The UK SRS regulatory timeline, by actor
Four parallel tracks of activity from the UK Technical Advisory Committee's first recommendation to the proposed in-force date. Reading by row shows what each regulator did and when; reading by column shows the cluster of activity in early 2026.
Last verified 12 May 2026 · Footnotes link to primary sources
ESOS, SECR, and UK SRS S2 are three separate UK regulatory regimes covering energy use and carbon emissions.
Large UK organisations may be in scope of all three.
ESOS Phase 4 (Energy Savings Opportunity Scheme) qualifies organisations on 31 December 2026 with a compliance deadline of 5 December 2027.
SECR (Streamlined Energy and Carbon Reporting) applies on an ongoing annual basis through the Directors' Report.
UK SRS S2 (Climate-related Disclosures) is proposed to apply to in-scope listed issuers from 1 January 2027 under FCA Consultation Paper CP26/5.
The three regimes have different regulators, different scopes, and different outputs — but they draw on substantially the same underlying energy and emissions data.
The UK government's Department for Energy Security and Net Zero (DESNZ) has committed only to consider how UK SRS energy and emissions data interacts with SECR, with a view to reducing unnecessary duplication where possible.
Its statutory post-implementation review of SECR, published on 26 May 2026, recommends retaining SECR with amendments, so no rationalisation has been confirmed and organisations should plan for full compliance with all three regimes separately.
The three regimes at a glance
| Regime | Scope | Frequency | Output | Regulator | Next deadline |
|---|---|---|---|---|---|
| ESOS Phase 4 | UK large undertakings (and their corporate groups) | Four-year cycle | Energy audit report and Action Plan submitted via MESOS portal | Environment Agency (England); Natural Resources Wales; SEPA; DAERA/NIEA | Qualification 31 December 2026; compliance 5 December 2027 |
| SECR | Large UK companies, LLPs, and quoted companies | Annual (Directors' Report) | Energy and carbon disclosure in the Strategic Report | Companies House filing; Companies Act 2006 framework | Annually with statutory accounts |
| UK SRS S2 | In-scope listed issuers on UKLR 6, 16 and 22 — proposed under FCA CP26/5 (UKLR 14 and 15 are within CP26/5's scope but would instead make a signposting statement, not report under UK SRS) | Annual (sustainability disclosure in annual financial report) | Climate-related financial disclosure under the four-pillar framework | FCA supervision; DBT (standards); FRC (assurance) | Proposed mandatory from accounting periods beginning 1 January 2027 |
Each regime has a different statutory basis, a different regulator, and a different reporting cadence.
The substantive overlap is in the underlying data: energy consumption, Scope 1 and Scope 2 emissions, and (for SECR quoted companies and UK SRS S2) Scope 3 emissions.
Who is in scope of which regimes
Am I in scope of UK SRS?
A practical decision tree walking through the rules in CP26/5, the Companies Act, and the proposed mandatory framework. UK SRS itself is available for voluntary adoption by any UK entity — the question of mandatory application is jurisdiction-specific.
Last verified 27 July 2026 · Subject to FCA Policy Statement on CP26/5, unpublished as of that date
Outcome categories
Most large UK organisations end up in scope of more than one regime.
The three common scenarios:
ESOS only.
Large UK undertakings that meet the ESOS test (250 or more employees, OR annual turnover above £44m AND balance sheet total above £38m) but are not in scope of SECR or UK SRS.
This is unusual — most ESOS qualifiers also meet SECR thresholds.
Example: an unlisted private group with significant industrial energy use that meets the 250-employee test but not the SECR "large company" definition.
ESOS and SECR.
Large UK companies and LLPs that meet both regimes' thresholds.
This is the most common position for large unlisted UK companies.
Obligations: an annual SECR disclosure in the Directors' Report plus an ESOS audit and compliance notification every four years.
ESOS, SECR, and UK SRS S2.
In-scope listed issuers on UKLR 6, 16 and 22 that also meet ESOS and SECR thresholds. (UKLR 14 and 15 issuers are within CP26/5's scope too, but would make a statement about the overseas or voluntary standards they follow rather than report under UK SRS itself — see below.)
Obligations: UK SRS S2 climate disclosure in the annual financial report (from accounting periods beginning 1 January 2027, subject to the FCA's final policy statement), annual SECR in the Directors' Report, and a four-yearly ESOS audit.
Example: a FTSE 350 commercial company with significant UK operations.
Quoted companies have additional SECR requirements: global Scope 1 and Scope 2 emissions disclosure, rather than just UK energy use.
