Location · UKLR 6.6.6R(8)(c) · UK SRS S1 ¶¶B45–B47
UK SRS report structure: where the disclosures sit
A UK SRS report is rarely a separate booklet.
For a listed company it lives in the annual financial report, or is reached from it by a cross-reference that UK SRS S1 strictly conditions.
Two shapes
Integrated, or cross-referenced
All UK SRS disclosures sit inside the annual financial report, with the location statement pointing to the section.
The disclosures sit in a separate report published at the same time and on the same terms, reached by a cross-reference.
Source: UKLR 6.6.6R(8)(c); UK SRS S1 ¶¶B45–B47.
Either shape satisfies the rule; what changes is how a reader gets to the disclosures.
The rule text sits in UKLR 6.6 from 1 January 2027.
Conditions
When a cross-reference works
A cross-reference is not a way to publish later or more quietly.
The separate report must be available on the same terms and at the same time as the annual report.
And the cross-reference must not make the disclosures as a whole harder to follow.
| Condition | Why |
|---|---|
| Same terms as the financial report | A reader is not asked to do more to reach it |
| Same time as the financial report | Paragraph 64 still applies |
| Not less understandable | Fragmenting the disclosures defeats the purpose |
Alongside the Companies Act
The strategic report and liability
Many listed companies also have the Companies Act climate-related financial disclosures, which sit in the strategic report.
That is a separate legal duty, and UK SRS does not remove it.
The government’s consultation response discusses how UK SRS disclosures relate to that duty and to the liability rule for reports in section 463.
Disclosures placed inside the strategic report fall within that report’s liability regime; disclosures placed elsewhere should be checked against it.
For what goes inside the disclosures, see the report checklist.
Frequently asked
Questions people ask
Where do UK SRS disclosures go?
For a listed company in scope, in the annual financial report.
UKLR 6.6.6R(8)(c) asks the company to state where the disclosures can be found and allows them to be included by cross-reference to another report the entity publishes, on the terms UK SRS S1 sets in paragraphs B45 to B47.
Can UK SRS disclosures be in a separate sustainability report?
Yes, by cross-reference, if the conditions in UK SRS S1 are met: the other report is available on the same terms and at the same time as the general purpose financial report, and the cross-reference does not make the disclosures less understandable.
Can a UK SRS report be published after the annual report?
No. UK SRS S1 paragraph 64 requires the disclosures at the same time as the related financial statements.
The UK removed the first-year option in IFRS S1 to report later.
Does UK SRS replace the Companies Act climate disclosures?
No. The Companies Act climate-related financial disclosures in section 414CB are a separate legal duty with their own scope.
The government’s consultation response discusses how the two fit together; a company within both still has to satisfy both.
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.
- Department for Business and TradeUK SRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (25 February 2026)
¶¶60–63 on location; ¶¶B45–B47 on cross-reference; ¶64 on timing.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (25 February 2026)
The climate Standard, including Appendix C on transition.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards (30 September 2026)
The final rules: comply or explain across UK SRS for UKLR 6, 14, 15, 16 and 22.
- Financial Conduct AuthorityPS26/19 — full text, including the made instrument (UKLR 6.6.6R(7A), (7B), (8) and UKLR TP 16)
Scope, timing, reliefs and the rule text itself.
- Financial Conduct AuthorityFCA Handbook, UKLR 6.6 — annual financial report (as from 1 January 2027)
The rule the new disclosure limbs sit in.
- Financial Conduct AuthorityFCA Handbook, DTR 4.1 — the annual financial report within four months
Sets when the report carrying the disclosures must be public.
- legislation.gov.ukCompanies Act 2006, s.414CB — the non-financial and sustainability information statement
The separate Companies Act climate disclosure duty, which UK SRS does not replace.
- legislation.gov.ukCompanies Act 2006, s.463 — liability for false or misleading statements in reports
The liability rule for disclosures placed in the strategic report.
- legislation.gov.ukSI 2022/31 — Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022
Created the Companies Act climate disclosures for large companies and LLPs.
- Department for Business and TradeGovernment response to the consultation on UK SRS — web version
What changed between the exposure drafts and the final Standards, and why.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation (open to 30 November 2026)
Says only that the government will consider how UK SRS is reflected in the Companies Act.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — publication page
Where both Standards were published on 25 February 2026.