UK SRS S1 and S2: what a preparer has to be able to show

UK SRS S1 and S2 were published on 25 February 2026 and are voluntary today. The FCA has consulted on making UK SRS S2 mandatory for listed companies from 1 January 2027, which is a proposal rather than a rule. The timeline is covered thoroughly elsewhere. What almost nobody sets out is the other half: for each of the four pillars, what a preparer has to be able to produce when an assurance provider asks, and which first-year reliefs Appendix C actually gives you.

What is actually settled, and what is not

The UK has two standards, both published on GOV.UK: UK SRS S2 Climate-related Disclosures and its general counterpart. UK SRS S1 covers general sustainability-related financial disclosures and UK SRS S2 covers climate. Both were published by the Department for Business and Trade on 25 February 2026, following a consultation on the exposure drafts that ran from June to September 2025 and drew 209 responses. They are built on the ISSB's IFRS S1 and IFRS S2, issued in June 2023.

Two things are commonly conflated in write-ups of the regime, and the distinction matters if you are planning work.

The standards are voluntary today. Publishing a standard does not oblige anyone to apply it. What creates the obligation is UK law or an FCA rule, and neither is finished. The FCA has consulted on requiring listed companies to report against UK SRS S2 for financial years beginning on or after 1 January 2027. Until the Policy Statement lands, that date is a proposal.

So the honest position for a UK reporter in 2026 is: the content of what you will have to disclose is now knowable, because the standard is final. The date you will first have to do it is not yet fixed. That asymmetry is useful, because the work that takes longest is not the drafting. It is having the evidence.

The six provisions in Appendix C

Most coverage of UK SRS stops at scope and dates. The provisions that decide how much work year one actually involves sit in Appendix C of the standard, and they are worth reading in full rather than in summary. In the published text:

• C1 removes the comparative information requirement in the first annual reporting period.
• C2 requires you to apply UK SRS S1 at the same time, insofar as S1 relates to climate-related risks and opportunities. The two are not separable in year one.
• C3 permits a greenhouse gas measurement method other than the Greenhouse Gas Protocol Corporate Standard (2004) in the first period, but only if you used that other method in the period immediately before.
• C4 removes the obligation to disclose Scope 3, and says explicitly that this includes financed emissions for entities in asset management, commercial banking or insurance.
• C5 lets you carry the C3 and C4 reliefs into later periods for the purpose of presenting comparatives.
• C6 subjects all of it, where the standard is required under UK law, to the Companies Act 2006 and to the rules or regulations that impose it.

C6 is the one with no direct equivalent in the ISSB text, and it is the one to watch. It means the reliefs are not free-standing. If a UK rule requires the standard, that rule can qualify what the reliefs give you. Reading Appendix C on its own, without the instrument that makes the standard apply to you, will give you an incomplete answer.

C3 and C4 also come with a condition that is easy to miss: under UK SRS S1 paragraph 73A, an entity that uses these provisions has to disclose that it did, alongside its statement of compliance. A relief you take quietly is not a relief you have taken properly.

What each pillar asks you to be able to produce

UK SRS S2 keeps the four-pillar structure: governance, strategy, risk management, and metrics and targets. Every guide to the regime sets those out. Almost none of them go on to the question that decides whether your first cycle is comfortable or not, which is what has to exist behind each pillar when somebody asks.

The distinction is not academic. A disclosure is a sentence in a report. The evidence is a document, a date, a version and a name, and it either exists at the time or it is reconstructed afterwards under pressure.

Governance is the clearest example. The disclosure is a description of the body or role that oversees climate-related risks and how it is informed. The evidence is the terms of reference for that body, the minute that records the oversight actually happening, and dated proof of what was put in front of them. Companies routinely have the first and struggle to produce the third.

Strategy is where the standard is most demanding. UK SRS S2 requires the entity to use climate-related scenario analysis to assess its climate resilience, using an approach commensurate with its circumstances. That last phrase is a proportionality mechanism, not an exemption, and what it produces is a set of judgements. The judgements need their inputs, the version of the scenario used, and a record of who accepted the conclusion.

Metrics is where finance teams are usually strongest, because the discipline resembles what they already do. Even so, a Scope 1 figure that an assurance provider can test needs the source document, the emission factor and the version of it, the calculation, and a named approver, all retained together rather than assembled from four places.

If you already report under IFRS S2

UK SRS is based on the ISSB standards, so a group already reporting under IFRS S2 is not starting again. The work is a mapping exercise rather than a rebuild, and the areas to check are the UK amendments, the Companies Act interaction at C6, and whether reliefs you took under IFRS S2 remain available in the same form.

Groups reporting in more than one jurisdiction have a harder problem, which is that the reliefs and the dates differ per market. We keep a jurisdiction-by-jurisdiction view of that in the adoption tracker and the dates in the deadline reference. The equivalent first-year reliefs under IFRS S2 itself, with paragraph references, are set out in our piece on the transition reliefs.

What a voluntary year is actually for

The temptation with a regime that is not yet mandatory is to wait for the Policy Statement. That is reasonable for drafting and wrong for evidence, because the evidence is retrospective. If the first mandatory period begins in January 2027, the governance minutes, the scenario run and the emission factors that support it are being created now, in meetings and spreadsheets that nobody is treating as working papers yet.

The cheapest version of this work is to start keeping the trail before you need it. A voluntary report prepared properly is a rehearsal with real inputs. A voluntary report prepared loosely teaches you nothing, because the hard part was skipped.

That is the part our product addresses, and it is worth being precise about the boundary. Auditably holds the disclosure requirements of the standard as tracked items, attaches evidence to each figure and hashes it on upload, records review and approval against named users, and writes every change to a log that cannot be edited afterwards. It does not calculate emissions, does not file anything with a regulator, and is not a substitute for advice on judgement calls such as materiality or scenario selection. The full boundary is on the coverage page, the price is published on the pricing page, and the append-only claim can be tested on a live demonstration tenant without an account.

Common questions

When does UK SRS become mandatory?

No date is fixed yet. The standards published on 25 February 2026 are available for voluntary use. The FCA has consulted on requiring listed companies to report against UK SRS S2 for financial years beginning on or after 1 January 2027, and that remains a proposal until the FCA issues its Policy Statement.

Who has to report under UK SRS?

Nobody is required to yet. The FCA's consultation is directed at UK-listed companies. Any wider application to large private companies would need separate legislation, which has not been made. Treat published scope figures as descriptions of a proposal rather than of a rule.

Can I omit Scope 3 in the first year?

UK SRS S2 paragraph C4 removes the requirement to disclose Scope 3 in the first annual reporting period, and states that this includes financed emissions for entities in asset management, commercial banking or insurance. Paragraph C5 allows that relief to be carried into later periods for comparatives. Under UK SRS S1 paragraph 73A you must disclose that you used the provision.

How does UK SRS S2 differ from IFRS S2?

It is based on the ISSB standard rather than a rewrite of it. The difference most likely to affect a preparer is paragraph C6, which has no direct ISSB equivalent: where the standard applies because UK law or regulation requires it, its application, including the availability of the C3 and C4 reliefs, is subject to the Companies Act 2006 and to the instrument that imposes it.

Should we report voluntarily before it is mandatory?

That is a judgement about your investors and your capacity rather than a compliance question. The argument for it is that the evidence behind a first report is created months before the report, so a voluntary cycle run properly is the only realistic rehearsal. The argument against is cost, and it is a real one.