UK carbon reporting requirements · the register
Carbon reporting requirements UK
There is no single UK carbon reporting law; there are six rules, each with its own trigger, content, place and enforcer.
SECR and the Companies Act climate disclosures are in force; the FCA’s final rules put listed companies on UK SRS, comply or explain, from periods beginning on or after 1 January 2027; ESOS, PPN 006 and, for EU groups, CSRD complete the set.
This page sets them out rule by rule; the carbon reporting hub explains how they fit together.
The register
Six rules, side by side
| Rule | Who | What | Where | From |
|---|---|---|---|---|
| SECR (quoted) | Every UK quoted company | Global Scope 1 and 2, global energy, an intensity ratio, methodology, efficiency action | Directors’ report | Years beginning on or after 1 April 2019 |
| SECR (unquoted, LLP) | Large unquoted companies and LLPs — exceeding two of £36m turnover, £18m balance sheet, 250 employees | UK energy (gas, electricity, transport fuel) and the emissions from it, an intensity ratio, methodology, efficiency action | Directors’ report; LLPs an energy and carbon report | Years beginning on or after 1 April 2019 |
| Climate-related financial disclosures | Traded, banking, insurance and AIM companies, and companies with turnover above £500m — each with more than 500 employees | Eight disclosures: governance, risk processes, principal risks, impacts, scenario resilience, targets, KPIs | Strategic report | Years beginning on or after 6 April 2022 |
| UK SRS (FCA rules) | Listed companies in UKLR 6, 14, 15, 16 and 22 | UK SRS S2 climate disclosures, including Scope 1, 2 and 3; then S1 | Annual financial report | Periods beginning on or after 1 January 2027 — comply or explain |
| ESOS | Large undertakings: 250 or more employees, or turnover above £44m and balance sheet above £38m | Energy audit of total consumption, action plan, notification | Notified to the Environment Agency | Phase 4: qualification 31 Dec 2026, compliance 5 Dec 2027 |
| PPN 006 | Bidders for in-scope central government contracts above £5m a year including VAT | A Carbon Reduction Plan: Scope 1, 2 and five Scope 3 categories; net zero by 2050 at the latest | The supplier’s website | Procurements advertised from 24 February 2025 |
Each rule takes its numbers from the same inventory, built to the GHG Protocol Corporate Standard with factors usually from the government conversion factors.
What differs is the boundary each asks for — UK-only energy for unquoted SECR, global emissions for quoted SECR and UK SRS, energy alone for ESOS, five named Scope 3 categories for PPN 006.
The method is covered in carbon accounting and the GHG Protocol.
Module 01 / 03
Shared inventory
Module 02 / 03
Different boundaries
Which apply to you
Put in one year’s figures and see which duties they trigger
The finder on this panel tests one year’s single-entity figures against each rule’s own wording, and shows the paragraph it used.
It covers SECR, the Companies Act climate disclosures, UK SRS and ESOS, and four ESG duties that turn on similar figures; PPN 006 depends on a contract rather than your size, and has its own check on the Carbon Reduction Plan page.
It does not aggregate groups or apply the two-consecutive-year rules; those are named in the result for you to check.
Three traps account for most wrong answers.
SECR’s unquoted test is an exemption, so a company is in only when it exceeds at least two of the three thresholds — and those thresholds were not changed by the April 2025 Companies Act uplift.
ESOS uses different figures again: 250 or more employees, or turnover above £44m and a balance sheet above £38m.
And an AIM company is unquoted for SECR but can be inside the Companies Act climate disclosure duty.
One year’s figures · eight UK duties
5 of 8 tests point to a duty on these figures.
No UK SRS duty for this category or for an unlisted entity.
The standards remain available for voluntary use.
Fewer than two conditions are met, so these figures point to a SECR duty: UK energy, emissions and an intensity ratio in the directors’ report.
At or under the 500-employee floor, which applies to every limb, so this duty does not arise.
The large-undertaking test is met.
For Phase 4 it is taken on 31 December 2026 across the UK group, with compliance notified by 5 December 2027.
Total turnover is not less than £36 million, so a supplier of goods or services publishes a slavery and human trafficking statement each financial year.
Subsidiaries’ turnover counts.
250 or more employees: a private or voluntary-sector employer publishes six figures within 12 months of the 5 April snapshot date.
The count is taken on that date, not as an average.
Larger than medium-sized on these figures, so the strategic report includes a statement of how the directors had regard to s.172(1)(a)–(f), including the environment.
Not applicable: the Code reaches the commercial companies and closed-ended investment funds categories only.
