SECR vs UK SRS · 30 September 2026
SECR vs UK SRS: two regimes, one set of data
SECR vs UK SRS is not a choice: SECR is law for quoted companies, large unquoted companies and large LLPs, and UK SRS is a pair of standards that listed companies now report against on a comply-or-explain basis.
The FCA’s final rules, PS26/19, published on 30 September 2026, apply to accounting periods beginning on or after 1 January 2027, with first reports in 2028.
Nothing replaces SECR, and this page sets out where the two meet.
The short answer
UK SRS does not replace SECR
SECR is a duty in the Companies Act regime, created by SI 2018/1155 and set out in Schedule 7 to SI 2008/410.
UK SRS S1 and S2 are standards, published by the Department for Business and Trade on 25 February 2026 and available for voluntary use by any entity.
The standards carry no effective date of their own; an obligation to use them has to come from the Companies Act, the FCA or another regulator.
The FCA has now made one, for listed companies only, and it is comply or explain.
The Companies Act route has not been proposed: the government says only that it will consider how UK SRS should be reflected in the Companies Act 2006.
So for most of the 19,900 organisations in SECR scope, UK SRS remains voluntary, and for listed companies it is an additional layer on top of SECR.
Law: SECR, for quoted companies, large unquoted companies and large LLPs.
Final listing rules: UK SRS on a comply-or-explain basis for listed companies in UKLR 6, 14, 15, 16 and 22, periods from 1 January 2027.
Voluntary: UK SRS for every other UK entity.
Proposed: moving SECR out of the directors’ report.
Planned: a DESNZ consultation on SECR and ESOS later in 2026.
PS26/19
What the FCA’s final rules say
The FCA’s landing page says it has finalised rules requiring listed companies to report against UK SRS on a comply-or-explain basis.
The policy statement adopts “a comply or explain approach across all categories of disclosures”, so UK SRS S2 is not mandatory under the final rules, although CP26/5 had proposed that it would be.
The rules cover listed companies in UKLR 6 (commercial companies), UKLR 14 (international commercial companies with a secondary listing), UKLR 15 (depositary receipts), UKLR 16 (non-equity and non-voting equity shares) and UKLR 22 (transition).
Closed-ended investment funds, open-ended investment companies, shell companies and issuers of debt, securitised derivatives and miscellaneous securities are excluded.
The policy statement gives no total company count; CP26/5 had estimated that around 600 listed companies would be affected.
Two reliefs are available: two years’ non-disclosure under UK SRS S1 for non-climate matters, and one year’s non-disclosure of Scope 3 emissions under UK SRS S2.
A company using a relief must say so, and no further explanation is required during the relief period.
Companies disclose whether they have a climate-related transition plan and, if so, where it can be found; there is no duty to have one.
Where assurance is obtained, the company names the provider, the disclosures assured and the assurance standards used; assurance itself is not required.
From consultation to rules
- 30 Jan 2026CP26/5 published
Proposed mandatory UK SRS S2 for most listed companies.
- 25 Feb 2026UK SRS S1 and S2 published
Department for Business and Trade; voluntary use.
- 20 Mar 2026CP26/5 closes
- 30 Sep 2026PS26/19 published
Final rules: comply or explain across UK SRS.
- 1 Jan 2027Periods begin
Accounting periods beginning on or after this date.
- 2028First reports
The first annual reports under the rules.
Sources: FCA CP26/5; DBT; FCA PS26/19
Side by side
SECR and UK SRS, compared
| SECR | UK SRS (S2 for climate) | |
|---|---|---|
| What it is | A statutory disclosure duty in the directors' report | A pair of standards; used under FCA listing rules or voluntarily |
| Legal basis | SI 2008/410 Sch 7 Parts 7 and 7A; SI 2008/1911 reg 12B | For listed companies, the UK Listing Rules as finalised in PS26/19 |
| Status | In force since 1 April 2019 | Comply or explain for listed companies from periods beginning 1 January 2027; voluntary for everyone else |
| Who | Quoted companies (any size), large unquoted companies, large LLPs — 19,900 in scope | Listed companies in UKLR 6, 14, 15, 16 and 22; CP26/5 estimated around 600 |
| Emissions | By activity: fuel, facilities and purchased energy (quoted); gas, transport fuel and electricity (unquoted, LLP) | Absolute gross Scope 1, 2 and 3 under the GHG Protocol Corporate Standard (¶29(a)) |
| Scope 3 | Transport fuel only, and only for large unquoted companies and LLPs | Required by the standard; under PS26/19 comply or explain, with a one-year relief |
| Beyond emissions | Energy in kWh, one intensity ratio, methodology, efficiency measures | Governance, strategy, risk management, metrics and targets |
| Transition plan | Not required | State whether one exists and where; not required |
| Assurance | Not required | If obtained, name the provider, scope and standards; not required |
The clause-by-clause reference for UK SRS S2 is maintained on uksrs.org.uk, and how the two standards fit together is at UK SRS S1 and S2.
