From SECR to UK SRS: Managing the Transition Without Gaps in Your Reporting

SECR vs UK SRS: What Is Different

The table above illustrates the scale of the step-change. SECR is primarily an energy and carbon data reporting exercise. UK SRS is a comprehensive sustainability disclosure framework that integrates governance, strategy, risk management, and metrics into a coherent narrative. Companies that have treated SECR as a standalone compliance exercise will need to fundamentally rethink their approach.

Timeline Overlap

The transition from SECR to UK SRS will not be a clean switch. There will be a period during which companies must comply with both frameworks simultaneously. SECR requirements remain in force under the Companies Act 2006 and the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. UK SRS requirements will layer on top of, rather than immediately replace, SECR obligations.

Companies should plan for at least one to two reporting periods of dual compliance. This means maintaining the ability to produce SECR-compliant disclosures in the directors’ report while simultaneously preparing UK SRS-compliant disclosures that may sit in a separate sustainability statement or integrated annual report. The risk of inconsistency between the two sets of disclosures is real and must be managed through a single underlying dataset and consistent methodology.

Closing the Five Key Gaps

1. Scope 3 emissions. SECR requires only Scope 1 and Scope 2 reporting, with Scope 3 encouraged but not mandated. UK SRS will require disclosure of all material Scope 3 categories. For many companies, Scope 3 represents the majority of their carbon footprint. Building the data collection processes, supplier engagement mechanisms, and estimation methodologies for Scope 3 takes time and should not be left until the final reporting period.

2. Governance disclosures. UK SRS requires companies to describe how their board and management oversee, assess, and manage climate-related risks and opportunities. This is not about adding a paragraph to the annual report; it requires demonstrable board competency, defined roles and responsibilities, and evidence that climate considerations are embedded in strategic decision-making.

3. Climate scenario analysis. UK SRS expects companies to assess the resilience of their strategy under different climate scenarios, including a scenario consistent with limiting global warming to 1.5 degrees Celsius. This requires analytical capability that most SECR reporters have not yet developed.

4. Transition plans. While SECR has no transition plan requirement, UK SRS will expect companies to disclose their plans for transitioning to a low-carbon economy, aligned with the TPT Disclosure Framework. Transition plans must be credible, time-bound, and supported by interim targets.

5. Assurance readiness. UK SRS disclosures are expected to be subject to independent assurance, initially at a limited assurance level and potentially moving to reasonable assurance over time. Companies need to ensure that their data, processes, and internal controls are assurance-ready, which means documented methodologies, clear audit trails, and internal quality checks.

Practical Transition Checklist

• Conduct a gap analysis between your current SECR reporting and UK SRS requirements.
• Identify all material Scope 3 categories and begin data collection.
• Establish or formalise board-level governance of climate-related issues.
• Conduct an initial climate scenario analysis, even at a qualitative level.
• Draft a transition plan aligned with the TPT Disclosure Framework.
• Engage an assurance provider early to understand their expectations and identify gaps.
• Review your carbon accounting software to ensure it can support both SECR and UK SRS outputs.

Common Mistakes in the Transition

Having advised companies across multiple sectors on sustainability reporting transitions, we see five errors repeated consistently. Avoiding these will save time, reduce risk, and produce stronger disclosures.

1. Assuming SECR data is sufficient for UK SRS. SECR requires energy consumption and Scope 1 and 2 emissions data, typically calculated using DEFRA conversion factors applied to utility bills and fuel purchase records. UK SRS demands significantly more: climate-related financial impacts, the effect of climate risks on business strategy, and forward-looking metrics such as internal carbon prices and capital expenditure aligned with climate goals. Companies that assume they can simply reformat their SECR data for UK SRS will find themselves with a disclosure that is quantitatively thin and qualitatively empty. The data architecture needs to be redesigned, not repurposed.

2. Treating Scope 3 as optional. Under SECR, Scope 3 disclosure is voluntary, and many companies have either omitted it entirely or reported only business travel. UK SRS, following IFRS S2, requires disclosure of material Scope 3 categories. For retailers, manufacturers, and financial services firms, Scope 3 can constitute 80 to 95% of total emissions. Starting Scope 3 data collection late means relying heavily on spend-based estimates in the first year, which reduces the credibility of the disclosure and limits the ability to set meaningful reduction targets. Companies should begin supplier engagement, activity data collection, and Scope 3 category screening at least 12 months before their first UK SRS reporting period.

