Does UK SRS apply to my business?

UK SRS is voluntary for private companies and SMEs, so most UK businesses have no direct obligation. The exception is UK-listed companies in certain FCA listing categories, which must report against it on a comply-or-explain basis for accounting periods starting on or after 1 January 2027.

This article reflects the position as of November 2026. The rules are still moving, so check the sources at the end before you rely on any detail.

What UK SRS is

UK Sustainability Reporting Standards (UK SRS) are the UK versions of the ISSB's IFRS S1 and IFRS S2, with minimal amendments. UK SRS S1 covers general sustainability-related disclosures and UK SRS S2 covers climate-related disclosures. The UK government published the finalised standards on 25 February 2026.

Any entity that chooses to use the standards may do so, and they are available to use immediately. There is no government requirement to use them yet.

The government also adopted the ISSB's December 2025 targeted amendments to S2. It removed the time limits on the Scope 3 and non-climate reliefs, so voluntary users can use those reliefs indefinitely. A regulator that mandates the standards may limit them.

Who must report from 2027

On 30 September 2026 the Financial Conduct Authority (FCA) published its final rules in Policy Statement PS26/19. Listed companies must report against UK SRS on a comply-or-explain basis. This replaces the climate rules based on the TCFD recommendations that have applied under the Listing Rules since 2020.

The rules apply to accounting periods starting on or after 1 January 2027, so the first reports will appear in 2028. They cover the listing categories of commercial companies, transition, non-equity and non-voting equity shares, and secondary listing and depositary receipts.

There are transitional reliefs: one year for Scope 3 emissions disclosures and two years for the wider sustainability disclosures under S1. We have not covered how AIM companies, funds or investment trusts are treated, so check the FCA's policy statement if that matters to you.

What this means for private companies and SMEs

Private companies and SMEs have no UK SRS obligation today. The government has said it will consider whether to introduce requirements for certain UK entities, and whether to require private companies to report under UK SRS. It has not committed to SME-specific measures. Respondents to its consultation asked for guidance, templates and simplified frameworks.

Existing UK duties are separate from UK SRS. They include the Companies Act climate-related financial disclosures for large companies and the Streamlined Energy and Carbon Reporting (SECR) rules.

What is still undecided

In September 2026 the UK government opened a consultation called Modernising Corporate Reporting to support long-term economic growth. According to a law-firm summary, it makes no proposals on the existing climate disclosure rules. It asks which companies should be in scope of non-financial reporting, including whether to create a new category of very large companies.

The government has said any effective date will be set out in regulation or legislation. Treat the outcome as unconfirmed until the government publishes its response.

Why an SME may still be asked for data

UK SRS S2 includes Scope 3 emissions, which are the emissions across a company's value chain. A listed customer that is in scope may therefore ask its suppliers for emissions data. The FCA's one-year Scope 3 relief gives listed companies some time to prepare.

We have not found a UK rule that limits what a customer can ask of a supplier. The EU's value-chain cap applies to companies in scope of the EU's CSRD, not to UK customers. Our article on CSRD and VSME explains how it works.

What to do now

Check whether your company is listed in one of the FCA categories. If it is not, find out whether any of your main customers are, and what they plan to ask of suppliers. Then build a baseline of Scope 1 and Scope 2 emissions, and read our explainer on Scope 1, 2 and 3 emissions.

aida ESG from Carbon Happy World is ESG reporting software covering CSRD, ISSB and the EU Taxonomy, among other frameworks.