SECR vs UK SRS 2026

Current Position (2026)

SECR Status

• Remains mandatory for quoted companies and large unquoted companies/LLPs
• In force since 1 April 2019
• Unchanged scope — approximately 11,900 organisations
• No modifications planned for 2026 filing cycle

UK SRS Status

• Standards published 25 February 2026 by the Department for Business and Trade
• FCA consultation closed 20 March 2026 on mandatory implementation
• Not yet mandatory — currently voluntary for all organisations

Proposed Changes from 2027

UK SRS S2 Mandatory Implementation

FCA CP26/5 proposes UK SRS S2 is proposed to become mandatory from 2027 for:

• Premium-listed companies on London Stock Exchange Main Market
• Standard-listed companies (subject to FCA Policy Statement)
• Approximately 515 primary-listed companies in initial scope
• Climate disclosures under UK SRS S2 framework

SECR Continues Unchanged

• Scope remains: Quoted companies + large unquoted companies/LLPs
• Requirements unchanged: Six core SECR disclosures continue
• Deadlines unchanged: Standard Companies House filing deadlines
• Government review promised: Interaction assessment to "reduce unnecessary duplication"

Scope Comparison

SECR Scope

UK SRS S2 Scope (Proposed from 2027)

Key Differences

• SECR includes unquoted companies — UK SRS S2 does not (initially)
• UK SRS limited to listed — much smaller scope than SECR
• Different size thresholds — SECR uses company size tests, UK SRS uses listing status

Requirements Comparison

SECR Requirements (Current)

1. UK energy consumption (kWh)
2. Scope 1 emissions (tCO₂e)
3. Scope 2 emissions (tCO₂e)
4. Intensity ratio (emissions per business metric)
5. Methodology description
6. Energy efficiency actions
7. Prior year comparatives

UK SRS S2 Requirements (Climate Standard)

1. Governance — oversight of climate risks and opportunities
2. Strategy — climate risks/opportunities and business impact
3. Risk Management — climate risk identification and management
4. Metrics and Targets — performance measurement including:
   • Scope 1, 2, and 3 emissions
   • Climate-related metrics
   • Progress against targets

Coverage Overlap

• Scope 1 & 2 emissions: Both frameworks require these
• UK SRS much broader: Includes governance, strategy, risk management
• UK SRS includes Scope 3: SECR does not mandate Scope 3
• SECR simpler: Six discrete requirements vs comprehensive framework

What This Means for Different Company Types

Quoted Companies (Listed)

Current (2026):

• ✅ SECR mandatory — continue existing compliance
• ⚪ UK SRS voluntary — may adopt early for preparation

From 2027:

• ✅ SECR continues — six core requirements remain
• ✅ UK SRS S2 likely mandatory — comprehensive climate framework
• 📋 Dual compliance — manage both frameworks simultaneously

Recommendation: Start UK SRS S2 preparation during 2026 to enable 2027 compliance

Large Unquoted Companies

Current (2026):

• ✅ SECR mandatory — continue existing compliance
• ⚪ UK SRS voluntary — may adopt for competitive advantage

From 2027 onwards:

• ✅ SECR continues — primary mandatory framework unchanged
• ⚪ UK SRS remains voluntary — not in proposed scope
• 📋 Supply chain pressure — customers may require UK SRS alignment

Recommendation: Monitor customer ESG requirements and consider voluntary UK SRS adoption

Large LLPs

Current (2026):

• ✅ SECR mandatory — continue existing compliance
• ⚪ UK SRS voluntary — available but not required

From 2027 onwards:

• ✅ SECR continues — unchanged requirements and deadlines
• ⚪ UK SRS remains voluntary — LLPs not listed entities
• 📋 Client requirements — may face pressure from listed clients

Recommendation: Focus on SECR compliance, monitor professional service client demands

Transition Planning Considerations

For Quoted Companies

1. Immediate (2026): Continue SECR compliance as normal
2. Preparation phase: Begin UK SRS S2 gap analysis and data system preparation
3. 2027 readiness: Establish processes for comprehensive climate disclosure
4. Efficiency planning: Identify overlapping data collection and reporting processes

For Large Unquoted Companies/LLPs

1. Core focus: Maintain robust SECR compliance systems
2. Market monitoring: Track customer/supply chain ESG requirements
3. Voluntary consideration: Assess business case for UK SRS adoption
4. Future-proofing: Build SECR systems with potential UK SRS expansion in mind

Timeline Summary

Key Differences Summary

The relationship between SECR and UK SRS is evolving. While SECR remains the primary mandatory framework for most organisations, quoted companies should prepare for dual compliance from 2027. The promised government review may bring changes, but SECR itself remains firmly in place as the UK's primary corporate climate disclosure requirement.