Scope · FCA PS26/19 ¶¶3.6–3.7
Who must apply UK SRS? Scope by listing category
Whether a company must apply UK SRS is a question about where its securities are listed, not how big it is.
The FCA’s final rules reach five categories of the UK Listing Rules, and nothing else in UK law yet requires the Standards.
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Answer three questions, get the provision
The tree asks only what the rule asks.
It never asks about turnover, employees or balance sheet, because PS26/19 does not.
A company with securities in more than one category is in scope if any of them is a category the rules reach.
The result names the provision it rests on, so it can be checked against the rule text in the full policy statement.
The five categories
Five categories in orbit around one rule
The inner ring carries the full set of disclosures, including the statement on transition plans.
The outer ring carries the same comply-or-explain duty, without that one statement.
PS26/19 ¶4.35 records 89 secondary-listing and depositary-receipt issuers identified by the FCA, and says they face the same requirements as domestic issuers.
The policy statement gives no total for all five categories.
The FCA’s consultation, CP26/5, estimated around 600 listed companies would be affected, using the Official List as at January 2025.
Outside the rule
Who is excluded, and who was never in
Exclusion from the FCA’s rules is not exclusion from every climate duty.
The Companies Act climate-related financial disclosures still apply to large companies and LLPs that meet their own tests, and they are a separate duty from UK SRS.
The government’s Modernising corporate reporting consultation says it will consider how UK SRS should be reflected in the Companies Act, without proposing a threshold or a date.
The government’s guidance calls the Standards available for any entity that chooses to use them, and the FRC says a voluntary reporter can use the reliefs indefinitely.
For when an in-scope company starts, read the effective-date page.
| Entity | UK SRS position | Why |
|---|---|---|
| Investment trusts and other closed-ended funds | Excluded | PS26/19 ¶3.7 |
| Open-ended investment companies | Excluded | PS26/19 ¶3.7 |
| Shell companies | Excluded | PS26/19 ¶3.7 |
| Debt and securitised derivatives issuers | Excluded | PS26/19 ¶3.7 |
| AIM companies | Voluntary | Not on the Official List |
| Private companies and LLPs | Voluntary | No rule or law requires UK SRS |
Frequently asked
Questions people ask
Who must apply UK SRS?
Under the FCA’s final rules in PS26/19, companies with securities listed in five UK Listing Rules categories: UKLR 6, 14, 15, 16 and 22.
They report against UK SRS S1 and S2 on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
No other entity is required to use UK SRS.
Is there a size threshold for UK SRS?
No. Scope under the FCA rules turns on the listing category of the company’s securities, not on turnover, balance sheet or employees.
A small company in UKLR 6 is in scope; a large private company is not.
Do AIM companies have to apply UK SRS?
No. Securities admitted to AIM are not on the Official List, so AIM companies are not in any of the five listing categories.
Some AIM companies have separate Companies Act climate disclosure duties, which UK SRS does not replace.
Do overseas companies listed in London have to apply UK SRS?
Those in UKLR 14 (international commercial companies with a secondary listing) and UKLR 15 (depositary receipts) are in scope.
PS26/19 says the 89 such issuers the FCA identified are subject to the same requirements as domestic listed issuers.
They do not make the transition plan statement, which applies only to UKLR 6, 16 and 22.
Are investment trusts and funds in scope of UK SRS?
No. PS26/19 excludes closed-ended investment funds and open-ended investment companies, along with shell companies, debt, securitised derivatives and miscellaneous securities.
Asset managers have separate FCA sustainability disclosure rules.
Can a private company use UK SRS?
Yes, voluntarily.
The government describes the Standards as available for voluntary use by any entity.
A voluntary reporter is bound by nothing in the FCA’s rules, and the FRC says it can use the Standards’ reliefs without a time limit.
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.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards (30 September 2026)
Scope at ¶3.6, exclusions at ¶3.7, overseas issuers at ¶4.35.
- 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 AuthorityFCA Handbook — UK Listing Rules (UKLR)
The listing categories that set who is in scope.
- Financial Conduct AuthorityFCA Handbook, UKLR 6.6 — annual financial report (as from 1 January 2027)
The rule the new disclosure limbs sit in.
- 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.
- 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 TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — publication page
Where both Standards were published on 25 February 2026.
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
Confirms a voluntary reporter can use the reliefs without time limits.
- legislation.gov.ukCompanies Act 2006, s.414CB — the non-financial and sustainability information statement
The separate Companies Act climate disclosure duty, which UK SRS does not replace.
- legislation.gov.ukSI 2022/31 — Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022
Created the Companies Act climate disclosures for large companies and LLPs.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation (open to 30 November 2026)
Says only that the government will consider how UK SRS is reflected in the Companies Act.
- 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.