ESOS and SECR · two regimes, one dataset
ESOS vs SECR: an audit every four years, a disclosure every year
ESOS and SECR are the UK’s two large energy duties, and many organisations owe both.
ESOS is a four-yearly assessment of energy use, notified to the Environment Agency; SECR is an annual disclosure of energy and emissions in the company’s own annual report.
Their scope tests share one number, 250 employees, and still give different answers — run your figures through both below.
Which applies
One set of figures, two different tests
The ESOS test in Schedule 1 to the ESOS Regulations is either/or: an undertaking qualifies if it employs at least 250 people, or if its turnover exceeds £44 million and its balance sheet exceeds £38 million.
The drafting is asymmetric: exactly 250 employees qualifies, but exactly £44 million turnover does not.
The SECR test in paragraph 20B is two-of-three and drafted as an exemption: an unquoted company reports when it exceeds at least two of £36 million turnover, £18 million balance sheet and 250 employees, over two consecutive years after its first.
Quoted companies are in SECR at any size, so a small listed company can owe SECR while falling below every ESOS limb.
ESOS takes a snapshot on the qualification date — 31 December 2026 for Phase 4 — and aggregates the UK group; SECR tests each company that files a directors’ report, with a parent tested on group figures.
SECR reaches only companies and LLPs, while the ESOS test is framed around “undertakings”, a wider word; the ESOS pages here explain who counts.
The ESOS requirements and SECR requirements pages set each test out in full.
SECR scope check · Schedule 7 ¶¶15, 20B, 20C
Enter all three figures for both years to see the result.
Whatever the result, a reporter that consumed 40,000 kWh or less may withhold the figures only by saying so in the report.
An indicative reading of SI 2008/410 Sch 7 ¶¶15(1), 20B, 20C and SI 2008/1911 reg 12B, and SI 2014/1643 Sch 1 ¶¶1, 1A.
Nothing you enter leaves this page.
Not legal advice.
Side by side
The two regimes, axis by axis
| ESOS | SECR | |
|---|---|---|
| Instrument | SI 2014/1643, under Energy Act 2023 ss.254–260 and 263 | SI 2018/1155, into SI 2008/410 Sch 7 and SI 2008/1911, under Companies Act s.416(4) |
| Who | Large undertakings and their UK groups | Quoted companies; large unquoted companies and LLPs |
| Cycle | Four-year phases; Phase 4 runs 6 Dec 2023 – 5 Dec 2027 | Every financial year |
| What is produced | An assessment of at least 95% of energy use (or ISO 50001), then an action plan and progress updates | Energy in kWh, emissions in tCO2e, a ratio, methodology, efficiency measures |
| Intensity ratios | One per organisational purpose — up to four | At least one emissions ratio |
| Who signs | One or two directors, depending on the lead assessor | The board, with the directors’ report |
| Goes to | The Environment Agency, through MESOS | Companies House, in the annual report |
| Public? | Selected data published by the scheme administrator | Yes — the filed accounts |
| Enforcement | Civil penalties to £50,000, daily sums, publication | Companies Act: s.419 offence, s.456 revision; no SECR penalty |
The share of energy an ESOS assessment must cover rose from 90% to 95% under the 2023 amendments, with up to 5% left as de minimis.
Phase 4 routes are the ESOS energy audit or ISO 50001; the 2026 amendments removed Display Energy Certificates and Green Deal Assessments.
The scheme administrator publishes selected ESOS information — the Environment Agency has released Phase 3 action plans and progress updates as open data — while SECR is public because it sits in the filed accounts.
The ESOS hub and the SECR overview cover each regime in the round.
Edge cases
Where the two tests part company
The 250 figure appears in both tests but does different work: in ESOS it qualifies on its own, in SECR it is one of three limbs, two of which must be exceeded.
The money limbs point the other way: ESOS needs both turnover and balance sheet above its higher figures, SECR needs any two of three above its lower ones.
Since April 2025 neither test follows the Companies Act size classes, so an auditor’s reclassification of a company as medium-sized settles neither.
ESOS first tests each undertaking’s size and status history; one qualifying UK member can bring its UK group into participation. It does not decide qualification by adding consolidated group figures (regulation 15). SECR has separate group-reporting provisions, including conditions for a subsidiary relying on a compliant group report.
No threshold alignment has been announced: the 2026 ESOS amendments left the ESOS test unchanged, and SECR’s has not moved since 2019.
| Figures (illustrative) | ESOS | SECR (unquoted) |
|---|---|---|
| 300 staff · £20m turnover · £10m balance sheet | In (staff) | Out (one limb exceeded) |
| 100 staff · £40m turnover · £20m balance sheet | Out | In (two limbs exceeded) |
| 260 staff · £50m turnover · £40m balance sheet | In | In |
| UK quoted company, 40 staff, £8m turnover | Out | In (quoted, any size) |
Energy audit and SECR
An ESOS report and a SECR section are different documents
People searching for “energy audit and SECR” are usually asking whether one piece of work can do both jobs, and the honest answer is that it can feed both but discharge only one.
An ESOS assessment looks at where the organisation uses energy, identifies cost-effective savings, and ends in a notification to the Environment Agency, backed by an evidence pack that stays with the participant.
