UK SRS vs. ISSB: What You Need to Know About the Key Differences

Jones Day
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On June 25, the UK Government published Exposure Drafts of the UK Sustainability Reporting Standards (UK SRS), based on the IFRS Sustainability Disclosure Standards (IFRS S1 and S2), but with six key proposed amendments tailored to the UK context:

  • Replacing the fixed effective date with a more flexible “Initial Application” approach;
  • Removing the ISSB’s one-year transition relief for delayed sustainability reporting (S1);
  • Extending the optional 'climate-first' transition relief to two years;
  • Clarifying that transition reliefs apply only once mandatory reporting begins, not during voluntary adoption;
  • Allowing the use of alternative classification systems, rather than mandating the Global Industry Classification Standard (GICS) required in IFRS S2;
  • And softening the requirement to “shall refer to” SASB materials to a more permissive “may refer to.”

The government has launched a public consultation on these draft standards, and stakeholders are encouraged to submit their views by August 10, 2025, to help shape the future of sustainability reporting in the UK.

This consultation is the culmination of the UK's process to assess the suitability of the ISSB Standards for use in the UK – in other words, whether they should be endorsed.

www.gov.uk/...

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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