Scope

Are asset managers in scope?

A listed asset-management group falls within the FCA's proposed UK SRS S2 regime under CP26/5, covering UK Listing Rules categories 6, 14, 15, 16 and 22 from financial years beginning on or after 1 January 2027 FCA CP26/5.

A large manager that is not listed may instead be caught by the climate-disclosure law in section 414CB of the Companies Act 2006 if it meets the 500-employee and £500 million testsCompanies Act 2006 s.414CB.

The standards to be applied — UK SRS S1 and S2 — were published by the Department for Business and Trade on 25 February 2026 DBT.

Entity-level reporting under UK SRS is distinct from product-level disclosure under the FCA sustainability regime, a distinction that matters more for asset managers than for any other sub-sector.

The core obligation

Portfolio emissions on assets under management

IFRS S2 requires Scope 1, 2 and 3 emissions on the GHG Protocol Corporate StandardGHG Protocol, and for an asset manager almost all of the reportable total is the financed emissions of the holdings it manages.

The IFRS S2 industry-based guidance for asset management asks specifically for these portfolio figuresIFRS S2 industry-based guidance.

The measurement method is the PCAF financed-emissions standard, applied here mainly to listed equity and corporate bonds, attributing each investee's emissions to the manager in proportion to the holding PCAF Standard, Part A.

Because a manager invests on behalf of clients, a key reporting decision is the boundary — what is consolidated at entity level versus disclosed per productIFRS S2.

Don’t conflate them

UK SRS and the FCA SDR regime are different things

Asset managers face a second, separate sustainability regime: the FCA's Sustainability Disclosure Requirements and investment-labels regime, finalised in PS23/16FCA PS23/16.

SDR governs how funds are labelled and marketed and what they disclose to investors at product level.

UK SRS S2, by contrast, is entity-level reporting about the manager itself and its portfolio emissions FCA CP26/5.

The two interact — both draw on the same underlying data — but they are not interchangeable, and a manager needs a programme that serves both.

A fuller treatment of the SDR side sits on the companion guide at sustainabilityreportingstandards.co.uk.

Timing

The timeline and what to build now

The proposed first UK SRS S2 reporting year for listed asset managers is the financial year beginning 1 January 2027 FCA CP26/5.

Portfolio emissions, as Scope 3, benefit from one year of transitional relief and become comply-or-explain a year later FCA CP26/5.

Since the same investee-data pipeline feeds both UK SRS S2 and SDR, building it once and well is the efficient path.

Assurance is not yet mandatory, but a manager that assures must disclose the provider, level and standard — in the UK, ISSA (UK) 5000FRC, ISSA (UK) 5000.

The standards underneath are on the IFRS S1/S2 hub.