PS26/19: Aligning listed issuers' sustainability disclosures with international standards

Key dates

2026-09-30

FCA published PS26/19 and the final UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026.

2026-10-28 Deadline

Deadline for responses to the FCA consultation on the proposed Technical Note supporting proportionate application of the comply-or-explain approach.

2027-01-01 Deadline

The final rules and UKLR TP 16 transitional provisions commence; they apply to accounting periods beginning on or after this date.

2028-01-01

First reporting year expected for issuers whose accounting periods begin on or after 1 January 2027, subject to the applicable accounting year-end and transitional reliefs.

2029-01-01 Deadline

For accounting periods beginning on or after this date, the Scope 3 and wider S1 climate-first transitional reliefs have expired and the full UK SRS comply-or-explain framework applies.

Suggested considerations

• Listed issuers should map their listing category to the applicable rules in UKLR 6.6, 14.3, 15.3, 16.3 or 22.2 and confirm whether any investment entity, shell-company or other exclusion applies.
• Compliance and reporting teams should perform a gap assessment against UK SRS S1 and UK SRS S2, including governance, strategy, risk management, metrics and targets, greenhouse-gas emissions and material sustainability-related risks and opportunities.
• Issuers should establish a documented comply-or-explain process capable of identifying each omitted or partial disclosure, the reason for the omission and the remediation steps planned.
• Finance and sustainability teams should plan for the one-year Scope 3 relief and the two-year S1 climate-first relief, including the required statement that the relevant UKLR and UK SRS transitional provisions are being used.
• Issuers should assess whether UK SRS disclosures can be incorporated by cross-reference under UK SRS S1 Appendix B paragraphs B45 to B47 and ensure referenced documents are accessible and consistently controlled.
• Governance teams should decide whether third-party assurance will be obtained and prepare the required assurance-provider, scope, level, standards and accessibility disclosures where assurance is used.
• Issuers should document their position on climate-related transition plans and prepare the required location statement or explanation for non-publication.
• Reporting teams should plan comparative information: no comparative information is required for the first period in which full or partial UK SRS disclosures are made, but comparatives are required from the immediately following accounting period.

What changed

The rules amend the FCA Handbook, including UKLR 6.6, 14.3, 15.3, 16.3 and 22.2, and ESG 2.2.6R. They require in-scope issuers to include UK SRS S2 climate-related disclosures and UK SRS S1 sustainability-related disclosures in their annual financial reports, or provide specified explanations where disclosures are absent or incomplete. Those explanations must identify the requirements or risks and opportunities not covered, explain why, and describe steps being taken or planned to enable future disclosure. The comply-or-explain approach applies across the framework, including Scope 3 emissions and wider S1 disclosures. A one-year transitional relief applies to Scope 3 disclosures for accounting periods beginning on or after 1 January 2027 but before 1 January 2028; a two-year climate-first

Who is affected

• UK-listed companies in the Equity Shares (Commercial Companies) category under UKLR 6
• International commercial companies with secondary listings under UKLR 14
• Depositary receipt issuers subject to UKLR 15.3 and the UKLR 14.3 framework
• Issuers of non-equity shares or non-voting equity shares under UKLR 16
• Issuers in the Equity Shares (Transition) category under UKLR 22

Related regulations

• UK Listing Rules (UKLR) 6.6, 14.3, 15.3, 16.3 and 22.2
• UKLR TP 16
• Environmental, Social and Governance sourcebook (ESG) 2.2.6R
• ESG TP 2
• UK Sustainability Reporting Standard S1
• UK Sustainability Reporting Standard S2
• ISSB IFRS S1 and IFRS S2
• TCFD-aligned FCA listing rules