercial companies)UKLR TP 16.4R(2)UKLR TP 16.5R(2)
Equity shares (transition)UKLR TP 16.17R(2)UKLR TP 16.18R(2)
Equity shares (international commercial companies secondary listing)UKLR TP 16.8R(2)UKLR TP 16.9R(2)
Certificates representing certain securitiesUKLR TP 16.8R(2), as applied by UKLR TP 16.11RUKLR TP 16.9R(2), as applied by UKLR TP 16.11R
Non-equity shares and non-voting equity sharesUKLR TP 16.13R(2)UKLR TP 16.14R(2)

From periods beginning on or after 1 January 2029 the Scope 3 and climate-first reliefs no longer apply. The comparatives point still does: none are needed the first time you report on something a relief covered (UKLR TP 16.6G(2)).


Disclosure text (fill in)


  • We have not disclosed our Scope 3 greenhouse gas emissions. We are relying on UKLR TP   and the relief in paragraph C4 of UK SRS S2.
  • We have reported on climate-related risks and opportunities only. We are relying on UKLR TP   and the relief in paragraph E3 of UK SRS S1 for climate-first reporting. We therefore do not make a statement of compliance with UK SRS S1.


7.5 Location, assurance and transition plan


Rules: UKLR 6.6.6R(8)(c)-(e)

Each in-scope company also states the following. Secondary listings and depositary receipts make the first two only.

  • where in the annual financial report its climate disclosures, and any explanation, can be found ((8)(c)). You can cross-refer to another report (UK SRS S1 B45-B47) if it is available at the same time and on the same terms, the cross-reference doesn't make the disclosures harder to understand, and you name the report, say how to access it and point to the exact part
  • whether it obtained third-party assurance. Assurance is voluntary. If you obtained it, give the provider, what was assured and to what level (for example limited or reasonable), the assurance standards used, and, if the assurance report is published, where to find it ((8)(d))
  • whether it has published a climate-related transition plan. If yes, where to find it; if no, why not ((8)(e)). Secondary listings and depositary receipts are not in scope of this statement (UKLR 14.3.24R(6) covers location and assurance only; PS26/19).


Disclosure text (fill in)


  • Our climate-related financial disclosures are on pages   of this report (or: in  , available at  ).
  • We have obtained   (limited / reasonable) assurance over   from  , using   (standards). The assurance report is available at   (if published). (Or: We have not obtained third-party assurance over our climate-related financial disclosures.)
  • Our climate-related transition plan is published at  . (Or: We have not published a climate-related transition plan because  .)


Rule references by listing category


Listing categoryExplain (UK SRS S2)Location, assurance, transition plan
Equity shares (commercial companies)UKLR 6.6.6R(7A)(b) (overseas companies: via 6.6.17R)UKLR 6.6.6R(8)(c)-(e) (overseas companies: via 6.6.17R)
Equity shares (transition)UKLR 22.2.24R(4)(b)UKLR 22.2.24R(6)(a)-(c)
Non-equity shares and non-voting equity sharesUKLR 16.3.23R(4)(b)UKLR 16.3.23R(6)(a)-(c)
Equity shares (international commercial companies secondary listing)UKLR 14.3.24R(4)(b)UKLR 14.3.24R(6)(a)-(b), location and assurance only
Certificates representing certain securitiesUKLR 14.3.24R(4)(b), as applied by UKLR 15.3.1R(3)UKLR 14.3.24R(6)(a)-(b), as applied by UKLR 15.3.1R(3)

International companies with a secondary listing or depositary receipts can rely on reporting for their home listing or country of incorporation, cross-referred from the UK annual financial report, and explain only the UK SRS gaps. Any explanation goes in the UK annual financial report (draft TN 803.1).

Evidence to keep ready

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Comply or explain, and assurance

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08

Glossary

UK SRS. The UK Sustainability Reporting Standards, issued by the Secretary of State for Business and Trade in February 2026 and based on the ISSB's IFRS S1 and S2. Read the UK SRS guide.

UK SRS S1. The general standard: how to report sustainability-related financial information, and the ground rules that also apply to climate reporting under UK SRS S2. UK SRS S1 explained.

UK SRS S2. The climate standard: what to disclose about climate-related risks and opportunities across governance, strategy, risk management, and metrics and targets. UK SRS S2 explained.

Comply or explain. The FCA's approach for listed companies: report in line with UK SRS, or explain which UK SRS S2 requirements you have not met (for UK SRS S1, which sustainability risks and opportunities you haven't reported on), why, and any steps you are taking or plan to take.

