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UK SRS · Finance

Financial sustainability reporting, for banks, insurers and asset managers

UKSRS Finance is an independent reference on financial sustainability reporting in the UK: UK SRS, IFRS S1 and S2, and the financed emissions behind them.

UK SRS is a voluntary standard; the FCA’s final rules in PS26/19, following CP26/5, require listed companies in scope to report against it on a comply-or-explain basis from 1 January 2027.

Some climate reporting already binds financial firms, and this site keeps the two apart.

Checked against 15 sources fromDepartment for Business and TradeFinancial Conduct Authoritylegislation.gov.ukBank of EnglandIFRS FoundationPCAFand 1 moreSee the sources

Status

Voluntary standards, comply or explain from 2027

UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 as the UK endorsements of the ISSB’s IFRS S1 and IFRS S2.

The standards are voluntary in themselves.

The FCA’s final rules in PS26/19, published on 30 September 2026, require listed companies in scope to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

The consultation had proposed mandatory UK SRS S2, and estimated that around 600 listed companies would be affected; the final rules put all of UK SRS on comply or explain instead.

Scope 3 — which, for a financial institution, includes its financed emissions — carries a one-year relief, during which a company only states that it is using it, and is comply-or-explain after that.

The sequence

  1. 25 Feb 2026
    UK SRS S1 and S2 published

    Department for Business and Trade. Voluntary for any UK entity.

  2. 30 Sep 2026
    FCA PS26/19: final rules

    UK SRS on a comply-or-explain basis for listed companies in scope.

  3. 1 Jan 2027
    Rules apply to listed companies

    Accounting periods beginning on or after this date; first reports in 2028.

  4. 1 Jan 2028
    Scope 3 relief ends

    After a one-year relief; financed emissions are Scope 3.

Sources: DBT; FCA PS26/19 ¶¶3.12, 3.14

Already in force

What already binds financial firms

Separate from UK SRS, four instruments already bear on climate reporting by UK financial institutions.

Our summary of each instrument’s own text, as at 30 September 2026.
InstrumentWhoWhat it asks
FCA ESG 2.3.9RIn-scope asset managers and asset owners with £5bn or more of relevant assetsTCFD product reports with Scope 1 and 2, Scope 3, total carbon emissions, total carbon footprint and weighted average carbon intensity
Companies Act 2006 s.414CBCompanies within the scope set by s.414CAClimate-related financial disclosures in the strategic report; UK SRS S2 is recognised as a national reporting framework for s.414CB(6)
PRA SS5/25PRA-regulated banks and insurersSupervisory expectations on managing climate-related risk, in force since 3 December 2025; not a disclosure rule
SI 2021/839Trustees of occupational pension schemes above its asset thresholds, and authorised master trustsClimate governance and reporting, including an absolute emissions metric, under a DWP regime enforced by The Pensions Regulator

The FCA’s sustainability labels and naming rules sit in ESG 4, which is drafted as a prohibition on using any of the four labels without qualifying.

None of these instruments names PCAF, and none of them is UK SRS.

How they combine for each kind of firm is on UK SRS for financial services.

Financed emissions

The number that defines finance-sector disclosure

Financed emissions are Scope 3 Category 15 of the GHG Protocol’s Scope 3 Standard: the emissions of what an institution lends to and invests in.

UK SRS S2 asks an entity with asset management, commercial banking or insurance activities for additional financed emissions information under ¶¶B59–B63A.

Its ¶29A, from the ISSB’s December 2025 amendments, lets an entity limit Category 15 to financed emissions, leaving out facilitated and insurance-associated emissions and derivatives.

The UK’s own addition, ¶B59A, is recorded in Annex A of the government’s response.

The figures themselves are usually calculated with the PCAF Standard, set out on the PCAF Standard and financed emissions reporting.

¶B59A — the UK asks for more

It is the one place UK SRS S2 goes further than IFRS S2.

An entity that cannot estimate financed emissions for the same period as its accounts must explain why and give its plan and timeline.

Elsewhere

Where else to read

This site goes deep on the financial-sector angle and does not repeat general definitions.

For those, the companion editorial site covers sustainability reporting standards more widely.

For the standards themselves, the UK SRS reference hub covers UK SRS S1 and UK SRS S2 clause by clause.

Both are published by the same company as this site, Fractional Quest Ltd.

To talk a question through, you can book a free 15-minute call; nothing on this site is financial, investment or legal advice.

