UK SRS S1 Appendix E · S2 Appendix C · UKLR TP 16
UK SRS transition reliefs: the Standard against the rule
Every UK SRS relief exists twice: once in the Standard, and once in the FCA’s transitional provisions for listed companies.
The government took the time limits out of the Standards and left it to whoever requires them to set their own.
The FCA did, so a listed company and a voluntary reporter read the same paragraph and get different answers.
Two readings of one relief
The Standard’s reliefs, re-timed by the FCA
Scope 3 and climate-first reliefs run without a time limit; comparatives are waived in the first period.
Scope 3 relief for the first period only; climate-first for the first two; comparatives unchanged.
Each block’s width is the number of reporting periods the relief covers, out of three.
The first reading is the one in the PDFs on GOV.UK.
The second is the one a company in UKLR 6, 14, 15, 16 or 22 actually works to.
When a relief ends under the FCA rules, the matter moves to comply or explain; nothing becomes mandatory.
Relief by relief
What each relief covers, and its catch
| Relief | In the Standard | Under the FCA rules | The catch |
|---|---|---|---|
| Climate-first | S1 ¶E3: report on climate only, applying S1 only so far as it relates to climate; no time limit | Two years from initial application | No statement of compliance with UK SRS S1 while it is used (S1 ¶73A) |
| Scope 3 emissions | S2 ¶C4: Scope 3 need not be disclosed; no time limit in the UK text | One year from initial application | Scope 3 then joins comply or explain |
| GHG measurement method | S2 ¶C4: keep a method other than the GHG Protocol in the first period, if used immediately before | Follows the Standard | The first-period limit stays, unlike Scope 3 |
| Comparatives | S1 ¶E1 and S2 ¶C1: none needed in the first period | Follows the Standard | A topic added when climate-first ends has its own comparatives tail (S1 ¶E4) |
| Who sets the timing | S1 ¶E5 and S2 ¶C6: UK law or regulation requiring the Standard | UKLR TP 16 | Voluntary reporters have no time limit |
Using a relief
The relief statement is not an explanation
A company using a relief says so, and for the matters the relief covers it explains nothing further.
That is a different item from the comply-or-explain explanation, which covers gaps no relief reaches.
Mixing the two makes a report harder to read: a relief is a permitted choice, an explanation is an account of a shortfall.
The comply-or-explain page covers the explanation itself.
That the company is using the relief, and which one; the FCA asks for nothing more about what the relief covers.
The price of climate-first
Climate-first and the compliance statement
Climate-first lets a first report concentrate on climate, the ground TCFD-aligned reporting already covered.
Its price is set by ¶73A of UK SRS S1, a UK addition: an entity using it may not assert compliance with UK SRS S1.
It can still assert compliance with UK SRS S2, disclosing the reliefs used beside the statement.
So the S2 compliance statement survives climate-first reporting and the S1 statement does not.
In periods
The FCA reliefs, counted
The FRC’s FAQs confirm the last figure: a voluntary reporter can use the reliefs indefinitely.
For the calendar dates that follow from these periods, use the effective-date finder.
Frequently asked
Questions people ask
What transition reliefs does UK SRS give?
Four matter in practice.
The climate-first relief lets an entity report only on climate in its early years.
The Scope 3 relief lets it leave out Scope 3 emissions.
The GHG-method relief lets it keep a different measurement method in the first period.
And both Standards waive comparatives in the first period.
In the Standards the first two have no time limit; the FCA’s rules time them for listed companies.
How long is the Scope 3 relief under UK SRS?
In UK SRS S2 itself, paragraph C4 sets no time limit, a UK change from IFRS S2.
For listed companies the FCA’s rules give one year from initial application.
After that, Scope 3 is on comply or explain like every other S2 requirement.
What is the climate-first relief?
UK SRS S1 paragraph E3 lets an entity report only on climate-related risks and opportunities, applying S1 only so far as it relates to climate.
The Standard sets no time limit; the FCA’s rules allow it for two years from initial application.
A company using it cannot state compliance with UK SRS S1, but can state compliance with UK SRS S2.
What must a company say when it uses a relief?
Under the FCA rules it states that it is using the relief.
For the matters the relief covers it gives no further explanation.
That relief statement is separate from the comply-or-explain explanation for anything else not disclosed.
Can an early adopter of UK SRS use the reliefs?
Yes.
A company whose period begins before 1 January 2027 and that adopts the UK SRS rules early can use the same transitional reliefs (PS26/19 paragraph 3.19).
The consultation had proposed denying them; the final rules did not.
Do voluntary UK SRS reporters have time limits on reliefs?
No. The FCA’s time limits apply only to companies within its rules.
The FRC says a voluntary reporter can use the reliefs in the Standards without time limits.
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 S1 General Requirements for Disclosure of Sustainability-related Financial Information (25 February 2026)
Appendix E: ¶¶E1, E3, E4, E5, and ¶73A on the compliance statement.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (25 February 2026)
Appendix C: ¶¶C1, C4, C6.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards (30 September 2026)
Reliefs ¶3.14, early adopters ¶3.19, the relief statement ¶3.20, expiry ¶¶3.23–3.24.
- 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.
- 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 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.
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
Confirms a voluntary reporter can use the reliefs without time limits.
- Financial Conduct AuthorityCP26/5 — the consultation the final rules replace (30 January 2026)
Cited only for what was proposed, including a mandatory UK SRS S2 that the final rules dropped.
- 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.
- 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.