SECR and UK SRS

Current position

The Streamlined Energy and Carbon Reporting (SECR) regulations and UK Sustainability Reporting Standards represent separate regulatory frameworks with different policy objectives.

SECR became effective 1 April 2019 and addresses energy efficiency and carbon transparency.

UK SRS S2 is proposed for mandatory application from 1 January 2027 and addresses climate-related financial risks and opportunities.

DBT’s UK SRS consultation response records a commitment on this point: the Department for Energy Security and Net Zero will consider how UK SRS energy and emissions data interacts with SECR, “with a view to reducing unnecessary duplication where possible” — not a commitment to merge or replace either regime.

UK SRS was not designed to replace SECR, and SECR was not conceived as a bridge to broader sustainability disclosure (DESNZ).

Each serves distinct policy purposes within the UK's climate regulatory framework.

Dual obligations

Companies may face dual obligations if they meet both SECR scope criteria (quoted companies, large unquoted companies, large LLPs) and the UK SRS scope CP26/5 proposes (UKLR categories 6, 16 and 22 in full; 14 and 15 signposting only).

Premium and standard listing ceased to exist on 29 July 2024.

The overlap primarily affects UKLR category 6 companies that also meet the SECR reporting thresholds (two of three: turnover >£36m, balance sheet >£18m, employees >250).

These SECR thresholds are unchanged.

The 2024 company-size uplift under SI 2024/1303 (in force 6 April 2025) raised the general medium and large accounts boundaries but left the SECR thresholds in Schedule 7 to SI 2008/410 untouched — so qualification for SECR is assessed on the same turnover, balance-sheet and employee tests as before.

Companies Act 2006 section 463 provides director safe harbour for false or misleading statements in the Strategic Report, Directors' Report, and directors' remuneration report.

Directors are only liable if they knew the statement was false or misleading, were reckless about it, or knew an omission was dishonest concealment.

This protection applies to both UK SRS content (in the Strategic Report, via the national reporting framework route at section 414CB(6)) and SECR content (in the Directors' Report filed under the SECR deadline framework).

Data overlap and reuse

SECR and UK SRS have limited but meaningful data overlap (SI 2018/1155).

SECR requires Scope 1 and 2 GHG emissions, UK energy consumption in kWh, and at least one intensity ratio expressing annual emissions against a quantifiable factor the company chooses (SI 2008/410 Sch 7 ¶¶15, 17, 20D and 20G).

UK SRS S2 requires Scope 1, 2, and 3 GHG emissions with materiality assessment and, under UK SRS S1’s Connected information requirements (¶¶21–24), consistent links to the financial statements.

Companies can reuse SECR Scope 1 and 2 emissions data for UK SRS, provided the methodology follows DBT Environmental Reporting Guidelines and GHG Protocol Corporate Standard.

However, UK SRS requires additional context including materiality justification, Connected information linking disclosures to the financial statements, and risk analysis that SECR does not address.

SECR energy consumption data (kWh) may inform UK SRS transition risk disclosures, particularly for energy-intensive sectors (UK SRS S1 and S2).

UK SRS intensity metrics should reflect business model risks and may extend beyond SECR's standardised revenue or employee ratios.

Regulatory review underway

DESNZ’s 2026 Post-Implementation Review of the SECR Regulations 2018 (26 May 2026) recommends retaining SECR requirements with amendments, not replacing them.

The review names five candidate areas for a possible future consultation on streamlining energy and emissions reporting, none yet opened: eligibility and boundary guidance, a standardised disclosure template, alignment with ISSB/CSRD/TCFD, light-touch forward-looking elements, and digital access options.

On the relationship with UK SRS specifically, DBT’s UK SRS consultation response records that DESNZ — not DBT generically — will consider how UK SRS energy and emissions data interacts with SECR, “with a view to reducing unnecessary duplication where possible.”

As at the 2026 review, no SECR consultation or statutory instrument implementing that commitment had appeared.

DBT’s 5 January 2026 letter to the FCA, cited elsewhere on this page for UK SRS relief timing, addresses transitional reliefs and FCA consultation coordination — it does not mention SECR and should not be read as addressing it.

DESNZ owns SECR and DBT owns UK SRS; the two departments’ commitments on this point are separate and should not be conflated.

Practical dual obligation management

Companies facing dual obligations should establish integrated data collection processes while maintaining regime-specific disclosure approaches (DBT Environmental Reporting Guidelines).

Consistent GHG accounting methodologies across both regimes reduce compliance burden and improve data quality.

Many companies also need to consider comprehensive carbon SECR PPN ESOS integration as part of their broader sustainability regulatory framework.

For disclosure location, SECR appears in the Directors' Report as a separate section, while UK SRS appears in the Strategic Report as part of the NFSIS (FRC).

The FRC's Strategic Report guidance recommends cross-referencing between sections where data overlap occurs.

Assurance considerations differ between regimes (SI 2018/1155).

SECR has no assurance requirement: no paragraph of SI 2008/410 Sch 7 Parts 7 or 7A mentions assurance, verification or audit, and the DBT Environmental Reporting Guidelines say so outright — “there is no statutory requirement to have your environmental information audited”.

UK SRS allows voluntary assurance under ISSA (UK) 5000.

Companies adopting UK SRS assurance may benefit from extending coverage to SECR disclosures for consistency.

Future relationship

The regulatory trajectory suggests continued parallel operation with potential coordination enhancements (DESNZ Post-Implementation Review).

Future SECR refinements, if pursued through the areas identified in the 2026 review, could improve alignment with UK SRS without merging the two regimes.

IFRS Foundation materiality guidance influences both UK SRS materiality assessment and potential future SECR refinements.

UK SRS adoption may drive broader corporate sustainability practices that enhance SECR compliance quality.

Companies developing UK SRS materiality processes, strategy integration, and risk analysis capabilities often find these benefit SECR implementation through improved data governance and internal controls.

The emergence of voluntary UK SRS assurance under ISSA (UK) 5000 may create market pressure for SECR assurance adoption, even though not required by regulation.

Professional services firms are developing integrated audit approaches covering both regimes.