Frequently asked

UKSRS Finance — frequently asked

What is UKSRS Finance?

UKSRS Finance is an independent reference on sustainability reporting for UK financial institutions: UK SRS and IFRS S1 and S2 for banks, insurers, asset managers and pension schemes, the PCAF Standard for financed emissions, and the FCA’s sustainability rules. It is published by Fractional Quest Ltd. It is not regulated and gives no financial, investment or legal advice.

What is financial sustainability reporting?

It is reporting on sustainability-related matters, such as climate, as they affect a company’s finances. UK SRS S1 and S2, the UK endorsements of IFRS S1 and S2, require information about sustainability-related and climate-related risks and opportunities that could reasonably be expected to affect an entity’s cash flows, its access to finance or its cost of capital.

Is UK SRS mandatory for banks and insurers?

Not mandatory. UK SRS S1 and S2 are voluntary standards. The FCA's final rules (PS26/19, 30 September 2026) require listed companies in scope, including listed banks and insurers in the relevant listing categories, to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. CP26/5, the consultation, had proposed mandatory UK SRS S2; the final rules did not adopt it.

What climate reporting already applies to UK financial institutions?

Several regimes are already in force. In-scope asset managers and asset owners with £5bn or more of relevant assets report emissions metrics in TCFD product reports under FCA ESG 2.3.9R. Companies within the scope of Companies Act 2006 section 414CA make climate-related financial disclosures under section 414CB. Trustees of large occupational pension schemes report under SI 2021/839. The PRA’s SS5/25 sets supervisory expectations on managing climate-related risk.

What does UK SRS S2 ask financial institutions about financed emissions?

An entity with asset management, commercial banking or insurance activities discloses additional information about its financed emissions under paragraphs B59 to B63A. The UK added paragraph B59A: where financed emissions cannot be reliably estimated for the same period as the financial statements, the entity explains why, how it estimated them, and its plan and timeline to align the periods.

Is PCAF required under UK SRS?

No. UK SRS S2 asks for financed emissions information and the method used, but does not name PCAF. PCAF is an industry-led method built to produce those figures, with more than 780 signatories as at 30 September 2026.

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.

  1. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2

    Published 25 February 2026 for voluntary use.

  2. Department for Business and Trade
    UK SRS S2 Climate-related Disclosures, ¶¶29(a)(vi)(2), 29A, B59–B63A

    Financed emissions for asset management, commercial banking and insurance.

  3. Department for Business and Trade
    UK SRS consultation response, Annex A and Chapter 3

    ¶B59A as the UK addition; UK SRS S2 as a national framework for s.414CB(6).

  4. Financial Conduct Authority
    PS26/19: Aligning listed issuers’ sustainability disclosures with international standards (30 September 2026)

    The final rules: listed companies in scope report against UK SRS on a comply-or-explain basis for accounting periods starting on or after 1 January 2027, with first reporting in 2028.

  5. Financial Conduct Authority
    CP26/5 — Aligning listed issuers’ sustainability disclosures with international standards

    The consultation PS26/19 finalises; it estimated that around 600 listed companies would be affected (Annex 2 ¶43).

  6. Financial Conduct Authority
    CP26/5 consultation page

    Published 30 January 2026; what was proposed.

  7. Financial Conduct Authority
    FCA Handbook, ESG 2.3.9R — TCFD product report metrics

    In force for in-scope asset managers and asset owners.

  8. Financial Conduct Authority
    FCA Handbook, ESG 4 — sustainability labels and naming and marketing

    The four SDR labels.

  9. legislation.gov.uk
    Companies Act 2006, section 414CB

    The climate-related financial disclosure duty in the strategic report.

  10. Bank of England
    PRA Supervisory Statement SS5/25

    Replaced SS3/19 in its entirety on 3 December 2025.

  11. legislation.gov.uk
    SI 2021/839 — Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021

    The separate DWP regime for trust-based schemes.

  12. IFRS Foundation
    IFRS S2 Climate-related Disclosures

    The international baseline UK SRS S2 endorses.

  13. IFRS Foundation
    Amendments to Greenhouse Gas Emissions Disclosures (IFRS S2), December 2025

    ¶29A: Category 15 may be limited to financed emissions.

  14. PCAF
    The Global GHG Accounting and Reporting Standard for the Financial Industry

    Parts A, B and C.

  15. GHG Protocol
    Corporate Value Chain (Scope 3) Standard

    Category 15, Investments.

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