Can You Claim UK SRS S1 Compliance While Using Climate-Only Relief?

Educational practitioner material. Illustrative examples and wording require adaptation and technical review.

Paragraph 72 establishes the general rule: an entity may make an explicit and unreserved statement of compliance only when its sustainability-related financial disclosures comply with all requirements of the UK Sustainability Reporting Standards being claimed. The paragraph also prohibits describing disclosures as complying unless that condition is met.

Paragraph 73A then addresses paragraph E3 specifically. It says that an entity using E3 is not permitted to assert compliance with UK SRS S1 and must disclose its use of the provision instead. The same paragraph preserves a possible UK SRS S2 claim, but only if the S2 requirements are otherwise met and the use of E3 and any relevant S2 exclusions is disclosed alongside the statement.

An explicit statement names the standard and makes the conclusion clear. An unreserved statement does not quietly qualify compliance through broad caveats, unexplained exclusions or contradictory wording elsewhere. A sentence such as “compliant with UK SRS S1 except for non-climate matters” is not a permissible way to convert E3 use into S1 compliance. The exception is the reason the S1 claim is unavailable.

The compliance conclusion should be consistent across the complete publication ecosystem: Basis of Preparation, standards index, directors’ approval paper, annual-report contents page, assurance report, investor presentation, website, press release, tender response and AI-generated summaries. A correct sentence in the report does not neutralise a broader unsupported claim in the headline or website metadata.

Claim hierarchy when paragraph E3 is used. The wording should never exceed the reporting basis and evidence actually supported.

The entity should adapt the statement for its reporting route, period, location, any S2 provisions used, and the scope of any assurance. It should not insert the bracketed S2 conclusion merely because the report is “substantially aligned” or contains the four pillars.

UK SRS does not prescribe a formal “with reference to” category equivalent to a compliance statement. In practice, an entity may use ordinary factual wording to explain that selected concepts, requirements or metrics informed a report. That wording should name the content used, identify material departures or limitations and avoid suggesting that the standard-setter has recognised an intermediate status.

UK SRS S1 and IFRS S1 are closely based on the same global architecture, but their transition provisions are not identical. IFRS S1 permits climate-only reporting as a transition relief in the first annual reporting period in which the entity applies IFRS S1. The final UK SRS E3 route has no fixed voluntary time limit at this review date. A company using UK E3 for more than its first year should not assume that its UK reporting basis also supports an IFRS S1 compliance statement.

Even in the first year, the entity should test the two standards separately. It should document the editions applied, the reporting period, the transition provisions used, UK amendments, sources of guidance and every difference affecting the claim. A single statement such as “complies with UK SRS and IFRS Sustainability Disclosure Standards” is available only if both complete assessments support it.

Decision: UK SRS S1 Climate-Only Relief - confirm availability and annual reassessment.

Implement: How to Prepare a UK SRS S1 Report - build the evidence and approval process.

Assess: UK SRS S1 Materiality Assessment - support the completeness and disclosure decisions behind the claim.

Expand: How to Identify Sustainability-Related Risks and Opportunities - move from climate-only to full S1 scope.