SECR Is Being Phased Out — Here's What That Means for Your Data
SECR Is Being Phased Out — Here's What That Means for Your Data
In January 2026, the Department for Energy Security and Net Zero (DESNZ) published its statutory evaluation of the Streamlined Energy and Carbon Reporting (SECR) regulations — the framework that has required large UK companies to report their energy use and associated carbon emissions since 2019.
The evaluation found that SECR works. Energy savings attributable to the regulations run at 4.5% to 6.2% of eligible consumption per year. Approximately 14,000 of the roughly 19,900 in-scope companies are filing their own reports. The data quality has improved year on year.
But the evaluation's final section is where the regulatory signal is most significant. DESNZ notes that its findings "will inform a statutory post-implementation review" and "will contribute to the evidence base for wider sustainability reporting requirements." In the context of UK SRS being published in February 2026 and the FCA proposing mandatory UK SRS adoption for listed companies from 1 January 2027, this language has one practical meaning: SECR's days as a standalone framework are numbered. The question is not whether SECR will be absorbed into UK SRS, but when.
What this means for companies currently reporting under SECR
If your company is currently reporting under SECR, the prospect of a regulatory transition might sound like additional burden — another framework to learn, another set of data to collect, another reporting cycle to manage. In reality, for companies that have been diligent about their SECR reporting, a significant portion of the work is already done.
Here is what your existing SECR data covers, and what it doesn't.
What SECR already gives you. SECR reporting requires disclosure of UK energy use, global Scope 1 emissions, and UK Scope 2 emissions — along with an intensity ratio. Under the UK SRS framework (which is closely aligned with IFRS S1 and S2), Scope 1 and Scope 2 are the foundational emissions metrics. A company with three or four years of clean SECR data already has the historical Scope 1 and 2 baseline that UK SRS requires for comparability disclosures. This is not a trivial starting point — it is the single hardest part of building a UK SRS climate disclosure for most companies.
What SECR doesn't cover. UK SRS requires substantially more than emissions data. The four core disclosure areas — governance, strategy, risk management, and metrics and targets — mean that companies will need to document board oversight of climate risks, describe how climate scenarios have been integrated into strategy, identify and assess physical and transition risks, and set measurable net zero targets with interim milestones. None of this is required under SECR, and none of it can be assembled overnight.
For most companies, the gap between a solid SECR disclosure and a full UK SRS disclosure is not primarily a data gap — it is a governance and narrative gap. The emissions numbers are largely available. What isn't in place is the management infrastructure to contextualise them.
The transition timeline
The FCA consultation on incorporating UK SRS into the UK Listing Rules closed on 20 March 2026. The proposed timeline is mandatory UK SRS reporting for listed companies from 1 January 2027. The UK government has indicated it will consult separately on extending UK SRS to the largest private entities — a consultation expected in 2026 or 2027.
For companies within the listed market, this means the 2027 reporting year is the first year of mandatory UK SRS disclosure. Given that UK SRS requires comparative data, the 2026 financial year effectively becomes the baseline year — meaning that decisions made now about how to collect and organise climate-related data will directly shape the quality of that first mandatory disclosure.
For private companies and SMEs, the direct mandatory obligation is further off — but the supply chain cascade is already in motion. Every listed UK company with a supply chain will need Scope 3 data from its suppliers from 2027. This is the driver of the growing wave of supply chain carbon data requests that UK SMEs are already beginning to receive.
Why acting now is commercially valuable — not just compliant
There is a temptation, when a regulatory transition is 12–24 months away, to wait and see. This is understandable but strategically costly for two reasons.
First, the companies that build their UK SRS-ready infrastructure early will have a meaningful advantage in capital markets, procurement processes, and talent markets. Investors, lenders, and large customers are already asking for climate data ahead of formal requirements. Being able to respond with structured, methodology-backed disclosures — rather than ad hoc estimates — signals credibility and risk management capability.
Second, the foundational data quality problem only gets harder the longer it is deferred. UK SRS will require multi-year trend data, intensity ratios, and scenario-tested risk narratives. Building a rigorous Scope 1 and 2 data record now, based on current GHG Protocol methodology and DESNZ conversion factors, means that the 2026 reporting year — the critical baseline year — will be clean and defensible. Starting in 2027 means starting from scratch, under mandatory disclosure conditions, with auditors and investors watching.
What UK companies should do with their SECR data now
If you are currently reporting under SECR and want to use that foundation productively in the transition to UK SRS, the following steps are directly actionable today.
Audit your data quality. Review your last three SECR reporting cycles for consistency of methodology, conversion factor vintages, and scope boundaries. Inconsistencies in historical data are harder to resolve after the fact than before. Common issues include mixed use of DESNZ conversion factor years, inconsistent treatment of subsidiary energy use, and intensity metrics that have changed their denominator without explanation.
Extend to Scope 3. SECR does not require Scope 3 disclosure, but UK SRS does — and your supply chain customers already want it. The most material Scope 3 categories for most companies are Category 1 (purchased goods and services) and Category 11 or 13 (use of sold products / downstream leased assets). Starting with a spend-based estimate for Category 1 gives you a material starting point without requiring a full supplier engagement programme.
Map your governance. UK SRS requires disclosure of board oversight of climate risks. Most SECR-reporting companies have finance teams that manage the reporting process without formal board engagement. Establishing a governance structure — even a simple one — that includes board review of climate data and risks is a necessary step before 2027.
Consider your intensity metric. SECR requires an intensity ratio but does not specify which one. UK SRS and investor benchmarking increasingly favour revenue-normalised intensity ratios (tCO2e per £m revenue), which allow for comparability across the market. Aligning your intensity metric now makes your historical SECR data more directly comparable to the benchmarks that UK SRS users will reference.
The message for SECR clients: your data is not wasted
The single most important thing to communicate to any company currently running SECR reporting is that the transition to UK SRS does not make their existing data redundant. It makes it foundational.
The companies that have been collecting consistent, methodology-backed SECR data for the past five years are in a significantly stronger position than those that have been filing the minimum required disclosure. The work that was done under SECR is the starting point for UK SRS — and the earlier companies begin extending that foundation, the better positioned they will be when the mandatory timeline arrives.
Compare Your Footprint supports SECR reporting for UK companies and is building UK SRS transition functionality based on the data our clients already hold. If you'd like to understand how your existing SECR data maps to UK SRS requirements, speak to our team.