One year, one entity, literal readings.
It does not aggregate groups, apply the two-year rules or the ESOS snapshot date.
Nothing you enter leaves your browser.
1 · SECR
Streamlined Energy and Carbon Reporting — the base layer
SECR was made by SI 2018/1155, which inserted Parts 7 and 7A into Schedule 7 of the large company accounts regulations and applies to financial years beginning on or after 1 April 2019.
Read the provisions and qualifications
DESNZ’s evaluation counted about 19,900 organisations in scope, 76% more than the impact assessment forecast.
Quoted companies report global Scope 1 and 2 emissions, global energy use, at least one intensity ratio, the methodology, and the energy efficiency action taken.
Large unquoted companies and LLPs report UK energy from gas, electricity and transport fuel, the emissions from it, an intensity ratio, methodology and efficiency action; transport fuel for which the company is responsible reaches some business travel, the one SECR limb outside Scope 1 and 2.
A company that consumed 40,000 kWh of energy or less in the period — in the UK, for unquoted companies and LLPs — need not give the energy and carbon information, provided the report states that this is the reason.
The government’s May 2026 post-implementation review decided to retain SECR and named areas for possible amendment without deciding them.
The SECR legislation page walks the statutory text, the SECR reporting guide the content, and SECR reporting software the tools.
Module 01 / 04
Legal instrument
Module 02 / 04
Evaluation
Module 03 / 04
Quoted disclosures
Module 04 / 04
Unquoted disclosures
2 · Climate-related financial disclosures
The Companies Act duty most summaries leave out
Since financial years beginning on or after 6 April 2022, s.414CB(2A) of the Companies Act has required eight climate-related financial disclosures in the strategic report.
Read the provisions and qualifications
Scope is in s.414CA: traded companies, banking companies, authorised insurance companies, companies carrying on insurance market activity, AIM companies and “high turnover” companies with turnover above £500m.
Every one of those limbs is then subject to a floor: a company with no more than 500 employees, or a parent whose group has no more than 500, is out.
The eight limbs are governance, risk identification and management, integration into overall risk management, principal risks and opportunities with their time periods, their impacts on the business model and strategy, scenario resilience, targets, and the key performance indicators.
Only the last four — (e) to (h) — may be omitted, and then only with a reasoned explanation.
The duty does not require emissions figures as such, but targets and KPIs usually are emissions, so the inventory feeds it.
The government has confirmed that UK SRS S2 is a national reporting framework under s.414CB(6), so a company reporting under UK SRS S2 need not duplicate these disclosures, and it will consider the future of the duty (consultation response, Chapter 3).
The first statutory review report is due before 6 April 2027.
Module 01 / 04
Eight disclosures
Module 02 / 04
Company routes
Module 03 / 04
Employee floor
Module 04 / 04
Required contents
3 · UK SRS
UK SRS for listed companies — comply or explain from 2027
UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 as voluntary standards.
Read the provisions and qualifications
The FCA’s PS26/19, published on 30 September 2026, makes them the reporting basis for listed companies on a comply-or-explain footing, finalising CP26/5.
A company that does not disclose under UK SRS S2, or does so in part, states a summary of the unmet requirements, the reasons, and the steps it is taking (UKLR 6.6.6R(7A)).
It also states whether it obtained third-party assurance and whether it has published a transition plan.
For accounting periods beginning before 1 January 2027, the existing TCFD-aligned disclosure applies, or a company can adopt UK SRS early and keep the reliefs.
No private-company threshold or date has been proposed anywhere.
UK SRS compliance covers the obligations in detail, UK SRS S1 and IFRS S2 the standards themselves, and when each standard applies is set out date by date.
Module 01 / 04
Voluntary standards
Module 02 / 04
FCA obligation
Module 03 / 04
Explanations
Module 04 / 04
Additional statements
Tables and tools
Comply or explain across all of UK SRS — S2 included.
Listed companies in UKLR 6, 14, 15, 16 and 22.
Accounting periods beginning on or after 1 January 2027; first reports in 2028.
One year’s relief for Scope 3; two years’ for S1’s non-climate matters.
Excluded: closed-ended funds, OEICs, shell companies and debt and specialist securities.
4 · ESOS
ESOS measures energy, not carbon — but it shares the data
The Energy Savings Opportunity Scheme requires large undertakings to measure their total energy consumption, audit it, and notify the Environment Agency (ESOS guidance).
Read the provisions and qualifications
The test, in Schedule 1, is 250 or more employees, or turnover above £44m and a balance sheet above £38m — different figures from SECR, applied to the whole UK group.
