Skip to main content

Regulatory Framework · United Kingdom

UK SRS and the FCA's PS26/19, for suppliers

From 2027, UK-listed companies in certain categories must report against the UK Sustainability Reporting Standards or explain why not. That binds the listed company, not you. Here is who is covered, what the dates really are, and what a supplier can sensibly have ready if a customer asks.

Last updated:

Build your Scope 1 and 2 recordHow this differs from SECR

Summary for orientation only, based on the FCA documents linked below as read on the review date above. Rules and guidance can change; confirm anything load-bearing with the FCA texts or a qualified adviser.

The short version
  • The obligation sits on listed companies in specific categories, not on UK businesses in general and not on their suppliers.
  • It applies to accounting periods beginning on or after 1 January 2027, with first reports in 2028.
  • It is comply or explain, with a one-year Scope 3 relief and a two-year relief for non-climate topics.
  • The FCA's technical note is still a draft.
  • A supplier request is plausible, not guaranteed. Nothing in the FCA texts requires a buyer to ask.

What UK SRS is, and what PS26/19 adds

UK SRS S1 (general requirements) and UK SRS S2 (climate) are published by the UK government and built on the ISSB's IFRS S1 and S2. They are the standards. They do not by themselves tell any particular company to report.

The FCA's PS26/19, published on 30 September 2026, is what makes them bite on listed companies. It amends the UK Listing Rules so that in-scope issuers report against UK SRS on a comply-or-explain basis, replacing the TCFD-aligned disclosures they make today. For the global baseline these standards share, see our IFRS S2 guide.

Who is in scope, and who is not

Scope is set by listing category (PS26/19, paragraphs 3.6 and 3.7). The rules apply to issuers in:

Listing categoryRule
Equity shares (commercial companies)UKLR 6
Equity shares (international commercial companies secondary listing)UKLR 14
Certificates representing certain securities (depositary receipts)UKLR 15
Non-equity shares and non-voting equity sharesUKLR 16
Equity shares (transition)UKLR 22

Excluded: closed-ended investment funds (UKLR 11), open-ended investment companies (UKLR 12), shell companies (UKLR 13), and debt, securitised derivatives and warrant-type securities (UKLR 17 to 19). The FCA's web summary lists the categories more loosely and states no exclusions, so the policy statement itself is the one to rely on.

Who is not caught: a UK business is not in scope because it is UK-based, because it supplies a listed company, or because it is large. If you are not listed in one of those categories, PS26/19 does not apply to you.

Dates and transitional reliefs

  • Start: accounting periods beginning on or after 1 January 2027 (paragraph 3.12). First reporting is in 2028.
  • Scope 3 relief: one year from the company's date of initial application.
  • Climate-first relief: two years, during which non-climate S1 disclosures can be left out.
  • Date of initial application is the start of the company's first period beginning on or after 1 January 2027 (paragraph 3.18). It is a company-by-company date, not a single calendar date.

A company that uses a relief must say so in its annual report; using one does not trigger the explain rule (paragraph 3.20). Read the practical effect carefully: the Scope 3 relief means a buyer may not need supplier-derived Scope 3 data for its first reporting year. That is an inference from the relief, not something the FCA says about suppliers.

What comply-or-explain means

An in-scope company either prepares its disclosures in accordance with UK SRS, or explains where they fall short. The FCA's draft technical note adds that a company which explains a gap cannot also make a statement of compliance with UK SRS (Annex 1). So following the FCA's rules and claiming full UK SRS compliance are not the same thing, and you should not treat one as the other when a customer describes its reporting to you.

That technical note, TN 803.1, is a draft for consultation. The FCA's PS26/19 page gives 28 October 2026 as the date for feedback. That is the consultation deadline and not a date for the final note.

Why a customer might ask you for data

Reading the FCA texts, what we can say plainly is limited. UK SRS S2 includes Scope 3 emissions (the draft note cites paragraph 29(a)(vi)), and for a company that buys goods and services, part of that picture comes from its suppliers. The draft note's illustrative wording even describes a company working with suppliers to obtain Scope 3 information. What the FCA texts do not do is oblige any company to collect data from suppliers, or set a format for doing so.

So treat a request as a commercial ask from a reporting customer, not as something you owe by law. Plenty of buyers will estimate from spend, ask only their largest suppliers, or ask for something other than emissions. Equally, your Scope 1 and 2 are not automatically the footprint of what that customer bought from you; they are one input among several. If the request is a questionnaire, our guide to answering one covers how to respond in proportion.

What is worth preparing

Scope 1 and Scope 2, with the basis stated

Annual electricity (kWh), fuel burned on site and in vehicles, the totals that follow from them, the emission factor, its vintage, and whether Scope 2 is location- or market-based. This is the core of what a climate-disclosure customer can use from you.

The reporting period and boundary

Which twelve months the figures cover, and which sites or entities are in. A buyer reporting on a different period will ask.

Evidence behind the numbers

Utility bills or meter exports, fuel records, and a short note on what was estimated. You are not asked for assurance by the standard itself, but a buyer can only rely on figures they can trace.

What you do not know

If a request goes beyond what you measure, such as your own suppliers' emissions, say where your data stops. Stating a limit is a better answer than a guess.

UK SRS and SECR

They are different regimes with different sources. SECR comes from UK company law and asks large and quoted companies for their own energy use and Scope 1 and 2, with Scope 3 voluntary. UK SRS, through the listing rules, asks in-scope listed companies for climate and (after the relief) wider sustainability disclosures, including Scope 3. A company can be subject to one, both or neither. We found nothing in PS26/19 that replaces or amends SECR, but that is a statement about what we read, not legal advice. See the UK SECR guide for who reports under SECR.

