UK SRS vs SECR · Comparison
UK SRS vs SECR: two regimes, side by side
SECR is a statutory duty, in force since 2019, for quoted companies, large unquoted companies and large LLPs to report energy use and emissions.
UK SRS is a pair of standards, voluntary for most entities, that listed companies report against on a comply-or-explain basis from 2027 under the FCA’s PS26/19.
Neither replaces the other, and a listed company can be in both.
Quick comparison
SECR and UK SRS, line by line
| SECR (statutory, in force) | UK SRS (voluntary; comply or explain for listed companies from 2027) | |
|---|---|---|
| Subject | Energy use and greenhouse gas emissions | All material sustainability-related risks and opportunities (S1), with climate set out in S2 |
| Who reports | Quoted companies of any size; unquoted companies exceeding at least two size limits; large LLPs | Listed companies in UKLR 6, 14, 15, 16 and 22; anyone else voluntarily |
| Legal basis | SI 2008/410 Sch 7 Parts 7 and 7A (inserted by SI 2018/1155); SI 2008/1911 reg 12B for LLPs | The standards, applied to listed companies by FCA listing rules (PS26/19) |
| Where it goes | Directors’ report (companies); energy and carbon report (LLPs) | General purpose financial reports; for listed companies, the annual financial report |
| Emissions | Quoted: emissions from activities the company is responsible for, plus purchased energy, with the UK share. Unquoted: UK energy use, gas, electricity and transport fuel | Absolute gross Scope 1, 2 and 3 under the GHG Protocol (S2 ¶29(a)) |
| Intensity ratio | At least one, chosen by the company | Not among the cross-industry metrics, which are absolute figures |
| Forward-looking content | None: no targets, no transition plan | Strategy, resilience, scenario analysis and targets |
| Assurance | Not required | Not required; if obtained, the provider, scope and standards are named |
| Transition plan | Not required | Disclose whether one exists and where (PS26/19); no duty to have one |
| Supervision | Companies Act: s.419 offence, court-ordered revision, FRC review | The FCA, under the listing rules |
SECR itself applies under SI 2018/1155 for financial years beginning on or after 1 April 2019, covering quoted companies, large unquoted companies and large LLPs.
SECR is covered in full in our guide to Streamlined Energy and Carbon Reporting.
Timeline
How the two regimes line up in time
SECR continues as a statutory requirement through 2026 and 2027.
UK SRS has been available for voluntary use since 25 February 2026, and applies to listed companies in scope for periods beginning on or after 1 January 2027.
The Department for Energy Security and Net Zero has committed to consider how energy and emissions data reported under UK SRS interacts with SECR, with a view to reducing unnecessary duplication where possible (government response, Chapter 3).
The Modernising corporate reporting consultation proposes abolishing the directors’ report, which would move SECR disclosures elsewhere in the first half of the annual report without changing who reports or what.
The same document says DESNZ intends to consult on SECR and ESOS later in 2026; that consultation has not yet appeared.
- 1 Apr 2019SECR begins
Financial years beginning on or after this date.
- 25 Feb 2026UK SRS S1 and S2 published
Voluntary use by any entity.
- 26 May 2026SECR review published
Retain SECR with amendments.
- 30 Sep 2026FCA PS26/19
Listed companies: UK SRS on comply or explain.
- 30 Nov 2026Modernising corporate reporting closes
Includes the proposal to move SECR out of the directors’ report.
- 1 Jan 2027UK SRS rules apply
Periods beginning on or after this date; SECR continues.
Sources: SI 2018/1155 · DBT · DESNZ · FCA · BIST
Key differences
Scope, emissions, format and direction of travel
Scope of reporting
SECR: energy consumption, greenhouse gas emissions, an intensity ratio and a narrative on energy-efficiency action.
UK SRS: climate-related disclosures under S2, plus every other material sustainability topic under S1, organised as governance, strategy, risk management, and metrics and targets.
Emissions reporting
SECR: for quoted companies, emissions from combustion of fuel and operation of facilities plus purchased electricity, heat, steam and cooling, with the share in the UK and offshore area; for unquoted companies and LLPs, UK gas, electricity and transport fuel.
UK SRS: absolute gross Scope 1, 2 and 3 under the GHG Protocol; financed emissions for banks, insurers and asset managers.
Reporting format
SECR: a section of the directors’ report: energy and emissions data, at least one intensity ratio, and a methodology statement.
UK SRS: disclosures within the general purpose financial reports, connected to the financial statements and closed with a statement of compliance.
