UK Government Publishes Final Sustainability Reporting Standards
On 25 February 2026, the Department for Business and Trade (DBT) published the final UK Sustainability Reporting Standards: UK SRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and UK SRS S2 (Climate-related Disclosures).
The publication follows a consultation on exposure drafts of UK SRS that ran from June to September 2025 and received 209 responses. These standards are based on the IFRS Sustainability Disclosure Standards (IFRS S1 and IFRS S2) published by the International Sustainability Standards Board (ISSB) in June 2023.
The standards are now available for voluntary use. However, the Financial Conduct Authority (FCA) is already consulting on proposals to require listed companies to report against UK SRS from 1 January 2027. If mandatory reporting requirements are introduced as anticipated, the effective date will be set out in future legislation.
Policy context
The UK was an early mover in requiring entities to report on financially material climate-related risks, having introduced TCFD-aligned requirements from 2022 for the largest privately held entities, from 2022 and 2023 for certain FCA regulated firms, and from 2021 and 2022 for listed entities (depending on if they were standard or premium listed).
However, the existing TCFD-based rules were at risk of becoming obsolete following the disbandment of the TCFD, which has effectively been superseded by the ISSB. The ISSB was established at COP26 in Glasgow in 2021 to create a global baseline for sustainability reporting. Its standards are designed to provide comparable and decision-useful information for investors.
The Government has positioned the UK SRS as part of its ambition to "deliver a world-leading sustainable finance framework" and to make the UK a global centre for sustainable finance.
Structure of UK SRS
UK SRS S1 sets out general requirements for disclosing sustainability-related financial information, covering governance, strategy, risk management, and metrics and targets. It applies to all sustainability-related risks and opportunities that could reasonably be expected to affect an entity's cash flows, access to finance, or cost of capital.
UK SRS S2 applies specifically to climate-related risks and opportunities, requiring disclosure of GHG emissions across Scope 1, 2, and 3, as well as information about climate resilience and scenario analysis.
Key changes from global standards
Whilst the UK SRS is based on the ISSB's global standards, the Government has made certain amendments to tailor them for the UK context. For example: references to SASB Standards have been made optional rather than mandatory, and specific time limits for transitional reliefs have been removed (see below). The standards also incorporate amendments issued by the ISSB in December 2025, including the exclusion of certain categories of Scope 3 emissions from reporting requirements.
Transitional reliefs
To ease implementation, the UK SRS provides transitional reliefs, including the ability to report exclusively on climate-related matters (omitting wider sustainability disclosures) and to defer Scope 3 GHG emissions reporting. Importantly, the standards do not specify time limits for these reliefs (although this does not apply to the GHG Protocol methodology relief, which remains limited) and this will be determined by UK regulators when mandatory requirements are introduced.
Legal clarifications for existing regimes
The government has confirmed that for companies considering UK SRS reporting, UK SRS S2 constitutes a national reporting framework for the purposes of section 414CB(6) of the Companies Act 2006. This should avoid duplication provided UK SRS S2 is clearly referenced in the relevant statement and the Companies Act 2006 disclosure requirements are otherwise met. This should mean companies reporting under UK SRS S2 do not need to duplicate their disclosures to meet existing climate reporting obligations. Additionally, if entities include UK SRS disclosures within their Strategic Report, the provisions in section 463 of the Companies Act will automatically apply.
FCA Consultation on Listing Rules
For listed companies, the practical effect of UK SRS will be determined by the FCA. As detailed in our earlier Law Now article, FCA Consultation on Sustainability Disclosures for Listed Companies (2 February 2026), the FCA published a consultation on 30 January 2026 proposing to replace its current TCFD-aligned framework with UK SRS-aligned requirements for listed companies from 1 January 2027. The publication of the final UK SRS standards provides the regulatory foundation for the FCA's proposals, confirming the content of the standards that listed companies will be required to report against.
Under the proposals, UK SRS S2 climate disclosures would be mandatory, whilst wider sustainability disclosures (UK SRS S1) and Scope 3 emissions would initially apply on a "comply or explain" basis with deferrals available. Responses are due by 20 March 2026 and can be submitted here, with final rules expected in autumn 2026.
Practical Implications
The UK SRS sits within the Government's “Modernising Corporate Reporting (MCR) programme” (announced in October 2025), which will consider extending requirements to private entities under the Companies Act (further information to be included in a consultation on MCR later in 2026).
The Government has also indicated it will review the interaction with existing Streamlined Energy and Carbon Reporting (SECR) requirements to reduce duplication (as highlighted by several consultation respondents, alongside TCFD-aligned reporting).
In-scope companies may want to begin assessing the gap between current TCFD-aligned disclosures and UK SRS requirements.