UK SRS for Asset Managers: FCA Rules from 2027

UK SRS for Asset Managers: FCA Sustainability Disclosure Requirements from 2027

The United Kingdom now has its own sustainability reporting rulebook, and asset managers sit in an unusual position within it. On 25 February 2026 the UK government published UK SRS S1 and UK SRS S2, the UK Sustainability Reporting Standards built on the International Sustainability Standards Board’s IFRS S1 and IFRS S2. The Financial Conduct Authority (FCA) has proposed making them mandatory for listed companies from 2027. For asset management firms, the UK SRS sustainability disclosure requirements arrive through more than one door, and the FCA sits on both sides.

The stakes are large. The UK is the world’s second-largest investment management centre after the United States, managing £10.0 trillion in assets at the end of 2024, according to the Investment Association. For the chief investment officers, compliance officers, and ESG heads running those assets, knowing which disclosure regime applies to which part of the business is now a live compliance question rather than a future one.

Source: The Investment Association, Investment Management in the UK 2024-2025 (13 August 2025).

Spectreco, an ESG technology and advisory firm with offices in Atlanta, London, Lisbon, and Lahore, advises FCA-regulated firms on where these obligations bite and how to prepare. This guide sets the UK SRS asset manager rules in plain terms: who is in scope, how UK SRS differs for asset managers versus listed issuers, where it meets the FCA anti-greenwashing regime, and when the first disclosures land.

Key takeaways

• UK SRS applies to listed issuers, not to asset managers as fund operators. A listed asset management group is caught as an issuer; its funds are not.

• Two separate regimes apply: UK SRS at corporate level through the FCA listing rules, and the FCA SDR at fund and product level. They are not the same rulebook.

• The first mandatory UK SRS disclosures cover accounting periods beginning on or after 1 January 2027, with the FCA’s final rules expected in autumn 2026.

• Around 515 listed companies fall inside CP26/5, feeding standardised, financially material climate data into every manager’s portfolio analysis.

Sources: UK government, UK Sustainability Reporting Standards; FCA, CP26/5.

Who counts as an asset manager in scope for UK SRS?

UK SRS S1 and S2 became available for voluntary use on 25 February 2026. They only become mandatory through separate rules, and for now that means the FCA’s listing rules. The FCA’s consultation paper CP26/5, published on 30 January 2026, would require around 515 listed companies to report under UK SRS in place of the current TCFD-aligned listing rules. Whether your firm is in scope depends on what kind of entity it is.

Three different positions

• Listed asset management groups: a manager whose shares are listed in the FCA’s commercial companies category is an issuer. It sits inside the roughly 515 companies covered by CP26/5 and must report at group level under UK SRS.

• Private and boutique managers: firms that are not listed fall outside CP26/5. The Department for Business and Trade is separately weighing whether private companies should report under UK SRS through its wider corporate reporting reform.

• Funds and investment vehicles: the FCA deliberately left closed-ended investment funds and open-ended investment companies out of the listing rules. It said the best way to introduce requirements for investment vehicles is through obligations on the asset manager, not the fund.

Source: FCA, CP26/5: Aligning listed issuers’ sustainability disclosures (30 January 2026).

That last point matters. Your funds will not report under UK SRS as issuers. Their sustainability disclosures continue to run through the FCA’s fund-level regime, which is a different rulebook with different deadlines. Our UK SRS guide for listed companies covers the issuer obligations in full.

How UK SRS obligations differ for asset managers and listed companies

For a listed operating company, UK SRS is the whole story. It replaces the TCFD listing rules with a single financial-materiality standard covering governance, strategy, risk management, metrics, and targets. UK SRS S2 (climate) leads, with transition reliefs proposed for Scope 3 emissions and for the broader UK SRS S1 disclosures in later years. For an asset manager, UK SRS works on two levels that are easy to confuse.

• Entity level: if you are listed, you report your own corporate sustainability position under UK SRS. If you are not listed, you do not, at least not yet.

