UK SRS S1 Company-Specific Disclosures: What to Do When No Dedicated Standard Exists

Technical status. UK SRS S1 and UK SRS S2 were published for voluntary use on 25 February 2026. At the date of review, climate is addressed by the dedicated UK SRS S2; other topics may require entity-specific judgement under UK SRS S1.

Limitation. Educational material. Examples are hypothetical and do not prescribe disclosures or metrics for a real entity.

UK SRS S1 is a general-requirements standard. Its purpose is to support complete sustainability-related financial disclosures even where the UK has not issued a topic-specific standard.

A common first-year mistake is to treat the absence of a dedicated standard as a gap that can be left blank. The opposite is true: the entity must do more documented judgement. It needs to identify what information primary users need to understand the governance, strategy, risk-management process, metrics and targets associated with a material risk or opportunity.

The practical challenge is to avoid two extremes:

generic narrative, which says the entity “manages” an issue without explaining exposure, performance or financial consequences; and

uncontrolled bespoke metrics, which may be precise internally but cannot be understood, compared or verified externally.

The answer is a company-specific disclosure architecture with a clear information need, stable methodology and evidence trail.

Where no dedicated standard applies, paragraph 57 requires the entity to identify information that:

is relevant to users' decisions; and

faithfully represents the sustainability-related risk or opportunity.

This judgement is made within the wider architecture of UK SRS S1. The entity must still provide material information about:

governance;

strategy, including current and anticipated financial effects;

risk-management processes; and

metrics and targets.

Paragraph 46 requires metrics the entity uses to measure and monitor the risk or opportunity and performance. Paragraph 48 requires industry-associated metrics. Paragraph 49 requires identification of an external source and metric. Paragraph 50 governs an entity-developed metric.

UK SRS S1 does not prescribe:

a universal template for company-specific disclosures;

one metric for every sustainability topic;

a fixed number of narrative or quantitative datapoints;

automatic use of every metric in SASB, GRI, ESRS or another framework;

a requirement to invent a precise number where the evidence cannot support it; or

permission to omit a material issue because measurement is difficult.

The entity's judgement therefore needs to be visible, not hidden behind a generic policy statement.

Stage 1 — define the primary-user information need

Start with the material sustainability-related risk or opportunity and the decision it could influence.

Ask:

1. What could affect cash flows, access to finance or cost of capital?

2. Which part of the business model, value chain, geography or asset base is exposed?

3. What does management need to know to allocate capital, set risk appetite or monitor performance?

4. What information would help a primary user understand exposure, response and progress?

5. What would be misleading if omitted or aggregated?

Write a one-sentence information need statement. For example:

This is more useful than beginning with a generic question such as “Which human-capital KPIs should we disclose?”

Stage 2 — design the disclosure architecture

A company-specific disclosure should normally answer a sequence of questions:

Governance: who oversees the issue, what information they receive and what decisions they make;

Strategy: how the risk or opportunity affects the business model and prospects, and how the entity is responding;

Risk management: how the issue is identified, assessed, prioritised, monitored and integrated with overall risk management;

Metrics and targets: how exposure, performance and progress are measured;

Judgements and uncertainty: which assumptions, estimates and limitations materially affect the information.

Not every section needs equal length. The design should follow the information need rather than reproduce headings mechanically.

Stage 3 — choose the construct to measure

Before choosing a unit, decide what type of fact the metric represents.

Input and activity metrics are often easier to measure but can be poor substitutes for outcomes. A strong disclosure explains why the selected construct represents the material risk or opportunity.

Stage 4 — build the metric specification

For every company-specific metric, define:

name and purpose;

numerator, denominator and unit;

qualitative scale, if applicable;

reporting entity and value-chain boundary;

period and frequency;

source systems and data owners;

formula and transformations;

estimates, assumptions and factors;

exclusions and limitations;

validation and review controls;

comparative treatment;

target linkage; and

change-control requirements.

Paragraph 50 requires disclosure of the definition, nature, validation, method, inputs, limitations and significant assumptions. The internal specification should be more detailed than the published note.

Figure 1. Eight design fields turn a reporting need into a controlled entity-specific metric. Original London Reporting Academy practitioner visual.

Stage 5 — test comparability and decision usefulness

A company-specific metric can still be comparable. Comparability does not require identical measures across every entity. It requires sufficient consistency and explanation for users to understand similarities and differences.

Test:

whether the definition is stable over time;

whether a common industry unit or denominator can be used;

whether the metric can be reconciled to regulatory or peer information;

whether historical data can be reconstructed reliably;

whether the metric is disaggregated at the level users need;

whether changes are transparent; and

whether the measure is balanced rather than designed to show only favourable activity.

Where a standard external metric is close but not suitable, consider adapting it. Identify the source and explain the difference, as paragraph 50(a) requires.

Stage 6 — design the evidence and control chain

Assurance readiness should begin when the metric is designed.