For Phase 4 the qualification date is 31 December 2026 and the compliance date 5 December 2027.
ESOS asks for no emissions figure, but its energy data — fuels, electricity, transport — is the same activity data SECR multiplies by a factor, which is why most organisations run the two together.
ESOS compliance guidance and the Phase 4 compliance guide cover the duties; ESOS and UK SRS covers running the two together.
Module 01 / 04
Assessment duty
Module 02 / 04
Size test
Module 03 / 04
Phase 4 dates
Module 04 / 04
Activity data
5 · PPN 006
Carbon Reduction Plans for government suppliers
PPN 006 asks bidders for in-scope central government contracts to provide a Carbon Reduction Plan, for procurements advertised from 24 February 2025.
Read the provisions and qualifications
It applies to central government departments, their executive agencies and non-departmental public bodies, for contracts above £5m a year including VAT, averaged over the life of the contract.
The plan reports Scope 1, Scope 2 and five Scope 3 categories — upstream transport, waste, business travel, employee commuting and downstream transport — and commits to net zero by 2050 at the latest.
It is a selection criterion in a procurement, not a statutory filing, and it is published on the supplier’s website.
PPN 026, published on 5 August 2026, applies from 1 January 2027 with a lower threshold; the Carbon Reduction Plan page covers both.
Module 01 / 04
Bidding supplier
Module 02 / 04
Buyer and value
Module 03 / 04
Emissions categories
Module 04 / 04
Selection and publication
6 · CSRD
The EU rule UK groups meet through their subsidiaries
The EU’s Corporate Sustainability Reporting Directive reaches UK companies through EU subsidiaries and EU turnover.
Read the provisions and qualifications
Omnibus I, Directive (EU) 2026/470, narrowed scope: from financial years beginning on or after 1 January 2027, an undertaking is in only if it exceeds both 1,000 employees and €450m net turnover.
The non-EU parent test rose to €450m of EU turnover, with an EU subsidiary or branch above €200m.
Climate reporting under CSRD follows ESRS E1, which requires both location-based and market-based Scope 2 — one of several differences from UK SRS S2.
CSRD vs UK SRS sets the two side by side.
Module 01 / 04
UK group exposure
Module 02 / 04
Amended scope
Module 03 / 04
Non-EU parent
Module 04 / 04
Climate standard
Enforcement
Who enforces what — and with which powers
The six rules are enforced in entirely different ways.
SECR carries no penalty of its own; a missing or wrong disclosure makes the directors’ report non-compliant under the Companies Act.
Directors who approve a report they know does not comply, or are reckless as to whether it does, and fail to take reasonable steps commit an offence under s.419; the FRC can apply to court under s.456 for a revised report.
For LLPs the regulations create matching offences attached to the energy and carbon report itself.
The FRC says it and its predecessors have resolved every case voluntarily, without a court order.
The Companies Act climate disclosures sit under the same directors’ report and strategic report regime.
UK SRS reporting is a Listing Rule obligation, so it is the FCA’s to supervise.
ESOS is the only one with a civil penalty table, enforced by the Environment Agency under Part 8 of the ESOS Regulations; the calculator on this panel works through the statutory maxima for each failure.
PPN 006 is enforced through the procurement: the plan is a selection criterion, so a bid without one that meets the Technical Standard can fail at that stage.
Part 8 of SI 2014/1643 · statutory maxima
Maximum so far: £5,000
Fixed £5,000 + 0 working days × £500 = £0 · statutory ceiling £45,000
The notification of compliance under regulation 29 was not made by the compliance date.
Every Part 8 penalty also carries publication: the regulator names the undertaking, the requirement breached and the amount.
An indicative reading of SI 2014/1643 regs 41 and 43–47, and the Environment Agency’s enforcement policy Annex 2.
The regulator sets the actual amount; nothing here is advice.
Dates
The dates that matter, 2019 to 2028
- 1 Apr 2019SECR
Applies to financial years beginning on or after this date.
- 6 Apr 2022Companies Act climate disclosures
Financial years beginning on or after this date.
- 24 Feb 2025PPN 006
Procurements advertised from this date.
- 25 Feb 2026UK SRS S1 and S2 published
By the Department for Business and Trade, as voluntary standards.
- 26 May 2026SECR review
Government decides to retain SECR.
- 30 Sep 2026FCA PS26/19
Final rules: UK SRS on a comply-or-explain basis.
- 31 Dec 2026ESOS Phase 4 qualification date
Size test applied on this date.
