UK SRS S2 · Climate-related Disclosures
UK SRS S2 climate disclosures: what the report holds
Shape of the report
Five blocks an investor should find
UK SRS S2 inherits its four headings from the TCFD recommendations of 2017.
In practice the strategy heading splits in two, because the paragraphs on financial effects and resilience do different work from those describing the business.
The first describes what climate means for the entity; the second puts numbers and stress tests on it.
Every block relies on UK SRS S1 for materiality, connection to the accounts and timing.
A report that reads as a separate sustainability brochure, unconnected to the financial statements, has missed the S1 half of the job.
| Block | Paragraphs | What it answers |
|---|---|---|
| Governance | ¶¶5–7 | Who oversees climate, how often, with what skills |
| Strategy and the business | ¶¶8–14 | Which risks and opportunities, over which horizons, and any transition plan |
| Financial effects and resilience | ¶¶15–22 | Effects on position, performance and cash flows; resilience under scenarios |
| Risk management | ¶¶24–26 | How climate risks are found, assessed and folded into overall risk management |
| Metrics and targets | ¶¶27–37 | The seven categories, any industry metrics, and targets with progress |
Paragraph 29
The seven metric categories, card by card
Every entity applying UK SRS S2 discloses these seven, whatever its industry.
Swipe or use the arrows; each card names its sub-paragraph.
- ¶29(a)Greenhouse gas emissionsAbsolute gross Scope 1, Scope 2 and Scope 3, measured under the GHG Protocol Corporate Standard unless a jurisdictional authority or exchange requires another method.
- ¶29(b)Transition risk exposureThe amount and percentage of assets or business activities vulnerable to climate-related transition risks.
- ¶29(c)Physical risk exposureThe amount and percentage of assets or business activities vulnerable to climate-related physical risks.
- ¶29(d)Climate-related opportunitiesThe amount and percentage of assets or business activities aligned with climate-related opportunities.
- ¶29(e)Capital deploymentThe amount of capital expenditure, financing or investment deployed towards climate-related risks and opportunities.
- ¶29(f)Internal carbon pricesWhether and how the entity applies a carbon price in decisions, and the price per tonne of emissions it uses.
- ¶29(g)RemunerationThe percentage of executive management remuneration recognised in the period that is linked to climate-related considerations, and how.
The GHG Protocol Corporate Standard is the default measurement method for the first card.
Scope 3 is measured after considering all fifteen categories in the Scope 3 Standard, and the entity says which it included.
The judgement call
Scenario analysis: how far quantitative?
Qualitative narratives and limited data can be a reasonable basis for the resilience assessment.
A more advanced, quantitative approach is required, not merely permitted.
Source: UK SRS S2 ¶¶22, B15–B18.
Paragraph 22 requires climate-related scenario analysis to assess resilience; it does not allow an entity to skip it.
What varies is the method, which must be commensurate with the entity’s circumstances.
The two inputs that set it are the entity’s exposure to climate-related risks and the skills, capabilities and resources it has.
An entity that is heavily exposed and well resourced cannot settle for narrative alone.
The analysis itself may follow the strategic planning cycle, but the resilience assessment is updated every reporting period.
Counts from the text
UK SRS S2 by its own numbers
Where the UK asks for more
Paragraph B59A: an added duty
Most UK changes to IFRS S2 loosen a requirement; ¶B59A adds one.
Where an entity finds it impracticable to estimate financed emissions for the same period as its financial statements, it says why.
It then explains the approach, inputs and assumptions behind the financed emissions it does report.
And it gives its plan, with a timeline, for bringing the two periods into line.
The full set of UK changes is on the differences page.
Asset managers, commercial banks and insurers that disclose financed emissions.
Under the FCA rules
What changes for a listed company
For a company in one of the five listing categories, the FCA’s rules require UK SRS S2 disclosures or an explanation of what was not disclosed.
The FCA’s consultation had proposed making S2 mandatory outright; the final rules put it on the same comply-or-explain footing as S1.
The Scope 3 relief is cut to the first year, after which Scope 3 joins everything else on comply or explain.
The reliefs page covers the timing, and the comply-or-explain page covers the explanation.
Frequently asked
Questions people ask
What does UK SRS S2 require a company to disclose?
Information about climate-related risks and opportunities that could reasonably be expected to affect the entity’s prospects, under four headings: governance, strategy, risk management, and metrics and targets.
Within strategy it asks for the effects on the business model and value chain, any transition plan, current and anticipated financial effects, and resilience tested by scenario analysis.
Within metrics it asks for seven cross-industry categories and the entity’s climate targets.
What are the seven cross-industry metrics in UK SRS S2?
Paragraph 29 lists them: greenhouse gas emissions (Scope 1, 2 and 3); the amount and percentage of assets or activities vulnerable to transition risks; the same for physical risks; the amount and percentage aligned with climate-related opportunities; capital expenditure, financing or investment deployed towards climate-related risks and opportunities; internal carbon prices; and the percentage of executive remuneration linked to climate considerations.
How quantitative must UK SRS S2 scenario analysis be?
Proportionate.
The approach must be commensurate with the entity’s circumstances, taking into account its exposure to climate-related risks and the skills, capabilities and resources available to it.
Qualitative scenario narratives can be enough for some entities, but an entity with a high degree of exposure and access to the necessary skills or resources is required to use a more advanced, quantitative approach (paragraphs B15 to B17).
Does UK SRS S2 require Scope 3 emissions?
Yes, in the Standard: paragraph 29(a) includes Scope 3, considering all fifteen categories of the GHG Protocol Scope 3 Standard.
Appendix C gives a relief from Scope 3 that has no time limit in the UK text.
For listed companies, the FCA’s rules limit that relief to the first year from initial application.
Is industry-based guidance mandatory under UK SRS S2?
No. IFRS S2 says an entity shall refer to and consider its Industry-based Guidance.
UK SRS S2 changes that to may, at paragraphs 12, 23 and 32.
The guidance remains available; the UK does not require an entity to consider it.
How is UK SRS S2 different from TCFD reporting?
It keeps the TCFD’s four headings but asks for more inside each, including quantified financial effects, a defined set of cross-industry metrics, Scope 3 emissions and rules on how targets are described.
For listed companies in scope, the FCA’s UK SRS rules replace the TCFD-aligned disclosure rule from periods beginning on or after 1 January 2027.
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 TradeUK SRS S2 Climate-related Disclosures (25 February 2026)
Paragraphs 5–37, B15–B18, B59A and Appendix C.
- 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 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 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.
- 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.
- GHG Protocol (WRI / WBCSD)Corporate Accounting and Reporting Standard
The measurement method UK SRS S2 points to for Scope 1, 2 and 3.
- GHG Protocol (WRI / WBCSD)Corporate Value Chain (Scope 3) Standard
The fifteen categories an entity considers when measuring Scope 3.
- Task Force on Climate-related Financial DisclosuresRecommendations of the TCFD (June 2017)
The four-heading architecture both Standards keep.
- 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.
- IFRS FoundationDisclosing information about an entity’s climate-related transition, including information about transition plans, in accordance with IFRS S2 (June 2025)
Educational material that adds no requirement; it reads across to UK SRS S2 ¶14.