UK SRS vs SECR: What's the Difference?
Comparing Mandatory SECR Reporting With the Proposed UK Sustainability Reporting Standards
UK SRS S1 & S2 published 25 February 2026 for voluntary use by any entity. The FCA has proposed mandatory reporting for most listed companies from periods beginning January 2027, but has not yet published its policy statement — nobody is required to report under UK SRS today.
Quick Comparison: SECR vs UK SRS
| Aspect | SECR (Mandatory Now) | UK SRS (Voluntary Now; Proposed From 2027) |
|---|---|---|
| Scope | Energy & carbon emissions only | Full sustainability: Environment, social, governance |
| Who Must Report | Quoted companies (any size, no size test); large unquoted companies & LLPs exceeding two of three size thresholds | Nobody today. If the FCA proceeds, listed companies in UKLR 6, 16 & 22 would be required; a lighter-touch statement is proposed for UKLR 14 & 15 |
| Reporting Location | Directors' report | Separate sustainability report or integrated annual report |
| Legal Basis | Statutory instrument (SI 2008/410 Sch. 7) — mandatory, not guidance | ISSB-aligned voluntary standards (S1 General, S2 Climate) — no statutory or regulatory duty exists yet |
| Emissions Scope | Scope 1 & 2 mandatory; Scope 3 not required for quoted companies, and mandatory only for the narrow transport-fuel limb for large unquoted companies & LLPs | Gross Scope 1, 2 & 3 proposed, subject to materiality — not in force for anyone yet |
| Assurance | Not required | Assurance proposed by the FCA for listed companies, not yet finalised |
| Transition Planning | Not required | No duty exists today; UK SRS S2 asks entities to disclose any transition plan they have, not to create one |
Transition Timeline
Now - December 2026
SECR continues as mandatory requirement
Continue SECR reporting in annual reports
Voluntary early adoption available now
Autumn 2026 (expected)
FCA expected to publish its policy statement on CP26/5 — no date has been announced
January 2027 (proposed)
FCA's proposed start date for mandatory reporting by in-scope listed companies, subject to its policy statement
Not yet confirmed — the FCA has not finalised its rules
No further phases have been announced
Beyond 2027
DESNZ has committed only to considering how UK SRS and SECR interact, with a view to reducing duplication where possible — not to a timetable for extending UK SRS to further entities
Key Differences Explained
Scope of Reporting
SECR (Current)
- Energy consumption only
- GHG emissions (Scope 1 & 2)
- Energy efficiency actions
UK SRS (Proposed From 2027)
- Full climate-related disclosures
- Material sustainability topics
- Governance & strategy
- Risk management
- Metrics & targets
Emissions Reporting
SECR Requirements
- Scope 1:Direct emissions (mandatory)
- Scope 2:Purchased energy (mandatory)
- Scope 3:Not required for quoted companies; large unquoted companies & LLPs must report only transport-fuel consumption
UK SRS — as proposed, not yet in force for anyone
- Scope 1:Gross direct emissions
- Scope 2:Purchased energy
- Scope 3:Material categories, subject to entity-specific materiality
- In-scope asset managers, banks & insurers already have separate financed-emissions duties under the FCA ESG sourcebook, in force since 2022/2023 — not part of UK SRS
Reporting Format
SECR Format
Brief section in Directors' Report (typically 1-2 pages)
- • Energy use & emissions data
- • Intensity ratio
- • Methodology statement
UK SRS Format
Comprehensive sustainability report (20-50+ pages)
- • TCFD-aligned structure
- • Scenario analysis
- • Transition planning
- • Cross-references to financials
Strategic Requirements
SECR Focus
Historical performance reporting
- • Past year emissions
- • Year-on-year comparison
- • Energy efficiency actions taken
UK SRS Focus
Forward-looking strategy & resilience
- • Climate scenario analysis
- • Transition plan disclosure, where the entity has one
- • Physical & transition risks
- • Strategic resilience testing
Who Is Affected by UK SRS?
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.
Nothing below is in force yet. These are the FCA's proposals in CP26/5, not confirmed requirements — see the FAQs for the current, voluntary-only status of UK SRS.