- 1 Jan 2027UK SRS and PPN 026
UK SRS periods begin; PPN 026 applies.
- Before 6 Apr 2027CFD review report
First statutory review of the climate disclosure duty.
- 5 Dec 2027ESOS Phase 4 compliance date
Notification due.
- 2028First UK SRS reports
For periods beginning in 2027.
Every date here is from the instrument that sets it; for the full UK SRS sequence see UK SRS S1 and S2.
Assurance depends on the regime. In-scope CSRD sustainability reporting requires limited assurance under Article 34. The FCA’s UK SRS rules require a statement of whether assurance was obtained, and SECR does not impose a statutory assurance duty. See sustainability assurance for the separate standards and obligations.
For the tools that produce the numbers, see carbon reporting software.
A reading and preparation sequence
carbon reporting requirements uk: from the question to the evidence
- Step 0101
Reporting routes
Each rule takes its numbers from the same inventory, built to the GHG Protocol Corporate Standardwith factors usually from the government conversion factors.Read the detail. - Step 0202
Energy and carbon report
SECR was made by SI 2018/1155, which inserted Parts 7 and 7A into Schedule 7 of the large company accounts regulations and applies to financial years beginning on or after 1 April 2019.Read the detail. - Step 0303
Climate disclosures
Since financial years beginning on or after 6 April 2022, s.414CB(2A)of the Companies Act has required eight climate-related financial disclosures in the strategic report.Read the detail. - Step 0404
Listed-company reporting
UK SRS S1 and S2 were published by the Department for Business and Tradeon 25 February 2026 as voluntary standards.Read the detail. - Step 0505
Energy assessment
The Energy Savings Opportunity Scheme requires large undertakings to measure their total energy consumption, audit it, and notify the Environment Agency (ESOS guidance).Read the detail. - Step 0606
Procurement plan
PPN 006asks bidders for in-scope central government contracts to provide a Carbon Reduction Plan, for procurements advertised from 24 February 2025.Read the detail. - Step 0707
EU reporting route
The EU’s Corporate Sustainability Reporting Directive reaches UK companies through EU subsidiaries and EU turnover.Read the detail.
Dates, with their status
The relevant dates, drawn in order
- Years from 1 April 201901
SECR begins
The 2018 regulations amend Schedule 7 and introduce the energy and carbon report for qualifying LLPs. - Years from 6 April 202502
Companies Act size limits change
The general accounts thresholds change; the self-contained SECR £36m and £18m limits do not move with them. - 11 June 202603
2026 conversion factors published
Match the factor year to the activity-data year. Publication or filing year is a different clock. - 31 July 202604
Flat-file correction
Unavailable values had been shown as zero. The corrected flat file restores blanks; the full-set workbook was not revised. - 30 September 202605
FCA final rules
PS26/19 sets a comply-or-explain reporting obligation for the five in-scope listing categories. It replaces the consultation proposals. - 31 December 202606
Qualification date
Assess the undertaking and group using the statutory tests and relevant accounts. - Periods from 1 January 202707
New listed-company regime
The first eligible accounting periods begin. Optional reliefs cover Scope 3 for one year and wider S1 sustainability information for two years. - 5 December 202708
Notify Phase 4 compliance
Complete the applicable assessment route, approvals and notification through MESOS.
Continue your research
Related reporting guides, one question at a time
Frequently asked
UK carbon reporting requirements, answered
Is carbon reporting mandatory in the UK?
For some organisations.
SECR requires every quoted company and every large unquoted company and LLP to report energy and emissions — about 19,900 organisations by DESNZ’s count.
Companies Act climate-related financial disclosures apply to traded, banking, insurance, AIM and high-turnover companies with more than 500 employees.
Listed companies report against UK SRS on a comply-or-explain basis for periods beginning on or after 1 January 2027.
ESOS requires large undertakings to measure energy, not report emissions.
Suppliers bidding for large central government contracts provide a Carbon Reduction Plan.
Who needs to report under SECR?
All UK quoted companies, whatever their size; and large unquoted companies and LLPs — those not exempt under Schedule 7 ¶20B, which exempts a company meeting two or more of turnover not more than £36m, balance sheet not more than £18m and not more than 250 employees.
So a company must exceed at least two of the three to be in scope.
What is the deadline for SECR reporting in the UK?
SECR has no deadline of its own.
The disclosures sit in the directors’ report, which is filed with the accounts — for a private company, normally nine months after the end of the financial year, and for a public company six months.
Is UK SRS replacing SECR?
