UK SRS: Prepare now and drive resilience and cost avoidance in your business

On 30 September 2026, the Financial Conduct Authority (FCA) finalised rules requiring listed companies to report against the UK Sustainability Reporting Standards (UK SRS) on a comply or explain basis. This means companies must either provide the required disclosures or explain why they have not done so, including how and when any gaps will be addressed. 

A consultation is currently underway on Technical Notes designed to help companies apply the comply or explain framework in a proportionate and consistent manner. Feedback is invited until 28 October 2026. 

The introduction of UK SRS will replace the FCA's current TCFD-aligned listing rules for accounting periods beginning on or after 1st January 2027. Until then, companies within scope may continue reporting under the existing TCFD-aligned requirements or choose to adopt UK SRS early. 

The UK SRS is based on two standards developed by the International Sustainability Standards Board (ISSB) and focuses on the disclosure of financially material sustainability-related information: 

• UK SRS S1: General Requirements for Disclosure of Sustainability-related Financial Information 
• UK SRS S2: Climate-related Disclosures 

The UK SRS expands on the Climate Financial Disclosure reporting conducted to date by listed and large companies in the UK, by including wider Sustainability disclosures under S1. To support the transition, companies may choose to take a “climate first” approach which means that non-climate matters can be excluded from S1 for up to 2 years. Additionally, under S2, Scope 3 emissions may be excluded for a period of 1 year.  

A financial materiality assessment is required under UK SRS to identify and assess material risks and opportunities across all relevant sustainability topics, ultimately extending beyond climate-related disclosures. By comparison, the European Union's Corporate Sustainability Reporting Directive (CSRD) requires organisations to undertake a double materiality assessment (DMA). This considers both the impact of sustainability matters on the organisation and the organisation's impacts on people and the environment. 

A robust assessment process can help build readiness for UK SRS while also supporting reporting under CSRD and other ISSB-aligned frameworks being introduced around the world. For many organisations, commencing or refreshing a materiality assessment now can provide significant benefits beyond compliance.  

The real opportunity however is to move from compliance to cost avoidance. Materiality assessments can reveal where sustainability-related risks translate into wasted resources, higher energy costs, supply-chain exposure or future operational costs. Addressing these issues can improve resource efficiency, strengthen resilience and reduce avoidable expenditure. With the right governance in place, compliance becomes more than reporting: it provides decision-useful insight that can support investment choices, operational efficiency and long-term business performance. 

Ultimately, organisations that begin preparing early will be better positioned not only to meet future disclosure requirements, but also to manage emerging sustainability risks, strengthen resilience and identify areas to avoid unnecessary costs and identify new business opportunities. 

Sign up today for Trio's Regulatory Readiness Assessment to discuss how you can help your business use this compliance process to drive business resiliency and cost avoidance whilst also remaining compliant, even if you have already undertaken your materiality assessment.