SECR and UK SRS: how the two regimes overlap

The Streamlined Energy and Carbon Reporting regulations, SI 2018/1155, in force for financial years beginning on or after 1 April 2019, require qualifying UK companies and LLPs to disclose their energy consumption and greenhouse gas emissions.

SECR applies to quoted companies regardless of size, and to unquoted companies and LLPs that fall outside a two-of-three size exemption.

The statute is drafted as an exemption: paragraph 20B(2) of Schedule 7 to SI 2008/410 exempts a company satisfying two or more of turnover not more than £36m, balance sheet total not more than £18m and not more than 250 employees.

So it is a two-of-three test, not an any-of-three test.

An unquoted company or LLP consuming 40,000 kWh or less of energy in the UK during the period may withhold the quantitative disclosure, but must state in the report that it is doing so for that reason; a quoted company’s version of the relief has no UK qualifier.

Whether a given company is caught at all is the subject of is SECR mandatory?, and how the three figures are measured is on the SECR thresholds page.

The disclosures cover energy consumption in kWh; emissions in tonnes CO2e from gas, transport fuel and purchased electricity — broadly Scope 1 and 2 in GHG Protocol Corporate Standard terms, with a narrow transport-fuel Scope 3 limb for unquoted companies and LLPs; at least one intensity ratio; and a narrative of energy efficiency measures taken during the period.

The SECR and UK SRS overlap is the energy and emissions dataset.

Both regimes report greenhouse gas emissions for the same period, so a company subject to both should be able to reconcile the two sets of figures.

Neither instrument requires the other’s figure to be reproduced, but the reporting boundaries differ.

SECR lets unquoted companies and LLPs exclude consumption outside the UK, and asks quoted companies under paragraph 15 for global figures with a UK and offshore proportion, while UK SRS S1 ¶20 requires the disclosures to cover the same reporting entity as the financial statements.

DESNZ’s post-implementation review records that “slight definitional and boundary differences still create duplicated effort and sometimes inconsistent numbers across reports”.

What the SECR side of that dataset has to contain is set out in our SECR reporting guide; if ESOS applies as well, see ESOS, SECR and UK SRS together.

SECR is the only mandatory framework of the two.

UK SRS is a voluntary standard, and for most entities it stays that way.

For in-scope listed issuers, the FCA’s final rules (PS26/19, 30 September 2026) require reporting against UK SRS on a comply-or-explain basis from accounting periods beginning on or after 1 January 2027, finalising FCA CP26/5.

Listed companies subject to both frameworks can benefit from structured processes to manage dual reporting efficiently from their first in-scope period.

Rather than treating SECR and UK SRS as separate workstreams, establish an integrated reporting process that produces data for both frameworks from a single underlying dataset.

That minimises duplication and the risk of inconsistent figures.

For what a programme involves, see the UK SRS compliance guide; for the legal bases side by side, see UK SRS legislation.