UK SRS S1 Sources of Guidance: SASB, CDSB, GRI, ESRS, TNFD and Industry Practice

Technical status. Final UK SRS S1 was published on 25 February 2026 for voluntary use. The final UK wording makes specific SASB references optional. Future FCA, Companies Act or sector-specific rules may affect how the Standard is applied in mandatory reporting.

Limitation. This article explains source hierarchy and controls. It does not establish equivalence between frameworks, determine a company's material information or replace specialist legal, technical or assurance review.

UK SRS S1 is designed to operate even when no topic-specific UK Sustainability Reporting Standard exists. At the date of this article, UK SRS S2 is the dedicated climate standard. For other material sustainability-related risks and opportunities, UK SRS S1 requires judgement.

That flexibility creates two opposite risks:

under-reporting, because the team assumes there is no requirement when no dedicated standard exists; and

framework accumulation, because the team combines every available standard without resolving differences in audience, materiality, boundary or methodology.

The correct model is neither “use SASB for everything” nor “choose whichever framework is easiest”. It is a controlled sequence: apply UK SRS, identify the information need, use permitted sources where helpful, resolve conflicts, filter for material information and disclose what was actually applied.

Paragraphs 54 and 56 put UK Sustainability Reporting Standards first. When a dedicated UK SRS applies, the entity uses that Standard to identify risks and opportunities and the applicable disclosure requirements.

For climate, UK SRS S2 supplies topic-specific requirements. UK SRS S1 still provides the general concepts that support S2, including materiality, reporting entity, connected information, sources of guidance, timing, comparatives, judgements and errors.

An external framework cannot be used to narrow, replace or override an applicable UK SRS requirement. It may support implementation, provided it does not create conflict or obscure material information.

UK SRS S1 makes two related but distinct decisions.

Identifying sustainability-related risks and opportunities

Paragraphs 54-55 address the sources used to identify sustainability-related risks and opportunities that could reasonably be expected to affect the entity's prospects.

In addition to UK SRS, the entity may consider:

SASB disclosure topics;

CDSB water- and biodiversity-related application guidance;

pronouncements of other standard-setters designed for general-purpose financial-report users; and

risks and opportunities identified by entities in the same industry or geographical region.

Identifying information and metrics to disclose

Paragraphs 56-58 address applicable disclosure requirements. Where no dedicated UK SRS exists, paragraph 57 requires judgement to identify information that is:

relevant to users' decisions; and

a faithful representation of the risk or opportunity.

Paragraph 58 then provides optional sources, including SASB metrics, CDSB, other investor-focused standard-setters, peer disclosures and Appendix C sources.

This distinction matters. A source can help identify a risk without providing the right metric. Equally, a useful metric can be drawn from a source even when the source's broader materiality process is not adopted.

Figure 1. UK SRS S1 creates a hierarchy of required sources, judgement conditions and optional inputs. Original London Reporting Academy practitioner visual.

SASB Standards contain industry descriptions, disclosure topics, metrics, activity measures and technical protocols. Under UK SRS S1, the specific obligation to refer to and consider SASB in IFRS S1 has been changed to permission.

A robust SASB assessment should still show:

1. which activities were mapped to which SASB industries;

2. which disclosure topics and metrics were considered;

3. which were selected, adapted or rejected;

4. why any apparent industry match was not relevant; and

5. how the result meets paragraph 48's industry-associated-metric requirement.

The entity should not make either of these unsupported statements:

“SASB is mandatory under UK SRS S1”; or

“SASB is optional, so industry-based analysis is unnecessary.”

The first overstates the final UK wording. The second ignores the required outcome.

Paragraphs 55(b)(i) and 58(b)(i) specifically identify the CDSB Framework Application Guidance for water-related and biodiversity-related disclosures.

This guidance can help teams identify:

dependencies and risk pathways;

exposure, management and performance information;

useful narrative structure;

possible metrics; and

connections to financial effects.

Its inclusion does not mean that every CDSB requirement becomes a UK SRS requirement. The reporting team must compare definitions, reporting boundary, materiality, period and presentation with UK SRS S1.

The IFRS Foundation has stated that CDSB materials remain useful until the ISSB issues standards on those topics. For a UK SRS reporter, the final UK text remains the controlling source.

Paragraphs 55(b)(ii) and 58(b)(ii) refer to pronouncements of other standard-setting bodies whose requirements are designed to meet the information needs of users of general-purpose financial reports.

This condition is important. It is not permission to import any sustainability framework. The team should ask:

Who are the intended users?

What decisions is the information designed to support?

Is the materiality lens compatible with the S1 objective?

Does the source address entity prospects over the short, medium and long term?

Does it conflict with UK SRS terminology or requirements?

Document the conclusion. The existence of an external standard does not establish that its entire content is relevant or material.

Peer reporting can improve completeness and comparability. It can reveal common metrics, risk pathways, units and investor questions.

However, peer practice has limitations:

a peer may have a different business model or boundary;

the disclosure may be driven by another jurisdiction;

the metric may be unaudited or poorly defined;

the peer may be using a legacy framework; and

widespread practice can still be immaterial for the reporting entity.

Use a controlled peer set and record why each peer is comparable. Separate prevalence from technical suitability. A metric disclosed by eight peers is not automatically material, and a company-specific metric used by no peer may still be necessary.

