UK FCA final policy on aligning listed issuers' sustainability disclosures with international standards

The UK Financial Conduct Authority (FCA) has published policy statement PS26/19, setting out its final rules to align listed issuers' sustainability and climate disclosures with UK Sustainability Reporting Standards (UK SRS), the UK-endorsed version of the International Sustainability Standards Board (ISSB) Standards. The final rules adopt a comply or explain approach across the UK SRS. The rules will replace the existing Task Force on Climate-related Financial Disclosures (TCFD)-aligned disclosures. Following feedback from the January consultation, the FCA has simplified the regime in two ways by requiring:

• a comply or explain approach across all categories of disclosures, bringing UK SRS S2 (climate disclosures) into line with the approach it consulted on for UK SRS S1 (non-climate disclosures) and Scope 3 (emissions data)
• international commercial companies with a secondary listing and depositary receipt issuers to also report against UK SRS on a comply or explain basis, in place of the consultation proposal to signpost any reporting requirements and disclosures under their home jurisdiction.

To support companies to apply the comply or explain rules, the FCA is also consulting on technical note (TN) 803.1 and related updates to existing technical guidance under TN 801.4, and the proposed deletion of TN 802.3. The proposals are outlined in the FCA's Primary Market Bulletin (PMB) 66. We cover PMB 66 separately in the Securities section above. The deadline for comments is 28 October and the FCA aims to finalise the guidance before the rules come into force.

The new rules will apply to accounting periods beginning on or after 1 January 2027, with first reporting due in 2028. Transitional reliefs will apply for one year for Scope 3 emissions disclosures and for two years for UK SRS S1 disclosures. The FCA also published some practical considerations in PMB 66 to support companies. The FCA also intends to organise a series of activities to help companies and investors understand the UK SRS and what is required under the rules.

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