UK SRS: what "comply or explain" means if you're not listed

The Financial Conduct Authority has settled how UK listed companies will report sustainability information. From accounting periods starting on or after 1st January 2027, they must follow the UK Sustainability Reporting Standards, or explain clearly why they haven't. First reports land in 2028.

That sounds like a London Stock Exchange story. For most of the businesses I talk to, it isn't a legal duty at all. You're not listed, so these rules don't land on your annual report.

What does change is the people you sell to and borrow from. Listed customers and larger lenders will be building climate disclosures for investors. Their own emissions come first. The emissions in their supply chain, which often means you, follow from 2028. When a big customer or a bank asks for your carbon numbers, that is usually why.

"Comply or explain" is not a free pass. Listed firms still have to give investors a proper account of what they're doing, or a proper reason why not. The FCA is consulting on guidance for those explanations until 28th October 2026, the same day as the Autumn Budget.

Private companies are still waiting for a separate government decision. For now, if you already do SECR, ESOS or a Carbon Reduction Plan, keep that data tidy. If you don't, a clear footprint and a short plan is fast becoming expected for bigger contracts.

If you'd like a plain sense-check of what you need (and what you don't), I'm happy to talk it through.

Source: FCA PS26/19