Direction of travel
SECR: historical performance: the past year, the prior-year comparison and action taken. DESNZ’s review calls it “backward-looking, with no forward targets or transition plans”.
UK SRS: forward-looking: climate resilience, scenario analysis, targets and any transition plan.
In-scope asset managers and asset owners already report financed emissions under the FCA’s ESG sourcebook, a separate duty from UK SRS.
Companies already reporting against the TCFD are closer to UK SRS than SECR-only reporters, and our page on TCFD reporting explains why.
Who is affected
Who reports under each, and the thresholds
SECR applies now, whatever the listing. Quoted companies report under Schedule 7 Part 7, with no size test at all.
Unquoted companies are in scope unless they meet two or more of the qualifying conditions in Schedule 7 paragraph 20B: turnover not more than £36 million, balance sheet total not more than £18 million, not more than 250 employees.
That test is self-contained and did not move when the Companies Act size limits were raised for periods beginning on or after 6 April 2025.
Large LLPs report under a separate provision, SI 2008/1911 regulation 12B, with the same figures.
An AIM company is unquoted for SECR, so the size test applies to it.
Charities, public bodies and academy trusts are not SECR categories; they are caught, if at all, as large unquoted companies.
UK SRS applies to listed companies in UKLR 6, 14, 15, 16 and 22 from periods beginning on or after 1 January 2027; the FCA’s consultation, CP26/5, estimated around 600 would be affected.
Details of the listing-rule obligation are on our UK SRS compliance page.
| SECR limb | Unquoted company (¶20B) | Parent, group (¶20C) |
|---|---|---|
| Turnover | Not more than £36m | Not more than £36m net (£43.2m gross) |
| Balance sheet total | Not more than £18m | Not more than £18m net (£21.6m gross) |
| Employees | Not more than 250 | Not more than 250 |
What to do
A preparation checklist for SECR reporters facing UK SRS
For a listed company with a calendar year end, the first UK SRS period starts on 1 January 2027. A company outside the listing rules can take the same steps voluntarily, on its own timetable.
| Step | What it involves |
|---|---|
| 1 · Gap analysis | Compare current SECR reporting with UK SRS S1 and S2; Scope 3, scenario analysis and governance disclosure are gaps by design, because SECR does not ask for them. |
| 2 · Data systems | Extend SECR energy and emissions data to the full reporting entity, add Scope 3 categories, and document methods and controls. |
| 3 · Governance | Name the board body and individuals that oversee climate risk, and record how often they are informed. |
| 4 · Strategy | Carry out scenario analysis; decide whether to disclose a transition plan (only if one exists) and any targets; record whether climate factors into executive pay, which UK SRS S2 ¶29(g) asks about. |
| 5 · First report | Publish with the annual financial report; decide on the reliefs; assurance is optional. |
A company that already collects SECR data is not starting from nothing: Scope 1 and 2 methods, the government conversion factors and the reporting cycle all carry across.
The difference is breadth: UK SRS reaches the whole reporting entity, the whole value chain and the future, where SECR looks at a year of energy use.
Enforcement
What happens if it goes wrong
A defective directors’ report is an offence under section 419 of the Companies Act 2006 for each director who knew it did not comply, or was reckless, and failed to take reasonable steps.
The court can also order the report to be revised under section 456, and the FRC reviews directors’ reports.
Under UK SRS, an explanation is a compliant answer; a listed company that neither discloses nor explains is in breach of the listing rules, which the FCA supervises.
UK SRS S2 is also a national reporting framework for section 414CB(6), so a company reporting under it need not duplicate its Companies Act climate-related financial disclosures.
DESNZ’s 2026 review of SECR found 19,900 organisations in scope, 76% more than the 11,300 forecast in 2018.
For a framework-by-framework guide to the underlying sustainability reporting standards, see the family’s standards site.
If it would help to talk through how SECR and UK SRS fit together for you, you can book a free 15-minute call.
Neither SI 2018/1155 nor Schedule 7 creates a penalty.
The consequences come from the Companies Act.
Frequently asked
Questions people ask
Will SECR be replaced by UK SRS?
No. SECR remains a statutory requirement. The Department for Energy Security and Net Zero's 2026 post-implementation review recommended retaining SECR with amendments, and the department has said it will consider how energy and emissions data reported under UK SRS interacts with SECR, with a view to reducing unnecessary duplication where possible. That is a review of overlap, not a merger.
Can we use the same data for SECR and UK SRS?
