UK SRS for financial services: who is in scope, and what it asks of you

The map

Two regimes catch financial institutions

There is no single “financial services” rulebook.

Whether a bank, insurer or asset manager must report depends on which of two overlapping regimes it falls into, and many large institutions fall into both.

The first is the FCA's proposed listing regime.

Under consultation paper CP26/5, UK SRS S2 would apply to roughly 500 listed companies — those in UK Listing Rules categories 6, 14, 15, 16 and 22 — for financial years beginning on or after 1 January 2027FCA CP26/5.

A listed bank, insurer or investment trust is caught here on the same basis as any other listed issuer.

The second is the existing climate-disclosure law in section 414CB of the Companies Act 2006, which already requires large companies — explicitly including banking and insurance companies — with more than 500 employees and turnover above £500 million or a balance sheet above £500 million to make climate-related financial disclosuresCompanies Act 2006 s.414CB.

This catches many large unlisted institutions that the FCA regime does not.

The defining obligation

Why financed emissions change everything

For an industrial company, climate disclosure is mostly about its own operations and supply chain.

For a financial institution, the material number is its portfolio.

IFRS S2 requires disclosure of Scope 1, 2 and 3 greenhouse-gas emissions on the GHG Protocol Corporate Standard GHG Protocol, and for financial firms Scope 3 dwarfs the rest.

IFRS S2 makes this explicit through industry-based guidance — derived from the SASB Standards — that asks asset-management, commercial-banking and insurance activities to disclose their financed, facilitated and insurance-associated emissionsIFRS S2 industry-based guidance.

These are the emissions a bank finances through its lending, a manager owns through its holdings, and an insurer underwrites through its policies.

Recognising the data challenge, the FCA proposes one year of transitional relief: in-scope companies would report Scope 3, financed emissions included, on a comply-or-explain basis a year after the rest of S2 takes effect FCA CP26/5.

For finance teams that deferral is the single most important date in the regime.

It is not uniform

How the regime lands by sub-sector

The standards are common but the burden is not.

A retail bank, a life insurer and a boutique asset manager face very different versions of the same requirement, because their balance sheets and the IFRS S2 activity guidance point at different thingsIFRS S2.

Banks report financed emissions across lending and investment books; insurers add insurance-associated emissions from underwriting; asset managers report on assets under management rather than their own balance sheet; and pension schemes sit under a separate but parallel trustee-led disclosure track s.414CB.

Each is worth treating on its own terms.

Dedicated guidance is being built for each: banks, insurers, asset managers, pension schemes, investment firms and private equity.

Timing and assurance

What to plan against

The standards exist now: UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 DBT.

The FCA's proposed first S2 reporting year is the financial year beginning 1 January 2027, with first reports published in 2028 FCA CP26/5.

Scope 3 and financed emissions follow a year later on comply-or-explain, and the broader S1 disclosures are proposed from 1 January 2029 FCA CP26/5.

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

A finance-specific reading of the full schedule is on the UK SRS timeline for financial institutions page, and the standards themselves are explained on the IFRS S1/S2 hub.