The Financial Conduct Authority published its final rules for sustainability reporting by listed companies on 30 September 2026, in policy statement PS26/19. Listed companies will report against the UK Sustainability Reporting Standards (UK SRS) on a comply or explain basis, for accounting periods beginning on or after 1 January 2027. The first reports appear in 2028. The rules replace the climate disclosures based on the Task Force on Climate-related Financial Disclosures (TCFD) that listed companies have made since 2021.
What the final rules say
| Topic | Final rule |
|---|---|
| Who | Companies with shares in the commercial companies, transition, non-equity and non-voting equity categories, plus secondary listings and depositary receipts |
| Standards | UK SRS S1 (general sustainability) and UK SRS S2 (climate), published by the government on 25 February 2026 and based on the ISSB standards |
| Basis | Comply or explain, for every part of the standards |
| Start | Accounting periods beginning on or after 1 January 2027 |
| Scope 3 | Comply or explain, with one year of relief from first application |
| Non-climate topics | Two years of relief, so companies can report on climate first |
| Transition plans | State whether you have a climate transition plan and where to find it, or explain why not; no duty to produce one; not for secondary listings and depositary receipts |
| Assurance | Say whether the report was assured, by whom and to what level; assurance is not required |
The biggest change from the consultation is on climate. The FCA had proposed making UK SRS S2 mandatory, with only Scope 3 on a comply or explain basis. After responses warned about the burden on smaller listed companies, it moved every part of the standards to comply or explain, and brought secondary listings into the same regime instead of letting them point to their home country's rules.
What comply or explain means in practice
Comply or explain is not optional reporting. A company either makes the disclosure or explains in its annual report why it has not, and the FCA expects that explanation to contain specific information. Under the TCFD rules the same approach produced high levels of disclosure among larger listed companies. Investors read the explanations, and a weak one is a signal in itself.
The FCA is consulting on its guidance, Technical Note 803.1, until 28 October 2026, and aims to finalise it before the rules start.
Why suppliers should care
Scope 3 relief lasts one year. For a listed company with a calendar financial year, that means Scope 3 emissions for the 2028 financial year onwards are expected in the report, or an explanation of why they are missing. Most of those emissions sit with suppliers. Companies that sell to UK listed groups should expect more requests for their own carbon footprint, by product or by customer, over the next two years.
A supplier that can answer with a Scope 1, 2 and 3 footprint calculated to the GHG Protocol, with the factor sources named, is easier to keep and easier to choose.
What about large private companies?
Nothing changes for them yet. The government's consultation "Modernising corporate reporting", published on 7 September 2026 and open until 30 November 2026, asks how UK SRS should be reflected in the Companies Act. The existing climate-related financial disclosure rules for large private companies stay in place in the meantime, and Streamlined Energy and Carbon Reporting continues as before.
For the standards themselves, see our guide to the UK Sustainability Reporting Standards. For energy and carbon reporting by private companies, see the SECR guide. Carbon accounting in Greener Ahead calculates Scope 1, 2 and 3 with the UK government conversion factors for UK activity.
Joost Thissen
