Summary

  • The UK has adopted the ISSB standards as UK SRS S1 and S2, and the FCA proposes mandatory UK SRS S2 climate disclosure for listed companies, with comply-or-explain treatment for Scope 3 and non-climate matters.

  • First mandatory reports cover accounting periods beginning on or after 1 January 2027 (proposed), published in 2028 for calendar-year companies.

  • Scope covers 515 companies in three FCA listing categories; private company requirements are subject to a separate government consultation.

  • UK listed and large companies have reported under the Task Force on Climate-related Financial Disclosures (TCFD) framework since 2021, so the four-pillar structure and the greenhouse gas inventory already exist.

United Kingdom climate disclosure at a glance

Regulator Department for Business and Trade issues UK SRS and sets Companies Act reporting requirements. The Financial Conduct Authority sets the rules for listed companies through the UK Listing Rules
Standard UK SRS S1 and UK SRS S2, the UK versions of IFRS S1 and IFRS S2 issued by the International Sustainability Standards Board, with four UK amendments
Companies in scope Proposed: companies in the FCA's commercial companies, non-equity shares, and transition listing categories. Companies with a secondary listing or depositary receipts disclose under home-jurisdiction rules. Private companies: subject to consultation
Estimated population 515 listed companies in the mandatory categories, plus 89 with secondary listings or depositary receipts (FCA cost benefit analysis)
First reporting year Accounting periods beginning on or after 1 January 2027 (proposed): a calendar-year company reports on financial year 2027 in its 2028 annual financial report
Scope 3 required Comply or explain (proposed), after a one-year transitional relief. A calendar-year company addresses Scope 3 from financial year 2028
Assurance No mandatory assurance proposed. Listed companies would state whether they obtained third-party assurance and, if so, the provider, level, and standard used
Penalty regime Not specified in the rule

The UK government published the final UK Sustainability Reporting Standards (UK SRS S1 and UK SRS S2) on 25 February 2026, and the Financial Conduct Authority (FCA) is consulting on making UK SRS S2 climate reporting mandatory for 515 listed companies for accounting periods beginning on or after 1 January 2027, with final rules due in autumn 2026.

The UK already requires climate reporting from large companies under the Companies Act and from listed companies under the Listing Rules, so UK SRS upgrades an existing regime. Until the FCA policy statement is published, every 2027 date on this page is a proposal.

Below: what the rules require, and how to prepare.

How the UK got here: three layers of climate reporting

The UK built its climate reporting rules in three layers between 2019 and 2022, and all three remain in force.

  • 2019, energy and carbon reporting. Streamlined Energy and Carbon Reporting requires quoted companies, large unquoted companies, and large limited liability partnerships to disclose annual energy use and Scope 1 and Scope 2 emissions, with an intensity ratio, for financial years beginning on or after 1 April 2019.

  • 2021, listed companies. The FCA's Listing Rules require listed commercial companies to state in their annual financial report whether they have made TCFD-consistent disclosures, and to explain any gaps. Premium listed companies started with accounting periods beginning 1 January 2021, standard listed companies a year later.

  • 2022, large companies. The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 require companies with more than 500 employees that are traded, quoted on AIM, banks, or insurers, or that have turnover above £500 million, to report against eight climate disclosure items for financial years beginning on or after 6 April 2022.

What the UK's climate disclosure rules require

Under the FCA's proposal, listed companies report climate-related financial information in accordance with UK SRS S2 in their annual financial report, alongside their financial statements.

  • UK SRS S1 (General Requirements): the disclosure architecture. Companies report material information about sustainability-related risks and opportunities that are reasonably expected to affect cash flows, access to finance, or cost of capital. The FCA proposes comply-or-explain treatment for the non-climate parts of UK SRS S1.

  • UK SRS S2 (Climate-related Disclosures): the climate-specific requirements, built on the four pillars, including absolute gross Scope 1, Scope 2, and Scope 3 emissions in tonnes of CO2 equivalent. The FCA proposes mandatory reporting for everything in UK SRS S2 except Scope 3, which stays on a comply-or-explain basis.

  • The Greenhouse Gas Protocol as the measurement standard: UK SRS S2 paragraph 29(a)(ii) requires emissions to be measured in accordance with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (2004). A company that used a different method in the prior year can keep it for one period under paragraph C3.

The four UK amendments to the ISSB text: no effective date (companies apply the standards when UK law requires or when they choose to); a two-year climate-first relief for non-climate disclosures; Scope 3 and alternative-measurement reliefs with the time limit set by the FCA or Companies Act; and optional references to SASB industry standards and the GICS classification.

Who is in scope

The FCA's proposal covers five listing categories, with full UK SRS reporting applying to three of them.

Full UK SRS reporting (proposed)

  • Commercial companies (UKLR 6): the main equity category since the July 2024 listing reform.

  • Non-equity shares and non-voting equity shares (UKLR 16).

  • Transition category (UKLR 22): former standard listed companies yet to move to the commercial companies category.

These three categories cover 515 companies with an aggregate market capitalisation of £3.8 trillion on the London Stock Exchange Main Market, according to the FCA's cost benefit analysis.

Home-jurisdiction reporting (proposed)

Companies with a secondary listing (UKLR 14) or depositary receipts (UKLR 15), 89 in total, would disclose the climate and sustainability information required in their primary listing jurisdiction or place of incorporation, plus the same assurance transparency statement.

Private companies

The government will consider whether to require private companies to report under UK SRS in a separate exercise. Its Modernising Corporate Reporting consultation, published 7 September 2026 and closing 30 November 2026, proposes no UK SRS requirements and states that the government intends to consult separately on which companies should be in scope.