What EcoDiligence does, and what needs more

A Passport records your Scope 1 and Scope 2 on published conversion factors, with the factor, its vintage and basis stated, plus the other structured facts customers commonly ask for. UK profiles already carry the ISSB S2 framework badge, and Pro includes an optional ISSB Transition Readiness layer. Everything in it is self-reported.

It is not a UK SRS report, a Scope 3 inventory broken down by category, an independent assurance opinion, or a statement that you or anyone else complies. A listed company's UK SRS disclosure is its own work, with its own advisers and auditors. If a customer needs product-level footprints, category-level Scope 3, or assured figures from you, that goes beyond a Passport and is worth agreeing with them explicitly.

Sources

Common questions

UK SRS S1 (general requirements) and S2 (climate) are the UK's sustainability reporting standards, published by the UK government and based on the ISSB's IFRS S1 and S2. They are standards, not a law that applies to a company by itself. PS26/19, published by the FCA on 30 September 2026, is the FCA's policy statement that adds rules to the UK Listing Rules requiring in-scope listed companies to report against UK SRS on a comply-or-explain basis. It replaces the existing TCFD-aligned listing-rule disclosures.

Issuers in five listing categories: commercial companies (UKLR 6), international commercial companies secondary listing (UKLR 14), depositary receipts (UKLR 15), non-equity and non-voting equity shares (UKLR 16) and the transition category (UKLR 22). Closed-ended investment funds, open-ended investment companies, shell companies, and debt, securitised derivative and warrant-type listings are excluded (PS26/19, paragraphs 3.6 and 3.7). Being a UK business, or supplying a listed company, does not put you in scope.

To accounting periods beginning on or after 1 January 2027, with first reporting in 2028 (PS26/19, paragraph 3.12). For a company with a calendar year, that means a first report in 2028 covering 2027. Companies whose period began earlier can keep using the existing TCFD-aligned rules or adopt UK SRS early.

Two. A one-year relief from Scope 3 emissions disclosure under UK SRS S2, and a two-year relief allowing non-climate S1 disclosures to be left out, often called climate-first reporting. Both run from the company's date of initial application, which is the start of its first accounting period beginning on or after 1 January 2027 (paragraphs 3.13, 3.14 and 3.18). A company using a relief must say so in its annual report; PS26/19 says that using a relief does not engage the explain rule (paragraph 3.20). The reliefs are time-limited, and what a given buyer chooses to do inside them is not something the policy statement tells us.

A company can prepare its disclosures in accordance with UK SRS, or explain where they fall short. It is not optional in the sense of being ignorable: the explanation is itself a requirement. And per the FCA's draft technical note, a company that explains a gap cannot also state that it complies with UK SRS. Meeting the FCA's rules and being able to claim full UK SRS compliance are therefore two different things.

No. Technical Note 803.1 is published as a draft for consultation. The FCA's PS26/19 page says feedback on it is due by 28 October 2026. That is a consultation deadline; it does not tell us when, or in what form, final guidance will appear. Treat anything attributed to the technical note as provisional until the FCA publishes the final version.

Not necessarily. Neither PS26/19 nor the draft technical note requires a listed company to collect data from its suppliers. What UK SRS S2 does require, subject to the Scope 3 relief, is disclosure of Scope 3 emissions, and for a company with a supply chain some of that depends on information from suppliers. The draft note's own illustrative explanation describes a company working with suppliers to obtain Scope 3 information. So a request is plausible from an in-scope customer, particularly after the relief period, but whether and how a given customer asks is a commercial decision. Many buyers will estimate from spend, ask only their largest suppliers, or ask for something other than emissions.

Not as a rule. A supplier's company-level Scope 1 and 2 are not the footprint of the particular goods or services a customer bought from them. They are one input a buyer may use, often with an allocation or an estimate. Do not assume a customer will accept, or will need, your company totals as their product-level figure.

SECR is a separate regime, set under UK company law, and is covered on our UK SECR page. Reading PS26/19 we found nothing in it that replaces or changes SECR, but the two have different sources and scopes, so a company can be subject to either, both, or neither; confirm the position for a specific company with an adviser. The practical difference for a supplier: SECR is about a company's own energy and Scope 1 and 2, with Scope 3 voluntary, whereas UK SRS S2 includes Scope 3.

A Passport gives you Scope 1 and Scope 2 on published factors with the vintage and basis stated, and a structured, self-reported set of facts you can reuse across customers. UK profiles already carry the ISSB S2 framework badge, and Pro adds an optional ISSB Transition Readiness layer. It does not produce a UK SRS report, a Scope 3 inventory by category, independent assurance, or a statement that anyone complies. A listed company's own UK SRS disclosure is its work, with its advisers and auditors.

Reviewed on October 21, 2026 against the FCA documents listed above as available on that date. The FCA's technical note was a draft at that point. This page is orientation, not legal or accounting advice; the FCA and the UK government are independent of EcoDiligence.

EcoDiligence ESG Passports are self-reported summaries structured for ESG disclosure workflows, built on the EFRAG VSME Basic Module with optional IFRS S2 climate inputs. Content is not independently assured and does not constitute compliance, certification or an audit.

Have your numbers ready before the question arrives

Scope 1 and Scope 2 on published factors, with the basis on the record. Free to start.

Create free PassportAnswering a customer questionnaire