ESOS Phase 4 — qualification, thresholds, and timeline
ESOS Phase 4 is the fourth four-year compliance cycle of the Energy Savings Opportunity Scheme, established by SI 2014/1643, originally made to implement the EU Energy Efficiency Directive and retained in UK law post-Brexit. The current amending instrument, SI 2026/701, is made under Energy Act 2023 sections 254–260 and 263 — that is now the operative vires, not the EU Directive.
Qualification date: 31 December 2026.
An organisation's status on this single date determines whether it is in scope of Phase 4.
Previous-phase non-qualification does not carry over — the test must be assessed afresh.
Thresholds (a UK undertaking is a "large undertaking" if):
- It employs 250 or more people, OR
- It has annual turnover above £44 million AND annual balance sheet total above £38 million (both financial tests must be met — meeting only one is not sufficient)
This is a different and higher test than SECR's. Alignment of the ESOS qualification thresholds with SECR was proposed but will not go ahead for Phase 4, and no Phase 5 commitment to it has been published.
If any UK undertaking within a corporate group meets the threshold, all other UK undertakings in that group are in scope.
The group definition follows the Companies Act 2006, capturing parent, subsidiary, and sister subsidiary undertakings.
Compliance period: 6 December 2023 to 5 December 2027.
The "responsible undertaking" must submit a notification of compliance to the Environment Agency (or devolved equivalent) by 5 December 2027.
Compliance routes (Phase 4):
- An ESOS energy audit reviewed by a Lead Assessor from an approved register (the standard route)
- ISO 50001 certification covering the organisation's total or significant energy consumption — significant meaning at least 95% of the total. Where it does, the participant is deemed to have complied with the duties to appoint a lead assessor, carry out the audit and produce the ESOS report; a notification of compliance is still required
- Display Energy Certificates (DECs) and Green Deal Assessments (GDAs) are removed as compliance routes: regulation 26 of SI 2026/701 omits regulation 34 of the 2014 Regulations, in force 22 July 2026
Penalties: ESOS enforcement is asymmetric.
Penalties attach to the compliance-date obligations — up to £50,000 plus up to £40,000 in daily penalties for failure to undertake an assessment, giving a £90,000 statutory maximum — but there is no direct penalty for non-submission of an action plan or a progress update: regulations 34A and 34B are named nowhere in Part 8's penalty chapter, a genuine statutory gap rather than regulatory forbearance.
The primary consequence is publication of the failure on the public register. There is a residual route: an enforcement notice served under regulation 38 requiring an action plan carries its own penalty (regulation 46(1)) if not complied with — £5,000 plus £500 per working day, capped at 80 working days.
The Environment Agency was actively enforcing Phase 3 compliance from 2024 onwards, including against organisations that filed late or filed incomplete notifications.
ESOS Thresholds
For more on thresholds and qualifying tests, see ESOS thresholds and qualification.
ESOS Action Plans and Progress Updates
ESOS Phase 3 introduced mandatory Action Plans and Annual Progress Updates — a significant reform that carries through into Phase 4.
Phase 3 Action Plan timeline (relevant to current obligations):
- Phase 3 Action Plan submission: originally 5 December 2024, extended to 5 March 2025 due to delays in the MESOS (Manage your Energy Savings Opportunity Scheme) portal
- Phase 3 Action Plan Progress Update 1: 5 December 2025 (covering the period 6 December 2024 – 5 December 2025)
- Phase 3 Action Plan Progress Update 2: 5 December 2026 (covering the period 6 December 2025 – 5 December 2026)
Phase 4 timeline (sequencing forward):
- Phase 4 qualification date: 31 December 2026
- Phase 4 compliance notification: 5 December 2027
- Phase 4 Action Plan: 5 December 2028, covering 6 December 2027 – 5 December 2031
- Phase 4 Progress Update 1: 5 December 2029
- Phase 4 Progress Update 2: 5 December 2030
- Phase 4 Progress Update 3: 5 December 2031 — new in Phase 4
These dates are tabulated in the Environment Agency's Phase 4 guidance, published 30 July 2026.
The third update was added by SI 2026/701 regulation 28.
The Action Plan must set out: steps to reduce energy consumption; implementation timelines; recommendations from the ESOS audit; expected energy savings over four years; and the methods used to estimate those savings.
Progress updates report on actual implementation and energy savings achieved.
Phase 4 adds two further duties: the ESOS report and notification must state the savings achieved during the compliance period — measures implemented, kWh saved per measure and each measure's saving category, with only the combined figure published — and must review the previous action plan, identifying proposed measures not implemented and why (not published).
