Response to FCA consultation paper on aligning listed issuers’ sustainability disclosures with UK SRS

24 Mar 2026

Liz Cole, Head of Policy - The Investor Relations Society

Consultation Responses 3.0 Corporate Reporting 4.0 Sustainability, ESG & CSR Annual reports

The Society responded to the FCA Discussion Paper (CP26/5): Aligning listed issuers’ sustainability disclosures with international standards.

The Society response highlights issuer‑side concerns around UK competitiveness and market readiness for the FCA’s proposals. The Society supports alignment with UK Sustainability Reporting Standards (UK SRS), based on the ISSB framework, to enhance the international comparability of UK listed sustainability disclosures. However, we are concerned that the pace, sequencing and design of the FCA’s proposed implementation risk moving the UK faster and harder than most peer jurisdictions, especially for small‑ and mid‑cap issuers. While global comparability is essential, it must be achieved in a way that preserves London’s competitiveness as a listing venue. Without size‑based phasing or thresholds, there is a risk the UK becomes an outlier, with adverse consequences for reporting quality and market attractiveness. 

Read the full response here.