The UK Sustainability Reporting Standards have been published. Here are some answers to your burning questions from our Sustainability Consultant, Emily Bird.
Will I have to report against the standards immediately?
Not yet. UK SRS is currently voluntary.
The FCA is consulting on whether UK SRS S2 will replace TCFD in the Listing Rules for:
- Commercial companies, non-equity shares and non-voting equity shares
- Secondary listings & depositary receipts (reduced scope)
The FCA is also proposing that reporting under UK SRS S1 will be on a ‘comply or explain’ basis and that companies in scope will need to disclose whether they have obtained third-party assurance on their sustainability disclosures.
When do I have to report?
Under the FCA’s proposed timeline:
- FY 2027 – SRS S2 (climate-related financial risks and opportunities)
- FY 2028 – scope 3 mandatory
- FY 2029 – full UK SRS (S1 + S2)
Are there any watch-outs for voluntary early adoption?
Yes.
Early adopters will not be eligible for transitional reliefs, meaning you will have to report UK SRS S1 and S2 in full from 2027 (assuming adoption via Listing Rules).
Should we adopt early?
It depends on payoff, resources and CSRD scope.
If you already report scope 3, or are gearing up for CSRD, early adoption might make sense. Transitional reliefs matter less, and you will align with investor needs earlier.
If not, it’s probably better to build SRS content gradually without claiming formal alignment. This will allow you to prepare while retaining transitional reliefs.
Where will UK SRS be housed?
Either in the Annual Report (no specific section), or in an external report, provided it is published at the same time as the Annual Report and cross-references to the information provided in the Annual Report.
What more will we need to include beyond what we already disclose in our TCFD reporting?
UK SRS adopt the same 4 pillars as TCFD, but requires:
- More granular information
- Disclosures beyond climate to broader (financially) material sustainability topics
- Scope 3 emissions, GHG protocol methodology, carbon credits
Climate transition plans are not mandatory. But if you have one, methodologies and assumptions will need to be disclosed.
What are the main differences to CSRD?
Scope and depth – CSRD is a fundamental shift in the way organisations report sustainability, SRS is a more manageable expansion from TCFD.
SRS is a financial risk framework for investors, based on single materiality.
CSRD requires consideration of impacts on wider stakeholders, with extensive data requirements.
How can we tackle both CSRD and UK SRS?
Aligning to CSRD and SRS in a single set of disclosures without reinventing the wheel will take some careful thought – it won’t be straightforward. But disclosure can be streamlined and simplified to avoid duplication or adding significantly to the length of the Annual Report.
How can we get ready?
Our RADAR approach gives you a checklist for making sure you have a plan in place to develop your sustainability reporting with confidence and clarity:
Readiness: Mapping current disclosure to SRS and CSRD, identifying gaps and quick wins, creating a roadmap towards SRS and/or CSRD
Alignment: Planning the necessary integration with your risk management and principal risk disclosures
Disclosure: Designing clear SRS and CSRD disclosures, structuring content to simplify and avoid duplication, drafting content
Activation: Translating reporting content into wider corporate communications, creating messaging for investors and other stakeholders, supporting consistency across your communications ecosystem
Reporting: Planning what information will live where across your reporting suite
At Conran we have the expertise to guide you through every stage of the journey. If you’d like to know more about how we can help, please get in touch.
