The UK SRS regulatory timeline
Five-year path from the Technical Advisory Committee's first endorsement recommendation to the proposed comply-or-explain mandate for broader sustainability disclosures. Three regulators, two committees, one set of standards.
Last verified 12 May 2026 · Tap a milestone for sources
Dual Obligation Period
SECR and UK SRS are separate obligations, and SECR is being kept.
The DESNZ statutory post-implementation review published on 26 May 2026 carries 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.
SECR Obligations Remain in Place
The Streamlined Energy and Carbon Reporting regulations, SI 2018/1155 (the SECR regulations), in force for accounting periods 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 large unquoted companies and LLPs that exceed at least two of three figures: turnover £36m, balance sheet total £18m, and 250 employees.
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 "not more than" those figures — so it is a two-of-three test, not an any-of-three test.
A 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.
The disclosure requirements include total UK energy consumption, GHG Protocol Corporate Standard Scope 1 and Scope 2 greenhouse gas emissions disclosure, an intensity ratio, and narrative description of energy efficiency measures taken during the reporting period.
How UK SRS Extends Beyond SECR
UK SRS does not replace SECR but significantly expands disclosure requirements.
Where SECR focuses on energy consumption and basic greenhouse gas emissions, UK SRS requires comprehensive disclosures including IFRS S2 scenario analysis, risk and opportunity assessment, and quantified financial impacts.
UK SRS S2 is not intended to supersede SECR, and no government document proposes that it should.
The DBT government response of 25 February 2026 commits only to consider the interaction: "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." The DESNZ post-implementation review of 26 May 2026 then recommended retaining SECR with amendments, with refinements to be explored through a planned 2026 consultation that has not yet launched.
Data Consistency Requirements
For companies subject to both frameworks, SECR emissions data and UK SRS disclosures cannot contradict each other.
Companies must maintain consistency using the same underlying GHG measurement systems while accommodating different reporting boundaries.
The practical risk is fragmentation if different teams prepare SECR and UK SRS disclosures using different methodologies.
Companies should establish a single source of truth for emissions data with clear reconciliation where reporting boundaries differ.
Who enforces what
There is no SECR-specific regulator and no SECR-specific civil sanction regime.
Enforcement rides on Companies Act 2006 machinery: the disclosures sit in the directors' report filed at Companies House, and the FRC's Conduct Committee — an authorised body under section 457 of the Companies Act 2006 — monitors compliance through Corporate Reporting Review and can apply to court for revised accounts.
DESNZ characterises the regime as "light touch", working "well for quoted companies, where FRC oversight is strongest", but "less effective for the wider private/LLP cohort".
UK SRS, by contrast, would be supervised by the FCA under the UK Listing Rules for in-scope issuers, with the approach to monitoring and enforcement to be set out in a future Primary Market Bulletin.
Managing the Dual Obligation
During the period when both frameworks apply, companies should adopt an integrated approach.
With FCA CP26/5 mandatory UK SRS S2 from 1 January 2027 proposed, companies need structured processes to manage dual reporting efficiently.
Rather than treating SECR and UK SRS as separate workstreams, companies should establish an integrated reporting process that produces data for both frameworks from a single underlying dataset, minimising duplication and inconsistency risks.