Energy and utilities reporting: which UK regimes apply, and how they fit together

It depends on the entity, not the sector. A company operating combustion units above 20 MW total rated thermal input is in the UK Emissions Trading Scheme. A quoted company, or a large unquoted company or LLP, reports energy and emissions under SECR. A UK group that is a large undertaking on 31 December 2026 must comply with ESOS Phase 4. A company listed in one of five UK Listing Rules categories reports against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. Electricity transmission and gas network licensees also publish an Ofgem Annual Environmental Report.

It is a carbon-pricing scheme with a reporting duty built in. Operators of permitted installations monitor emissions for each calendar year, submit a verified annual emissions report by 31 March of the following year, and surrender one allowance per tonne of reportable emissions by 30 April. The UK ETS replaced the UK's participation in the EU ETS on 1 January 2021.

GOV.UK guidance for installations says an operator that does not surrender enough allowances by 30 April receives a mandatory penalty of £100 per tonne of CO2, multiplied by the inflation factor, and that the penalty applies even if the operator surrenders in full after the deadline. The regulator may also issue a deficit notice.

Not under UK SRS S2, which requires location-based Scope 2 emissions and information about contractual instruments only where that information is needed to understand the figure. The GHG Protocol Scope 2 Guidance asks for both location-based and market-based totals where a company operates in markets with contractual instruments such as REGOs. Many UK companies therefore report both, with location-based as the required figure.

Only in a market-based Scope 2 figure, and only if the instruments meet the GHG Protocol quality criteria. Ofgem issues one REGO per megawatt hour of eligible renewable output, their primary use is Fuel Mix Disclosure, and they can be traded with or without the electricity. A location-based figure, which UK SRS S2 requires, uses the grid average factor whatever REGOs are held.

No. The Environment Agency's Phase 4 guidance says participation in UK ETS, Climate Change Agreements or SECR does not automatically count as ESOS compliance. UK ETS emissions data can feed the ESOS total energy calculation, but sites and activities outside the permit need additional data collection.

Ofgem's RIIO-3 Environmental Reporting Guidance says the report for the regulatory year beginning 1 April 2026 must be published on licensees' websites by 31 October 2027, and by 31 October in each later year. The obligation sits in Special Condition 9.1 of the electricity transmission, gas transmission and gas distribution licences.

No. 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 for accounting periods beginning on or after 1 January 2027, with first reporting in 2028. A company may use a one-year Scope 3 relief and a two-year relief for UK SRS S1 matters beyond climate.