Short answer
The answer, before the reasoning
UK SRS S2 requires absolute gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions in metric tonnes of CO2 equivalent when those disclosures are provided. The default measurement basis is the GHG Protocol Corporate Standard, subject to the Standard’s jurisdictional-method provisions.
Preparers must connect the reporting entity to the accounting group, other investees and the value chain; report location-based Scope 2; identify the Scope 3 categories included; and explain methods, inputs, assumptions and changes. A credible number therefore needs a controlled boundary, source data, factor and GWP versions, estimates, reconciliations, review and an evidence trail—not just a calculation workbook.
The three scopes have different sources and boundaries but share one controlled measurement architecture.
At a glance
1. Start with the disclosure architecture, not the emissions spreadsheet
The measurement project begins with a reporting architecture. UK SRS S2 paragraph 29(a) asks for absolute gross emissions classified as Scope 1, Scope 2 and Scope 3. “Gross” means the emissions are reported before deductions for carbon credits, avoided emissions, removals or renewable-energy claims. Credits and removals may be relevant elsewhere, but they do not reduce the gross inventory disclosed under paragraph 29(a).
The same paragraph also requires an explanation of the measurement approach, inputs and assumptions, why they were chosen, and changes made during the period. The disclosure is therefore both a number and an account of how the number was produced.
2. Reconcile the reporting entity, accounting group and other investees
UK SRS S1 establishes the reporting entity for sustainability-related financial disclosures by reference to the related financial statements. UK SRS S2 then adds a specific presentation requirement for Scope 1 and Scope 2: emissions are disaggregated between the consolidated accounting group and other investees, such as associates, joint ventures and unconsolidated subsidiaries. This is a presentation bridge—not permission to ignore investees or to use an undocumented boundary.
3. Measure Scope 1: direct sources within the selected boundary
Scope 1 normally covers direct emissions from sources owned or controlled under the selected GHG accounting approach. The source register should distinguish stationary combustion, mobile combustion, process emissions and fugitive emissions. Refrigerants deserve separate attention because additions, recoveries, equipment movements and gas-specific GWP values can make a small activity record financially and quantitatively significant.
Reconcile fuel invoices and tank movements to operational consumption, fleet records and general-ledger accounts.
Maintain equipment and refrigerant registers with gas type, opening balance, purchases, recoveries, closing balance and service evidence.
Document process-emissions formulas, production data, stoichiometric factors and engineering approvals.
Test units, heating-value basis, duplicate records, cut-off and source completeness.
4. Measure Scope 2: the location-based amount is the required core
Scope 2 covers emissions from purchased or acquired electricity, steam, heat and cooling. UK SRS S2 specifically requires a location-based Scope 2 figure. This generally uses grid-average or other location-representative emission factors for the place where energy is consumed. Contractual instruments can add useful information, but they do not replace the required location-based amount.
A Scope 2 control file should reconcile consumption by site and meter, identify the applicable grid factor, record any supplier-specific factor, and link PPAs, certificates or energy attributes to the relevant market, vintage, volume, ownership and retirement evidence.
5. Assess all 15 Scope 3 categories
The Scope 3 boundary is the upstream and downstream value chain, not a simple extension of the consolidation perimeter. UK SRS S2 requires the entity to disclose the categories included in its Scope 3 measure by reference to the 15 categories in the GHG Protocol Scope 3 Standard. A category screening should consider the entity’s activities, expenditure, assets, products, customers, logistics, leased assets, franchises and investments.
All categories should be assessed, even where the first-year estimate uses secondary data or a proxy.
Data quality is not binary. UK SRS S2’s Scope 3 measurement framework prioritises reasonable and supportable information and differentiates direct measurement, estimation, primary data and secondary data. The practical objective is to choose information that is sufficiently representative of the activity, geography, technology and period, explain the estimate and improve the most decision-useful categories.
A practical Scope 3 data hierarchy
Use counterparty- or supplier-specific primary data where it is available, controlled and representative.
Use internal activity data combined with suitable emission factors where direct emissions data is unavailable.
Use secondary data selected for technology, geography and temporal representativeness.
Use spend, average-data or proxy methods transparently for screening or data gaps.
Prioritise improvement according to materiality, uncertainty, concentration and the influence the entity can exercise.
6. Control factors, GWP values and conversions
Emission factors and global warming potential values are controlled reference data. UK SRS S2 generally requires the latest Intergovernmental Panel on Climate Change 100-year GWP values available at the reporting date, unless a jurisdictional authority or exchange requires different GWP values for the entity or an affected part. The factor register should therefore capture source, edition, year, geography, technology, units, heating-value basis, effective dates and superseded versions.
7. Estimates, uncertainty and changes
An estimate is often necessary, particularly for Scope 3. It should not be hidden. Record the population, method, assumptions, source data, factor, uncertainty, known bias, sensitivity and improvement action. Where methods, factors, boundaries or inputs change, assess whether the comparative information must be recalculated or whether the change is an estimate change that should be explained.
8. End-to-end measurement workflow
Confirm the reporting entity and financial-statement consolidation perimeter.
Approve the GHG consolidation approach and disaggregation between the accounting group and other investees.
Build the facility, source and value-chain registers.
Collect activity data and perform completeness, cut-off, duplicate and reconciliation tests.
Select controlled factors, GWP values and units.
Calculate Scope 1 and location-based Scope 2; add contractual information separately.
Screen all 15 Scope 3 categories and calculate included categories using the data-quality hierarchy.
Review Category 15 and financed-emissions requirements where financial activities are present.
Complete independent recalculation, variance analysis and methodology-change review.
Approve the disclosures, evidence index and report wording.
