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Level 2 · Decision guide·UK SRS S1 · Disclosure guides

How to Prepare a UK SRS S1 Report: Complete Step-by-Step Guide

A controlled first-cycle method covering the reporting basis, materiality, risk and opportunity identification, governance, strategy, financial effects, metrics, data, controls, UK SRS S2, drafting and approval.

Who this is for A 14-minute read for reporting teams working through Running the reporting cycle and publishing the disclosures, and for reviewers testing whether the evidence behind it holds.

Published passport

Current as at 10 August 2026
RK Reviewed by Dr Ross KurinkoLinkedIn Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert 15+ years on FTSE 100 & Fortune Global 500 disclosures Canary Wharf, London LRA educational guidance · Not issued or endorsed by UK Government

Edition written against

UK SRS S1 (February 2026)

Principal paragraph anchors: UK SRS S1 paragraphs 1-4, 17-19, 20-24, 25-53, 54-59, 60-71, 72-86; Appendix B …

Published

10 Aug 2026

Knowledge Hub guide

Last reviewed

10 Aug 2026

Short answer

The answer, before the reasoning

Prepare a UK SRS S1 report as a controlled reporting system, not as a late drafting exercise. Fix the reporting basis and intended claim first; identify the complete population of sustainability-related risks and opportunities; assess investor-focused materiality; connect material matters to governance, strategy, risk management, financial effects, metrics and targets; apply UK SRS S2 at the same time unless paragraph E3 is used; build data and control evidence; then draft, challenge and approve a connected report published with the related financial statements.

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

Quick orientation

Quick orientation

Applies to
Entities voluntarily applying UK SRS S1, and teams preparing for a possible future mandatory route.
Primary decision
How to organise the first reporting cycle and retain enough evidence to support the final report and claim.
Key source
UK SRS S1, with UK SRS S2 for climate-related disclosures.
Common confusion
Treating UK SRS S1 as a disclosure checklist rather than an investor-focused reporting process connected to finance and governance.

Why the implementation sequence matters

UK SRS S1 asks for material information about sustainability-related risks and opportunities that could reasonably be expected to affect an entity’s prospects. That objective reaches across the business model, value chain, strategy, risk management, finance, data systems and governance. A report assembled only by collecting existing ESG text will usually miss one of three things: completeness of the risk and opportunity universe, connectivity to financial planning, or evidence supporting the published claim.

The most efficient approach is to design the reporting basis, decision records and control trail before writing narrative. The article below uses a twelve-month cycle, but the same stages can be compressed or extended. The critical point is sequence: scope before collection, identification before materiality, materiality before disclosure design, and evidence before approval.

Step 1 - lock the reporting basis and intended public claim

Create a short Basis of Preparation decision paper. It should identify the reporting entity, reporting period, standards and editions applied, whether application is voluntary or required by a specific route, the location of the disclosures, the intended compliance or alignment wording, reliefs expected to be used, and the approval body. The reporting entity should be the same as for the related financial statements, and the sustainability-related financial disclosures should cover the same reporting period and be published at the same time.

Do not leave the claim until the final legal review. A full UK SRS S1 compliance statement requires compliance with all applicable requirements. Climate-only use under paragraph E3 changes that outcome and must be designed into the basis from the start.

In practice

Basis field Decision to record Evidence
Reporting entity and period Group, parent-only or other permitted reporting entity; period aligned to financial statements Consolidation map, reporting calendar, finance sign-off
Standards and edition UK SRS S1 and S2 issued February 2026; any other basis separately identified Controlled source register and version record
Reporting route Voluntary application or specific future legal/regulatory route Legal and regulatory applicability note
Claim Full compliance, UK SRS S2 compliance with disclosed relief, or scoped reference wording Claim decision and approval record
Reliefs and limitations E3 and any other reliefs, data limitations and transition decisions Relief register and remediation plan

Step 2 - establish governance, ownership and project controls

Set a governance model that reflects how the organisation actually operates. Name the board or committee that oversees sustainability-related risks and opportunities, the executives accountable for the reporting process, the owners of each material risk or opportunity, data owners, preparers, reviewers and the final approver. Terms of reference, role descriptions, reporting calendars and information flows should support the governance disclosure rather than being created after the narrative is drafted.