The evidence chain normally includes:

1. source population and data extraction;

2. controlled definition and boundary;

3. calculation or model;

4. estimates, assumptions and uncertainty;

5. reconciliation and validation controls;

6. management review and materiality challenge;

7. governance approval; and

8. published disclosure and source note.

For narrative information, the evidence may include policies, minutes, risk assessments, plans, investment approvals, incident records and management reports. A narrative claim such as “the programme reduced disruption” needs outcome evidence, not only proof that the programme occurred.

Figure 2. A company-specific disclosure is supported by a traceable path from source population to published claim. Original London Reporting Academy practitioner visual.

Stage 7 — approve the judgement and manage changes

Paragraphs 74-75 require disclosure of significant judgements, including judgements about sources of guidance and material information. Paragraphs 77-82 require information about significant measurement uncertainty.

The approval record should show:

why no dedicated UK SRS or suitable external metric fully addressed the information need;

why the chosen disclosure is relevant and faithfully representative;

which sources were considered;

materiality and aggregation decisions;

significant estimates and uncertainties;

why the metric is comparable enough to be useful;

who prepared, challenged and approved it; and

what events trigger reassessment.

Cyber resilience

A digital-services entity may identify a material risk that critical third-party outages could disrupt revenue and customer service. A company-specific metric might measure the proportion of critical services with tested recovery within a defined time, disaggregated by dependency type. The disclosure should explain testing scope, failed tests, exclusions and the connection to financial exposure.

Workforce capability

A professional-services group may disclose the percentage of revenue-generating roles in defined critical-skill categories that have adequate succession and retention coverage. The metric needs a controlled definition of “critical skill”, the population, coverage threshold and limitations.

Water dependence

A manufacturer may develop a metric for production value located in catchments where water availability could constrain operations under defined planning conditions. The design should separate physical exposure from actual withdrawal and explain scenario and site assumptions.

Product safety and customer trust

A consumer-products entity may disclose the rate of material product-safety incidents per unit sold, time to corrective action and revenue associated with affected product lines. Regulatory definitions may provide a starting point but may require adaptation to the reporting boundary.

Artificial-intelligence governance

A technology entity may identify a material opportunity and risk relating to deployment of high-impact AI systems. Company-specific information might cover the population of systems within a defined risk taxonomy, completion of independent review, unresolved high-severity findings and revenue exposure. The entity should avoid implying that completion of a review proves the absence of harm.

Context. An engineering group has a large infrastructure order book and depends on specialist design engineers. Management believes skills shortages could delay delivery and increase contractor costs.

Information need. Users need to understand the scale of the exposure, the effectiveness of the response and the financial consequences.

Sources considered. The team considers SASB human-capital metrics, workforce information reported by peers, UK labour-market statistics and selected GRI/ESRS workforce data. No external metric captures the group's specific project and skill structure.

Metric designed. The group develops “critical work packages without confirmed internal or contracted skill coverage within the next 18 months”, expressed as a percentage of forecast project value. It discloses the definition of critical work package, the 18-month horizon, treatment of contractors, planning assumptions and limitations.

Supporting metrics. It also discloses turnover in critical roles, vacancy duration and training completion, but explains that these are supporting indicators rather than the main exposure measure.

Governance. The metric is reconciled to the project-planning system, reviewed by HR and finance, challenged by risk, and approved by the audit committee.

Limitation. This is an illustrative design. It is not a model metric for all engineering companies.

Why it is stronger: the wording identifies the metric, period, comparative, boundary, data source, management use, assumptions and limitation.

Evidence required: controlled project population, role taxonomy, workforce data, contractor evidence, calculation, reconciliation, review and approval.

1. Treating the absence of a standard as an omission reason

Correction: apply paragraph 57 and build entity-specific information for every material risk or opportunity.

2. Selecting an easy activity metric instead of the material outcome

Correction: identify the risk pathway and distinguish input, activity, output, outcome and financial effect.

3. Designing the metric after the report is drafted

Correction: establish definition, source, controls and owner before the reporting period closes.

4. Using an internal KPI without reconciling the reporting boundary

Correction: compare management and UK SRS populations, periods, units and exclusions.

5. Hiding the methodology to protect “proprietary” information

Correction: protect genuinely sensitive detail while disclosing enough for users to understand and compare the metric.

6. Claiming effectiveness from activity evidence

Correction: distinguish implementation evidence from outcome evidence and avoid unsupported causality.

7. Ignoring comparatives and change control

Correction: design the current-year metric as the future comparative and apply paragraphs 52, 70 and B49-B54 when it changes.

Paragraphs 25-44: governance, strategy and risk management.

Paragraphs 45-53: metrics and targets.

Paragraphs 54-59 and Appendix C: sources of guidance.

Paragraph 70 and B49-B54: comparatives and metric changes.

Paragraphs 74-82: judgements and measurement uncertainty.

Appendix D: qualitative characteristics of useful information.