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
202420262027202820292025
DBT
Standards publisher · private companies
12 May 2026
25 Jun 2025Consultation opens[1]
17 Sep 2025Closes · 209 responses[2]
25 Feb 2026UK SRS S1, S2 published[3]
FCA
Listed-company regulator · CP26/5
12 May 2026
30 Jan 2026CP26/5 published[4]
20 Mar 2026Consultation closes[5]
Autumn 2026Policy Statement[6]
FRC
Assurance · TAC and PIC secretariat
12 May 2026
Dec 2024TAC initial advice[7]
12 Nov 2025ISSA (UK) 5000 issued[8]
26 Jan 2026TAC final letter to DBT[9]
15 Dec 2026ISSA (UK) 5000 effective[8]
Effect
Proposed mandatory application
12 May 2026
1 Jan 2027UK SRS S2 in force[10]
1 Jan 2028Scope 3 relief ends[10]
1 Jan 2029S1 deferral ends[10]
DBT events
FCA events
FRC events
Mandatory effect (proposed)
Future / proposed (hollow marker)
Reading guide. The horizontal "now" line shows the date the page was last verified. Hollow markers and italic labels indicate future events that are proposed but not yet legally binding — they depend on the FCA's autumn 2026 Policy Statement or on separate DBT regulation. The clustering of events around February 2026 is genuine: in a five-week window the FCA opened CP26/5 (30 Jan), the TAC sent its final letter to DBT (26 Jan), and DBT published the final standards (25 Feb).
Primary sources
[1]DBT, "Consultation on Exposure Drafts of UK Sustainability Reporting Standards" — published 25 June 2025, closed 17 September 2025. gov.uk consultation page
[2]DBT Government Response, paragraph 1.6 — 209 responses (170 online survey, 39 by email; 199 organisations, 10 individuals). Government Response · web version
[3]DBT publication of final UK SRS S1 and S2 — 25 February 2026. Standards available for voluntary use immediately; no effective date clauses. DBT publication page
[4]FCA Consultation Paper CP26/5 — "Aligning listed issuers' sustainability disclosures with international standards", published 30 January 2026. FCA CP26/5 landing page
[5]FCA CP26/5 consultation closed — 20 March 2026. Substantive submissions from Norges Bank Investment Management, the Quoted Companies Alliance, the Investment Association and Big Four assurance firms. Norges Bank IM response
[6]FCA Policy Statement — expected autumn 2026, per CP26/5 timetable. Final rules subject to Policy Statement; could adopt, modify, or delay the proposals.
[7]UK Sustainability Disclosure Technical Advisory Committee (TAC) — initial endorsement recommendations to DBT, December 2024. Hosted by the FRC. FRC · TAC page
[8]FRC, ISSA (UK) 5000 — sustainability assurance standard published 12 November 2025, effective for engagements covering periods beginning on or after 15 December 2026. FRC · ISSA (UK) 5000
[9]TAC supplementary written recommendations to the Secretary of State for Business and Trade — 26 January 2026. Addressed financed emissions and incorporation of ISSB December 2025 amendments to IFRS S2. FRC · TAC endorsement project
[10]FCA CP26/5, Chapter 8 (Implementation and transitional arrangements) — proposed in-force date 1 January 2027 for UK SRS S2 (UKLR 6, 16, 22); one-year optional Scope 3 deferral; two-year optional S1 deferral. All dates subject to Policy Statement. CP26/5 full text (PDF)
Dual Compliance
Large companies often need both ESOS 4-yearly audits and SECR annual reporting — coordination reduces costs and improves consistency
UK large undertakings (250+ employees, OR turnover above £44m AND balance sheet total above £38m)
Quoted companies of any size; large unquoted companies and LLPs exceeding at least two of £36m turnover, £18m balance sheet total, 250 employees
Output
Energy audit + Action Plan
Directors' Report disclosure
Deadline
Qualification 31 December 2026; compliance 5 December 2027 (Phase 4)
Annual, with the statutory accounts
Regulator
Environment Agency + devolved
Companies House filing
Penalties
Civil penalties up to £90,000 for failure to undertake an assessment; none for a missed action plan or progress update
No SECR-specific sanction; enforcement rides on Companies Act 2006 machinery via the FRC's Conduct Committee
The two threshold tests are not the same
Announced alignment of the ESOS qualification thresholds with SECR was postponed to Phase 5.