All Action Plans and Progress Updates are submitted via the MESOS portal and made publicly available by the Environment Agency.
Where an organisation chooses not to submit an Action Plan or Progress Update, there is no direct financial penalty for that non-submission — the Environment Agency publishes the failure instead. There is a residual route, though: if a regulator serves an enforcement notice demanding one, failing to comply with that notice does carry the standard penalty under regulation 46(1).
SECR — Streamlined Energy and Carbon Reporting
SECR was introduced by The Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (SI 2018/1155), amending the Companies Act 2006 (particularly section 414CB) to require energy and carbon reporting in the Directors' Report or LLP Energy and Carbon Report.
Who is in scope:
- Quoted companies — companies whose equity share capital is on the Official List under FSMA Part 6, officially listed in an EEA state, or admitted to dealing on the NYSE or Nasdaq (Companies Act 2006 s.385(2)) — no size test, and additional requirements covering global Scope 1 and Scope 2 emissions. AIM-listed companies are not "quoted" for SECR — AIM securities are not admitted to the Official List, so an AIM company only reaches SECR scope via the size test below, and reports UK-only (not global)
- Large unquoted UK companies and LLPs — the size test is drafted as an exemption in paragraph 20B(2) of Schedule 7 to SI 2008/410, which exempts a company satisfying two or more of "not more than" £36 million turnover, "not more than" £18 million balance sheet total and "not more than" 250 employees. In scope therefore means exceeding at least two of those figures
- Large parent companies — must include consolidated group information where consolidated accounts are prepared
The "two of three" test is important: exceeding just one figure does not trigger SECR.
It is a two-of-three test, not an any-of-three test.
What must be reported:
- UK energy use (gas, electricity, transport fuel) for the reporting period in kWh
- Scope 1 and Scope 2 emissions (Scope 1 globally; Scope 2 globally for quoted companies, UK-only for unquoted)
- At least one intensity ratio (such as emissions per £m turnover or per unit of production)
- Methodology used to calculate the figures
- Narrative on energy efficiency measures taken during the reporting period
- Prior-year comparatives (from the second year of reporting)
- Voluntary Scope 3 disclosure is permitted but not required
De minimis exemption: An organisation consuming 40,000 kWh or less of energy in the UK during the reporting period may withhold the quantitative information.
The relief is not automatic — paragraph 20D(7)(a) requires the report to state that the information is not disclosed for that reason.
It is measured on UK consumption, and the figure is 40,000 kWh or less, not "under 40 MWh".
SECR Thresholds Update
SI 2024/1303 raised the general Companies Act 2006 size thresholds by roughly 50% for financial years beginning on or after 6 April 2025 (large for accounts purposes now above £54m turnover / £27m balance sheet). However, SECR thresholds were not amended. SECR continues to use £36m turnover and £18m balance sheet total.
The consequence is worth stating plainly: the SECR thresholds are now lower than the medium-sized accounts thresholds, so a company reclassified from large to medium-sized for accounts purposes can still be in SECR scope.
UK SRS S2 — the climate disclosure standard
UK SRS S2 is the UK-endorsed version of IFRS S2 — Climate-related Disclosures, published by the Department for Business and Trade on 25 February 2026.
It is available for voluntary use by any UK entity.
The FCA's Consultation Paper CP26/5, published 30 January 2026 and closed 20 March 2026, addresses five UK Listing Rules categories, but proposes mandatory UK SRS application to only three of them: UKLR 6 (Commercial companies), UKLR 16 (Non-equity shares), and UKLR 22 (Transition category), from accounting periods beginning on or after 1 January 2027.
UKLR 14 (Secondary listings) and UKLR 15 (Depositary receipts) are in scope of CP26/5 too, but would not report under UK SRS at all — they would instead make a statement identifying the overseas climate and sustainability disclosure requirements they are subject to (or any standards they voluntarily follow), and signposting where those disclosures can be found, alongside a sustainability-assurance statement on the same footing as Chapter 7.
Under CP26/5:
- UK SRS S2 climate disclosures would be mandatory, with Scope 3 emissions on a comply-or-explain basis
- Wider sustainability disclosures under UK SRS S1 would apply on a comply-or-explain basis
- In-scope companies must state whether and where a transition plan has been published, and whether voluntary assurance has been obtained
- No mandatory transition plan or mandatory assurance is proposed at this stage
No transitional relief periods survive in the final Standards
CP26/5's exposure-draft text (¶8.6) described a two-year non-disclosure relief for UK SRS S1 non-climate matters and a one-year relief for UK SRS S2 Scope 3 emissions. Neither period survives into the final published Standards — UK SRS S1 Appendix E and UK SRS S2 Appendix C carry no time-limited relief of that kind. Do not cite a one- or two-year deferral for either Standard.