Proposed to Comply, If FCA Rules Proceed
- Commercial companies category (UKLR 6)
- Non-equity & non-voting equity shares category (UKLR 16)
- Transition category (UKLR 22)
- Around 515 of ~600 affected listed companies
Lighter-Touch Statement Proposed
- Secondary listing category (UKLR 14)
- Depositary receipts category (UKLR 15)
- Around 89 companies — a statement of overseas/voluntary standards followed, not UK SRS disclosure
SECR Applies Now, Separately of Listing
- Quoted companies — any size, no size test
- Large unquoted companies exceeding two of three thresholds
- Large LLPs, under a separate provision
- Charities, public bodies & partnerships are not a distinct SECR category — only caught, if at all, as a large unquoted company
SECR size thresholds (unquoted companies): large = exceeding two of: turnover more than £36m, balance sheet total more than £18m, more than 250 employees — a company sitting exactly on a limb is not in scope. This test is self-contained in Sch. 7 ¶20B of SI 2008/410 and did not move when Companies Act size limits were uplifted in April 2025. Large LLPs use a different, separately-numbered threshold in SI 2008/1911 reg 12B.
What Companies Need to Do Now
Preparation Checklist for UK SRS
The FCA has proposed 1 January 2027 as the start date for mandatory reporting by in-scope listed companies, but it has not yet published its policy statement, so this date is not confirmed. The steps below are worth starting on a voluntary basis regardless of the eventual date.
1. Gap Analysis (Q2 2026)
- • Assess current SECR reporting against UK SRS requirements
- • Identify data gaps, especially for Scope 3 emissions
- • Review governance structures for sustainability oversight
2. Data Systems (Q3 2026)
- • Implement carbon accounting software
- • Establish Scope 3 data collection processes
- • Set up internal controls and audit trails
3. Governance (Q4 2026)
- • Appoint board-level sustainability committee
- • Define roles and responsibilities
- • Link executive remuneration to sustainability metrics
4. Strategy Development (Q1 2027)
- • Conduct climate scenario analysis
- • Develop transition plan to net zero
- • Set science-based targets
5. First Report (Q1 2028)
- • Draft UK SRS-compliant sustainability report
- • Obtain limited assurance (if required)
- • Publish alongside annual report
Benefits of Early UK SRS Preparation
Competitive Advantage
Early adopters attract ESG investors and win sustainability-focused contracts
Smoother Transition
Avoid last-minute rush and ensure high-quality first UK SRS report
Cost Efficiency
Build on existing SECR processes rather than starting from scratch in 2027
UK SRS vs SECR FAQs
Will SECR be replaced by UK SRS?
Not on any confirmed timetable. SECR remains a mandatory Companies Act requirement today, and nobody is currently required to report under UK SRS — it is available for voluntary use only, and the FCA has not yet published a policy statement on its proposed rules for listed companies.
The Department for Energy Security and Net Zero has committed to considering how UK SRS and SECR interact, with a view to reducing unnecessary duplication where possible — a commitment to consider, not a commitment to merge the two regimes.
If your company later becomes subject to UK SRS, your SECR-style energy and Scope 1 & 2 data would likely feed into UK SRS S2's climate disclosures, but the two remain separate legal requirements today.
Can we use the same data for both SECR and UK SRS?
Largely yes. If you already collect SECR data — Scope 1 & 2 emissions, energy consumption — it can feed directly into UK SRS S2's climate disclosures if you adopt UK SRS voluntarily or once it is mandated.
UK SRS asks for considerably more: material Scope 3 categories, climate-related risks and opportunities, governance information, and forward-looking metrics that go well beyond SECR's requirements.
Is UK SRS mandatory, and what would happen if a company didn't comply?
No — as things stand, UK SRS is voluntary for every entity and nobody is required to report against it. The FCA has proposed making it mandatory for most listed companies from periods beginning January 2027, subject to a policy statement it expects to publish in autumn 2026 but has not yet published.
If and when the FCA's rules take effect, non-compliance by a listed company would be handled under the FCA's existing Listing Rules enforcement powers, rather than a separate UK SRS penalty regime, because none currently exists.
How much more work is UK SRS compared to SECR?
Substantially more. SECR is a short section of the directors' report covering historical energy and emissions data. UK SRS is a full sustainability report spanning governance, strategy, risk management, and metrics and targets, with material Scope 3 categories and (if adopted) transition-plan disclosure.
The first year typically involves the most work — gap analysis, new data collection, governance changes and report drafting — with a lighter ongoing burden once processes are established. We have not found a government-published estimate of the hours involved, so treat any specific figure you see elsewhere with caution.
For a framework-by-framework guide to the underlying sustainability reporting standards, see our sister reference site.
Want to Talk It Through?
If it would help to talk through your transition from SECR to UK SRS, we offer a free, no-obligation call — no sales pitch.