Appoint one accountable reporting owner and a cross-functional steering group spanning sustainability, finance, risk, strategy, legal, company secretariat, investor relations and internal audit.

Create a RACI for identification, materiality, financial effects, metrics, controls, drafting, technical review and board approval.

Open a decision log, source register, risk and opportunity register, data and evidence register, relief register and issue log.

Define change control: who can change a methodology, boundary, estimate, target or claim, and what reapproval is required.

Step 3 - map the business model and value chain

The starting population is not a generic ESG topic list. Map the activities, products and services, geographies, assets, workforce, key customers and suppliers, distribution routes, financing relationships, joint ventures and other business relationships that shape cash generation. Then identify the resources and relationships the entity depends on and affects. UK SRS S1 makes clear that dependencies and impacts may exist throughout the value chain and can give rise to risks and opportunities for the entity.

The output should be a value-chain map at a level useful for decision-making, with known data gaps visible. It need not be a perfect end-to-end traceability exercise. The standard uses reasonable and supportable information available without undue cost or effort and does not require an exhaustive search. However, a team should not use that principle to ignore information already used in strategy, risk management, financial planning, procurement or operations.

Step 4 - identify sustainability-related risks and opportunities

Run structured identification workshops by business model and value-chain segment. Consider dependencies, impacts and external change; then trace each issue to a plausible effect on cash flows, access to finance or cost of capital over the short, medium or long term. Record both risks and opportunities. A positive initiative is not automatically an opportunity under UK SRS S1: the team needs a credible pathway to the entity’s prospects.

Internal inputs: enterprise risk register, strategy, budgets, capital allocation, asset reviews, procurement, workforce data, legal matters, customer insight, complaints and internal audit.

External inputs: law and policy, market and technology change, scientific and sector evidence, credit and insurance information, investor questions, peer experience and relevant statistics.

Value-chain inputs: supplier and customer concentration, location and commodity exposure, contractual dependencies, outsourced activities, product use and end-of-life effects.

Completeness challenge: sectors, geographies, time horizons and low-probability/high-impact outcomes that the first pass may have missed.

Step 5 - perform investor-focused materiality assessment

For each identified risk or opportunity, first identify the information that could be relevant under the specifically applicable UK SRS or the sources of guidance in UK SRS S1. Then assess whether that information, individually or in combination, is material in the context of the complete sustainability-related financial disclosures. The test is whether omission, misstatement or obscuring could reasonably be expected to influence the decisions of primary users.

Document both quantitative and qualitative factors. Consider the nature and magnitude of effects, the range and likelihood of uncertain outcomes, timing, aggregation and presentation. Do not apply one universal monetary threshold. A low-probability, high-impact outcome or highly scrutinised qualitative matter may be material even where a single expected-value figure is small.

Step 6 - apply UK SRS S2 and other disclosure sources

UK SRS S1 and UK SRS S2 are designed to be applied together. Unless the entity deliberately uses the climate-only provision in paragraph E3, UK SRS S1 covers all material sustainability-related risks and opportunities while UK SRS S2 supplies the climate-specific requirements. Climate identification, scenario analysis, resilience, greenhouse gas emissions, industry metrics and targets therefore need a dedicated workstream that remains connected to the S1 materiality, finance and governance decisions.

For non-climate matters without a specific UK SRS, apply the sources of guidance in paragraphs 54-59. The final UK standard permits, rather than requires, reference to SASB materials. Record which industry or other sources were used, why they are relevant, and what entity-specific information was added.

Step 7 - develop the four-pillar disclosure architecture

Design the outline around connected decisions, not around copying the order of standard paragraphs. For example, the material risk table should link to strategy responses, financial effects, metrics and the responsible governance body. Cross-references can reduce duplication, but only when they are precise, accessible, published at the same time and do not obscure material information.