The first mandatory UK SRS S2 reports would be published during 2028 for entities with December 2027 year-ends, and later for entities with later year-ends.
That is an inference from the effective date rather than an FCA statement.
A final FCA Policy Statement is expected in autumn 2026 and had not been published as of 20 August 2026.
The data overlap — same meters, different outputs
The three regimes draw on substantially the same underlying energy and emissions data, but require different presentations:
| Data type | ESOS Phase 4 | SECR | UK SRS S2 |
|---|---|---|---|
| Scope 1 GHG emissions | Required as part of audit baseline | Mandatory disclosure | Core climate metric (paragraph 29(a)) |
| Scope 2 GHG emissions | Required as part of audit baseline | Mandatory disclosure | Core climate metric, location-based mandatory (paragraph 29(a)(v)) |
| Scope 3 GHG emissions | Not required (some categories may inform audit) | Voluntary | Mandatory across all 15 categories where material; comply-or-explain under CP26/5 with optional one-year deferral |
| Energy consumption (kWh) | Central audit requirement | Mandatory disclosure (UK energy for unquoted; global for quoted) | Context for climate metrics |
| Energy efficiency measures | Action Plan requirement | Narrative disclosure required | Strategy and transition-plan context under paragraph 14 |
| Financial impact of energy/climate | Required for audit business cases (cost-benefit) | Voluntary commentary | Required quantitatively under paragraphs 15–21 |
| Scenario analysis | Not required | Not required | Mandatory under paragraph 22 |
| Targets and progress | Action Plan commitments (4-yearly) | Narrative disclosure | Required quantitative target disclosure under paragraphs 33–37 |
| Carbon credits | Not directly applicable | Optional commentary | Required disclosure where used to meet net targets under paragraph 36(e) |
The practical implication: an organisation in scope of all three regimes that builds three separate data infrastructures will be collecting the same meter readings, fuel invoices, and emission factors three times.
An organisation that builds one integrated infrastructure and outputs three regime-specific reports will save significant cost and reduce reporting error.
Where DESNZ has signalled rationalisation
The UK government's response to the UK SRS consultation, published by DBT on 25 February 2026, included an explicit commitment to consider how SECR interacts with UK SRS:
"DESNZ will consider how energy and emissions data reported by an entity using UK SRS interacts with the SECR requirements, with a view to reducing unnecessary duplication where possible."
Government Position
The DESNZ commitment on SECR interaction stops short of committing to any specific rationalisation — it signals intent without scope or timeline.
Note also that the DBT letter of 5 January 2026, sometimes cited as confirming that SECR and UK SRS continue as separate obligations, does not mention SECR at all. The correct citation is the government response of 25 February 2026 quoted above.
The 26 May 2026 post-implementation review
DESNZ published the statutory post-implementation review of SECR on 26 May 2026, with the formal departmental recommendation "Amend".
"The overarching recommendation is to retain the SECR requirements with amendments… Removing SECR would risk reversing gains in transparency and board level accountability."
Refinements will be explored through a planned 2026 consultation on streamlining energy and emissions reporting, which had not launched as of 27 July 2026.
The review also describes SECR enforcement as "light touch", working "well for quoted companies, where FRC oversight is strongest", but "less effective for the wider private/LLP cohort".
There is no SECR-specific regulator: enforcement rides on Companies Act 2006 machinery through the FRC's Conduct Committee, an authorised body under section 457, via Corporate Reporting Review.
Claims that UK SRS will replace or phase out SECR are therefore not supported by any government document.
What has been signalled:
- Recognition that UK SRS S2 and SECR cover overlapping data and create duplicative reporting
- DESNZ commitment to "consider" the interaction with a view to reducing duplication "where possible"
- Acknowledgement that large companies will be in scope of both regimes
- Recognition that ESOS, SECR, and TCFD-aligned reporting are all candidates for streamlining under the wider Modernising Corporate Reporting (MCR) programme
What has not been decided:
- Whether ESOS will be included in any rationalisation review (the explicit DESNZ commitment names SECR but not ESOS)
- Timeline for any changes to reporting requirements
- Whether formal cross-referencing between regimes will be permitted, and how
- Whether the SECR provisions in sections 414CA and 414CB of the Companies Act 2006 will be amended or repealed
- The interaction with the FCA's Listing Rules and the proposed CP26/5 mandatory regime
Planning assumption: Until further guidance is published, organisations should plan for full compliance with all three regimes separately.
