UK SRS · Financial institutions

UK SRS for financial services: who is caught, and by what

UK SRS for financial services is not one rulebook: a bank, insurer, asset manager or pension scheme meets UK SRS through whichever of several regimes reaches it.

On 30 September 2026 the FCA published PS26/19, its final rules for listed companies: UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

For everyone else the standards remain available for voluntary use, and the defining disclosure for this sector is financed emissions.

Who is caught →Read the FAQ

Checked against 18 sources fromFinancial Conduct AuthorityDepartment for Business and Tradelegislation.gov.ukPrudential Regulation AuthorityPCAF (standard-setter, not a regulator)GHG Protocoland 2 moreSee the sources

Scope

Three routes in, and none of them is “the sector”

No instrument applies UK SRS to financial services as a sector.

The Department for Business and Trade issued UK SRS S1 and UK SRS S2 on 25 February 2026, and neither standard contains an effective date.

A requirement to use them has to come from the Companies Act, the FCA or another regulator, and only the FCA has made one.

The FCA’s rules follow the listing, not the business model: a bank or insurer is caught as a listed issuer, on the same footing as any other listed company.

The second route is existing company law, which already names banks and insurers.

Section 414CA of the Companies Act 2006 lists banking companies, authorised insurance companies and companies carrying on insurance market activity among those that must include a non-financial and sustainability information statement, each subject to a more-than-500-employee test and the small and medium-sized exclusions.

Section 414CB(A1) requires that statement to contain climate-related financial disclosures, and the government has confirmed that UK SRS S2 is a national reporting framework for section 414CB(6).

The general scope rules for every sector, including private companies, are set out in the companion guidance on who must comply with UK SRS.

Quick scope test

If you are…	What reaches you
A listed bank, insurer or asset manager (UKLR 6, 14, 15, 16 or 22)	FCA PS26/19: UK SRS on comply-or-explain from periods beginning 1 January 2027
A large banking or insurance company, listed or not	Companies Act ss.414CA–414CB climate-related financial disclosures, in force since 2022
An asset manager or asset owner with £5bn or more	FCA ESG 2 TCFD entity report; simplified product-level rules from 25 September 2026
An occupational pension scheme	SI 2021/839, the trustees’ own climate regime

Our summary of the instruments cited on this page, as at 30 September 2026.

The FCA’s final rules

PS26/19: comply-or-explain, not mandatory climate reporting

The FCA consulted in January 2026 on making UK SRS S2 climate disclosures mandatory for listed companies.

The rules it published on 30 September 2026 take a different line.

Sources: FCA CP26/5; FCA PS26/19.
Question	CP26/5 (January 2026, proposed)	PS26/19 (30 September 2026, final)
UK SRS S2 climate disclosures	Mandatory, except Scope 3	Comply or explain, ¶1.7
Scope 3	Comply or explain, one-year relief	Comply or explain, one-year relief (¶3.14)
UK SRS S1 non-climate	Comply or explain, two-year relief	Comply or explain, two-year relief (¶3.14)
Secondary listing and depositary receipts (UKLR 14, 15)	A statement about overseas standards, no UK SRS	Report against UK SRS on comply-or-explain (¶3.6)
Closed-ended funds and OEICs (UKLR 11, 12)	Excluded	Excluded — obligations sit with the asset manager (¶3.7)
First accounting periods	Beginning on or after 1 January 2027	Beginning on or after 1 January 2027, first reporting in 2028 (¶3.12)

In the consultation the FCA estimated that around 600 listed companies would be affected (CP26/5 Annex 2 ¶43).

PS26/19 does not restate a total, and that estimate described a proposal that has since changed shape.

Where a company does not report in accordance with UK SRS, the FCA’s view is that a proportionate explanation of its reasoning and judgement can itself be useful to investors (PS26/19 ¶1.3).

The FCA has said it will keep the requirements under review, including the case for going further (¶2.84).

The defining disclosure

Financed emissions: the number that makes this sector different

For an industrial company, climate reporting starts with its own operations.

For a financial institution the material figure is its portfolio: the emissions of the companies it lends to, invests in and insures.

UK SRS S2 paragraph 29(a)(vi)(2) asks for additional information about financed emissions, which are part of Scope 3 Category 15, where an entity’s activities include asset management, commercial banking or insurance.

Emissions are measured under the GHG Protocol Corporate Standard unless a jurisdictional authority requires otherwise.

Paragraph 29A, part of the ISSB’s December 2025 amendments carried into UK SRS S2, lets an entity limit Category 15 to financed emissions and exclude emissions attributable to derivatives.

UK SRS S2 names no methodology, but asks the entity to disclose the one it used; most institutions use the PCAF Financed Emissions Standard, whose third edition was published in December 2025.

The arithmetic — attribution factors by asset class and the data-quality score — is covered on the financed emissions reporting and Scope 3 Category 15 pages, with the standard itself on the PCAF standard in the UK page.

The one place UK SRS asks for more

Paragraph B59A is the only UK change that is stricter than IFRS S2.

If an entity cannot reliably estimate financed emissions for the same period as its financial statements, it must say why, disclose its approach, and give a plan with a timeline to align the periods.