• Portfolio level: whether or not you report under UK SRS, your investee companies increasingly will. Around 515 UK issuers producing standardised, financially material climate data changes the quality of what flows into your analysis and your fund disclosures.

This is the practical upside for managers. Standardised issuer data feeds financed-emissions calculations, stewardship, and product reporting. Financed emissions are Scope 3 Category 15: the emissions tied to a firm’s loans and investments, and for most financial institutions the largest part of their footprint. Pulling that data from 515 filings by hand does not scale, which is where a connected sustainability platform that maps issuer disclosures to portfolio metrics earns its place.

UK SRS also differs sharply from the EU regime. It uses single financial materiality, while CSRD and the EU’s ESRS require double materiality: how climate affects the business and how the business affects climate and society. Managers with UK and EU footprints run both, and the two are not interchangeable.

Sources: FCA, CP26/5; GOV.UK, UK SRS guidance.

How UK SRS and the FCA SDR fit together

UK SRS is a corporate-level reporting standard for issuers. The FCA’s Sustainability Disclosure Requirements (SDR) is a separate fund and firm regime for asset managers, covering investment labels, naming and marketing, product reports, and the anti-greenwashing rule. They overlap in subject but are distinct rulebooks with different scope and timing. For most asset managers, the SDR is where UK sustainability rules already bite.

What the SDR already requires

• Anti-greenwashing rule: in force since 31 May 2024 for all FCA-authorised firms. Every sustainability claim must be fair, clear, and not misleading.

• Investment labels and naming rules: labels available from 31 July 2024; naming and marketing rules applied from 2 December 2024.

• Entity-level sustainability reports: firms with assets under management above £50 billion report from 2 December 2025; firms above £5 billion from 2 December 2026.

Sources: FCA, PS23/16 (SDR and investment labels); FCA anti-greenwashing guidance.

Then there is CP26/17. Published on 5 June 2026 as part of the FCA’s quarterly consultation, it proposes to streamline product-level TCFD climate reports, replacing them with simpler, Consumer Duty aligned information for retail investors while letting institutional clients request emissions data on demand. The FCA estimates the change could save firms around £20 million a year. The direction of travel is clear: fund-level climate disclosure is being simplified even as issuer-level UK SRS reporting expands.

Source: FCA, CP26/17 – simpler climate reporting rules (5 June 2026).

When do the first UK SRS disclosures apply?

Under CP26/5, the FCA proposes that in-scope listed issuers report under UK SRS for accounting periods beginning on or after 1 January 2027. The FCA expects to confirm final rules in a policy statement in autumn 2026. A listed manager with a calendar financial year would publish its first UK SRS disclosures in 2028, covering the 2027 period. Private managers have no fixed UK SRS date, but SDR duties and portfolio data demands already call for the same underlying systems.

Sources: FCA, CP26/5 and CP26/17.

What asset managers should do before 2027

Preparation splits by firm type, but the groundwork overlaps. Four steps put a manager ahead of the FCA’s final rules.

1. Confirm your door. Establish whether the group is a listed issuer inside CP26/5, a private firm outside it, or both an issuer and a fund operator. The answer sets your obligations.

2. Separate entity from product. Map UK SRS entity reporting against SDR and TCFD product reporting so teams stop treating them as one project.

3. Fix the data pipeline. Build the capability to ingest standardised UK SRS issuer data and convert it into financed-emissions and product metrics.

4. Pressure-test claims. Review fund names, labels, and marketing against the anti-greenwashing rule before disclosure volumes rise.

Frequently asked questions (FAQs)

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Map your 2027 obligations with Spectreco

Spectreco’s London-based advisory team helps FCA-regulated asset managers separate their UK SRS issuer obligations from their SDR fund duties, then build the data pipeline to satisfy both. Book a UK sustainability disclosure readiness review through our Compliance, Reporting and Disclosures advisory and map your 2027 obligations before the FCA confirms final rules.

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