It does not apply to ESOS Phase 4, and any source telling you the two regimes now share a threshold is wrong.
ESOS is an OR between limbs with an AND inside the financial limb; SECR is a two-of-three test drafted as an exemption in paragraph 20B(2) of Schedule 7 to SI 2008/410.
Detailed Side-by-Side Comparison
Legal Basis:
ESOS: Energy Savings Opportunity Scheme Regulations 2014
SECR: Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018
Entity Types:
ESOS: Any undertaking (companies, partnerships, LLPs, unincorporated associations)
SECR: Companies and LLPs only (partnerships exempt unless corporatised)
Geographic Scope:
ESOS: UK operations only
SECR: UK operations only (with some international subsidiaries included)
SECR: External assurance encouraged but not mandatory
De minimis:
ESOS: audits must cover at least 95% of total energy consumption
SECR: a company or LLP consuming 40,000 kWh or less of energy in the UK may withhold the quantitative information, but must state in the report that it is doing so for that reason
Compliance Scenarios by Organisation Type
Sustainability Reporting Standards · Scope decision aid
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
Question 1
Is the entity listed on the UK Main Market?
i.e. admitted to one of the categories under the UK Listing Rules
No, AIM-listed or unlisted
Yes, Main Market
Question 2
Which UKLR category?
The category determines the rules under FCA CP26/5
UKLR 6, 16, 22
Proposed mandatory UK SRS S2 from 1 Jan 2027
For Commercial (UKLR 6), Non-equity (UKLR 16), and Transition (UKLR 22) listed companies, FCA CP26/5 proposes UK SRS S2 climate disclosures — excluding Scope 3 — and comply-or-explain UK SRS S1 disclosures from accounting periods beginning on or after 1 January 2027. 515 listed companies are in full scope, of around 600 affected. Subject to the FCA Policy Statement (autumn 2026, not yet published). A company may elect a one-year Scope 3 relief and a two-year S1 relief; when each expires the topic falls to comply-or-explain, which is drafted without a sunset.
For Secondary listing (UKLR 14) and Depositary Receipts (UKLR 15), the FCA proposes a flexible approach. Companies would not apply UK SRS in full but would disclose the climate and sustainability reporting requirements applicable in their primary listing location, plus any voluntary standards adopted.
AIM is an LSE-operated market governed by AIM Rules, not the UKLR
Yes, AIM-listed
Out of CP26/5
Not in scope of FCA's proposed mandatory rules
AIM is operated by the London Stock Exchange under the AIM Rules for Companies — it is not a UKLR category. AIM companies are out of scope of CP26/5. AIM Rules may impose their own sustainability disclosure requirements; AIM companies may also voluntarily adopt UK SRS at any time.
Banks, insurers, large entities of public significance
PIE — Yes
s414CB(1)–(5) climate disclosures apply
PIEs must include a non-financial and sustainability information statement in the Strategic Report. Under s414CB(2A), the Government has designated UK SRS S2 as a national reporting framework — using UK SRS S2 satisfies the climate-related disclosure requirements. Voluntary adoption strongly recommended.
Voluntary adoption available · monitor MCR consultation
Large unlisted companies meeting the SECR two-of-three test (£36m turnover, £18m balance sheet, 250 employees) continue under SECR. UK SRS is voluntary today. The Modernising Corporate Reporting programme will consider whether the Companies Act should require private entities to report against UK SRS, but that consultation has not been published and no scope, threshold or date has been proposed by government.
UK SRS is available for voluntary use by any UK entity — including small businesses, charities, LLPs and partnerships. Voluntary adoption is all-or-nothing for the standard adopted (S1 or S2) and reliefs can be used indefinitely until any future mandatory rules apply.
ESOS only:
Large private companies, partnerships, LLPs meeting ESOS thresholds but not SECR company thresholds.
Example: Private partnership with 300+ employees, £30m turnover. Obligations: ESOS audit every 4 years only.
SECR only:
UK companies in SECR scope but not ESOS.