Appendix C says that an entity may refer to and consider GRI Standards and ESRS when no dedicated UK SRS applies, but only to the extent that they:

help meet the objective of UK SRS S1; and

do not conflict with UK SRS.

Appendix C also says that material information required by UK SRS must not be obscured. Applying GRI or ESRS without applying UK SRS does not support an explicit and unreserved UK SRS compliance statement.

Definition conflicts to test

A dual-reporting project can reuse data and evidence. It should not collapse distinct framework conclusions into one undifferentiated claim.

TNFD provides recommendations and guidance on nature-related dependencies, impacts, risks and opportunities. It can be valuable in identifying nature-related issues, structuring governance and strategy information, and organising a nature assessment.

Final UK SRS S1 does not specifically list TNFD in paragraphs 55, 58 or Appendix C. Therefore:

do not describe TNFD as a named mandatory or preferred UK SRS source;

identify the legal or technical route through which TNFD information is being considered;

test whether the information meets the S1 objective and does not conflict;

use the materiality filter rather than importing all TNFD recommendations; and

disclose TNFD or industry practice under paragraph 59 if it was actually applied.

In practice, TNFD may support a CDSB-, SASB-, other-standard-setter- or industry-practice-based analysis. The precise characterisation should be reviewed and documented rather than assumed.

A source conflict is not limited to a direct contradiction. It can arise when two sources use the same word differently or measure different populations.

Test at least:

1. objective and audience — investor-focused information versus broader stakeholder or impact reporting;

2. materiality threshold — what makes information material and at what level;

3. reporting entity — consolidated group, facilities, products, projects or value-chain population;

4. time horizon — current period, lifecycle or long-term pathway;

5. metric method — unit, denominator, gross/net treatment, estimates and uncertainty;

6. presentation — aggregation, disaggregation, cross-references and connected information; and

7. claim — compliance, alignment, reference or interoperability.

Where the source is useful but the definition differs, the entity can adapt the information and explain the difference. It should not retain the external label if that label would mislead users.

Figure 2. External information passes through source-route, conflict, objective, quality and materiality tests before disclosure. Original London Reporting Academy practitioner visual.

A permitted source identifies potentially relevant information; it does not determine materiality automatically.

The team should test each candidate disclosure against the entity-specific materiality standard. Ask whether omitting, misstating or obscuring the information could reasonably be expected to influence primary-user decisions.

This prevents two common failures:

disclosing every datapoint because it appears in a framework; and

excluding a material company-specific fact because no framework names it.

The materiality decision should be recorded at the level at which the information is assessed. A topic may be material while a particular metric is not, or a metric may be material only for one geography or business line.

A source register should record:

source title and issuing body;

version, publication date and effective period;

URL or controlled document identifier;

paragraphs or sections used;

role in the analysis;

applicable industries or topics;

adaptations made;

conflicts identified and resolved;

owner and reviewer; and

update trigger.

Version control is especially important where a source is revised independently of UK SRS. A new SASB technical protocol, ESRS amendment or TNFD guidance note can change a metric definition without changing UK SRS S1. The reporting team should assess whether the change affects comparatives, targets, controls or disclosure wording.

Paragraph 59 requires identification of:

the specific standards, pronouncements, industry practice and other sources applied; and

the industries specified in UK SRS, SASB or other industry sources that were applied, including in identifying metrics.

A useful disclosure is specific enough to be understood but does not reproduce the internal source register.

Illustrative wording — adapt to the entity's facts

Why it works: it identifies the sources and industries actually used, distinguishes application from consideration, and signals adaptations.

What must be added: the entity-specific risks, exact metrics, boundary differences, materiality conclusion and evidence.

Context. A food manufacturer identifies a potential raw-material supply risk linked to water scarcity, ecosystem condition and supplier concentration.

Sources considered. The team applies UK SRS S1, considers relevant SASB topics and metrics, uses CDSB water and biodiversity guidance to structure the risk pathway, reviews TNFD's nature assessment approach, and examines peer disclosures. GRI and ESRS metrics are considered as possible data inputs.

Conflict identified. One GRI metric measures the organisation's impacts on water resources across a wider population than the investor-focused supply-risk boundary. The team retains the underlying water data but develops a UK SRS disclosure focused on suppliers, sourcing regions, exposure, mitigation and anticipated financial effects.

Outcome. The report identifies the sources actually used, explains the adapted boundary and does not claim that the TNFD or GRI process is equivalent to UK SRS S1.

Limitation. This is an illustrative scenario, not a prescribed nature-disclosure model.

1. Treating all sources as equal

Correction: preserve the hierarchy: applicable UK SRS first, paragraph 57 judgement second, permitted supporting sources third.

2. Importing a whole framework without a conflict test

Correction: compare objective, audience, materiality, boundary, method and claim before use.

3. Calling TNFD a named UK SRS requirement

Correction: present TNFD as supporting practice only where a defensible route and materiality conclusion exist.

4. Using peer prevalence as evidence of compliance

Correction: use peers for comparability and completeness, not as normative authority.

5. Combining GRI, ESRS and UK SRS materiality into one unexplained score

Correction: preserve framework-specific decision criteria and outputs, even when evidence is shared.

6. Naming sources without identifying industries or metrics

Correction: meet paragraph 59 with specific source and industry information linked to the disclosures prepared.

7. Failing to update source versions

Correction: maintain a source register with effective period, change log and review triggers.