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
Quick Overview: ESOS vs SECR
The two threshold tests are not the same
Announced alignment of the ESOS qualification thresholds with SECR was postponed to Phase 5.
SI 2026/701, the Phase 4 amendment in force 22 July 2026, did not change the ESOS thresholds.
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)
Measurement Standards:
- ESOS: DBT guidance methodology + approved standards
- SECR: Environmental Reporting Guidelines methodology
Assurance Requirements:
- ESOS: Lead Assessor sign-off mandatory
- 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
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Last verified 27 July 2026 · Subject to FCA Policy Statement on CP26/5, unpublished as of that date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
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
Practical Integration Strategies for Dual Compliance
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.
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 a detailed Action Plan with specific energy efficiency measures, and from Phase 4 a report of the savings actually achieved — measures implemented and kWh saved per measure, per the Environment Agency Phase 4 guidance of 30 July 2026
- 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