SECR and UK SRS

Current position

1The Streamlined Energy and Carbon Reporting (SECR) regulations and UK Sustainability Reporting Standards represent separate regulatory frameworks with different policy objectives2.

SECR became effective 31 April 2019 and addresses energy efficiency and carbon transparency.

UK SRS S2 is proposed for proposed mandatory application from 41 January 2027 and addresses climate-related financial risks and opportunities.

The Department for Business and Trade confirmed in its 5 January 2026 letter to the FCA2 that both regimes will continue.

UK SRS was not designed to replace SECR, and 1SECR was not conceived as a bridge to broader sustainability disclosure.

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

Dual obligations

Companies may face dual obligations if they meet both 3SECR scope criteria (quoted companies, large unquoted companies, large LLPs) and 4UK SRS scope criteria (UKLR Premium and Standard listed companies).

The overlap primarily affects Premium listed companies that also meet the 3SECR reporting thresholds(two of three: turnover >£36m, balance sheet >£18m, employees >250).

Companies Act 2006 section 4636 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 under section 414CB(2A)7) and SECR content3 (in the Directors' Report filed under the SECR deadline framework).

Data overlap and reuse

SECR and UK SRS have limited but meaningful data overlap. 3

SECR requires Scope 1 and 2 GHG emissions, UK energy consumption in kWh, and intensity metrics (GHG per revenue or per employee). 5

UK SRS S2 requires Scope 1, 2, and 3 GHG emissions with materiality assessment and financial connectivity analysis.

Companies can reuse SECR Scope 1 and 2 emissions data for UK SRS, provided the 8methodology follows DBT Environmental Reporting Guidelines and GHG Protocol Corporate Standard.

However, UK SRS requires additional context including materiality justification, strategic connectivity, and risk analysis that SECR does not address.

3SECR energy consumption data (kWh) may inform UK SRS transition risk disclosures, particularly for energy-intensive sectors. 5

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

Regulatory review underway

1DESNZ completed a post-implementation review of SECR in February 2024, finding the regime "broadly effective" in improving corporate energy and carbon transparency.

The review identified areas for improvement including clearer methodology guidance, better integration with net zero policies, and enhanced data quality requirements.

The review concluded that 1"SECR and UK SRS serve complementary purposes without duplication" and recommended maintaining both frameworks.

DESNZ stated that any future enhancements to SECR would focus on 1"operational improvements rather than fundamental restructuring."

2DBT's 5 January 2026 letter to the FCA confirmed this position, stating that "both regimes address different policy objectives and will continue to operate in parallel."

The letter noted that 2"coordination between departments ensures complementary rather than duplicative requirements."

Practical dual obligation management

Companies facing dual obligations should establish integrated data collection processes while maintaining regime-specific disclosure approaches. 8

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, 3SECR appears in the Directors' Report as a separate section, while 7UK SRS appears in the Strategic Report as part of the NFSIS. 9

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

Assurance considerations differ between regimes. 3

SECR has no assurance requirement. 4

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. 1

DESNZ's post-implementation review signalled openness to "methodological harmonisation" without regime merger. 10

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 5UK 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.