The entity identifies sustainability-related risks and opportunities that could reasonably be expected to affect its cash flows, access to finance or cost of capital, looking across its value chain.
UK SRS S1 · General Requirements
UK SRS S1 general requirements, in six decisions
Purpose
What S1 does that S2 does not
UK SRS S1 is a rulebook for disclosures rather than a list of topics.
It says nothing specific about water, labour or biodiversity.
Instead it fixes the test that decides whether any such matter belongs in the report, and the shape the report takes when it does.
Climate is the one topic with a Standard of its own, UK SRS S2, which relies on S1 for everything that is not climate-specific.
That dependence runs one way: S2 cannot be applied without S1, but S1 can be applied to topics S2 never mentions.
| Question | UK SRS S1 paragraphs |
|---|---|
| Which risks and opportunities are in scope? | ¶3, ¶¶54–58 |
| What is material? | ¶¶17–19 |
| What goes under each content area? | ¶¶25–53 |
| How do disclosures connect to the accounts? | ¶¶21–24 |
| Where and when is it published? | ¶¶60–69 |
| When can compliance be claimed? | ¶¶72–73B |
| What eases the first years? | Appendix E |
The sequence
Six decisions, in the Standard’s order
Scroll through the six steps a preparer takes, each pinned to the paragraphs that govern it.
- ¶3 · ¶¶54–58
Which risks and opportunities could affect the entity’s prospects?
- ¶¶17–19
Which information about them is material?
Information is material if leaving it out, misstating it or obscuring it could reasonably be expected to influence the decisions of investors, lenders and other creditors.
- ¶¶25–53
What goes under each of the four content areas?
Governance at ¶¶26–27, strategy at ¶¶28–42, risk management at ¶¶43–44, and metrics and targets at ¶¶45–53.
- ¶¶21–24
How do the disclosures connect?
To each other, and to the financial statements, using consistent data and assumptions where possible.
- ¶¶60–69
Where and when is it published?
As part of general purpose financial reports, at the same time as the related financial statements and for the same reporting period.
- ¶¶72–73B
Can the entity say it complies?
Only explicitly, unreservedly, and only when every requirement is met.
Decision two
Materiality, looked at from the lender’s desk
The test in ¶18 is about the users of the report, not about the world outside the company.
A large environmental impact that has no reasonable prospect of affecting the entity’s finances is outside the test.
A modest impact that could trigger regulation, litigation or a change in borrowing costs is inside it.
That is single, financial materiality, the ISSB’s approach, and the UK kept it word for word.
It differs from the EU’s European Sustainability Reporting Standards, which add a test of impact on people and the environment.
Materiality is also judged afresh each period, so a matter left out one year may be required the next.
The test in one line
Would a reasonable investor or lender decide differently without this information?
Where the UK text differs
Three departures from IFRS S1
IFRS S1
SASB consideration required; a first-year option to report after the accounts; no rule on climate-only compliance claims.
UK SRS S1
SASB becomes optional; reporting stays with the accounts; a climate-only reporter may not claim S1 compliance.
Source: Annex A of the government response; UK SRS S1.
The government lists every difference in Annex A of its consultation response.
The first change makes the SASB Standards a source an entity may use rather than one it shall consider.
The second removes the first-year option to publish sustainability disclosures after the financial statements.
The third, ¶73A, stops an entity that reports on climate alone from claiming compliance with S1.
Paragraph 73B and ¶E5, also UK additions, make the Standard subject to any UK law or regulation that requires it.
The differences page sets these beside the S2 changes.
Decision six
The statement of compliance and its limits
Paragraph 72 asks for an explicit and unreserved statement of compliance, and forbids describing disclosures as compliant unless they meet every requirement.
There is no partial compliance under the Standard.
For a listed company, the FCA’s rules work differently: a gap is explained, not hidden, and the explanation is the compliance with the listing rule.
The FCA’s draft Technical Note 803.1 says an issuer explaining a gap in a Standard should not also make an unreserved statement of compliance with it.
The comply-or-explain page sets out what that explanation contains.
Frequently asked
Questions people ask
What is UK SRS S1?
UK SRS S1 General Requirements for Disclosure of Sustainability-related Financial Information is the UK-endorsed version of IFRS S1, published by the Department for Business and Trade on 25 February 2026.
It sets the rules every sustainability-related financial disclosure follows: which risks and opportunities to consider, how to judge materiality, the four core content areas, where and when to report, and when a statement of compliance may be made.
Does UK SRS S1 only cover climate?
No. UK SRS S1 covers any sustainability-related risk or opportunity that could reasonably be expected to affect the entity’s cash flows, access to finance or cost of capital.
Climate has its own Standard, UK SRS S2.
An entity may report on climate alone at first, using the climate-first relief, but it then cannot claim compliance with UK SRS S1.
What materiality test does UK SRS S1 use?
Financial materiality.
Information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users of general purpose financial reports make on the basis of those reports.
Primary users are existing and potential investors, lenders and other creditors.
The UK kept the ISSB’s test unchanged.
Must UK SRS S1 use the SASB Standards?
No. In IFRS S1 an entity shall refer to and consider the applicability of the SASB Standards when identifying risks and opportunities and the disclosures about them.
UK SRS S1 changes that to may, at paragraphs 55(a) and 58(a).
The SASB Standards remain a source the entity can use; they are no longer one it must consider.
Can UK SRS S1 disclosures be published after the annual report?
Not under the Standard’s timing rule.
Paragraph 64 requires the sustainability-related financial disclosures to be reported at the same time as the related financial statements.
IFRS S1 gave a first-year option to report later; the UK removed it, so it is not available under UK SRS S1 and, because S2 is applied with S1, not for climate disclosures either.
When can a company say it complies with UK SRS S1?
Only when it meets every requirement.
The statement must be explicit and unreserved.
Paragraph 73A, added by the UK, bars an entity using the climate-first relief from asserting compliance with UK SRS S1, although it may still state compliance with UK SRS S2.
Under the FCA’s draft guidance, an issuer that explains a gap should not also make an unreserved statement of compliance with that Standard.
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.
Checked against 13 sources fromDepartment for Business and TradeIFRS FoundationFinancial Conduct AuthorityFinancial Reporting Council
- Department for Business and TradeUK SRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (25 February 2026)
Paragraphs 3, 17–25, 26–53, 55, 58, 60–73B, B45–B47 and Appendix E.
- 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.
- Department for Business and TradeUK Sustainability Reporting Standards — GOV.UK guidance
Describes the Standards as available for voluntary use by any entity.
- Department for Business and TradeConsultation response, Annex A — the tables of differences from IFRS S1 and S2
The authoritative list of UK departures; where a requirement is not in the table there is no difference.
- 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 TradeLetter to the FCA on finalising UK SRS (5 January 2026)
Why the time limits on the reliefs were taken out of the Standards.
- IFRS FoundationIFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information
The source text for UK SRS S1.
- IFRS FoundationSASB Standards
Industry guidance UK SRS S1 says an entity may consider.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards (30 September 2026)
The final rules: comply or explain across UK SRS for UKLR 6, 14, 15, 16 and 22.
- Financial Conduct AuthorityPS26/19 — full text, including the made instrument (UKLR 6.6.6R(7A), (7B), (8) and UKLR TP 16)
Scope, timing, reliefs and the rule text itself.
- Financial Conduct AuthorityDraft Technical Note 803.1 (September 2026, for consultation)
Draft guidance on what an explanation should contain; comments by 28 October 2026.
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
Confirms a voluntary reporter can use the reliefs without time limits.
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