Climate-related risks. Ways climate change could harm a company. Physical risks come from extreme weather (acute) or gradual changes such as rising temperatures (chronic). Transition risks come from the move to a lower-carbon economy: policy, legal, technology, market and reputation.

Climate-related opportunities. Ways climate change could benefit a company, often through the work of cutting emissions or adapting to a changing climate.

Financial materiality. The test for what to report: information is material if leaving it out, getting it wrong or burying it could reasonably be expected to influence the decisions investors, lenders and other creditors make based on the company's reports.

Climate resilience. How well a company's strategy and operations can adjust to climate change and the response to it, managing the risks and taking the opportunities. It covers both strategic and operational resilience.

Scenario analysis. A way of testing how a company's strategy and business model would fare under different possible climate futures.

Transition plan. A company's plan for moving its business towards a lower-carbon economy, as part of its wider strategy: what it is aiming for, what it will do and what it will put in, such as the steps it will take to cut its emissions.

Scope 1, 2 and 3 emissions. Direct emissions from sources a company owns or controls (Scope 1); indirect emissions from the electricity, steam, heating or cooling it buys or acquires and uses (Scope 2); all other indirect emissions in its value chain, upstream and downstream (Scope 3).

Financed emissions. The share of an investee's or borrower's emissions attributed to a company's loans and investments. Part of Scope 3 Category 15.

Internal carbon price. A price per tonne of emissions that a company uses in its own decisions, for example as a shadow price or an internal charge.

Carbon credit. A certificate showing that greenhouse gas emissions were cut or removed, issued under a crediting scheme and tracked on a registry so that each one can only be used once.

Transitional reliefs. Temporary reliefs for the first years of UK SRS reporting: Scope 3 (periods beginning in 2027), climate-first reporting (periods beginning in 2027 and 2028), and keeping a non-GHG Protocol measurement method for periods beginning in 2027 if you used it the year before. Using one is stated in the annual financial report, not explained. (Companies that adopt UK SRS early can use the reliefs sooner.)

Statement of compliance. An explicit, unreserved statement that a company has met all the requirements of a UK SRS standard. Not possible for a standard you explain against, or, for UK SRS S1, if you use the climate-first relief.

FAQs

UK SRS S2 checklist questions, answered

Is UK SRS S2 mandatory?

Not in the way AASB S2 is in Australia. For listed companies in the five FCA listing categories, the listing rules work on a comply or explain basis: for accounting periods beginning on or after 1 January 2027, you report against UK SRS S2 or explain in your annual financial report which requirements you have not met, why, and the steps you are taking or plan to take. For calendar-year companies, the first reports are published in 2028. For every other company, UK SRS is voluntary for now.

What does UK SRS S2 require you to disclose?

Climate-related financial disclosures across the areas this checklist follows: basis of preparation, governance, strategy, risk management, metrics and targets, plus the statements the listing rules add on comply or explain, location, assurance and transition plans. Each section above lists the disclosures and the UK SRS S2 paragraphs they come from.

What happens if we can't meet a requirement?

You explain. Your annual financial report sets out a summary of the UK SRS S2 requirements you have not met, the reasons, and any steps you are taking or plan to take. The FCA expects it to name the requirements, give specific reasons rather than generic ones, and read clearly. If you explain for any part of UK SRS S2, you cannot make an unreserved statement of compliance with it. Section 07 covers what a good explanation looks like.

Do first-year reporters get any relief?

Yes. For accounting periods beginning in 2027 you can leave out Scope 3 emissions, and for periods beginning in 2027 and 2028 you can report on climate only rather than all sustainability topics. A company that used a measurement method other than the Greenhouse Gas Protocol in the period before can keep it for periods beginning in 2027. Using a relief is stated in the annual financial report, not explained. Section 7.4 covers how to state each one.

What is the difference between UK SRS S1 and UK SRS S2?

UK SRS S2 is the climate standard: what to disclose about climate-related risks and opportunities. UK SRS S1 is the general standard for all sustainability-related financial information, and it sets the ground rules UK SRS S2 is applied with, as far as they relate to climate. The listing rules' first-year relief lets you report on climate only, so most companies start with UK SRS S2.

Does UK SRS S2 require scenario analysis?

Yes. The strategy disclosures include an assessment of your climate resilience using climate-related scenario analysis, with an approach that suits your circumstances: a simpler, qualitative approach where it fits, and a more advanced quantitative approach for a company with high exposure to climate risk and the skills and resources to do it (UK SRS S2 22 and B1-B18). Section 3.5 lists what to disclose about the scenarios and assumptions you use.

Where you stand

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