On 30 September 2026 the Financial Conduct Authority published Policy Statement PS26/19, responding to its January consultation (CP26/5) on evolving rules for listed companies' sustainability disclosures. The PS sets final rules to align listed issuers' sustainability and climate disclosures with the UK Sustainability Reporting Standards (UK SRS), the UK-endorsed version of the International Sustainability Standards Board (ISSB) Standards.
- A comply-or-explain approach across all categories of disclosure, bringing UK SRS S2 (climate disclosures) into alignment with the approach consulted for UK SRS S1 (non-climate) and for Scope 3 emissions data.
- International commercial companies with secondary listings and depositary receipt issuers are required to report against UK SRS on a comply-or-explain basis instead of merely signposting to home-jurisdiction reporting requirements.
The FCA frames the comply-or-explain approach as a balance between investor needs for comparable, financially material information and market readiness plus current reporting maturity. By giving issuers the option to explain why a disclosure is not included, the FCA aims to increase the quantity, quality and comparability of useful information while avoiding imposing absolute mandatory formulas where market practices remain uneven.
Supporting materials and technical notes
To help issuers apply the new rules the FCA is consulting on Technical Note 803.1, updating TN 801.4, and deleting TN 802.3. The proposals and practical considerations are set out in Primary Market Bulletin 66 (PMB 66), which is open for comments until 28 October 2026. The FCA plans outreach activities, including a webinar on 19 October 2026, to explain the updated requirements and TN 803.1.
Practical impact for issuers and investors
Issuers in scope should plan for new reporting against the UK SRS and prepare to use the comply-or-explain framework where necessary. International issuers with secondary listings and depositary receipt structures will now need to consider UK SRS alignment rather than relying on home-jurisdiction reports alone. Investors can expect more standardized, financially focused sustainability information, subject to the limits of comply-or-explain disclosures.
Stakeholders can comment on PMB 66 by 28 October 2026. The FCA will continue implementation work and stakeholder engagement through published technical notes and targeted outreach ahead of the 2027 accounting-period start date.