UK listed companies must disclose Scope 3 from 2027

Emission Reporting

The FCA has finalised the reporting rules that bring UK listed companies into line with the ISSB standards, Scope 3 included. The grace periods are short.

What was finalised

On 30 September 2026 the UK Financial Conduct Authority published Policy Statement PS 26/19, "Aligning listed issuers' sustainability disclosures with international standards", amending the UK Listing Rules. The FCA gave further detail on its approach at a webinar on 19 October.

In-scope listed companies will report against the UK Sustainability Reporting Standards, UK SRS S1 and S2, on a comply or explain basis. UK SRS is built on the ISSB's IFRS S1 and S2, the same international baseline the UK government endorsed for voluntary use in February 2026. The new rules make reporting against it compulsory, on a comply or explain footing, for listed issuers.

The requirement applies for accounting periods beginning on or after 1 January 2027, with first disclosures landing in 2028 annual reports. Issuers can continue reporting on a TCFD basis, or adopt UK SRS early, for periods before that date.

The grace periods, and when they end

Two transitional reliefs apply from the date a company first reports under UK SRS. It can omit Scope 3 emissions under UK SRS S2 in its first year, and it can limit UK SRS S1 reporting to climate-related matters for its first two years, deferring the wider sustainability disclosures.

Both reliefs fall away for accounting periods beginning on or after 1 January 2029. A company with a January year end effectively has two full years, 2027 and 2028, before Scope 3 and the non-climate S1 disclosures are both compulsory.

What that means for supplier data

Scope 3 is, for most listed companies, mostly a supplier question. A reporting team that has a year or two of relief still needs that time: building a supplier emissions baseline from scratch, in the run-up to a comply-or-explain deadline, is not a task to start in the final quarter before it is due.

DitchCarbon provides verified emissions data for over 2 million organisations, built on primary data wherever it exists, so a baseline can start from what suppliers have already disclosed rather than from a blank survey.

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