UK SRS S2 and SECR: Why Emissions Reporting May Still Be Duplicated

Functional visual created for London Reporting Academy. The visual is educational and should be read with the article.

A single organisation may publish at least three apparently similar figures: SECR energy and emissions, UK SRS S2 Scope 1 and Scope 2 emissions, and operational data used in targets or transition-plan reporting. When the figures differ, users may suspect error even where the difference is caused by a legitimate boundary, method or period distinction. When the figures are forced to match without analysis, one of the regimes may be misstated.

The correct objective is not 'one number at all costs'. It is one governed source dataset, clearly controlled transformations and a transparent reconciliation of the outputs required by each reporting basis.

SECR was introduced through the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 and applies to financial years starting on or after 1 April 2019. It remains a mandatory framework for organisations within scope.

UK SRS S2 was issued in February 2026 for voluntary use. The Government's consultation response made a specific no-duplication clarification for Companies Act section 414CB climate disclosures, but it did not create an equivalent SECR exemption. Instead, it stated that DESNZ will consider how energy and emissions data reported under UK SRS interacts with SECR, with a view to reducing unnecessary duplication where possible.

Until legislation or official guidance changes, reporting teams should assume that both outputs are required when the entity is within SECR scope and chooses, or is later required, to report under UK SRS S2.

SECR scope

The legislation affects:

quoted companies required to prepare a Directors' Report;

large unquoted UK companies, including qualifying charitable companies; and

large LLPs.

Quoted companies are subject regardless of size. Unquoted companies and LLPs use the applicable statutory definition of 'large', including current turnover, balance-sheet and employee tests. Those thresholds can change, so a current-year legal scope check is preferable to copying figures from the 2019 guidance.

SECR also contains group-reporting rules and a low-energy-user provision. An organisation consuming 40 MWh or less in the relevant UK energy categories may qualify for reduced reporting, but it must disclose that it is a low-energy user. Entity type, group structure, report location and exclusions still need to be assessed.

UK SRS S2 scope

Voluntary UK SRS S2 is not limited by company form, listing status or size. The reporting entity is the same entity as the related general purpose financial statements under UK SRS S1, while individual metrics can extend beyond the consolidated accounting group.

FCA CP26/5 proposes a listing-category scope for future climate reporting. That proposed scope does not follow the SECR size tests. A listed entity could therefore be in both regimes, only one, or neither, depending on its legal form, listing category and reporting basis.

Quoted-company SECR boundary

Quoted companies report annual global GHG emissions from activities for which the company is responsible, including fuel combustion and operation of facilities, plus a separate figure for emissions from purchased electricity, heat, steam or cooling for the company's own use. They also report the underlying global energy use.

The totals are broadly comparable to Scope 1 and Scope 2, but SECR terminology and statutory source definitions should not be replaced mechanically with a GHG Protocol label. The entity must state its organisational boundary and methodology and explain material exclusions.

Large unquoted-company and LLP SECR boundary

Large unquoted companies and large LLPs report UK energy use and associated GHG emissions as a minimum for gas, electricity and transport fuel for which they are responsible. The geographic and activity scope can therefore be narrower than a group-wide S2 inventory.

UK SRS S2 boundary

S2 requires gross Scope 1, Scope 2 and Scope 3 emissions in accordance with paragraph 29(a), subject to the applicable measurement method, materiality and reliefs. It also requires:

disclosure of the measurement approach, inputs and assumptions;

disaggregation of Scope 1 and Scope 2 between the consolidated accounting group and other investees in specified circumstances;

location-based Scope 2 emissions and information about contractual instruments;

Scope 3 categories and additional financed-emissions information for relevant financial activities; and

explanation of changes in the measurement approach, inputs or assumptions where relevant.

S2's value-chain and investment-related boundary can therefore be substantially wider than SECR.

A practical operating model has six layers.

Layer 1 - source register

Maintain a complete register of meters, utility invoices, landlord statements, fuel cards, fleet systems, refrigerant logs, production records, travel data and supplier or investee data. Each source should have an owner, period, unit, quality rating and evidence location.

Layer 2 - canonical activity dataset

Convert source records into standard units while preserving original values and audit trail. Record estimates, missing periods, allocation rules, acquisitions, disposals and changes in operational responsibility.

Layer 3 - factor and methodology library

Control emission factors by source, version, geography, gas, unit and valid period. Separate government conversion factors, supplier factors, residual-mix or grid factors and other approved sources. Method changes should require review and a restatement assessment.

Layer 4 - boundary engine

Tag every record against multiple dimensions rather than hard-coding one report:

financial reporting entity;

SECR quoted-company global boundary;

SECR large-unquoted/LLP UK boundary;

GHG Protocol organisational boundary;

S2 consolidated-group versus other-investee presentation;

Scope and Scope 3 category;

business unit, country and facility; and

target or intensity-ratio boundary.

Layer 5 - controlled calculations

Run recalculations, unit checks, factor checks, duplicate tests, completeness reconciliations and year-on-year variance analysis. Lock the approved dataset at the annual-report cut-off and retain change logs.

Layer 6 - reporting views

Generate separate output tables for SECR, S2 and internal management reporting. The tables can draw on the same records but apply their own filters, aggregations, labels, materiality decisions and disclosures.

A UK-headquartered group has operations in the UK, France and Canada, a leased logistics fleet, a joint venture and a large purchased-goods footprint.

The published report should explain the bridge rather than presenting unexplained totals.

Illustrative figures should not be invented for publication. The structure above is a control template.

For companies, SECR information is normally presented in the Directors' Report. Large LLPs prepare an Energy and Carbon Report. UK SRS S2 information forms part of the general purpose financial reports under S1 and must be reported at the same time and for the same period as the financial statements.

A company may place an integrated emissions table in one annual-report section and use precise internal cross-references, provided every applicable statutory and UK SRS location condition is satisfied. The table should identify which columns or notes satisfy SECR and which satisfy S2. A general statement that 'the data is reported elsewhere' is not enough.