Example: a small quoted company with 200 employees and £40m turnover — in SECR scope because quoted companies are caught regardless of size, but below the ESOS test. Obligations: Annual SECR in Directors' Report only.
Both regimes:
Large companies meeting both sets of thresholds.
Example: Major listed company, 500+ employees, £100m+ turnover. Obligations: Annual SECR + ESOS audit every 4 years.
Neither regime:
Small unquoted companies and partnerships below both tests.
Example: Private company, 50 employees, £10m turnover. Obligations: No energy reporting requirements.
Data Overlap and Synergies
High overlap areas:
Scope 1 & 2 emissions: Both require calculation from energy consumption data
Energy consumption: Core data requirement for both regimes
Methodology: Similar calculation approaches for comparable outputs
Low overlap areas:
Scope 3 emissions: SECR optional, ESOS excludes
Energy efficiency measures: ESOS requires detailed analysis, SECR brief narrative
Future projections: ESOS Action Plan vs SECR historical focus
Same meter readings
Most organisations collect the same underlying energy data twice rather than building integrated systems. Energy consumption and emissions calculations use similar methodologies but different reporting formats.
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
Foundation phase
Data infrastructure
Governance & controls
Assurance & output
Critical path workstream
Workstreams
M1
M2
M3
M4
M5
M6
M7
M8
M9
M10
M11
M12
M13
M14
M15
M16
M17
M18
Materiality assessment
Gap analysis & strategy
Governance framework
Training & capability
Scope 1 & 2 data
Scope 3 supplier engagement
Scope 3 data validation
Scenario methodology
Quantitative scenarios
Connectivity mapping
Transition planning
Dry run & rehearsal
Assurance preparation
Report preparation
Click any bar above for workstream detail, typical effort, and dependencies.
Critical path
18 months
From kickoff to first UK SRS S2 report. Driven by Scope 3 supplier engagement and quantitative scenario modelling — neither compressible.
Scope 3 dominance
14 months
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.
Earliest sensible start
3 months
Foundation phase before data work meaningfully begins. Materiality assessment and gap analysis are pre-requisites — running data collection without these creates wasted effort.
Single data collection system:
Centralised energy consumption database covering all UK operations
Standardised meter reading and invoice processing procedures
Consistent organisational boundary definitions where possible
Shared emission factors and calculation methodologies
Coordinated reporting cycle:
ESOS audit conducted in year of SECR enhanced disclosure
Energy efficiency measures identified in ESOS feed into SECR narrative
Lead Assessor engagement timed to support both reporting requirements
ESOS audit years (every 4 years):
Enhanced SECR disclosure with ESOS audit insights
Detailed energy efficiency analysis for both reports
Action Plan development supports future SECR narratives
Non-ESOS years (3 out of 4 years):
Standard SECR compliance with basic energy efficiency measures
Implementation tracking of ESOS Action Plan measures
Data collection maintenance for next ESOS cycle
Common governance structure:
Single sustainability/ESG team managing both regimes
Integrated compliance calendar and deadline management
Coordinated external advisor procurement for efficiency
Planning recommendation
Organisations subject to both regimes should establish integrated energy data systems and coordinate reporting cycles. This reduces duplication and ensures consistency between ESOS Action Plans and SECR energy efficiency narratives.
Key Differences in Practice
Data requirements:
ESOS requires 95% coverage of total energy consumption
SECR requires all UK energy consumption (100% coverage)
Reporting outputs:
ESOS produces detailed Action Plan with specific energy efficiency measures
SECR produces Directors' Report narrative with summary information
Enforcement approach:
ESOS uses civil penalties administered by the Environment Agency — up to £50,000 plus up to £40,000 in daily penalties for failure to undertake an assessment, but no penalty at all for a missed action plan or progress update
SECR has no dedicated regulator and no civil sanction regime of its own. Enforcement rides on Companies Act 2006 machinery: the FRC's Conduct Committee, an authorised body under section 457, monitors compliance through Corporate Reporting Review. DESNZ described this in May 2026 as "light touch"
Professional requirements:
ESOS requires qualified Lead Assessor involvement
SECR has no mandatory professional oversight requirement