Preparing a listed property group for UK SRS: gap review, data and assurance

For a listed property group, the FCA's decision to move listing-rule climate reporting onto the UK Sustainability Reporting Standards is less a change of framework than a change of discipline. TCFD-aligned statements could be written largely by the sustainability team. UK SRS disclosures sit inside the annual financial report, run on the financial reporting timetable and invite the same questions an auditor or investor would ask of any other number. The groups that will find the first cycle manageable are the ones that treat the coming months as a readiness project, not a drafting exercise.

This briefing sets out what the FCA has confirmed, then the preparation sequence we use with property clients: a gap review, data readiness and assurance preparation, followed by the board decisions that comply or explain requires.

The position confirmed by the FCA

• The rules. In PS26/19, published on 30 September 2026, the FCA replaced its TCFD-based listing rules with requirements to report against UK SRS on a comply or explain basis. They apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
• The standards. UK SRS S1 (general sustainability-related disclosures) and UK SRS S2 (climate) were published by the government in February 2026. They are the UK-endorsed versions of the ISSB standards. They are not identical to them: the FCA lists UK-specific differences, including that there is no first-year relief allowing sustainability disclosures to be published after the financial statements.
• Who is in scope. Companies with shares in the commercial companies, transition, non-equity and non-voting equity shares, international commercial companies secondary listing and depositary receipts categories. That covers listed REITs and other listed property companies. Private property businesses are not directly in scope.
• What the annual financial report must contain. S2 climate disclosures, or an explanation of what has not been met, why, and the steps planned; and S1 disclosures, or the equivalent explanation, or a statement that no sustainability risks have been identified.
• Optional reliefs. One year for Scope 3 emissions and two years for wider S1 disclosures.
• Transition plans and assurance. Companies with a primary UK listing must state whether and where they have published a climate transition plan, or why not. All in-scope companies must disclose any third-party sustainability assurance they have obtained voluntarily, including its provider, scope, level and standard.
• Still to come. The FCA is consulting on a Technical Note on comply or explain (TN 803.1) until 28 October 2026. Its suggested preparation steps are in Primary Market Bulletin 66, and it plans to publish its supervisory approach in the second half of 2027.

Step 1: a gap review against UK SRS, not against last year's report

A gap review should start from the standards and work back to the group, rather than starting from the existing TCFD statement and asking what to add. For each S2 requirement we record whether the group has the governance, process and data to meet it now, what is missing, and who owns closing the gap. The same exercise is run more lightly for S1, so that the board knows what the two-year relief is buying time for.

The output is a short register, not a long report. It shows which requirements the group expects to comply with in the first year, which it may need to explain, and which relief it intends to use. Those positions are provisional, but setting them early gives the audit committee something concrete to challenge.

Step 2: data readiness across the estate and the lease line

For property groups, most of the effort sits in data that crosses ownership and lease boundaries:

• Landlord-controlled energy in common parts, central plant and vacant space, with meter coverage and estimation methods documented.
• Tenant-controlled energy, which for a landlord typically falls in Scope 3 as downstream leased assets. Whether or not the one-year Scope 3 relief is used, the data-sharing arrangements, green lease clauses and estimation methods take time to put in place.
• Building attributes that connect emissions to the financial story: floor areas on a consistent basis, EPC ratings and expiry dates, and planned improvement works.
• One method across regimes. The same boundaries, emission factors and estimation rules should feed SECR, ESOS and UK SRS, so figures reconcile across the annual report, the directors' report and regulatory submissions.

Because UK SRS disclosures are published with the financial statements, this data needs to be reliable on the audit timetable. For a group whose first in-scope period begins on 1 January 2027, the metering, data-sharing and estimation decisions belong before that date, not in the year-end close.

Step 3: assurance preparation, even where assurance is voluntary

The FCA rules require disclosure of any voluntary assurance obtained, not assurance itself. In our view, preparing as if limited assurance will be sought is still the most efficient route. It forces documented methods, a clear audit trail from meter or invoice to reported figure, review and sign-off steps, and a record of judgements such as estimation and boundary choices. Those controls make the disclosures easier to defend whether or not an assurance provider is appointed, and they shorten the work if one is appointed later.

Step 4: board decisions that comply or explain requires

Comply or explain moves several choices to the board and audit committee:

• which S2 requirements the group will meet in the first year, and the wording and timetable for any explanation;
• whether to use the Scope 3 and S1 reliefs, which must be stated but need not be justified;
• the position on a published transition plan, for groups with a primary UK listing;
• whether to obtain voluntary assurance, and over which disclosures.

These are governance decisions with disclosure consequences. They are best taken with the gap register and data position in front of the board, and revisited once the FCA finalises its Technical Note.

Questions for the audit committee

• Do we have a gap register against UK SRS S2, with an owner for each gap?
• Which disclosures do we expect to comply with in the first year, and which may we need to explain?
• Will we use the Scope 3 or S1 reliefs, and what will the position be when they end?
• Is our tenant and landlord energy data good enough to meet the financial reporting timetable?
• Do SECR, ESOS and UK SRS figures use the same methods and reconcile?
• Are our controls ready for assurance, whether or not we commission it?

How NZC Consultants can help

We support listed property groups with UK SRS gap reviews against S1 and S2, data readiness across the estate and the lease line, assurance-ready methods and audit trails, and board briefings on comply or explain choices. This work sits within our climate disclosure advice for TCFD, ISSB and UK SRS and connects to our SECR and ESOS services, so the same building data supports every report.

To discuss your group's UK SRS readiness, speak to an NZC Consultants director.

Primary sources

• FCA, PS26/19: Aligning listed issuers' sustainability disclosures with international standards (published 30 September 2026, updated 13 October 2026)
• FCA, Sustainability reporting requirements (updated 30 September 2026)
• GOV.UK, Department for Business and Trade, UK Sustainability Reporting Standards (updated 25 February 2026)

This briefing is general commentary on published FCA rules and government standards as at 16 October 2026, checked against the sources above. It is not legal, accounting or assurance advice. Confirm your listing category and reporting obligations against PS26/19 and the FCA Handbook.