Largely, for Scope 1 and 2. SECR energy use and emissions data can feed UK SRS S2's greenhouse gas metrics. UK SRS asks for more: gross Scope 3 across the value chain, climate-related risks and opportunities, governance, scenario analysis and targets. The boundaries also differ: UK SRS covers the same reporting entity as the financial statements, while SECR for unquoted companies is UK energy use.
Is UK SRS mandatory, and what happens if a listed company does not comply?
UK SRS is voluntary for most entities. For listed companies in scope, the FCA's final rules in PS26/19 require reporting against UK SRS on a comply-or-explain basis from accounting periods beginning on or after 1 January 2027, so an explanation is a compliant answer. A listed company that neither discloses nor explains is in breach of the listing rules, which the FCA supervises.
Who has to report under SECR?
Three populations: quoted companies of any size; unquoted companies that exceed at least two of the three size limits (turnover more than £36 million, balance sheet total more than £18 million, more than 250 employees); and large LLPs under a separate provision with the same figures. AIM companies are unquoted for SECR, so the size test applies to them.
Did the SECR thresholds change in April 2025?
No. The Companies Act size limits rose for periods beginning on or after 6 April 2025, but SECR's test is written into its own table in Schedule 7 paragraph 20B of SI 2008/410 and does not refer to them. The SECR figures remain £36 million turnover, £18 million balance sheet total and 250 employees.
Does SECR require Scope 3 emissions?
Only very narrowly. Unquoted companies and LLPs report emissions from fuel used for transport, and no other Scope 3 category appears in the regulations. Quoted companies have no Scope 3 duty under SECR. UK SRS S2 asks for gross Scope 3 emissions, which listed companies report or explain after a one-year relief.
Does SECR need to be assured?
No. Nothing in the SECR provisions mentions assurance, verification or audit. The statutory auditor checks that the directors' report is consistent with the accounts and prepared in accordance with the law, which is not assurance over the emissions data. UK SRS does not require assurance either.
How much more work is UK SRS than SECR?
Substantially more. SECR is a backward-looking section of the directors' report on energy and emissions. UK SRS covers governance, strategy, risk management, and metrics and targets, with Scope 3, scenario analysis and forward-looking information. No government estimate of the hours involved is cited here, so treat any specific figure seen elsewhere with caution.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- legislation.gov.ukThe Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (SI 2018/1155)
The instrument that created SECR, for financial years beginning on or after 1 April 2019.
- legislation.gov.ukSI 2008/410, Schedule 7, Part 7 (quoted companies), ¶¶15–20
No size test; emissions from activities the company is responsible for.
- legislation.gov.ukSI 2008/410, Schedule 7, Part 7A (unquoted companies), ¶¶20A–20K
UK energy use, transport fuel, the intensity ratio and the 40,000 kWh relief.
- legislation.gov.ukSI 2008/410, Schedule 7, paragraph 20B — the size test
Exempt where two or more of: turnover not more than £36m; balance sheet not more than £18m; not more than 250 employees.
- legislation.gov.ukSI 2008/1911 (LLP accounts regulations), regulation 12B
The LLP energy and carbon report and its thresholds.
- legislation.gov.ukCompanies Act 2006, section 419
The directors’ offence for a non-compliant directors’ report.
- legislation.gov.ukCompanies Act 2006, section 414CB
Climate-related financial disclosures; UK SRS S2 is a national framework under s.414CB(6).
- Department for Energy Security and Net Zero2026 post-implementation review of the SECR Regulations 2018
Published 26 May 2026: retain SECR with amendments.
- Department for Energy Security and Net ZeroSECR post-implementation review, final conclusions (PDF)
19,900 organisations in scope against 11,300 forecast; "no forward targets or transition plans".
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures, ¶29 (PDF)
Gross Scope 1, 2 and 3 and the other cross-industry metrics.
- Department for Business and TradeGovernment response to the UK SRS consultation, Chapter 3
DESNZ will consider the UK SRS–SECR interaction.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Final rules, 30 September 2026.
- Financial Conduct AuthorityPS26/19 policy statement (PDF)
¶¶1.7, 2.24, 3.6, 3.12–3.14.
- Financial Conduct AuthorityCP26/5 consultation paper (PDF)
The consultation the final rules replace.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Open until 30 November 2026.
- Department for Business, Innovation, Science and TradeModernising corporate reporting, ¶¶149–150 (PDF)
Proposes moving SECR out of the abolished directors’ report; DESNZ to consult on SECR and ESOS.
- GHG ProtocolCorporate Accounting and Reporting Standard
The Scope 1, 2 and 3 framework UK SRS uses.
- Department for Energy Security and Net ZeroGovernment conversion factors for company reporting
UK emission factors, published each year.