UK SRS for SME suppliers: what your large customers are about to ask you

UK Sustainability Reporting Standards were published on 25 February 2026. Listed companies are now planning their first disclosures, with FCA mandatory adoption expected from 1 January 2027. That timeline matters to you as an SME supplier because: large companies cannot report their Scope 3 emissions without data from their supply chain, and their data collection will start in the second half of 2026 — well before the reporting deadline.

This article is not written for in-scope reporting companies. It is written for the UK SME suppliers who will receive questionnaires from in-scope customers and need to know what to prepare.

The commercial trigger: UK SRS creates a supply chain cascade

UK SRS is aligned with ISSB's IFRS S1 and S2 — the international sustainability disclosure standards now being adopted across major economies. Under UK SRS E1 (the climate standard), in-scope companies must disclose Scope 3 emissions across material categories. Scope 3 Category 1 — purchased goods and services — captures the emissions embedded in what they buy from suppliers.

As ICAEW noted in its February 2026 commentary on UK SRS publication: "Smaller businesses in supply chains should anticipate requests for emissions data from in-scope customers." ICAEW is not known for alarmism. When the accountants' professional body uses the word "anticipate," the requests are already coming.

The supply chain data requests from UK SRS-aligned reporters will differ from standard procurement questionnaires in one important way: they will reference specific UK SRS data fields, and customers will increasingly expect answers that map to those fields rather than generic carbon footprint summaries.

⚖️ Regulatory note: UK SRS is available for voluntary use from February 2026. The FCA is consulting on mandatory adoption for listed companies from 1 January 2027. SME suppliers have no direct UK SRS reporting obligation — but their customers do, and those customers need supplier data to meet it.

The five data points you will actually be asked to provide

UK SRS E1 covers a significant amount of ground for in-scope reporters. For SME suppliers, the data requests will focus on the fields that are materially relevant to a customer's Scope 3 calculation. Here is what to expect:

1. Your Scope 1 greenhouse gas emissions (tCO₂e)

Total direct emissions from on-site combustion and company-owned or controlled vehicles, measured in tonnes of CO₂e. This is gas boilers, diesel generators, and your company car fleet. Calculated using DEFRA/DESNZ conversion factors for the relevant reporting year.

2. Your Scope 2 greenhouse gas emissions (tCO₂e)

Indirect emissions from purchased electricity, measured using a location-based method (UK grid average) or a market-based method (renewable energy certificates or supplier contracts). Most supplier questionnaires accept location-based. If you purchase renewable electricity under a contract with a guarantee of origin, disclose that alongside the location-based figure.

3. Your total energy consumption (MWh by fuel type)

The raw input data behind your Scope 1 and Scope 2 figures. Total electricity in MWh, gas in MWh, fuel in litres (convertible to MWh). UK SRS E1 requires in-scope reporters to disclose energy consumption split by renewable and non-renewable sources — and they will need to categorise the energy embedded in their purchased goods. Your figures by fuel type give them that.

4. Whether you have a net zero target or transition plan

UK SRS requires in-scope reporters to disclose their own targets and plans — and to describe whether their suppliers' targets are consistent with their own transition trajectory. For a supplier, this means: do you have a net zero target, what year does it cover, and what is your plan to get there? You are not required to have one. But "no target" is an answer, and it is one your customers will need to document.

5. Whether you have identified climate-related risks to your business

UK SRS E1 requires in-scope companies to assess physical and transition climate risks across their value chain. For a supplier, you may be asked: have you assessed whether climate-related risks (flooding, supply disruption, energy price volatility, regulatory change) affect your operations? A brief, documented answer — even if the answer is "we have considered these and our principal risk is energy price volatility" — is far more useful to a customer than a blank.

Methodology guidance from Alice Roberts, Head of Methodology at Compare Your Footprint.

UK SRS supplier data request: what comes next

Once you have these five data points prepared, the mechanics of responding to a UK SRS-aligned questionnaire are straightforward. The practical challenge for most SME suppliers is not the questionnaire — it is not having the underlying data in the first place.

Suppliers who currently complete SECR reports have a significant head start: the Scope 1 and Scope 2 data and energy consumption figures are already calculated. Suppliers who have never formally measured their carbon footprint will need to do so before they can answer a questionnaire with a defensible number.

The timing is not as distant as it might appear. In-scope listed companies with a 31 December 2026 year end will need to complete their UK SRS disclosures in early 2027. Supplier data collection will be underway in Q3 and Q4 2026. An SME that starts its carbon footprint calculation in September 2026 will be scrambling; one that starts now is ahead.

What the UK SRS small business reporting requirement looks like in practice

One question that comes up frequently: does UK SRS require SMEs to do anything directly? The answer is no — UK SRS reporting is mandatory only for in-scope listed companies (from 2027). SMEs have no direct disclosure obligation.

The indirect obligation is the one that matters commercially. If your largest customer is a listed UK company, they will need your data. If you cannot provide it, you become a gap in their Scope 3 disclosure — and a procurement risk.