Carbon reporting requirements UK: every duty in one register

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.

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.

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.

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.

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.

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.

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.

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.

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.

SECR is one of several UK carbon reporting requirements: the energy and emissions disclosure in the annual report of quoted companies and large unquoted companies and LLPs.

The others are the Companies Act climate-related financial disclosures, UK SRS for listed companies, PPN 006 for government suppliers, ESOS energy audits, UK ETS emissions reports, CBAM returns on imports and the climate reports of pension scheme trustees.

Operators of installations carrying out regulated activities, including fuel combustion on sites with more than 20MW total rated thermal input, aircraft operators on covered routes, and since 1 July 2026 operators of ships of 5,000 gross tonnage and above on domestic voyages and in port.

They submit a verified emissions report for the previous scheme year by 31 March and surrender allowances by 30 April.

It is a tax rather than a disclosure, but its return is built on the embodied emissions of imported goods.

CBAM commences on 1 January 2027 for aluminium, cement, fertiliser, hydrogen, and iron and steel goods; an importer of £50,000 or more of CBAM goods in 2027 registers by 31 January 2028 and files the first return and payment by 31 May 2028.

Trustees of larger occupational pension schemes, and of authorised master trusts and collective money purchase schemes, must run climate governance and publish a TCFD-aligned report within seven months of each scheme year end under SI 2021/839.

They obtain, as far as they are able, the emissions attributable to the scheme’s assets, with Scope 3 excused in the first scheme year.

Usually not, unless a specific trigger applies.

A small private company is outside SECR unless it is quoted, and outside ESOS and the Companies Act climate disclosures by size.

A bid for a central government contract above £5 million a year can still bring a Carbon Reduction Plan, and imports of CBAM goods can bring CBAM duties.

Not in general.

Listed companies report Scope 3 under UK SRS S2 on comply or explain after a one-year relief, SECR reaches only transport fuel for unquoted companies and LLPs, and PPN 006 asks for five Scope 3 categories.

SECR and most voluntary reporting use DESNZ’s government conversion factors for the year in which the activity took place; the 2026 set was published on 11 June 2026.

UK SRS S2 prescribes no factors.

The UK ETS and CBAM use monitored or verified emissions, or CBAM default values.

Not for SECR, PPN 006 or UK SRS.

Listed companies under the FCA’s rules state whether they obtained third-party assurance.

UK ETS emissions reports must be verified, and CBAM actual data must be verified emissions intensity data.

Proposals are open.

The Modernising corporate reporting consultation, closing on 30 November 2026, proposes to abolish the directors’ report and move SECR disclosures elsewhere in the annual report without changing their content.

The SECR review recommended keeping SECR with amendments, and the review of the Companies Act climate disclosures is due by spring 2027.