9. Hypothetical group example
10. Illustrative disclosure anatomy
This wording works only if it is supported by a category register, coverage calculation, factor library, boundary memo, methodology file and approval record. It must be adapted to the entity’s categories and facts.
11. Common measurement mistakes
Netting carbon credits or renewable certificates against gross Scope 1, Scope 2 or Scope 3.
Using the consolidated financial perimeter as the entire GHG boundary without assessing leases, investees and the value chain.
Reporting only a market-based Scope 2 figure and omitting the required location-based amount.
Selecting Scope 3 categories by data availability rather than by a complete category assessment.
Using factors without edition, unit, geography or effective-date controls.
Treating estimates as a generic limitation rather than documenting method, uncertainty and improvement.
Failing to separate preparation, review and final approval.
12. Measurement readiness checklist
Reporting entity and accounting-group reconciliation approved.
Facility, source, investee and value-chain registers complete.
Gross Scope 1, location-based Scope 2 and included Scope 3 categories calculated.
Scope 1 and Scope 2 disaggregation prepared.
All 15 Scope 3 categories assessed and decisions documented.
Factors, GWP values and conversions version-controlled.
Estimates and data-quality limitations explained.
Contractual instruments and renewable claims separately controlled.
Independent recalculation and variance review completed.
Evidence index, governance approval and disclosure wording reconciled.
Sources, status and limitation
UK SRS S2 was issued in February 2026 for voluntary use. Any mandatory filing, assurance, relief or presentation requirement must be checked against the applicable FCA, Companies Act, sector or other regulatory route. GHG Protocol source documents are methodology references and should be checked for amendments or revision projects before each reporting cycle.
Editorial and technical production layer
Quick orientation
Quick orientation
- Applies to
- Reporting, finance, operational data, investment and assurance-readiness teams preparing UK SRS S2 GHG disclosures.
- Primary decision
- How to define the boundary, measure gross emissions and retain sufficient evidence for each scope.
- Key sources
- UK SRS S2 paragraphs 29(a), B19-B57 and B58-B63A; GHG Protocol Corporate, Scope 2 and Scope 3 Standards.
- Common confusion
- Treating the financial-statement consolidation perimeter, the GHG accounting boundary and the Scope 3 value chain as one identical population.
In practice
Population
| Population | Boundary question | Control evidence |
|---|---|---|
| Consolidated accounting group | Which parent and subsidiaries are consolidated in the related financial statements? | Finance perimeter, consolidation schedule and approved reporting-entity memo. |
| Associates and joint ventures | How are Scope 1 and Scope 2 emissions measured and presented for other investees? | Investment register, relationship classification, GHG method and disaggregation schedule. |
| Leased and outsourced operations | Does the selected GHG consolidation approach include the source in Scope 1/2 or place it in Scope 3? | Lease data, operational-control assessment and category mapping. |
| Value-chain counterparties | Which upstream and downstream activities fall within the 15 Scope 3 categories? | Value-chain map, category register, contracts and activity populations. |
Rule
CONTROL POINT
A factor is not “approved” merely because it appeared in last year’s workbook. The reviewer should confirm the source edition, unit conversion, applicability and whether a revised factor requires a comparative recalculation.
Hypothetical scenario
HYPOTHETICAL EXAMPLE
A UK manufacturing group consolidates eight subsidiaries, holds a 35% associate and leases a distribution centre. The finance perimeter supports the reporting entity. The GHG boundary memo determines that the leased centre is outside Scope 1 and Scope 2 under the selected approach and is assessed in Scope 3. The associate’s Scope 1 and Scope 2 are measured and shown in the “other investees” disaggregation. Supplier-specific data is available for steel but not for packaging, so Category 1 uses a hybrid method. The report explains the methods, factors, data coverage and planned packaging-data improvement. Illustrative scenario only; the correct treatment depends on facts and the selected GHG approach.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
Hypothetical scenario
ILLUSTRATIVE WORDING — ADAPT TO FACTS
“The Group reports gross Scope 1, Scope 2 and Scope 3 emissions in metric tonnes of CO2e. Scope 1 and Scope 2 are disaggregated between the consolidated accounting group and other investees. Scope 2 is presented on a location-based basis; relevant contractual-instrument information is provided separately. Scope 3 includes Categories 1, 3, 4, 5, 6, 7, 9, 11, 12 and 15. Supplier-specific data represented 42% of Category 1 emissions; the balance used region- and product-representative secondary factors. The principal estimation uncertainty relates to packaging and downstream use assumptions.”
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
Technical status
PUBLISHING STATUS
This section is for LRA editorial, technical-review, CMS and AI/RAG workflows. The public article ends before this page.
Questions
Questions people ask
Does UK SRS S2 require gross emissions?
UK SRS S2 requires absolute gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions in metric tonnes of CO2 equivalent when those disclosures are provided. The default measurement basis is the GHG Protocol Corporate Standard, subject to the Standard’s jurisdictional-method provisions.
How are associates and joint ventures treated?
UK SRS S1 establishes the reporting entity for sustainability-related financial disclosures by reference to the related financial statements. UK SRS S2 then adds a specific presentation requirement for Scope 1 and Scope 2: emissions are disaggregated between the consolidated accounting group and other investees, such as associates, joint ventures and unconsolidated subsidiaries.
Must all Scope 3 categories be assessed?
UK SRS S2 requires the entity to disclose the categories included in its Scope 3 measure by reference to the 15 categories in the GHG Protocol Scope 3 Standard. All categories should be assessed, even where the first-year estimate uses secondary data or a proxy.
Can estimates be used?
UK SRS S2’s Scope 3 measurement framework prioritises reasonable and supportable information and differentiates direct measurement, estimation, primary data and secondary data. The practical objective is to choose information that is sufficiently representative of the activity, geography, technology and period, explain the estimate and improve the most decision-useful categories.
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