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From meter to annual report: AI-prepared UK SRS data, signed off by a consultant

By James Cutter · Published 19 October 2026

A climate disclosure is only as credible as the weakest number in it. Under the new UK rules, that number has to be ready when the accounts are, and someone has to stand behind it.

That is the job we built NZC AI for, and it is designed to become the specialist AI layer inside NZC Portal. It gathers the evidence, checks it and drafts. It does not decide what is true. A qualified consultant does that, and signs off.

The deadline has moved closer to the audit

The FCA's policy statement PS26/19, published on 30 September 2026, moves listed companies from TCFD-based rules to the UK Sustainability Reporting Standards that the Department for Business and Trade issued in February 2026. The rules cover accounting periods starting on or after 1 January 2027, so first reports land in 2028. Disclosure is on a comply-or-explain basis.

For data teams, the detail that matters most is timing. UK SRS does not carry the ISSB baseline's first-year option to publish climate information after the accounts. A company that complies publishes both together. Building energy and emissions figures therefore sit on the same critical path as the audit.

If you want the full regulatory picture for landlords and property businesses, including who is in scope and how UK SRS sits alongside SECR, ESOS and MEES, read our sister article on NZC Portal: what the FCA's UK SRS rules mean for landlords. This piece looks at the workflow behind the numbers.

Where the time actually goes

Ask a sustainability team where a climate report's hours go and few will say "writing". Most of the effort is chasing: invoices from one supplier, half-hourly data from another, floor areas from a valuer, tenant consumption that arrives late or not at all, and conversion factors that need to match last year's. The GHG Protocol asks for completeness, consistency and transparency. Spreadsheets passed between inboxes rarely deliver all three.

Property adds a twist. Energy crosses the lease line. Tenant-bought energy in let space usually sits in a landlord's Scope 3 (downstream leased assets), and landlord-supplied energy usually sits in an occupier's (upstream leased assets). PS26/19 gives an optional one-year relief for Scope 3, after which it becomes a comply-or-explain item. That relief buys time to sort out the data-sharing. It doesn't remove the need to.

Four stages, one human gate

We split UK SRS preparation into four stages. Software does the first three. A person owns the fourth.

1. Gather. NZC AI collects each building's records through a client request for information (RFI): meter and invoice data, EPC ratings and expiry dates, floor areas, lease type and who buys each supply. Every value keeps a pointer to where it came from.

2. Check. The engine looks for the things that undermine a report: missing months, duplicated meters, sudden jumps in intensity, out-of-date EPCs and factor sets that don't match the reporting year. It flags them. It does not quietly fill them in. Where an estimate is needed, it is labelled as one, with its method, so a reviewer can accept or reject it.

3. Draft. From the checked data, NZC AI drafts the narrative and tables a UK SRS S2 disclosure typically needs: operational energy and emissions by building and portfolio, how they link to EPC and MEES exposure and planned retrofit spend, and a note of which transitional reliefs have been used. It also prepares reports for download, so finance and audit teams can see the inputs behind each figure.

4. Review and sign off. A qualified consultant reviews the draft (in our own work, NZC Consultants Ltd, a separate company): the boundary, the estimates, the methods and the wording. The consultant changes what needs changing, asks the client for what is missing, and signs off. Nothing becomes a disclosure without that step.

Why the human stage isn't optional

AI is good at volume and consistency. It can read thousands of invoices, apply the same rule every time and point out what doesn't fit. It is not accountable, and UK SRS is about accountability. Directors put their names to annual reports. The FCA also asks companies to disclose details of any voluntary third-party assurance: who provided it, its scope, its level and the standard used. Assurers and auditors will question the judgement calls, and those calls belong to qualified people.

That is why we describe NZC AI as preparation, not certification. It shortens the route to a reviewable draft. It does not replace the assessor, the consultant or the auditor, and we would be wary of any tool that claims to.

What the drafted output can and can't claim

A few limits we hold ourselves to:

  • Comply-or-explain cuts both ways. If data for a requirement isn't good enough, the honest answer may be an explanation and a plan, not a figure. The draft says so.
  • No borrowed precision. Estimates stay labelled as estimates through to the final table.
  • One method across reports. The same factors, boundaries and estimation rules feed UK SRS, SECR and ESOS work, so the numbers reconcile rather than compete.
  • Transition plans are referenced, not invented. Companies with a primary UK listing must say whether, and where, they have published a transition plan, or explain why not. The engine can draft supporting text from agreed inputs. It does not create commitments.

Getting ready before 1 January 2027

For a December year-end, the first in-scope year starts in under three months. The data you'll need in early 2028 is being generated now. Practical steps:

  1. Decide whether you are directly in scope, supplying data to someone who is, or both.
  2. Get meter coverage and data-sharing clauses in place before the year starts, not at year-end.
  3. Agree one set of methods and factors across all your energy and carbon reporting.
  4. Choose who will review and sign off, and involve them early.

The FCA is also running a webinar on 19 October 2026 and consulting on a Technical Note on comply-or-explain (TN 803.1) until 28 October 2026. Its reporting requirements page is the place to follow updates.

If you'd like to see how AI-prepared evidence and consultant sign-off could fit your reporting, book a live demo or browse more resources.

This article is general information, not legal or accounting advice.

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