GC26/6: Primary Market Bulletin No. 66

Key dates

2026-09-30

The FCA published GC26/6 and PS26/19; the consultation on the proposed Knowledge Base changes opened.

2026-10-28 Deadline

Deadline for comments on the proposed Technical Note 803.1, amendments to TN 801.4 and deletion of TN 802.3.

2027-01-01

The new UK SRS sustainability disclosure rules apply to accounting periods beginning on or after this date.

2029-01-01

The transitional reliefs for Scope 3 and UK SRS S1 disclosures are expected to fall away for accounting periods beginning on or after this date.

Suggested considerations

• Compliance teams may wish to review the proposed TN 803.1 and assess whether current annual-report processes can produce sufficiently specific explanations for each UK SRS disclosure that is omitted or only partially provided.
• Issuers should consider mapping existing TCFD disclosures, sustainability reporting and climate metrics against UK SRS S1 and UK SRS S2, identifying gaps in governance, strategy, risk management, metrics and targets.
• Issuers should consider establishing ownership, evidence trails and internal controls for Scope 3 data, transition-plan disclosures and explanations of non-compliance, including procedures for board or audit committee review.
• Listed companies may wish to assess whether they have published a climate-related transition plan and prepare the required statement on its existence and location, or the reasons why no plan has been published.
• Issuers should consider confirming whether third-party sustainability assurance has been obtained and how that status will be described in the annual financial report.
• Compliance teams may wish to plan for the transitional relief timetable, including the one-year Scope 3 deferral and two-year deferral for UK SRS S1 disclosures, while avoiding reliance on reliefs that will no longer be available for accounting periods beginning on or after 1 January 2029.
• Interested parties should consider submitting comments on the proposed Knowledge Base changes to the FCA by 28 October 2026.
• Legal, reporting and investor-relations teams may wish to monitor the final version of TN 803.1 before the new rules apply and update disclosure templates, reporting calendars and controls accordingly.

What changed

The FCA proposes to add Primary Market/TN/803.1, “UK SRS sustainability disclosures for listed companies”, explaining the expected level of detail where an issuer complies with, or explains non-compliance with, UK SRS requirements. It proposes consequential amendments to Primary Market/TN/801.4, “Disclosures in relation to sustainability matters, including climate change”, and deletion of Primary Market/TN/802.3, “TCFD aligned climate-related disclosure requirements for listed companies”. The underlying PS26/19 regime requires in-scope listed issuers to include UK SRS S1 sustainability-related disclosures and UK SRS S2 climate-related disclosures in their annual financial reports, or provide sufficiently detailed explanations of omissions, reasons and any steps being taken to comply in fut

Who is affected

• Companies with equity shares admitted to UK regulated markets under UKLR 6
• International commercial companies with a secondary listing under UKLR 14
• Issuers of certificates representing certain securities or depositary receipts under UKLR 15
• Issuers of non-equity shares and non-voting equity shares under UKLR 16
• Issuers in the equity shares transition category under UKLR 22
• UK-listed commercial companies preparing annual financial reports under the FCA’s new sustainability disclosure regime
• Auditors and sustainability assurance providers supporting in-scope listed issuers
• Investors and governance committees assessing listed issuers’ sustainability disclosures

Related regulations

• UK Listing Rules (UKLR) 6
• UK Listing Rules (UKLR) 14
• UK Listing Rules (UKLR) 15
• UK Listing Rules (UKLR) 16
• UK Listing Rules (UKLR) 22
• UK Sustainability Reporting Standards S1
• UK Sustainability Reporting Standards S2
• Task Force on Climate-related Financial Disclosures framework