Who mustcomply withUK SRS?

The FCA's final rules, Policy Statement PS26/19 of 30 September 2026, apply to companies with equity shares listed in the commercial companies category (UKLR 6), the international commercial companies secondary listing category (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16), and the transition category (UKLR 22). Out of scope: closed-ended and open-ended investment funds, shell companies, and debt and debt-like securities.

What the rules require. Disclosures in accordance with UK SRS S1 and S2 in the annual financial report, on a comply-or-explain basis. A company that does not make the disclosures, or makes them only in part, must state which requirements were not met, the reasons, and any steps it is taking or plans to take to make them in future. The FCA consulted on making UK SRS S2 mandatory and decided against it.

From when. Accounting periods beginning on or after 1 January 2027, so the first reports are published in 2028. A company with an accounting period beginning before 1 January 2027 keeps the TCFD-aligned rules for that period, or may adopt UK SRS early.

Two transitional reliefs. Scope 3 emissions may be left out for the first year, and the non-climate parts of UK SRS S1 for the first two years. A company using a relief states that it has done so, and no further explanation is needed while the relief runs. Both reliefs have expired for periods beginning on or after 1 January 2029.

Transition plans and assurance. Neither is required. Companies in the commercial companies, non-equity and non-voting equity shares, and transition categories state whether they have published a climate-related transition plan and where to find it, or why they have not. In-scope companies also state whether they obtained third-party sustainability assurance and, if so, from whom, over what, to what level and under which standards; no explanation is needed where none was sought.

If this is your route, the decision is not whether but how. Drova's IFRS S1 and S2 solution is built for this: the financial materiality assessment, the governance and evidence behind each disclosure, and the disclosure output.

Since financial years beginning on or after 6 April 2022, the Companies Act has required certain companies to include climate-related financial disclosures in the strategic report: traded companies, banking companies, authorised insurance companies, companies carrying on insurance market activity, and companies with securities admitted to AIM, each with more than 500 employees; and any other company with more than 500 employees and turnover above £500 million. Large limited liability partnerships have a parallel regime.

Section 414CB(6) lets a company meet those requirements by publishing the information under a national reporting framework, as long as it says which framework it used. The government has confirmed that UK SRS S2 is a national reporting framework for that purpose.

What that means in practice. If you are on route 2, you already produce climate-related financial disclosures. Reporting under UK SRS S2 is a way of meeting the same duty with the structure the FCA and the ISSB now use, rather than a new obligation. Many route 2 companies are also on route 1, in which case the FCA's rules and dates apply as well.

Voluntary. The government's guidance says the standards are available for voluntary use by any entity that chooses to.

Nothing has been proposed for private companies outside route 2. The Modernising Corporate Reporting consultation, open from 7 September to 30 November 2026, says only that the government will consider how UK SRS should be reflected in the Companies Act, and puts forward no scope, thresholds or dates. The review of the existing climate disclosure regulations is due to complete by spring 2027.

What to watch. The consultation outcome, and any change to the 414CB thresholds that comes out of the spring 2027 review. Neither has a date for change.

Why some route 3 companies report anyway. Large customers, lenders and tender processes may ask for climate-related information regardless of whether the law does, and a company in a listed group may be asked to feed its parent's UK SRS report. Voluntary use of UK SRS gives that reporting a recognised structure.

• Route 1, listed. Rules apply to accounting periods beginning on or after 1 January 2027. First reports 2028. Scope 3 relief for one year; non-climate UK SRS S1 relief for two years; both expired for periods beginning on or after 1 January 2029. Early adoption permitted for periods beginning before 1 January 2027.
• Route 2, Companies Act. Duty in force since financial years beginning on or after 6 April 2022. No UK SRS date: using UK SRS S2 is a choice of framework, not a new deadline.
• Route 3, voluntary. No date. UK SRS carries no effective date of its own.
• Everyone. UK SRS S1 lets a company report climate only, with no time limit for voluntary users; a company doing so cannot assert compliance with S1.

Comply or explain. Disclose in accordance with UK SRS, or state which requirements were not met, why, and what you plan to do about it. The basis of the FCA's final rules.

Listing categories. The UKLR chapters that group listed securities. Five are in scope: UKLR 6, 14, 15, 16 and 22.

Section 414CB. The Companies Act provision requiring climate-related financial disclosures in the strategic report for companies in scope, and allowing a national reporting framework such as UK SRS S2 to be used to meet it.

Transitional relief. A period in which a requirement need not be met: one year for Scope 3, two years for non-climate UK SRS S1, under the FCA's rules.