UK SRS S2 on financed emissions

¶29(a)(vi)(2)
The trigger
Additional information if activities include asset management, commercial banking or insurance.
¶29A
The boundary
Category 15 may be limited to financed emissions; derivatives may be excluded.
¶¶B61–B63A
The detail by activity
Gross emissions, exposure and coverage, by industry and asset class.
¶B59A
The UK addition
Explain, and plan to fix, any period mismatch.

Source: UK SRS S2

By sub-sector

The same standard, four different burdens

A retail bank, a life insurer, a fund manager and a pension scheme face different versions of the question, because different regimes and different paragraphs reach them.

Sources: UK SRS S2; SI 2021/839; FCA ESG 1A.1.
Sub-sector	UK SRS S2 financed emissions	Other regimes that already bind
Banks	Commercial banking, ¶¶B62–B62A: by industry and asset class, with gross exposure and coverage	ss.414CA–414CB if large; PRA SS5/25 expectations; the FCA anti-greenwashing rule
Insurers	Insurance, ¶¶B63–B63A: the investment portfolio, not the underwriting book	ss.414CA–414CB if large; PRA SS5/25; FCA ESG 2 for life insurers as asset owners
Asset managers	Asset management, ¶B61: gross emissions and the share of assets under management covered	FCA ESG 2 TCFD entity report at £5bn; SDR labels and naming rules
Pension schemes	Not reached — trustees are not listed issuers	SI 2021/839: TCFD-aligned trustee reports, enforced by the Pensions Regulator

Prudential

PRA SS5/25

Expectations on climate risk management for banks and insurers since 3 December 2025; it creates no disclosure duty.

Conduct

The anti-greenwashing rule

Binds every FCA-authorised firm on product claims — see the anti-greenwashing rule.

Products

SDR labels

Four labels a qualifying fund manager may use — see the SDR investment labels.

Asset owners

FCA 2026/59

Product-level TCFD reports simplified from 25 September 2026 (Handbook Notice 144).

Timing

What happens when

The standards exist now, and the listing rules that apply them are final.

PS26/19 paragraph 3.12 applies the rules to accounting periods beginning on or after 1 January 2027, with first reporting in 2028.

It keeps a one-year transitional relief for Scope 3 disclosures — financed emissions included — and a two-year relief for UK SRS S1.

A relief is not a holiday: a financed-emissions figure for a December 2028 year end needs counterparty data collected across 2028, and the attribution method settled before that.

Firms weighing outside support for that work can start from the uksrs.org.uk guide to ESG consulting services.

The standards themselves, and how UK SRS differs from IFRS S1 and S2, are explained in our guide to IFRS S1 and S2, and the clause-level text of the climate standard is in the UK SRS S2 reference.

25 Feb 2026
UK SRS S1 and S2 issued
Available for voluntary use by any entity.
30 Sep 2026
FCA PS26/19 published
Final comply-or-explain rules for listed issuers.
1 Jan 2027
First accounting periods
Periods beginning on or after this date; Scope 3 relief for the first year, S1 relief for two.
2028
First reports
The FCA expects first reporting in 2028.

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

Assurance and transition plans

Two statements, neither of them a mandate

PS26/19 does not require sustainability assurance.

A listed company must state whether it has obtained third-party assurance and, if it has, name the provider, say which disclosures were assured and name the assurance standards used (PS26/19 ¶2.45).

It does not have to explain the absence of assurance (¶2.51).

The FRC issued ISSA (UK) 5000 on 12 November 2025 for voluntary use, effective for periods beginning on or after 15 December 2026; the FCA’s rules name no assurance standard.

On transition plans, a listed company must disclose whether it has published a climate-related transition plan, or state why not (PS26/19 ¶¶2.37–2.38); no UK law requires a firm to have one.

A disclosure plan for a specific institution is worth talking through with someone who knows its book; you can book a free 15-minute call.

Not advice

This page is an independent reference, not legal, regulatory or investment advice.

Check the FCA’s made rules and your own counsel before relying on any date or scope statement here.

Frequently asked

Questions people ask

Is UK SRS mandatory for banks and insurers?

Not as a sector rule. UK SRS S1 and S2 were issued on 25 February 2026 for voluntary use by any entity. A bank or insurer is caught only if it is a listed company: on 30 September 2026 the FCA published PS26/19, which requires listed companies in UK Listing Rules categories 6, 14, 15, 16 and 22 to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. An unlisted bank or insurer is outside those rules, though a large one already makes climate-related financial disclosures under the Companies Act.

What did the FCA decide in PS26/19?

The FCA moved to a comply-or-explain approach across every category of UK SRS disclosure, including climate. CP26/5 had proposed mandatory UK SRS S2 climate reporting with comply-or-explain only for Scope 3 and UK SRS S1. The final rules apply to accounting periods beginning on or after 1 January 2027 with first reporting in 2028, and keep a one-year relief for Scope 3 and a two-year relief for UK SRS S1.

Which banks and insurers already report climate risk under UK law?

