Carbon legislation readiness check

A carbon legislation readiness check screens which UK carbon and energy rules may apply to an organisation, what each would require and by when. This page's check covers SECR, ESOS Phase 4, the FCA’s UK SRS rules for listed companies, climate-related financial disclosures, PPN 006 Carbon Reduction Plans, the UK ETS and UK CBAM. It is a screen, not a determination: the instruments decide.

Any UK organisation near a threshold: quoted companies (SECR applies at any size), unquoted companies and LLPs exceeding two of £36m turnover, £18m balance sheet and 250 employees (SECR), undertakings with at least 250 employees or turnover over £44m and balance sheet over £38m (ESOS), listed companies (UK SRS, on comply or explain), bidders for central government contracts above £5m a year (PPN 006), and operators or importers in the UK ETS or UK CBAM.

At least once a year, before the financial year starts, and whenever something material changes: growth past a threshold, an acquisition, a new listing, a first bid for a large public contract or a change in the rules. Two dates in the next fifteen months matter: ESOS Phase 4 qualification on 31 December 2026 and the start of the FCA's final UK SRS rules for listed companies, for accounting periods beginning on or after 1 January 2027.

It depends on the regime. ESOS has civil penalties in the 2014 Regulations: up to £50,000 for failing to undertake an assessment plus up to £500 per working day for up to 80 working days, and up to £5,000 plus the same daily amount for failing to notify. SECR has no penalty of its own; a defective directors' report is caught by the Companies Act 2006. Missing a PPN 006 plan means failing a condition of participation in that procurement.

Map which regimes apply and the provision behind each, build one energy and emissions data set to a documented method, fix the dates that follow from the financial year-end, confirm who will act as ESOS lead assessor and responsible officer, and mark anything that is only proposed. Re-run the check when the business or the rules change.

Not in the strict sense. UK SRS S1 and S2 are voluntary standards. The FCA's final rules (PS26/19, 30 September 2026) require listed companies in UKLR 6, 14, 15, 16 and 22 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. CP26/5, the consultation, had proposed mandatory UK SRS S2; the final rules did not adopt it.

No. For SECR an AIM company is unquoted, so it reports under Schedule 7 Part 7A only if it exceeds two of the three size limits, rather than under the quoted-company rules that apply at any size.

Carbon Legal is an independent reference, not a consultancy with clients, and it does not carry out compliance work. A service is in development. You can book a free 15-minute call to talk the results through, and where it helps we can introduce you to independent specialists.