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UK SRS is now in the Listing Rules: what the FCA’s new rules mean for UK landlords and property businesses

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On 30 September 2026 the Financial Conduct Authority (FCA) published its final rules requiring UK-listed companies to report against the UK Sustainability Reporting Standards (UK SRS). The policy statement, PS26/19, replaces the TCFD-based climate disclosure rules that listed companies have followed since 2021.

If you run a listed property company, this changes your annual report. If you are a private landlord, occupier or operating company, it still matters, because listed tenants, landlords, lenders and investors will need building-level energy and emissions data from you to complete their own disclosures.

This article summarises what has actually been decided, based on FCA and GOV.UK sources checked on 13 October 2026. It is not legal or accounting advice.

What has been decided

The standards. The Department for Business and Trade published the final UK SRS on 25 February 2026:

They are the UK-endorsed versions of the International Sustainability Standards Board (ISSB) standards IFRS S1 and IFRS S2. Any organisation can use them voluntarily, in whole or in part.

The rules for listed companies. The FCA’s PS26/19 makes UK SRS the reporting basis for listed companies on a “comply or explain” basis across both standards. According to the FCA:

Who is directly in scope

The FCA rules apply to companies with shares listed in these categories:

For property, that captures listed REITs, listed developers and listed operating companies that hold large estates.

Private companies are not directly in scope of the FCA rules. The government has said it will consider whether to extend UK SRS reporting to non-listed companies as part of its wider work on modernising corporate reporting. No decision has been made, so treat that as something to watch rather than a requirement.

Three differences from TCFD that matter for property data

1. Disclosures must be published with the accounts. Unlike the ISSB baseline, UK SRS has no first-year relief allowing climate disclosures to follow later. If you comply, the sustainability information is published at the same time as the related financial reporting. For a December year-end, that means building energy and emissions figures for 2027 need to be reliable early in 2028, on the same timetable as the audit.

2. Scope 3 becomes a comply-or-explain item. After the one-year relief, listed companies will be expected to report Scope 3 emissions or explain why not. For landlords, the energy that tenants buy and use in let space usually sits in the landlord’s Scope 3 (downstream leased assets). For occupiers, landlord-supplied energy usually sits in theirs (upstream leased assets). Either way, the data has to cross the lease line.

3. Metrics must connect to the financial story. UK SRS S2 asks companies to explain how climate-related risks and opportunities affect their strategy, cash flows and financial position. For property, that typically means linking emissions and energy performance to things like EPC ratings, the minimum energy efficiency standards, retrofit capital expenditure and valuation risk, rather than reporting a carbon total on its own.

What this means if you are not listed

NZC Portal is built for private landlords, investors and operating companies. For them, the practical effect over the next 18 months is likely to be more data requests, not new filing duties:

The organisations that can answer quickly, with consistent methods and evidence, will be easier to lease to, lend to and invest in.

How UK SRS sits alongside SECR, ESOS and MEES

UK SRS does not replace the UK’s existing energy and carbon duties:

In practice, the same building data serves all of them: metered energy, floor areas, EPC ratings and planned improvement works. Collecting it once, to a consistent standard, avoids reconciling different numbers in different reports.

A practical checklist for the next six months

  1. Confirm your position. Are you directly in scope (listed), indirectly affected (tenant, landlord, borrower or investee of a listed company), or both?
  2. Map your estate’s data. For each building, record who buys each energy supply, how it is metered, the EPC rating and expiry date, and the lease type.
  3. Fix the gaps in 2026. If the first in-scope period starts on 1 January 2027, the meter readings, data-sharing clauses and estimation methods need to be in place before that year starts, not during year-end.
  4. Agree data-sharing with tenants and landlords. Green lease clauses or simple data-sharing agreements make the Scope 3 numbers far easier to defend.
  5. Line up your methods. Use the same emission factors, boundaries and estimation rules for SECR, ESOS and UK SRS, so your figures reconcile.
  6. Link energy to money. Record the cost and timing of planned EPC and MEES upgrades so they can feed transition planning and financial disclosures.
  7. Follow the FCA guidance as it lands. The FCA is hosting a webinar on 19 October 2026 and inviting feedback on a Technical Note on applying comply-or-explain until 28 October 2026. It plans to set out its supervisory approach in the second half of 2027.

How NZC Portal helps

NZC Portal’s live modules bring building energy, EPC and MEES status, SECR figures and ESOS evidence together in one place for UK property portfolios. Scope 3 reporting for occupiers is in development in the Company ESG module, coming in 2027. That gives landlords and operating companies a single, consistent source to answer UK SRS-driven data requests and to prepare their own reporting. Book a demo to see it with your own buildings.

Sources (checked 13 October 2026)