What CP26/5 is
CP26/5 is a consultation paper published by the UK's Financial Conduct Authority (FCA) on 30 January 2026, proposing to replace the existing TCFD-aligned Listing Rules with requirements aligned to UK SRS (the UK's endorsement of ISSB's IFRS S1 and S2). The consultation closed 20 March 2026.
What it proposes
- UK SRS S2 (climate-related disclosures) becomes mandatory for in-scope listed companies, for financial years beginning on or after 1 January 2027.
- Scope 3 emissions disclosure on a comply-or-explain basis from 2028.
- UK SRS S1 (general sustainability disclosures) on a comply-or-explain basis from 2029.
- In-scope companies must disclose whether they have published a climate transition plan.
Who's affected
Based on the proposal, roughly 500–515 UK listed companies would be in scope for mandatory UK SRS S2 reporting. See our UK SRS guide for the fuller picture, including the possible future extension to private companies.
What happens next
The FCA is expected to publish a Policy Statement responding to the consultation in autumn 2026, which would confirm the final rules. Until then, this remains a proposal, not a confirmed rule — treat the dates above as the FCA's stated intention rather than settled law.
Frequently Asked Questions
Has CP26/5 been finalised?
Not as of when this page was last reviewed — it's a consultation, with the consultation period having closed in March 2026. The FCA's Policy Statement, expected autumn 2026, would confirm the final rules.
Which companies would CP26/5 affect?
Based on the proposal, roughly 500-515 UK listed companies would be affected by mandatory UK SRS S2 (climate) reporting — see our UK SRS guide for the fuller detail.
Does CP26/5 cover Scope 3 emissions?
Yes, proposed on a comply-or-explain basis from 2028 — a year after the main UK SRS S2 mandatory start date.