This month, the UK government released its long‑awaited Sustainability Reporting Standards (SRS), aligned with the International Sustainability Standards Board’s (ISSB) IFRS S1 and IFRS S2. It’s a defining moment that finally gives UK companies a clear blueprint for sustainability reporting. The draft UK Sustainability Reporting Standards (UK SRS) set out the core disclosure content based on IFRS S1 and S2, while the FCA’s CP26/5 consultation explains how those standards would be applied specifically to UK‑listed companies. In practice, the UK SRS define what must be disclosed, whereas CP26/5 sets who must report, when the rules take effect, and how they will operate within the UK Listing Rules —…
The Scope of the UK SRS and CP26/5 Requirements
The FCA proposes that the new rules apply to the following categories of listed companies:
- Commercial companies (UKLR 6)
- Non equity shares and non voting equity shares (UKLR 16)
- Transition category (UKLR 22)
- Secondary listing (UKLR 14)
- Depositary receipts (UKLR 15)
Categories excluded from the requirements
Source: FCA Consultation Paper CP26/5
The FCA suggests excluding:
- Closed-ended investment funds (UKLR 11) and open-ended investment funds (UKLR 12)
- Shell companies (UKLR 13)
- Debt and debt-like securities (UKLR 17)
- Securitised derivatives (UKLR 18), as well as warrants, options, and other miscellaneous securities (UKLR 19)
How the UK SRS Compare to IFRS and TCFD
If you’re familiar with IFRS or the former TCFD framework, Novata has prepared a helpful comparison table summarising key differences and similarities across UK SRS, IFRS S1/S2, and TCFD.
| UK SRS | IFRS S1 & S2 | TCFD Framework | |
| Status | UK-endorsed sustainability standards (exposure drafts published) | Global baseline standards issued by the ISSB | Voluntary global disclosure framework for climate risks (TCFD disbanded in 2023 |
| Primary Objective | Provide consistent, decision-useful sustainability information for UK capital markets | Provide a global baseline of sustainability disclosures focussed on enterprise value | Improve transparency on voluntary climate-related risks and opportunities |
| Scope | SRS S1: All sustainability-related risks and opportunities SRS S2: Climate-related disclosures | IFRS S1: General sustainability disclosures IFRS S2: Climate-related disclosure | Climate-related risks and opportunities only |
| Materiality Focus | Enterprise value (financial materiality) | Enterprise value (financial materiality) | Financial impacts of climate risks and opportunities |
| Structure | Mirrors IFRS & TCFD structure across four core pillars | Incorporates TCFD four pillars: Governance, Strategy, Risk Management, Metrics & Targets | Four pillars: Governance, Strategy, Risk Management, Metrics & Targets |
| Alignment with TCFD | Full incorporates and builds on TCFD principles | IFRS S2 incorporates and extends TCFD | Original framework |
| Prescriptiveness | High: detailed, standardised disclosure requirements | High: detailed, standardised disclosure requirements | Moderate: principles-based guidance |
| Climate Scenario Analysis | Required under SRS S2 where climate risk is material | Required under IFRS S2 | Recommended |
| Transition Plans | Required disclosure where applicable | Required disclosure where applicable | Recommended |
| Scope 1 & 2 Emissions | Mandatory under SRS S2 | Mandatory under IFRS S2 | Recommended |
| Scope 3 Emissions | Required where material, with transitional reliefs | Required where material, with transitional reliefs | Recommended |
| Link to Financial Statements | Requirement to connect sustainability and financial reporting | Explicit requirement to connect sustainability and financial reporting | No formal linkage requirement |
| UK-Specific Elements | May include UK-specific phasing, guidance, or regulatory interaction | Explicit requirement to connect sustainability and financial reporting | Not jurisdiction-specific |
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The UK SRS Timeline and What Happens Next
The UK government published the draft UK SRS following its 2025 consultation. The FCA is currently requesting feedback on its Consultation Paper (CP26/5), which opened on January 30th and will close on March 20th. The goal is to ensure that UK SRS align with international frameworks and improve transparency for investors, consumers, and companies.
Expected implementation timeline
A final FCA policy statement is expected this autumn, once the UK SRS are finalised (anticipated this spring). This would enable the new rules to take effect on 1 January 2027 — the proposed start date for mandatory UK SRS reporting for listed companies.
FCA implementation roadmap
In their Consultation Paper (CP26/5), the FCA lays out its proposed timeline for the implementation of the SRS
Source: FCA Consultation Paper CP26/5
Conclusion
As the UK moves toward adopting the UK Sustainability Reporting Standards, organisations should recognise that these rules signal a major shift toward more transparent, globally aligned sustainability reporting.
How to prepare for UK SRS reporting
By combining the content of UK SRS S1 and S2 with the FCA’s CP26/5 implementation framework, companies now have a clear understanding of what they must disclose, who will be in scope, and how reporting expectations will be phased in ahead of 2027.
Preparing early—by strengthening data, governance, and reporting processes—will help businesses ensure compliance, meet investor expectations, and gain a strategic advantage as the UK transitions to a more consistent, investor focused sustainability disclosure regime.
Sources
- “CP26/5: Aligning listed issues’ sustainability disclosures with international standards” by the Financial Conduct Authority (6 Feb 26) CP26/5: Aligning listed issuers’ sustainability disclosures with international standards | FCA
- “Disclosure Scope and Requirement: UK SRS vs IFRS S1 & S2 vs TCFD” by Novata (2026) 260126-Blog-SRS Table.pdf
- “FCA launches consultation on new sustainability disclosures for listed companies” by Michael Barlow for Burges Salmon (13 Feb 26) https://www.burges-salmon.com/articles/102micz/fca-launches-consultation-on-new-sustainability-disclosures-for-listed-companies/
- “UK FCA Proposes New Sustainability Disclosure Rules for Listed Companies” by Crowell (10 Feb 26) UK FCA Proposes New Sustainability Disclosure Rules for Listed Companies | Crowell & Moring LLP
- “UK Sustainability Reporting Standards” by the Government of the UK (8 Jan 26) UK Sustainability Reporting Standards – GOV.UK
