UK SRS S1 and S2 are now available for voluntary use, while the UK government considers which companies should be required to report under the new standards.

By Michael D. Green, Nicola Higgs, Betty M. Huber, Anne Mainwaring, James Bee, Toon Dictus, and Sara Sayma

On 25 February 2026, the UK government’s Department of Business and Trade (DBT) published the final UK Sustainability Reporting Standards (UK SRS), along with feedback to DBT’s June 2025 consultation on the exposure drafts of the UK SRS. The UK SRS consist of: General Requirements for Disclosure of Sustainability-related Financial Information (UK SRS S1) and Climate-related Disclosures (UK SRS S2). The standards are now available for voluntary use in the UK.

The Final Standards

DBT directly based the exposure drafts of UK SRS S1 and UK SRS S2 on the International Sustainability Standards Board (ISSB) IFRS S1 and S2 standards. A number of minor amendments to the IFRS S1 and S2 were proposed to reflect their use in a UK context. The proposed amendments included changes to the applicability of transition reliefs, amendments to certain references to other standards and materials, and the removal of “effective date” clauses so that the standards may be applied on a voluntary basis prior to any mandatory reporting obligations. 

DBT reveals that its consultation received a large number of responses (209), indicating a high level of interest in the proposals. In the final standards, the key differences between the original ISSB IFRS standards published in July 2023 and the UK SRS include:

• References to industry-based guidance: The references to SASB Standards (UK SRS S1) and the Industry-based Guidance on Implementing IFRS S2 (UK SRS S2) have been changed from mandatory (“shall”) to optional (“may”).
• Effective date removed and transitional provisions updated: There is no fixed effective date for the UK SRS. Any effective date will be set by legislation or regulation. Consequently, the climate-only relief (E3) and Scope 3 emissions relief (C4) are not time-limited. The relief permitting sustainability disclosures after financial statements (IFRS S1 E4) has been removed.
• Statement of compliance: Entities using the climate-only relief (E3) may not assert compliance with UK SRS S1, but entities using the reliefs in paragraph E3 of UK SRS S1 or paragraphs C3 (greenhouse gas emission measurement methodology) or C4 (Scope 3) of UK SRS S2 are not prevented from asserting compliance with UK SRS S2, provided that the use of the applicable relief is disclosed.
• Clarification of subordination to UK law: Both standards are subject to the requirements in the Companies Act 2006, FCA rules, and other UK regulatory requirements.
• UK SRS S2-specific provisions: The UK SRS add financed emissions explanation requirements (para B59A) and incorporate ISSB December 2025 amendments (e.g., removal of Global Industry Classification Standard (GICS) requirement, and exclusion of derivatives from Scope 3 Category 15 (Investments)).

Potential Mandatory Application of the UK SRS to UK Listed (and Non-Listed) Companies

The FCA has already launched its consultation on applying the UK SRS to companies with UK listings (see this Latham blog post). To date, there has been no contemplation that the FCA public company reporting rules would apply the UK SRS to companies listed in other jurisdictions without a UK listing.

The government has also committed to deciding on a potential extension to non-listed UK companies. It is planning to consult shortly on a programme of work to modernise the UK’s corporate reporting requirements (the Modernising Corporate Reporting programme) and will consider whether to require non-listed UK companies to report under the UK SRS as part of that exercise.

Related Initiatives

Alongside its consultation on the exposure drafts of the UK SRS, DBT also consulted on the potential design of future climate transition planning requirements, and on creating a registration regime for providers that offer assurance services for sustainability-related financial disclosures in the UK (see this Latham blog post). The timing for next steps in relation to these initiatives has not yet been set out.

Latham & Watkins will continue to monitor developments relating to the UK sustainability reporting regulatory landscape.