You've read the UK SRS standards. You understand the four pillars. You've started thinking about which AI tools to use. But when you sit down to actually produce a disclosure, something becomes painfully clear: the data isn't there. Not "doesn't exist in the world" — it exists somewhere. It's in a property manager's spreadsheet, a utility portal nobody has logged into since last year, an EPC certificate filed in a drawer. Here are the five data gaps that will cause the most pain for UK property firms, and what to do about each one.

Gap 1: Tenant energy consumption

For multi-let buildings, tenant energy consumption is typically the largest source of emissions and the hardest to measure. Tenants have their own utility contracts, their own meters, and often no obligation to share data with you. Without tenant data, your Scope 3 figure is either missing or estimated. Under UK SRS S2's comply-or-explain approach, a missing Scope 3 figure requires a public explanation.

What to do: Introduce data-sharing clauses in new and renewed leases (the Better Buildings Partnership has model language). For existing tenants, ask — many corporate occupiers will share willingly because they need the data for their own reporting. Use EPC-based estimates as a fallback, but plan to replace estimates with measured data over time.

Gap 2: Refrigerant data

Scope 1 emissions from air conditioning refrigerant leakage are often overlooked. Refrigerant leakage from older systems has a high global warming potential — a single leak event can represent more emissions than a building's annual gas consumption.

What to do: Require your facilities management contractors to report refrigerant top-ups (type and quantity) as part of regular reporting. Check F-gas records — systems containing 5 tonnes CO2e or more already require leak checks under the F-gas Regulation. The data exists; it's just not flowing into your emissions calculations.

Gap 3: Waste data by stream

UK SRS and GRESB want waste by stream (general, recycling, organic, hazardous) and by destination (landfill, incineration, recycling, recovery). Most property firms can't provide this breakdown. Poor waste data doesn't just lose you points — it suggests weak operational control over your buildings.

What to do: Ask your waste contractors for detailed waste transfer notes broken down by stream and destination. Most contractors can provide this — it's data they're required to keep under duty of care regulations.

Gap 4: Floor area consistency

Emissions intensity metrics (kgCO2e per square metre) require accurate, consistent floor area data. GIA vs NIA vs NLA. Different measurements from different surveyors at different times. Buildings where floor area changed after refurbishment but nobody updated the records.

What to do: Standardise on one measurement basis (GIA is most common for emissions reporting) across your entire portfolio. Reconcile against your property management system, your valuations, and your EPC certificates. Flag any asset where the discrepancy exceeds 5% and investigate.

Gap 5: Historical baseline data

UK SRS requires you to show trends. GRESB rewards improvement over time. All of this requires a consistent historical baseline — and for many firms, data from three or five years ago was collected differently, with different boundaries, different conversion factors, and sometimes different assets in the portfolio. Without a consistent baseline, you can't show progress.

What to do: Establish a clear base year. Restate historical data on a consistent basis — same methodology, same conversion factors, same portfolio boundary. Document every adjustment. AI can automate much of this recalculation, but you need to define the rules.

The common thread

All five gaps share the same root cause: sustainability data has historically been treated as a reporting afterthought. UK SRS changes that. Sustainability data needs the same infrastructure, the same rigour, and the same year-round attention as financial data. None of these gaps are technically difficult to close. They require process changes, not technology breakthroughs. The firms that close these gaps in 2026 will produce their first UK SRS disclosure with confidence. Everyone else will produce it with caveats.