Any rationalisation is likely to be incremental and take several years to implement.
Section 463 Companies Act 2006 — the safe harbour for sustainability disclosure
Where UK SRS disclosures are included in the Strategic Report, the protective provisions of section 463 of the Companies Act 2006 automatically apply.
Section 463 is a liability limitation for directors, not a source of additional liability — a point sometimes misreported.
Under section 463, a director is only liable to compensate the company for an untrue or misleading statement in (or omission from) the Strategic Report or Directors' Report where the director:
- Knew the statement to be untrue or misleading, or was reckless as to whether it was untrue or misleading, or
- Knew the omission to be a dishonest concealment of a material fact
The DBT consultation response confirmed that this safe harbour applies to UK SRS disclosures included in the Strategic Report, providing welcome clarity for directors of in-scope companies.
The same protection does not automatically extend to disclosures published outside the Strategic Report — companies should consider where they locate UK SRS disclosures for this reason.
The 2026–2027 timing pressure
UK SRS S2 is proposed mandatory from January 2027, just under a year before the ESOS Phase 4 compliance deadline on 5 December 2027.
Organisations in scope of both face a compressed window:
2026 preparation year:
- 5 December 2026 — Phase 3 ESOS Action Plan Progress Update 2 deadline
- 31 December 2026 — ESOS Phase 4 qualification date
- Throughout 2026 — UK SRS S2 preparation and voluntary application; SECR continues annually
- Autumn 2026 — FCA Policy Statement on CP26/5 expected (confirming or amending mandatory listed-issuer scope and timeline)
- 15 December 2026 — ISSA (UK) 5000 becomes effective for engagements on periods beginning on or after this date, or as at a specific date on or after it (earlier application is permitted, and the standard is for voluntary use in any event)
2027 compliance year:
- 1 January 2027 — UK SRS S2 proposed mandatory for in-scope listed issuers (for accounting periods beginning on or after this date)
- Throughout 2027 — ESOS Phase 4 audits conducted with Lead Assessors
- 5 December 2027 — ESOS Phase 4 compliance notification deadline
- SECR continues with annual Directors' Report inclusion
2028 first reports year:
- Spring 2028 — First mandatory UK SRS S2 reports published (for December 2027 year-ends)
- Scope 3 transition relief ends under CP26/5 proposals (Scope 3 then comply-or-explain ongoing)
- 5 December 2028 — Phase 4 Action Plan deadline
The risk for in-scope organisations is sequential rather than simultaneous reporting deadlines, with overlapping data requirements but separate compliance teams.
Building integrated data infrastructure in 2026 is the single most effective preparatory action.
Managing all three regimes with one data infrastructure
Most large UK organisations approach ESOS, SECR, and UK SRS as separate compliance projects with separate teams, separate consultants, and separate datasets.
A more efficient approach treats them as different outputs from one underlying data infrastructure:
Common data foundation
- Energy consumption data: meter readings, supplier invoices, calculated consumption by fuel type and site. Required for all three regimes; the granularity required by ESOS audits is the most demanding and naturally satisfies SECR and UK SRS needs.
- Scope 1 and Scope 2 emissions: calculated from energy data using the UK GHG conversion factors published annually each June by DESNZ. The current set is Greenhouse gas reporting: conversion factors 2026, published on 11 June 2026. Core requirement across ESOS, SECR, and UK SRS S2.
- Organisational boundaries: financial control, operational control, or equity share methodologies. Consistency across regimes is recommended but not strictly required; document any differences explicitly.
- Baseline and historical data: ESOS audits need 12 months of continuous data within the qualification period; SECR requires annual data with prior-year comparatives; UK SRS S2 requires trend disclosure under cross-industry metrics.
Regime-specific outputs
- ESOS Phase 4: energy audit report and Action Plan, submitted via MESOS portal four-yearly. Lead Assessor sign-off required. Includes energy efficiency opportunities and business case analysis.
- SECR: Directors' Report disclosure, filed annually with statutory accounts. Includes energy figures, methodology note, and energy efficiency narrative.
- UK SRS S2: climate-related financial disclosure in the annual financial report (Strategic Report or equivalent), annually. Four-pillar framework: governance, strategy, risk management, metrics and targets. Includes Scope 1, 2, and 3 emissions; scenario analysis; targets; and (for financial institutions) financed emissions.