3. Underestimating governance requirements. Some companies plan to satisfy UK SRS governance disclosures by adding a paragraph about board oversight to their existing directors’ report. This is insufficient. UK SRS requires specific disclosures about the skills and competencies available to the board on climate matters, how climate is integrated into remuneration policies, and how often the board reviews climate-related information. Companies that have not genuinely embedded climate into board agendas, committee terms of reference, and executive incentive structures will struggle to make credible governance disclosures.

4. Leaving transition plans to the last minute. A credible transition plan is not a document that can be drafted in the final weeks before a reporting deadline. It requires strategic analysis, target-setting grounded in science-based methodologies, identification of decarbonisation levers, capital expenditure planning, and stakeholder engagement. The TPT Disclosure Framework sets out a detailed structure covering ambition, actions, and accountability. Companies that begin their transition planning process in the same year they need to report will produce plans that are aspirational rather than actionable, and investors and assurance providers will recognise the difference.

5. Not engaging assurance providers early. The market for sustainability assurance is still developing, and the supply of qualified assurance practitioners is limited relative to expected demand. Companies that wait until their first UK SRS report is drafted before approaching assurance providers risk being unable to secure an engagement, or finding that the assurance provider identifies fundamental data quality or process issues that cannot be resolved before the filing deadline. Early engagement, ideally 12 to 18 months before the first assured reporting period, allows the assurance provider to conduct a readiness assessment, identify gaps, and give the company time to remediate before the formal assurance engagement begins.

Building One Data System for Both

The most effective way to manage the SECR-to-UK-SRS transition is to build a single data system that serves both frameworks. Running parallel data collection processes for SECR and UK SRS creates duplication, increases the risk of inconsistency, and doubles the internal resource burden. A unified approach ensures that the same underlying activity data feeds both sets of disclosures, with methodology and output differences handled at the reporting layer rather than the data collection layer.

Single source of truth. All energy consumption, fuel use, and emissions data should be captured once, in one system, at the most granular level available. Utility bills, meter readings, fuel delivery records, refrigerant logs, fleet telematics, and supplier emissions data should flow into a central repository. This repository becomes the single source of truth for both SECR (which requires UK energy consumption and Scope 1/2 emissions) and UK SRS (which requires a broader set of climate-related metrics including Scope 3, financial impacts, and transition plan progress indicators).

Controlled methodology. The system should apply emissions factors, allocation rules, and calculation methodologies consistently and transparently. SECR typically uses DEFRA’s UK Government GHG Conversion Factors for Company Reporting. UK SRS, following IFRS S2, is methodology-agnostic but expects consistency with the GHG Protocol Corporate Standard and Scope 3 Standard. A well-designed system allows the user to select the appropriate methodology and conversion factor set and produces outputs for both frameworks from the same activity data.

Audit trail. Every data point should be traceable from the final reported figure back to the source document. This means maintaining records of data entry, any manual adjustments, the conversion factors applied, the estimation methodologies used where primary data is unavailable, and the approvals applied at each stage of the data pipeline. An assurance provider will expect to follow this trail during their engagement, and a clear audit trail significantly reduces the time and cost of the assurance process.

Selecting the right platform. The carbon accounting software market has matured significantly, and several platforms now offer the ability to produce both SECR-format outputs (for the directors’ report) and ISSB/UK-SRS-format outputs (for the sustainability statement) from the same underlying dataset. When evaluating platforms, companies should assess coverage of all 15 Scope 3 categories, the ability to import supplier-specific emissions data, integration with financial systems for spend-based estimates, support for multiple emissions factor databases, and the quality of the audit trail and data governance features. The platform should also support scenario modelling to facilitate the climate scenario analysis required by UK SRS.

Data architecture principles. Beyond platform selection, companies should adopt four foundational principles. First, collect data at the most granular level (site, asset, or activity level) rather than at a consolidated entity level, as this enables both accurate SECR reporting (which requires UK-specific data) and comprehensive UK SRS reporting (which requires global data). Second, tag all data with metadata including source, period, geography, business unit, and quality indicator, enabling flexible aggregation and filtering for different reporting requirements. Third, establish clear data ownership, with named individuals responsible for data accuracy at each collection point. Fourth, implement automated validation rules that flag anomalies, missing data, and outliers before they reach the reporting stage, reducing the risk of errors that would be identified during assurance.