Section 414CA of the Companies Act 2006 brings banking companies, authorised insurance companies, companies carrying on insurance market activity, traded companies, AIM companies and high-turnover companies (over £500 million) into the non-financial and sustainability information statement. Each must also have more than 500 employees and must not be small or medium-sized. Section 414CB(A1) then requires that statement to contain climate-related financial disclosures, and UK SRS S2 is a national reporting framework for section 414CB(6).

What are financed emissions under UK SRS S2?

They are the part of an investee’s or counterparty’s gross greenhouse gas emissions attributed to the entity’s loans and investments, and they sit in Scope 3 Category 15. UK SRS S2 paragraph 29(a)(vi)(2) asks for additional information about them where an entity’s activities include asset management, commercial banking or insurance, with the detail in paragraphs B59 to B63A.

Does UK SRS S2 require insurance-associated or facilitated emissions?

No. Paragraph 29A permits an entity to limit Scope 3 Category 15 to its financed emissions and to exclude emissions attributable to derivatives. PCAF publishes separate methods for facilitated emissions (Part B) and insurance-associated emissions (Part C) for firms that choose to report them.

Is UK SRS stricter than IFRS S2 for financial institutions?

In one place. UK SRS S2 paragraph B59A, which IFRS S2 does not have, requires an entity that finds it impracticable to reliably estimate financed emissions for the same reporting period as its financial statements to explain why, disclose the approach it used, and set out a plan with a timeline to align the periods. Every other UK change to the ISSB text is permissive.

Is sustainability assurance mandatory for listed financial institutions?

No. PS26/19 requires a listed company to state whether it has obtained third-party assurance and, if it has, to name the provider, which disclosures were assured and the assurance standards used. It need not explain why it has no assurance. ISSA (UK) 5000, issued by the FRC on 12 November 2025, is available for voluntary use.

Do pension schemes report under UK SRS?

No. Trustees of large occupational pension schemes report under their own regime, the Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021, enforced by the Pensions Regulator. The FCA’s listing rules reach listed companies, not trust-based schemes.

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.

Financial Conduct Authority
PS26/19 — Aligning listed issuers’ sustainability disclosures with international standards (September 2026)
¶1.7 comply-or-explain across all categories; ¶3.6 categories; ¶3.12 periods from 1 January 2027, first reporting 2028; ¶3.14 Scope 3 and S1 reliefs; ¶2.45 assurance statement.
Financial Conduct Authority
PS26/19 landing page — first published 30 September 2026
The publication date and the FCA’s own summary of the final rules.
Financial Conduct Authority
CP26/5 — Aligning listed issuers’ sustainability disclosures with international standards
The January 2026 proposals; Annex 2 ¶43 estimated that around 600 listed companies would be affected.
Department for Business and Trade
UK SRS S1 and UK SRS S2 — publication page (25 February 2026)
The two standards, issued by the Secretary of State for Business and Trade.
Department for Business and Trade
UK Sustainability Reporting Standards — guidance
“The standards are available for voluntary use, by any entity that chooses to do so.”
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; the Category 15 limitation; ¶B59A.
Department for Business and Trade
UK SRS consultation response, Chapter 3 and Annex A
UK SRS S2 is a national reporting framework for s.414CB(6); ¶B59A is the one UK addition.
legislation.gov.uk
Companies Act 2006, section 414CA — who must include the statement
Banking and insurance companies among the categories; the 500-employee and size gates.
legislation.gov.uk
Companies Act 2006, section 414CB — climate-related financial disclosures
(A1) the duty; (2A)(a)–(h) the eight disclosures; (6) national reporting frameworks.
Prudential Regulation Authority
SS5/25 — Enhancing banks’ and insurers’ approaches to managing climate-related risks
Commenced 3 December 2025 and replaced SS3/19 in its entirety; supervisory expectations, not a disclosure rule.
Financial Conduct Authority
FCA Handbook ESG 1A.1 — application of ESG 2 and the £5bn exemption
Asset managers and asset owners in scope of TCFD entity reporting.
Financial Conduct Authority
FCA Handbook ESG 2.3 — product-level reporting, as amended 25 September 2026
ESG 2.3.1BR (retail) and ESG 2.3.5AR (institutional data on request).
Financial Conduct Authority
Handbook Notice 144 (September 2026), ¶1.3 and ¶¶2.24–2.26
FCA 2026/59, following CP26/17, in force 25 September 2026.
legislation.gov.uk
SI 2021/839 — Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021
The separate trustee regime for occupational pension schemes.
PCAF (standard-setter, not a regulator)
Financed Emissions, Part A, third edition (December 2025)
Attribution factors by asset class; data-quality scores 1 (highest) to 5 (lowest).
GHG Protocol
Corporate Accounting and Reporting Standard
The measurement basis UK SRS S2 ¶29(a) refers to.
IFRS Foundation
IFRS Sustainability Standards Navigator
IFRS S1 and IFRS S2, the ISSB standards UK SRS endorses.
Financial Reporting Council
Assurance standards — ISSA (UK) 5000 (12 November 2025)
Issued for voluntary use; effective for periods beginning on or after 15 December 2026.