What SECR asks for, paragraph by paragraph, is on SECR requirements.
Listed companies
Both regimes, one set of energy data
A UK company whose shares are on the official list is a quoted company under section 385 of the Companies Act 2006, so it reports under SECR at any size.
If it is in one of the FCA’s categories, it now reports against UK SRS as well, from accounting periods beginning on or after 1 January 2027.
The same energy records feed both, but the figures are not interchangeable.
UK SRS S2 paragraph 29(a) requires absolute gross Scope 1, Scope 2 and Scope 3 emissions measured under the GHG Protocol Corporate Standard.
SECR describes emissions by activity, and the government guidance calls the mapping to Scope 1 and 2 broadly similar, not identical.
Neither allows offsets to be netted off: S2 asks for gross emissions, and SECR has no netting provision.
DESNZ has committed to “consider how energy and emissions data reported by an entity using UK SRS interacts with the SECR requirements, with a view to reducing unnecessary duplication where possible”, in the government’s UK SRS consultation response.
That is a commitment to consider, not to merge; as at 30 September 2026 no consultation or instrument has followed it.
The same response confirms that UK SRS S2 is a national reporting framework for section 414CB(6), so a company can use it to meet its climate-related financial disclosure duty without duplicating it.
And section 463’s safe harbour applies to UK SRS disclosure placed in the strategic report, as the response confirms, so where it sits matters.
Boundary: UK SRS follows the financial statements’ reporting entity; SECR follows Schedule 7.
Categories: SECR counts activities; UK SRS S2 counts scopes.
Scope 3: SECR’s transport-fuel limb is not a Scope 3 inventory.
Unquoted companies and LLPs
SECR stays; UK SRS is optional
For large unquoted companies and LLPs, SECR is the only one of the two that is required.
No UK entity outside the FCA’s listed categories is required to use UK SRS, and no government document proposes a threshold or date for private companies.
The Modernising corporate reporting consultation, published on 7 September 2026 and open until 30 November 2026, says the government “will consider how UK SRS should be reflected in the Companies Act 2006”; that is the whole of it.
An AIM company is unquoted for SECR, and AIM is not one of the listing categories PS26/19 covers, so unless it also holds such a listing, UK SRS is voluntary for it and SECR applies only if it is large.
Any entity may adopt the standards voluntarily, and the government’s guidance says so in those terms.
Whether an unquoted company or LLP is large enough for SECR is on SECR thresholds and SECR for LLPs.
Is SECR being replaced?
Reviewed, retained, possibly relocated
SECR was designed in a 2017–18 consultation as a streamlined successor to earlier energy and carbon schemes, and it has not been amended since it came into force.
DESNZ’s post-implementation review, published on 26 May 2026, recommended retaining SECR requirements with amendments.
Alignment of SECR definitions and metrics with ISSB, CSRD and TCFD is one of five areas a planned consultation may explore, and the review says none of the five is a final decision.
The Modernising corporate reporting consultation proposes abolishing the directors’ report, and says SECR disclosures will move with no prescribed replacement location — an address, not a duty.
The same document records that DESNZ intends to consult on SECR and ESOS later in 2026, to explore longer-term options to reform SECR; as at 30 September 2026 that consultation has not been published.
Until any of that becomes law, the SECR duty is unchanged, and the DESNZ evaluation that informs it counted 19,900 organisations in scope.
For the fuller UK SRS timeline, see the dedicated tracker; the primary reference for the UK Sustainability Reporting Standards is uksrs.org.uk.
In practice
What each kind of company should do now
Listed, in UKLR 6, 14, 15, 16 or 22
Keep filing SECR. Plan UK SRS reporting for the first accounting period beginning on or after 1 January 2027, decide which reliefs you will use, and reconcile the SECR boundary and categories with a GHG Protocol inventory.
Large unquoted company or LLP
Keep filing SECR on the paragraph 20B or regulation 12B basis. UK SRS is voluntary; watch the Modernising corporate reporting outcome and the promised DESNZ consultation.
Below the SECR thresholds
Neither regime requires anything. A customer may still ask for energy or emissions data, and the SECR structure is a sensible template for it.
The SECR reporting cycle itself is on SECR reporting, and the regime’s other neighbour is covered on ESOS vs SECR.
To talk a specific company’s position through, you can book a free 15-minute call.
Frequently asked
SECR and UK SRS — frequently asked
Is SECR being replaced by UK SRS?
No. SECR remains in force for quoted companies, large unquoted companies and large LLPs, unamended since 1 April 2019. DESNZ's 2026 review recommended retaining it with amendments, and DESNZ has said only that it will consider how UK SRS data interacts with SECR, with a view to reducing unnecessary duplication where possible. No instrument or decision replaces SECR.
Is UK SRS S2 mandatory?
No. UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 for voluntary use by any entity. The FCA's final rules in PS26/19, published on 30 September 2026, require listed companies in scope to report against UK SRS on a comply-or-explain basis — including S2 — for accounting periods beginning on or after 1 January 2027. CP26/5 had proposed making S2 mandatory; the final rules do not.
Which companies do the FCA's UK SRS rules cover?
Listed companies in UKLR 6 (commercial companies), UKLR 14 (international commercial companies with a secondary listing), UKLR 15 (depositary receipts), UKLR 16 (non-equity and non-voting equity shares) and UKLR 22 (transition). Closed-ended investment funds, open-ended investment companies, shell companies and issuers of debt, securitised derivatives and miscellaneous securities are excluded. CP26/5 estimated that around 600 listed companies would be affected; PS26/19 gives no total.
Do listed companies still have to do SECR?
Yes. A UK company whose shares are on the official list is a quoted company under Companies Act 2006 section 385, and SECR applies to every quoted company whatever its size. The FCA's UK SRS rules are a listing-rule obligation on top of SECR, not a substitute for it.
Do private or unquoted companies have to use UK SRS?
No. No UK entity outside the listed categories is required to use UK SRS, and no government document proposes a threshold or date for private companies. The Modernising corporate reporting consultation, open until 30 November 2026, says only that the government will consider how UK SRS should be reflected in the Companies Act 2006.
Can SECR data be used for UK SRS S2?
It is a starting point, not a substitute. UK SRS S2 requires absolute gross Scope 1, Scope 2 and Scope 3 emissions measured under the GHG Protocol Corporate Standard, for the same reporting entity as the financial statements. SECR describes emissions by activity, confines large unquoted companies to UK sources if they choose, and requires Scope 3 only for transport fuel. The energy records underneath are shared; the figures usually need extending and reconciling.
Does UK SRS require Scope 3 when SECR does not?
UK SRS S2 itself requires Scope 3 emissions. Under PS26/19 listed companies report against it on a comply-or-explain basis, with a one-year relief during which a company that does not disclose Scope 3 need only state that it is using the relief. SECR requires Scope 3 only as fuel consumed for transport, and only from large unquoted companies and LLPs.
What did PS26/19 change from CP26/5?
CP26/5 had proposed mandatory UK SRS S2 reporting for most listed companies, excluding Scope 3, and only a signposting statement for secondary listings and depositary receipts. PS26/19 adopts comply or explain across all categories of UK SRS disclosure, and brings secondary listings and depositary receipt issuers into the same comply-or-explain reporting.
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.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
First published 30 September 2026: final rules, comply or explain, from periods beginning 1 January 2027.
- Financial Conduct AuthorityPS26/19 — policy statement (PDF)
¶¶1.2, 1.7 (comply or explain), 3.6–3.7 (scope), 3.12–3.20 (timing and reliefs), 2.37 and 2.45.
- Financial Conduct AuthorityCP26/5 — the consultation PS26/19 finalises
Published 30 January 2026; closed 20 March 2026.
- Financial Conduct AuthorityCP26/5 (PDF)
Annex 2 ¶43: the consultation's estimate of around 600 listed companies affected.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
Published 25 February 2026.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
"Available for voluntary use, by any entity that chooses to do so."
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF)
¶29(a): absolute gross Scope 1, 2 and 3 emissions under the GHG Protocol.
- Department for Business and TradeUK SRS consultation response (PDF), Chapter 3
DESNZ "will consider" the UK SRS–SECR interaction; UK SRS S2 as a s.414CB(6) framework.
- Department for Business and TradeUK SRS consultation response — web version
Chapter 3: s.463 applies to UK SRS disclosure placed in the strategic report.
- legislation.gov.ukSI 2018/1155 — the SECR regulations
In force for financial years beginning on or after 1 April 2019.
- legislation.gov.ukSI 2008/410, Schedule 7 — SECR disclosures
Parts 7 and 7A.
- legislation.gov.ukCompanies Act 2006, section 385 — quoted companies
Why a UK company on the official list is in SECR at any size.
- legislation.gov.ukCompanies Act 2006, section 463
The safe harbour, which follows the location of the disclosure.
- legislation.gov.ukCompanies Act 2006, section 414CB
Climate-related financial disclosures; s.414CB(6) national frameworks.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation (7 September 2026)
¶149 SECR's location; ¶150 DESNZ's SECR and ESOS consultation; ¶¶154–155 UK SRS.
- Department for Energy Security and Net Zero2026 Post-Implementation Review of the SECR Regulations 2018
Retain SECR with amendments; alignment with ISSB, CSRD and TCFD a candidate area, not a decision.
- Department for Energy Security and Net ZeroIndependent evaluation of SECR (29 January 2026)
19,900 organisations in SECR scope.
- GOV.UKStreamlined energy and carbon reporting — consultation (BEIS, 2017–18)
The consultation that designed SECR.
- GHG ProtocolCorporate Accounting and Reporting Standard
The measurement basis UK SRS S2 requires.