Can a Company Claim Both UK SRS S1 and IFRS S1 Compliance?

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London Reporting Academy · Working publication package · 2 August 2026

A statement of compliance is not a general description of alignment. Both UK SRS S1 paragraph 72 and IFRS S1 paragraph 72 use an all-requirements threshold: an entity makes an explicit and unreserved statement only when its sustainability-related financial disclosures comply with all requirements of the relevant standards. The statement therefore sits at the end of the reporting process, after scope, materiality, sources of guidance, disclosures, reliefs, comparatives and publication controls have been tested.

Because UK SRS S1 was developed from IFRS S1, a large proportion of the work can be common. However, a dual claim requires the team to identify every UK amendment and to determine whether the chosen UK treatment also meets IFRS S1. The safest operating assumption is non-identity until the gap assessment proves otherwise.

The first question is not whether the report looks similar to IFRS S1. It is whether the entity has applied IFRS S1 and IFRS S2 together, subject to the IFRS transition provisions, and met every applicable requirement. The second question is whether it has applied UK SRS S1 and UK SRS S2 together, subject to the UK provisions and any UK regulatory rules, and met every applicable requirement.

An entity can design one integrated disclosure package, one governance process and one evidence file. It should nevertheless maintain two controlled completion checklists. Each checklist records the requirement, the report location, evidence, preparer, reviewer, relief used, unresolved issue and final sign-off.

IFRS S1 paragraphs 55(a) and 58(a) require an entity to refer to and consider the applicability of SASB disclosure topics and associated metrics. The entity may conclude that a topic or metric is not applicable, but the consideration itself is required.

UK SRS S1 changes those provisions from 'shall' to 'may'. A UK reporter can use other reasonable sources and still comply with UK SRS, provided it produces relevant, faithfully representative and industry-associated information and identifies the sources applied. That UK treatment does not by itself establish that the mandatory IFRS consideration step occurred.

IFRS S1 paragraph E5 permits climate-only reporting in the first annual reporting period in which IFRS S1 is applied. IFRS educational material explains that an entity can still assert IFRS compliance in that first year when it applies all requirements of IFRS S1 and IFRS S2 relevant to the climate-first relief and makes the required disclosure about using the relief.

UK SRS S1 paragraph E3 also permits an entity to disclose exclusively climate-related information, but the final UK provision is not expressly limited to the first year. The compliance consequence is more restrictive: paragraph 73A states that an entity using E3 is not permitted to assert compliance with UK SRS S1 and must disclose use of the provision. A UK SRS S2 claim may still be possible if all S2 requirements and the related disclosure conditions are met.

IFRS S1 paragraph E4 permits first-time reporters to publish sustainability-related financial disclosures after the related financial statements within specified deadlines. UK SRS S1 does not contain that delayed-publication relief. Paragraph 64 requires UK SRS disclosures at the same time and for the same period as the related financial statements.

An entity that uses IFRS E4 and publishes the sustainability disclosures later would need to assess whether it can make an IFRS claim, but it would not meet the UK SRS timing requirement for the same reporting package. A dual reporter should normally adopt simultaneous publication, which satisfies the base timing requirement in both standards.

IFRS S1 is effective for annual reporting periods beginning on or after 1 January 2024, with earlier application permitted if IFRS S2 is also applied. The final UK standard does not set a standard-level mandatory effective date. It is available for voluntary use, while any mandatory commencement date is determined through the relevant UK regulatory or legislative route.

UK SRS S1 paragraphs 73B and E5 make application of the standard, including the compliance and climate-only provisions, subject to Companies Act requirements, FCA rules and other competent UK regulation when the entity is required to report. Future rules may narrow reliefs, specify report location, set transitional provisions or prescribe statement wording. A dual-compliance memo must therefore include both the standards and the applicable UK rulebook.

1. Lock the proposed statements. Write the exact UK SRS and IFRS wording the entity hopes to publish; do not begin with the assumption that one statement includes the other.

2. Confirm the reporting package. Identify UK SRS S1/S2 and IFRS S1/S2 editions, reporting period, date of initial application, financial reporting basis and applicable UK regulatory route.

3. Build a paragraph map. Start with the UK SRS text and map each paragraph to IFRS S1, highlighting amended, added, removed or jurisdiction-dependent provisions.

4. Test source-of-guidance processes. Add an IFRS-specific SASB topics and metrics consideration record, even if the UK process concluded that other industry sources were more appropriate.

5. Review every relief and exemption. Distinguish permitted omissions that preserve compliance from transition provisions that change claim availability, particularly UK paragraph E3.

6. Reconcile timing, location and cross-references. Ensure the same published information is available with the financial statements and that cross-referenced material meets both standards' conditions.

7. Complete topic and metric testing. Verify that all material sustainability-related risks and opportunities are covered, not only climate, unless a valid IFRS transition route is being used and no UK S1 claim is made.

8. Approve two completion checklists. Technical reporting, legal or regulatory review and the responsible governance body should approve the exact statement wording and any qualifications.

Visual: dual-compliance decision tree

The decision tree places the UK climate-only restriction before the IFRS gap assessment and shows the additional controls needed for an explicit dual statement.

The basis section should then identify the editions applied, date of initial application, reporting entity, location of the disclosures, sources of guidance, significant judgements, reliefs and any regulatory requirements. Do not add phrases such as 'substantially compliant' or 'fully aligned' beside an explicit statement unless their meaning is defined and technically supportable.

The bracketed UK SRS S2 statement requires its own completion test. The relief disclosure is not a substitute for explaining the reporting basis clearly to users.

Where the entity has complied with UK SRS but has not completed the IFRS SASB consideration or another IFRS requirement, the report should make the UK statement only. It can describe international alignment factually, but it should not imply an IFRS compliance conclusion.

The UK SRS conclusion can be supportable because specific SASB reference is optional. For an IFRS claim, the group retains a documented review of the relevant SASB industries, disclosure topics and metrics, including why they were not applicable and how the alternative metrics better represent the material risks. The process difference is closed even though the published metric set remains the same.

A first-time reporter publishes climate-only disclosures and applies IFRS S1 E5 and UK SRS S1 E3. If it meets all IFRS conditions, an IFRS S1/S2 compliance claim may be available for that first year. UK paragraph 73A nevertheless prevents a UK SRS S1 claim. The entity might be able to claim UK SRS S2 compliance, but that is not a dual S1 claim.

Another first-time reporter uses IFRS E4 and publishes its sustainability disclosures six months after the financial statements. The timing may fall within the IFRS relief, but it does not meet UK SRS paragraph 64. The entity cannot make a UK SRS compliance statement for that package merely because all content requirements were completed later.

UK SRS S1 General Requirements for Disclosure of Sustainability-related Financial Information. February 2026, especially paragraphs 54-59, 64, 72-73B and Appendix E Official source

IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information. June 2023, especially paragraphs 54-59, 64, 72-73 and Appendix E Official source

IFRS educational material on climate-first reporting. Applying IFRS S1 when reporting only climate-related disclosures, January 2025 Official source

UK Sustainability Reporting Standards guidance. Voluntary status and future implementation routes Official source

Government response to the UK SRS consultation. Finalisation rationale and voluntary availability Official source

FCA CP26/5. Proposed listed-issuer implementation; final Policy Statement pending at 2 August 2026 Official source

Neither Standard prescribes one universal dual-compliance sentence. Where both completion checklists are complete, the statement should name UK SRS S1 and S2 and IFRS S1 and S2 separately, be explicit and unreserved, and be checked against the applicable UK rulebook.