In practice

Pillar Core work Evidence retained
Governance Oversight body, management roles, mandates, skills, information, decision frequency and links to remuneration where relevant Terms of reference, role descriptions, board papers, minutes, skills assessment
Strategy Material risks and opportunities, time horizons, business-model and value-chain effects, responses, financial effects and resilience Strategy papers, plans, scenario records, budget and valuation links, decision log
Risk management Processes to identify, assess, prioritise, monitor and integrate risks and opportunities Methodology, criteria, ERM mapping and review records
Metrics and targets Cross-industry, industry-based and entity-specific metrics; target design and progress Definitions, methods, source data, reconciliations, target approvals and change records

Step 8 - connect material matters to current and anticipated financial effects

Build a risk-to-finance bridge for every material risk and opportunity. Start with the operational or strategic pathway, identify affected revenue, costs, assets, liabilities, cash flows, access to finance or cost of capital, and then connect the analysis to budgets, forecasts, capital expenditure, impairment testing, provisions, useful lives, insurance, financing plans or other relevant financial processes. The analysis may be quantitative or qualitative depending on the facts and the reliefs in paragraphs 36-40, but the reason for any inability to quantify should be transparent.

Current financial effects: effects recognised or experienced in the reporting period.

Anticipated financial effects: possible effects over the entity’s defined time horizons.

Planning connection: assumptions, ranges and scenarios consistent, to the extent possible, with approved plans and the financial statements.

Uncertainty: methods, assumptions, limitations and significant estimation uncertainty clearly disclosed.

Step 9 - define metrics, targets and data lineage

Create a metric register before requesting data. For each metric, record the definition, unit, boundary, period, source, method, assumptions, estimates, responsible owner, reviewer, controls, target linkage, prior-period comparability and any restatement policy. Metrics from external sources should identify the source. Entity-developed metrics require enough explanation for users to understand what is measured and how.

Industry information is not optional merely because use of SASB materials is optional. UK SRS S1 requires metrics associated with the business models, activities or common features that characterise participation in an industry. The team should document the industry sources considered and the basis for selecting, adapting or rejecting candidate metrics.

Step 10 - design controls and assurance readiness

Apply a control framework proportionate to the risk of material misstatement. Core controls normally cover source-system access, completeness, methodology approval, calculation and model review, estimate governance, reconciliations, period and boundary checks, segregation of preparation and review, evidence retention, disclosure tie-outs, change control and management representations. Internal audit or an independent readiness review can test the design before year end.

Rule

Assurance is not the same as compliance

<p>UK SRS S1 does not impose a general requirement for independent assurance. A voluntary or future mandatory assurance engagement has its own subject matter, criteria, boundary, level and conclusion. The report should not imply that the whole UK SRS report was assured when only selected metrics were covered.</p>

Step 11 - draft a connected report and run technical challenge

Draft from approved registers and decision records. Use a Basis of Preparation, a material risk and opportunity overview, the four pillars, metric and target notes, judgements and uncertainty, relief disclosures and exact cross-references. Keep management information and public disclosure consistent, but do not publish confidential evidence merely to prove that a control exists.

Run at least three reviews: a technical claim review against the standards and source anchors; a finance and connectivity review against the annual report and financial statements; and a red-team review looking for omitted conditions, unsupported compliance language, obscured material information, inconsistent periods, weak evidence and overconfident examples.

Step 12 - obtain management and board approval

The final approval paper should state the exact documents and claim being approved, material judgements, reliefs, open limitations, financial-effect conclusions, control assessment, assurance scope, changes since committee review and conditions attached to approval. Named executive owners should provide representations over completeness and accuracy. The board should be able to explain not only what is disclosed, but how the organisation concluded that the report is complete and decision-useful.

A twelve-month reporting journey that keeps scope, materiality, finance, controls and approval connected. The sequence is illustrative and should be adapted to the entity's reporting timetable.

