Where this comes from
Primary sources unless labelled otherwise.
UK SRS S1 and S2 are issued by the Secretary of State for Business and Trade. They follow IFRS S1 and S2 closely, but the ISSB has not prepared or endorsed them.[1]
The government removed the effective-date clauses on purpose, so that the timing of any requirement, and of the transition reliefs, can be set by Companies Act regulations or FCA rules.[3]
UK SRS S2 is confirmed as a national reporting framework for section 414CB(6) of the Companies Act 2006, so companies already making climate disclosures can use it to meet them.[1],[3]
Climate disclosures against TCFD on a comply-or-explain basis under the listing rules (UKLR 6.6.6R(8)).
The eight Companies Act climate disclosures, if over 500 employees.
FCA policy statement expected, finalising rules on the final UK SRS.
Report against UK SRS under the FCA's proposal, with reliefs for Scope 3 and non-climate topics in the early years. First reports would land in 2028.
The departures are few and mostly about timing. One commonly cited difference, dropping the GICS industry requirement, is not a UK change: the ISSB made it in December 2025.[3],[6]
| Topic | IFRS S1 and S2 | UK SRS S1 and S2 |
|---|---|---|
| Effective date | Periods beginning on or after 1 January 2024 | None. Removed deliberately; timing is for legislation or FCA rules |
| Climate-first relief | First annual reporting period only | No time limit in the Standard; regulators will set it |
| Scope 3 relief | First annual reporting period only | No time limit in the Standard; regulators will set it |
| GHG Protocol method relief | First annual reporting period | First annual reporting period (kept) |
| Report after the accounts in year one | Permitted | Removed |
| Statement of compliance | Full compliance statement | A company using climate-first relief cannot claim compliance with UK SRS S1 |
The exposure drafts were consulted on from 25 June to 17 September 2025. The final Standards followed on 25 February 2026.[3]
For the full UK picture, including SECR, ESOS and the FCA’s anti-greenwashing rule, see our sister reference, uksrs.org.uk.[7]
Under the FCA’s proposal in CP26/5, for accounting periods beginning on or after 1 January 2027, with first reports in 2028. The FCA aims to publish its final rules in autumn 2026.[4]
It is closely based on them, but not endorsed by the ISSB. The differences that matter: no effective date; climate-first and Scope 3 reliefs with no fixed time limit; no relief to report after the accounts in year one; and a company using climate-first relief cannot claim compliance with UK SRS S1.[1],[3]
Large companies, those over 500 employees and £500m turnover, and traded companies over 500 employees make eight climate-related financial disclosures in the strategic report, for periods from 6 April 2022.[5] Listed companies also report against TCFD on a comply-or-explain basis under the listing rules.[4]
Primary sources unless labelled otherwise.