FCA listed issuer sustainability disclosures: what CP26/5 changes for UK listed companies

The Financial Conduct Authority (FCA) wants to replace its current Task Force on Climate-related Financial Disclosures (TCFD)-aligned listing rules with a United Kingdom Sustainability Reporting Standards (UK SRS) regime for in-scope listed issuers. Climate disclosure would become mostly mandatory under UK SRS S2, while Scope 3 emissions and wider sustainability reporting would still sit on a comply-or-explain edge.

This is a listed-company proposal, not a universal United Kingdom reporting mandate. The government published final UK SRS S1 and UK SRS S2 for voluntary use on 25 February 2026. FCA consultation paper CP26/5 would decide how a specific set of listed issuers use those standards inside the listing regime.

The timing boundary matters. CP26/5 opened on 30 January 2026 and closed on 20 March 2026. The FCA says it aims to publish a policy statement in autumn 2026, subject to the final UK SRS, with rules coming into force from 1 January 2027. Until then, the current listed-company climate rules remain the live rulebook.

The practical question for issuers is therefore narrower than "what is the International Sustainability Standards Board (ISSB)?" It is: which disclosures would move from the old TCFD-shaped regime into UK SRS, which parts would stay flexible, and which listed categories would actually have to follow the new route?

What CP26/5 would change

The structure is less sweeping than "mandatory UK SRS for everyone" and more demanding than a simple TCFD refresh. The FCA is proposing a more formal climate baseline for listed issuers, but it is also acknowledging that Scope 3 emissions and wider sustainability reporting are not equally mature across the market.

Which listed issuers the proposal covers

The FCA says the proposed rules would apply, with some variation by category, to commercial companies, issuers of non-equity shares and non-voting equity shares, the transition category, secondary listings and depositary receipts.

That list matters because it keeps the scope close to the existing listed-company climate perimeter rather than expanding immediately into every security type. The FCA is also proposing to keep some categories outside the new regime for now, including closed-ended investment funds, open-ended investment companies, shell companies, debt and debt-like securities, and certain derivative categories.

This is one reason the article deserves its own route rather than being folded entirely into the broader UK SRS guide. The standards guide explains what UK SRS is. CP26/5 answers the narrower operational question of which listed issuer categories would have to use that framework through FCA rules, and which would not.

Climate reporting would become more formal, but not fully uniform

The FCA's central proposal is to move in-scope issuers to mandatory reporting against UK SRS S2 for climate-related disclosures, while leaving Scope 3 emissions on a comply-or-explain basis. That split is the practical heart of the consultation.

The regulator's logic is straightforward. Climate reporting is already the most established part of the listed-company sustainability file, because issuers have been reporting against TCFD-aligned rules for several years. UK SRS S2 broadly tracks that architecture, but with more detail in places such as industry-based metrics, transition-plan information and value-chain emissions.

The break in uniformity appears where the data is hardest. Scope 3 emissions can be financially material and important to investors, but they rely on information from suppliers, customers, investees and other third parties that many issuers still find difficult to collect and defend. Under CP26/5, an issuer that explains instead of complying would need to identify the relevant UK SRS S2 paragraphs and explain why the Scope 3 disclosures were not produced.

The proposal therefore tightens the climate route without pretending that every part of the standard is equally settled in practice. A company with mature value-chain data may move quickly to full compliance. Another may still need to explain gaps while it strengthens methods, controls and supplier evidence.

Wider sustainability stays on a softer edge

UK SRS S1 would be newer territory for many listed issuers than climate reporting. It covers sustainability-related risks and opportunities more broadly, not only climate. The FCA is therefore proposing a comply-or-explain approach for UK SRS S1 rather than immediate mandatory reporting across the board.

The consultation paper pairs that with optional two-year transitional relief. That does not remove the direction of travel. It recognises that many issuers have not yet built the same reporting discipline for biodiversity, water, labour, supply-chain or other sustainability topics that could still affect financial prospects.

The consequence for readers is important. A listed company could be under a more mandatory climate regime while still explaining or phasing in some wider sustainability disclosures. Investors and governance teams should not assume that a move to UK SRS means every sustainability topic will arrive at the same level of maturity on day one.

Transition plans and assurance become disclosure questions, not new FCA mandates

One easy mistake is to read CP26/5 as a direct transition-plan mandate. The FCA says mandating that companies have transition plans is a matter for government. Its proposal is narrower. Issuers in scope would disclose whether and where they have published a transition plan, or explain why they have not.

That still matters. A public statement about whether a plan exists creates a cleaner boundary between companies that have published one, companies still developing one and companies that have chosen not to. It also makes it easier for investors to compare the public narrative with the annual-report sustainability disclosures.

The same logic applies to assurance. CP26/5 does not create a single mandatory assurance standard for every disclosure. It would require issuers to say whether they have obtained third-party assurance on sustainability disclosures. That transparency can be useful without implying that every assured figure is equally reliable or that every unaudited figure is weak.

International and secondary-listed issuers would not follow the same path

The FCA is proposing a more flexible approach for international issuers with a primary listing in another jurisdiction. Instead of requiring the same full UK SRS route in every case, it would focus more on transparency about the reporting requirements and standards that apply in the issuer's home market or that the issuer applies voluntarily.

This reflects a real duplication problem. A company already reporting under another market's sustainability regime could otherwise face overlapping disclosure work for its United Kingdom listing. The trade-off is that comparability may depend more heavily on how clearly the issuer explains its home-market rules, reporting standards and assurance position.

For United Kingdom readers, that means "in scope" does not always mean "identical disclosure package". The listing category and primary-market position still matter.

What CP26/5 does not do

• It does not make UK SRS mandatory for every United Kingdom company. The government's published standards remain available for voluntary use unless and until sector-specific or company-law requirements change.
• It does not replace other sustainability-reporting routes, such as company-law climate disclosures, asset-manager product-reporting proposals or public-sector reporting guidance.
• It does not mean the 1 January 2027 start is fixed. The FCA still ties that aim to the final UK SRS and its autumn 2026 policy statement.
• It does not turn a listed company into a high-quality reporter merely because the standards change. Evidence quality, governance and controls still decide whether disclosures are useful.

What listed companies can prepare before autumn 2026

1. Confirm the listing-category perimeter. Check exactly which category or categories the issuer uses and whether any overseas or depositary-receipt structure changes the expected disclosure path.
2. Map the current TCFD file against UK SRS S2. Identify where the issuer already has climate governance, metrics and risk disclosures, and where UK SRS adds detail, especially on industry metrics and transition-plan information.
3. Test the Scope 3 evidence route. Decide whether the issuer is likely to comply or explain, and document the current data gaps rather than leaving that judgement until the annual-report timetable tightens.
4. Separate climate from wider sustainability readiness. UK SRS S1 may require a broader materiality and evidence discussion than many listed companies have built so far.
5. Check the public document set. If a transition plan or assured sustainability metric is mentioned, make sure the underlying report, scope and timing are clear enough to withstand investor comparison.

The preparation value is not only compliance. A cleaner file on scope, controls and evidence also makes it easier to answer investor questions, lender requests and board scrutiny even before the final rules land.

Official sources

• Financial Conduct Authority: CP26/5 consultation page
• Financial Conduct Authority: CP26/5 full consultation paper
• Financial Conduct Authority: sustainability reporting requirements
• GOV.UK: UK Sustainability Reporting Standards guidance
• GOV.UK: final UK SRS S1 and UK SRS S2
• Feature image: 12 Endeavour Square, Stratford by Yirba, CC0 1.0, via Wikimedia Commons