In practice

Illustrative twelve-month implementation plan

Month Primary work Key output / approval
1 Confirm reporting basis, standards, reporting entity, period, intended claim and project governance Approved project charter and Basis of Preparation decision
2 Map business model, value chain, source universe and existing processes Value-chain map, source register and gap inventory
3 Identify climate and other sustainability-related risks and opportunities Controlled risk and opportunity longlist
4 Challenge completeness across business units, geographies and time horizons Revised register and completeness sign-off
5 Assess investor-focused materiality and approve material matters Materiality matrix and decision records
6 Develop governance, strategy, risk-management and S2 workstreams Four-pillar disclosure plan and climate workplan
7 Define metrics, targets, industry information and data requests Metric register and data owner instructions
8 Build data lineage, evidence files, controls and remediation Evidence register, control matrix and issue log
9 Complete current and anticipated financial-effects analysis Risk-to-finance bridge and finance review
10 Draft report, Basis of Preparation, reliefs and cross-references First complete connected draft
11 Technical, finance, legal, controls and assurance-readiness challenge Resolved findings and final approval draft
12 Management representations, committee review, board approval and publication Approved report, claim and post-publication action plan

Hypothetical first-year scenario

Teaching point: the reporting system changed the answer. A pre-existing ESG content list would not have demonstrated completeness, financial connectivity or a supportable claim.

Hypothetical scenario

Illustrative example - diversified manufacturer

<p>A UK group decides to apply UK SRS S1 and S2 voluntarily. Its first topic list is dominated by carbon, waste and employee engagement. The value-chain review reveals additional exposure to water availability at two supplier clusters, product-safety regulation, specialised labour shortages and customer demand for lower-impact products. The team records the business pathway for each issue, assesses the related information for investor materiality and connects the material conclusions to procurement, capex, inventory strategy and workforce plans. Because data for one supplier cluster is incomplete, the report describes the estimation method, limitation and improvement plan rather than excluding the risk from the assessment.</p>

Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.

In practice

Common mistakes and corrections

Mistake Why it creates risk Correction
Starting with a disclosure checklist The population of risks and opportunities may be incomplete Map the business model and value chain, identify pathways, then assess material information
Treating climate as the whole of S1 without using E3 The report can omit material non-climate matters and overstate the claim Either apply full S1 scope or explicitly use and disclose the climate-only provision
Collecting every ESG metric Cost increases while material information may be obscured Define metrics from material risks, industry information and decision needs
Separating sustainability from finance until late drafting Financial effects and planning assumptions become generic or inconsistent Build a risk-to-finance bridge during assessment and planning
Using polished narrative as evidence Narrative does not prove the process, data or approval Retain source, method, owner, review, judgement and approval records
Leaving the compliance claim to the final day Reliefs and gaps may make the intended wording unavailable Design the claim and relief register at project inception and reassess throughout

Readiness

First-cycle readiness checklist

  • The reporting entity, period, standards, route, location and intended claim are approved.
  • Governance mandates and information flows match the disclosure.
  • The business model and value chain have been mapped at a decision-useful level.
  • A complete longlist of climate and other sustainability-related risks and opportunities has been challenged.
  • Materiality decisions consider nature, magnitude, likelihood, timing, aggregation and obscuring.
  • UK SRS S2 is integrated, or use of paragraph E3 is explicit and controlled.
  • Material matters link to strategy, financial effects, metrics, targets and owners.
  • Industry information and source choices are documented.
  • Data lineage, methods, estimates, controls and evidence are retained.
  • Reliefs, limitations, judgements and uncertainty are transparent.
  • The report has passed technical, finance, legal and red-team review.
  • Management representations and board approval cover the exact final claim and publication version.

Next steps and related learning

Next: UK SRS S1 Materiality Assessment - approve the material information decision method.

Apply: How to Identify Sustainability-Related Risks and Opportunities - build the controlled longlist and register.

Decision: UK SRS S1 Climate-Only Relief - determine whether a climate-first route is appropriate.

Review: Can You Claim UK SRS S1 Compliance While Using Climate-Only Relief? - approve the public wording.

Take it with you

The checklists as a working spreadsheet

Every checklist and table on this page, with empty status, owner and evidence columns for your team to fill in and keep.

Download .xlsx

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