FCA Confirms UK Sustainability Reporting Rules for Listed Companies from 2027
The FCA's PS26/19, published on 30 September 2026, requires in-scope listed companies to report against UK SRS on a comply-or-explain basis for accounting periods from 1 January 2027. Smaller suppliers may feel the effects through Scope 3 data requests.
By Entrepreneur Group · Published · Updated
The Financial Conduct Authority has confirmed how UK listed companies will report on sustainability. Its policy statement PS26/19, published on 30 September 2026, requires in-scope listed companies to report against the UK Sustainability Reporting Standards (UK SRS) on a comply-or-explain basis, for accounting periods starting on or after 1 January 2027. The first reports will appear in 2028 annual reports, according to Davis Polk.
Most startups and small businesses are not directly covered. But if you sell to a large listed company, its new reporting may lead to requests for your emissions data.
What the rules require
The government published the UK SRS in final form in February 2026. There are two standards: UK SRS S1, covering general sustainability-related disclosures, and UK SRS S2, covering climate. Both are based on the international IFRS S1 and S2 standards.
Under PS26/19:
- Who is in scope: broadly the same listed issuers that already report under the TCFD climate framework, including commercial companies with equity shares listed in London. AIM companies, closed-ended investment funds and shell companies are out of scope, Davis Polk notes.
- Comply or explain: companies must report against the standards or explain why they have not. This applies to all the requirements, including Scope 3 emissions. The FCA has said it has no current plans to remove the option to explain.
- Transition plans: companies must say whether they have published a climate transition plan and where to find it, or explain why not. They do not have to produce one.
- Assurance: third-party assurance is not mandatory, but companies must say whether they obtained it.
Transitional reliefs
Regulation Tomorrow and Davis Polk both describe reliefs for the first years:
- Scope 3 emissions can be left out in the first year of reporting.
- Reporting under UK SRS S1 can be limited to climate-related matters for the first two years.
- Comparative figures can be left out in the first reporting period.
All the reliefs end for accounting periods starting on or after 1 January 2029.
Why it matters for smaller businesses
Scope 3 emissions are those in a company's supply chain, which includes its suppliers. When large customers start reporting Scope 3, they often ask suppliers for data. The first-year relief means many listed companies will not need full Scope 3 figures until reports for 2028 accounting periods, so there is time to prepare.
This section is editorial guidance.
- Know your own footprint. Start measuring your energy use, fuel and main purchases now. Simple, consistent records are more useful than a complex estimate done once.
- Ask your big customers. If you supply a listed company, ask what data it expects and in what format.
- Be careful with claims. Only state environmental figures you can back up. Evidence counts for more than marketing.
- Make it a selling point. Being able to supply credible emissions data quickly can help you win and keep contracts with large companies.
Frequently asked questions
When do UK listed companies have to report under UK SRS?
For accounting periods beginning on or after 1 January 2027, with first disclosures in 2028 annual reports, under the FCA's PS26/19 published on 30 September 2026.
Is UK SRS reporting mandatory?
For in-scope listed companies it applies on a comply-or-explain basis. Companies must report against the standards or explain why they have not.
Do small businesses have to report under UK SRS?
The FCA rules apply to in-scope listed companies, not to most private small businesses or AIM companies. Smaller firms may still be asked for emissions data by large customers that report Scope 3.
Sources
- Davis Polk: UK listed companies to report under new sustainability standards from 2027 (reviewed 27 October 2026)
- Regulation Tomorrow: PS26/19 Aligning listed issuers' sustainability disclosures with international standards (reviewed 27 October 2026)