How ESOS data feeds UK SRS S2 disclosures
The energy audit data collected for ESOS supports several UK SRS S2 requirements directly:
| ESOS output | UK SRS S2 requirement supported |
|---|---|
| Energy consumption by site, fuel, and process | Scope 1 and Scope 2 emissions calculation (paragraph 29(a)); business model and value chain disclosure (paragraph 13) |
| Energy efficiency opportunities identified | Strategy and decision-making — current and anticipated mitigation efforts (paragraph 14(a)(ii)) |
| Business case analysis (cost-benefit) | Current and anticipated financial effects (paragraphs 15–21); capital deployment metrics (paragraph 29(e)) |
| Action Plan commitments | Transition plan information (paragraph 14(a)(iv)); how the entity plans to achieve targets (paragraph 14(a)(v)) |
| Progress against Action Plan | Progress against plans disclosed in previous reporting periods (paragraph 14(c)); performance against targets (paragraph 35) |
| Lead Assessor sign-off | Supports verification and assurance readiness for UK SRS S2 |
How long UK SRS S2 implementation actually takes
Companies waiting for the FCA Policy Statement to begin preparation are already late. Practitioner consensus puts end-to-end implementation at twelve to eighteen months — driven by Scope 3 data, which can't be compressed.
Last verified 27 July 2026 · Click any workstream for detail
From kickoff to first UK SRS S2 report. Driven by Scope 3 supplier engagement and quantitative scenario modelling — neither compressible.
Of Scope 3 data work — from supplier engagement onset through validation. Of the 15 GHG Protocol categories, Category 1 and Category 11 typically account for >70% of total Scope 3 emissions.
Foundation phase before data work meaningfully begins. Materiality assessment and gap analysis are pre-requisites — running data collection without these creates wasted effort.
The reverse flow also works: UK SRS S2 scenario analysis (paragraph 22) can inform ESOS audit scoping by identifying which sites, processes, or assets are most exposed to transition risks and therefore where energy efficiency measures will have the greatest financial impact.
Practical recommendations
If you are in scope of ESOS Phase 4 only:
- Confirm qualification at 31 December 2026 — assess group structure including joint ventures and complex ownership
- Engage a Lead Assessor, or maintain ISO 50001 certification covering total or significant energy consumption — and still submit a notification of compliance
- Begin or refresh energy data collection covering the 12-month audit reference period
- Identify and cost energy efficiency opportunities; prepare Action Plan content, and the achieved-savings and action-plan-review data Phase 4 now requires
- Submit compliance notification via MESOS portal by 5 December 2027
- Submit Phase 4 Action Plan by 5 December 2028, then progress updates on 5 December 2029, 2030 and 2031
If you are in scope of ESOS and SECR:
- Complete all ESOS Phase 4 steps above
- Ensure SECR annual disclosure in the Directors' Report uses the same underlying energy data, with appropriate methodology disclosure
- Track Companies Act 2006 size threshold changes — the 2025 increases did not change SECR thresholds, but future amendments could
- Document organisational boundaries consistently across both regimes
If you are in scope of all three regimes:
- Complete ESOS and SECR steps as above
- Map existing TCFD-aligned disclosures against UK SRS S2 requirements (paragraphs 5–37); identify gaps in governance, strategy, risk management, metrics, and targets
- Begin or upgrade climate scenario analysis to meet UK SRS S2 paragraph 22 — consider NGFS and IEA scenarios
- Begin Scope 3 emissions data infrastructure (supplier engagement is the long-lead-time work); use CP26/5 one-year transition relief if needed
- Engage assurance providers early for ISSA (UK) 5000 scoping
- Build governance integration across sustainability, finance, risk, legal, and operations functions
- Monitor the FCA Policy Statement (autumn 2026) for confirmed scope and timeline
For all organisations regardless of regime:
- Treat ESOS Action Plan content as a regulatory commitment, not a paper exercise. Phase 4 requires explanation of unmet commitments and ties progress reporting to compliance status
- Use the same emission factors and organisational boundaries across all reports unless there is a specific reason not to. Inconsistency triggers assurance queries and reduces report credibility
- Plan for assurance readiness even though assurance is not mandatory. ISSA (UK) 5000 is for voluntary use — it governs how an assurance engagement is performed if one is commissioned, and creates no obligation to obtain assurance — and CP26/5 proposes only that in-scope companies state whether or not they have obtained it