No. SECR is a Companies Act duty in the directors’ report; UK SRS is a set of standards the FCA applies to listed companies.
A listed company subject to SECR does both.
The government’s May 2026 review decided to retain SECR, with amendments still to be considered.
Is UK SRS mandatory for listed companies?
Not in the sense of “must comply in full”.
The FCA’s final rules (PS26/19) require listed companies in UKLR 6, 14, 15, 16 and 22 to report against UK SRS or explain what they have not disclosed, why, and what they plan to do — for accounting periods beginning on or after 1 January 2027, with first reports in 2028.
What happens if a company does not comply with SECR?
There is no SECR-specific fine.
Non-compliance makes the directors’ report defective under the Companies Act: directors who approve a report they know does not comply, or are reckless about it, commit an offence under s.419, and the FRC can seek a court order for revision under s.456.
The FRC says every case so far has been resolved voluntarily.
What are the ESOS penalties?
The Environment Agency can impose civil penalties under Part 8 of the ESOS Regulations.
The largest, for failing to carry out an energy audit or alternative compliance route, is up to £50,000 plus up to £500 for each working day of continued failure, capped at 80 working days; others start at £5,000.
Do private companies have to report against UK SRS?
No. No government document proposes a threshold or date for private companies.
Large private companies remain under SECR and, above the Companies Act thresholds, under the climate-related financial disclosure duty in s.414CB.
Do UK companies need to comply with CSRD?
Only through EU exposure.
After Omnibus I, an EU undertaking is in scope from financial years beginning on or after 1 January 2027 if it exceeds both 1,000 employees and €450m net turnover; the non-EU parent test is €450m of EU turnover with an EU subsidiary or branch above €200m.
EU subsidiaries of UK groups are where most UK companies meet it.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- legislation.gov.ukThe Companies (Directors’ Report) and LLP (Energy and Carbon Report) Regulations 2018 (SI 2018/1155)
SECR: Schedule 7 Parts 7 and 7A to SI 2008/410.
- legislation.gov.ukSI 2008/410 Schedule 7 Part 7A — large unquoted companies
¶20B exemption; ¶20D content.
- legislation.gov.ukSI 2008/410 Schedule 7 Part 7 — quoted companies
Global Scope 1 and 2, energy, an intensity ratio.
- legislation.gov.ukCompanies Act 2006 s.414CA — climate-related financial disclosure: scope
Traded, banking, insurance, AIM and high-turnover companies, each with more than 500 employees.
- legislation.gov.ukCompanies Act 2006 s.414CB — the eight disclosures
(2A)(a)–(h); omission with explanation for (e)–(h) only.
- legislation.gov.ukCompanies Act 2006 s.419 — approval of the directors’ report
The offence behind a non-compliant SECR disclosure.
- legislation.gov.ukCompanies Act 2006 s.456 — court-ordered revision
Exercised through the FRC since 6 May 2021.
- DESNZ (GOV.UK)SECR regulations: evaluation (29 January 2026)
About 19,900 organisations in scope.
- DESNZ (GOV.UK)SECR post-implementation review (26 May 2026)
Retain, with amendments to be considered.
- HM GovernmentEnvironmental Reporting Guidelines (March 2019)
SECR guidance.
- Financial Conduct AuthorityPS26/19: final rules on UK SRS for listed issuers (30 September 2026)
Comply or explain for periods beginning on or after 1 January 2027.
- Financial Conduct AuthorityPS26/19 (PDF), Appendix 1
UKLR 6.6.6R(7A), (8); UKLR TP 16.
- Financial Conduct AuthorityCP26/5 — the consultation the rules finalise
Consultation page.
- Department for Business and Trade (GOV.UK)UK SRS S1 and S2
Published 25 February 2026.
- Department for Business and TradeUK SRS consultation response, Chapter 3
UK SRS S2 is a national reporting framework under s.414CB(6).
- Environment Agency (GOV.UK)Energy Savings Opportunity Scheme (ESOS)
Phase 4 guidance.
- legislation.gov.ukESOS Regulations 2014, Schedule 1
The large-undertaking test.
- Cabinet Office (GOV.UK)PPN 006: Taking account of Carbon Reduction Plans in the procurement of major government contracts
Above £5m a year including VAT; from 24 February 2025.
- Cabinet Office (GOV.UK)PPN 026
Published 5 August 2026; applies from 1 January 2027.
- DESNZ (GOV.UK)Government conversion factors for company reporting
The factors most UK reporters use.
- GHG ProtocolCorporate Accounting and Reporting Standard
The method under every regime here.