Annex A · UK SRS against IFRS S1 and S2
UK SRS and IFRS S1/S2 differences: the Annex A ledger
UK SRS follows the ISSB’s texts almost word for word, so the useful question is where it does not.
The government answered that in Annex A of its consultation response, which says that where a requirement is not in its tables there is no difference.
The ledger below reproduces those tables in plain words, with the UK paragraph for each row.
The ledger
Every UK departure, filterable by Standard
Filter by Standard, sort by effect, or search for a paragraph.
The effect column is this site’s reading: loosens, tightens, defers to UK law, or unchanged.
| ¶¶55(a), 58(a) | SASB Standards: shall refer to and consider becomes may | Loosens |
| ¶64; IFRS ¶E4 removed | No first-year option to publish after the financial statements | Tightens |
| ¶E3 | Climate-first relief kept with no time limit | Loosens |
| ¶E5 (new) | Where UK law or regulation requires the Standard, application is subject to it | Defers |
| ¶73A (new) | A climate-only reporter may not assert compliance with UK SRS S1 | Tightens |
| ¶73B (new) | The Standard is subject to UK law or regulation requiring it | Defers |
| Appendix E | Effective date removed; transition paragraphs renumbered | Defers |
| ¶¶12, 23, 32 | Industry-based Guidance: shall refer to and consider becomes may | Loosens |
| ¶B59A (new) | Explain why financed emissions cannot match the reporting period, and the plan to align | Tightens |
| ¶C4 | Scope 3 relief loses its first-period limit | Loosens |
| ¶C4 | GHG measurement-method relief keeps its first-period limit | Unchanged |
| ¶C6 | UK law or regulation may set the availability of both reliefs | Defers |
| Appendix C | Effective date removed | Defers |
13 of 13 rows
Paraphrased from Annex A; read the government’s tables for the exact wording.
Why there is no count
Proposed, withdrawn, replaced, added
The June 2025 consultation said the government proposed six minor amendments.
That was a count of proposals, and the set changed before publication.
One proposal fell away when the ISSB made the same change in its December 2025 amendments to IFRS S2.
Another was replaced, after the department’s letter to the FCA said the time references on the reliefs would be removed.
Four provisions not in the drafts were then added.
A page that says “six amendments” is quoting the proposal, not the Standards.
- Jun 2025Six minor amendments proposedThe exposure-draft consultation’s own count of proposals.DBT consultation
- Dec 2025The ISSB amends IFRS S2 itselfOne UK proposal becomes unnecessary and is withdrawn.IFRS Foundation
- Jan 2026Relief time limits to come outThe department tells the FCA the reliefs will lose their time references.DBT letter, 5 Jan 2026
- Feb 2026Final Standards and Annex AOne proposal replaced; ¶¶73A, 73B, E5 and B59A added.Annex A
The pattern
What the differences have in common
Read together, the rows fall into three groups.
The first makes the Standards fit UK law: no effective dates, and deference to whichever UK body requires them.
The second loosens what the UK thought premature: the SASB and industry guidance, and the time limits on reliefs.
The third tightens in two narrow places: timing alongside the accounts, and the compliance claim of a climate-only reporter.
Paragraph B59A is the one addition that asks a sector for more disclosure.
An untimed relief in the Standard is not an untimed relief for a listed company, because the FCA’s transitional rules set their own limits.
The IFRS Foundation tracks how each jurisdiction adopts the ISSB Standards on its jurisdiction pages.
Frequently asked
Questions people ask
How does UK SRS differ from IFRS S1 and S2?
In a small number of specific places, all listed in Annex A of the government’s consultation response.
Industry guidance moves from shall to may, the effective dates are removed, the time limits on the climate-first and Scope 3 reliefs are removed, a climate-only reporter may not claim compliance with UK SRS S1, the Standards defer to UK law where it requires them, and a new paragraph asks financial institutions to explain mismatched financed-emissions periods.
How many UK amendments are there?
Annex A gives no count, and this page does not invent one.
The June 2025 consultation said the government proposed six minor amendments.
Before publication one was withdrawn because the ISSB made the change itself, one was replaced, and four provisions were added.
Counting depends on how the rows are grouped.
Are the ISSB’s December 2025 amendments UK differences?
No. The ISSB amended IFRS S2 in December 2025, and UK SRS S2 carries those amendments.
Because the change is in both texts, it is not a difference between them.
Does UK SRS change the materiality test?
No. Both UK Standards keep the ISSB’s financial materiality test, focused on investors, lenders and other creditors.
The UK did not add an impact test.
Can a UK SRS report also claim compliance with IFRS S1 and S2?
That depends on whether the report meets every IFRS requirement, which UK SRS does not guarantee.
Where the UK text is looser, such as industry guidance or the untimed reliefs, an entity relying on the looser UK position may not meet the IFRS text.
The entity has to test the claim against the IFRS Standards themselves.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- Department for Business and TradeConsultation response, Annex A — the tables of differences from IFRS S1 and S2
The two difference tables this page reproduces in its own words.
- Department for Business and TradeGovernment response to the consultation on UK SRS — web version
What changed between the exposure drafts and the final Standards, and why.
- Department for Business and TradeExposure drafts: UK Sustainability Reporting Standards — consultation (25 June to 17 September 2025)
The draft Standards and the amendments as first proposed.
- Department for Business and TradeLetter to the FCA on finalising UK SRS (5 January 2026)
Why the time limits on the reliefs were taken out of the Standards.
- Department for Business and TradeUK SRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (25 February 2026)
The general Standard, read at the paragraph.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (25 February 2026)
The climate Standard, including Appendix C on transition.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — publication page
Where both Standards were published on 25 February 2026.
- IFRS FoundationIFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information
The source text for UK SRS S1.
- IFRS FoundationIFRS S2 Climate-related Disclosures
The source text for UK SRS S2.
- IFRS FoundationISSB issues targeted amendments to IFRS S2 (December 2025)
The ISSB’s own amendments, carried into UK SRS S2 — not UK departures.
- IFRS FoundationSASB Standards
Industry guidance UK SRS S1 says an entity may consider.
- Financial Reporting CouncilUK Sustainability TAC issues final recommendations (18 December 2024)
The technical recommendation to endorse IFRS S1 and S2 for the UK.
- IFRS FoundationUse of ISSB Standards by jurisdiction
Where the UK sits among adopting jurisdictions.
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
Confirms a voluntary reporter can use the reliefs without time limits.