Key dates and milestones

Milestone Measurement year First reporting date
Streamlined Energy and Carbon Reporting (current) Financial years from 1 April 2019 2020 annual reports onward
FCA TCFD comply-or-explain for listed companies (current) Accounting periods from 1 January 2021 (premium) and 2022 (standard) 2022 and 2023 annual reports onward
Companies Act climate-related financial disclosures (current) Financial years from 6 April 2022 2023 annual reports onward
Final UK SRS S1 and S2 published 25 February 2026 Voluntary use from publication
FCA policy statement and final rules Autumn 2026 (proposed) Rules in force 1 January 2027 (proposed)
Mandatory UK SRS S2, excluding Scope 3, for listed companies Accounting periods beginning on or after 1 January 2027 (proposed) 2028 annual financial reports
Scope 3 on a comply-or-explain basis Second reporting period: financial year 2028 for calendar-year companies (proposed) 2029 annual financial reports
Non-climate UK SRS S1 on a comply-or-explain basis Third reporting period: financial year 2029 for calendar-year companies (proposed) 2030 annual financial reports
Private companies under UK SRS Subject to consultation Not yet published

Comparative information is not required in the first period. Companies with an accounting period beginning before 1 January 2027 can keep the TCFD-aligned rules for that period or adopt the new rules early, without the transitional reliefs.

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How companies should prepare

Calendar-year listed companies start measuring financial year 2027 in sixteen months, and the greenhouse gas inventory is the slowest part to build.

  • Establish your greenhouse gas inventory on the GHG Protocol. Companies reporting under Streamlined Energy and Carbon Reporting already have Scope 1 and Scope 2 data; the gap is Scope 3 by category, and the one-year transitional relief is preparation time.

  • Build assurance-ready processes early. The FCA proposes that every listed company state publicly whether it obtained assurance, and investors will read the difference. Methodology documentation, source-data traceability, and review controls need to be in place during measurement so that a limited assurance engagement is a decision, with the evidence ready.

  • Build on the frameworks you already use. The four TCFD pillars carry directly into UK SRS S2, and existing Companies Act climate disclosures, CDP responses, and EU Corporate Sustainability Reporting Directive work map onto the standard. The new work is the metrics: Scope 3, industry-specific metrics, and scenario analysis.

Deciding whether to obtain assurance on your first UK SRS S2 report?

Download Your First Climate Audit: A Practical Guide for a step-by-step walkthrough of what assurance providers ask for and how to get your data ready.

Download the guide

How Terrascope can help

Terrascope's AI-powered platform helps companies operating in the UK move from baseline emissions data to audit-ready disclosures, including Princes Group, the Liverpool-headquartered food and drink group that went from deadline crunch to SBTi-validated Forest, Land and Agriculture targets in three and a half months.

  • Scope 1, 2, and 3 emissions measurement. Integrations pull emissions data from your source systems monthly, so your inventory stays current across every entity in scope and every Scope 3 category you need before the relief ends.

  • Audit-ready reporting. Audit Trail makes every figure traceable from data entry to disclosure, with assurance-provider access built in, so your assurance transparency statement can say "yes".

  • Supply-chain intelligence. Analytics shows you where your Scope 3 hotspots sit before the comply-or-explain decision, so the transitional relief becomes reduction planning time.

  • Multi-framework alignment. ISSB Reporting drafts your UK SRS S1 and S2 disclosures from your measured data, reviewed by your team, ready for the annual financial report.

Frequently asked questions

What is the UK's climate disclosure rule?

The UK Sustainability Reporting Standards, UK SRS S1 and UK SRS S2, published by the government on 25 February 2026, adopt the ISSB standards with four UK amendments. The FCA is consulting on making UK SRS S2 mandatory for listed companies from 2027.

When does climate disclosure start in the UK?

Under the FCA proposal, listed companies report under UK SRS S2 for accounting periods beginning on or after 1 January 2027, so calendar-year companies publish first reports in 2028. The FCA expects to finalise its rules in autumn 2026.

Who has to report under UK SRS?

The FCA proposes mandatory UK SRS S2 reporting for 515 companies in its commercial companies, non-equity shares, and transition listing categories. Companies with secondary listings or depositary receipts disclose under home-jurisdiction rules. Private company requirements are subject to a separate government consultation.

Does UK SRS require Scope 3 reporting?

UK SRS S2 paragraph 29(a) requires Scope 3 emissions. The FCA proposes a comply-or-explain basis for Scope 3 after a one-year transitional relief, so listed companies either disclose Scope 3 from their second reporting period or explain the gap and their plan to close it.

What is the GHG Protocol's role in UK SRS?

UK SRS S2 paragraph 29(a)(ii) requires greenhouse gas emissions to be measured in accordance with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (2004). A company using another method in the prior year can keep it for the first reporting period.

When does assurance become mandatory in the UK?

The FCA proposes no assurance mandate. Listed companies would state in their annual financial report whether they obtained third-party assurance on UK SRS disclosures and, if so, the provider, level, and standard. The government and the Financial Reporting Council are developing a voluntary registration regime for sustainability assurance providers.

How does UK SRS differ from the existing TCFD rules?

UK SRS S2 keeps the four TCFD pillars and adds prescribed metrics: Scope 1, 2, and 3 emissions measured under the GHG Protocol, industry-specific metrics, and climate scenario analysis. The FCA proposal also moves climate disclosure from comply-or-explain to mandatory for listed companies.

 

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Are you ready to get ahead of the UK's UK SRS requirements? Speak to a Terrascope expert and see how we help companies move from baseline emissions data to audit-ready disclosures.