UK SRS S1 Climate-Only Relief: How It Works and How Long Voluntary Reporters Can Use It

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

UK SRS S1 normally requires an entity to apply UK SRS S1 and UK SRS S2 at the same time. Paragraph E3 creates an exception: an entity may exclusively disclose information about climate-related risks and opportunities and may apply UK SRS S1 only to the extent relevant to that climate reporting. This is a scope provision, not a waiver of the climate requirements that remain applicable.

Paragraph E3 itself does not state that the provision expires after one reporting period. In finalising the UK standards, the UK Government retained the climate-only route for voluntary use without the one-year limit associated with the original international transition relief. The Financial Reporting Council has also stated in its current implementation FAQ that voluntary users can apply the relief indefinitely. That confirmation should be read together with paragraphs E5 and 73B: a future law, regulation or listing rule can determine whether the relief is available and on what terms for entities required to report.

It does not allow an entity to omit difficult or data-poor climate disclosures merely because they are inconvenient.

It does not turn a TCFD-style narrative, a carbon inventory or a climate questionnaire into a UK SRS S2 report automatically.

It does not remove the need for investor-focused materiality within the climate scope.

It does not remove the need to consider climate effects throughout the business model and value chain.

It does not create permission to claim compliance with UK SRS S1.

It does not override company law, listing rules or other reporting requirements that may require broader sustainability information.

Paragraph 73A requires the entity to disclose its use of paragraph E3 instead of asserting UK SRS S1 compliance. A robust Basis of Preparation should make the scope visible before users read the detailed climate disclosures. It should also prevent the annual report, website, press release and assurance report from implying a broader basis than the report actually uses.

Paragraph 72 allows an explicit and unreserved compliance statement only when the sustainability-related financial disclosures comply with all requirements of the UK Sustainability Reporting Standards being claimed. Paragraph 73A is more specific for E3: an entity using paragraph E3 is not permitted to assert compliance with UK SRS S1 and must disclose use of the provision instead. The restriction is therefore not a drafting preference or a conservative interpretation; it is part of the final standard.

Use of paragraph E3 does not, by itself, prevent an entity from asserting compliance with UK SRS S2. The entity still needs to satisfy all applicable S2 requirements and disclose use of E3 alongside the S2 compliance statement. Other S2 provisions that permit specified exclusions must also be disclosed when used. A report should therefore keep the S1 scope statement and the S2 compliance conclusion separate rather than compressing them into a vague sentence such as “compliant with UK SRS”.

Paragraph E4 provides a specific comparative path. In the first annual reporting period in which the entity applies the standards using E3, it is not required to provide comparative climate information. When it later ceases to use E3, it is not required to provide comparative information for non-climate sustainability-related risks and opportunities until the second annual reporting period after it stops using the provision. The team should document the transition schedule rather than assume that every metric and narrative must have a prior-year comparison immediately.

Decision and expansion path for a voluntary reporter using paragraph E3. The relief changes the claim and must be reassessed against future law or regulation.

The standards do not require a voluntary reporter to follow a prescribed multi-year expansion plan. Nevertheless, a roadmap reduces the risk that climate-only reporting becomes a permanent silo. A proportionate sequence is:

Adaptation warning: the final sentence is appropriate only after a complete UK SRS S2 compliance assessment. The wording should also be checked against the report location, applicable law or regulation, assurance scope and other public claims.

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

Implement: How to Prepare a UK SRS S1 Report - build the first-cycle reporting system.

Expand: How to Identify Sustainability-Related Risks and Opportunities Under UK SRS S1.

Decide: UK SRS S1 Materiality Assessment - determine what information is material within each approved scope.