A SECR section reports what was consumed and emitted in one financial year, with a ratio and a narrative, inside a report anyone can download from Companies House.
So the ESOS output is private and forward-looking, and the SECR output is public and backward-looking.
The ESOS rules on what is published make the difference sharper: only the combined kWh saving is published, while a SECR narrative describing the measures behind it puts more on the public record than the ESOS register does.
The practical overlap is the dataset: the twelve months of consumption ESOS requires, its savings estimates in kWh and its record of measures implemented are exactly what the SECR energy figure and efficiency paragraph draw on.
The quiz beside this text tests the distinctions that most often go wrong, each with the provision behind the answer.
ESOS and SECR: true or false?
A company with 300 employees, £20m turnover and a £10m balance sheet is in both ESOS and SECR.
An ESOS energy audit satisfies the SECR disclosure.
Both regimes now measure energy in kWh.
SECR, like ESOS, has a fixed qualification date for everyone.
Only the combined ESOS energy saving is published, not each measure.
The Environment Agency can fine a company for a missing SECR section.
0 of 6 answered.
Nothing you choose is stored or sent.
Enforcement
A regulator with penalties, and a company-law duty without one
ESOS is enforced by the compliance bodies — the Environment Agency in England, Natural Resources Wales, SEPA in Scotland and the Northern Ireland regulator — under Part 8 of the Regulations.
There is no penalty in Part 8 for missing an action plan or progress update, though the failure is published and a regulator could serve a notice; the ESOS penalties page covers the detail.
SECR has no regulator and no penalty in its own instruments.
A directors’ report that omits the section exposes directors who knew or were reckless to an offence under section 419 of the Companies Act 2006, and the FRC can apply to court for its revision; the accounts filing deadline carries the ordinary late-filing penalty.
The SECR legislation page explains why: SECR was made under a Companies Act power as part of company reporting, while ESOS rests on an energy statute with an administrator of its own.
The Modernising Corporate Reporting consultation (¶149) would move SECR out of the abolished directors’ report, and says DESNZ intends to consult on SECR and ESOS together later in 2026 (¶150).
Neither is law.
| ESOS failure | Maximum | Daily sum |
|---|---|---|
| Failure to notify (reg 43) | £5,000 | £500 per working day, 80 working days |
| Failure to keep records (reg 44) | £5,000 plus audit cost | None |
| No ESOS assessment (reg 45) | £50,000 | £500 per working day, 80 working days |
| Ignoring a notice (reg 46) | £5,000 | £500 per working day, 80 working days |
| False or misleading statement (reg 47) | £50,000 | None |
The wider map
Both regimes in the UK reporting landscape
ESOS extends to England and Wales, Scotland and Northern Ireland, with a regulator in each; the regimes by jurisdiction page sets out how each duty applies across the four nations.
SECR’s instrument is SI 2018/1155; ESOS’s is SI 2014/1643, and the Environment Agency’s ESOS guidance and Phase 4 guidance explain the scheme.
For every UK duty on energy and emissions in one place, see carbon reporting, and for putting ESOS into practice, ESOS compliance guidance.
Frequently asked
ESOS and SECR, answered
What is the difference between ESOS and SECR?
ESOS is a four-yearly assessment of an organisation’s energy use, notified to the Environment Agency, with its own qualification test and civil penalties.
SECR is an annual disclosure of energy use and emissions in the directors’ report, or an LLP’s energy and carbon report, filed with the accounts.
They use different tests, run on different clocks and have different enforcement, though they draw on the same energy data.
Can an organisation be in ESOS but not SECR, or the other way round?
Yes.
ESOS catches an undertaking with at least 250 employees, or with turnover in excess of £44 million and a balance sheet in excess of £38 million.
SECR catches every quoted company, and unquoted companies and LLPs exceeding two of £36 million turnover, £18 million balance sheet and 250 employees.
So 300 staff and £20 million turnover is in ESOS but, with a £10 million balance sheet, out of SECR; £40 million turnover, a £20 million balance sheet and 100 staff is in SECR but out of ESOS.
Does ESOS compliance satisfy SECR?
No. Neither discharges the other.
An ESOS assessment is not a SECR disclosure, and a SECR disclosure counts for nothing in ESOS.
The link is practical: the audited energy data and the measures identified in ESOS are good evidence for SECR’s annual energy figures and its efficiency narrative.
What are the ESOS and SECR deadlines?
ESOS runs in fixed four-year phases for everyone: in Phase 4 the qualification date is 31 December 2026 and notification of compliance is due by 5 December 2027.
SECR runs on each company’s own financial year and is filed with the accounts — nine months after the year end for a private company or LLP, six months for a public company.
Who enforces ESOS and SECR?
ESOS is enforced by the compliance bodies — the Environment Agency in England, and the equivalent regulators in Wales, Scotland and Northern Ireland — with civil penalties whose statutory maximum is £50,000 for the most serious breaches, some with £500 for each working day of continued failure, capped at 80 working days, plus publication.
SECR has no regulator or penalty of its own: a defective directors’ report is a Companies Act matter, and the FRC can seek a court order to revise it.
Do ESOS and SECR both need an intensity ratio?
Yes, but not the same one.
SECR needs at least one emissions ratio against a factor the company chooses.
ESOS needs an energy intensity ratio for each organisational purpose that applies — transport, industrial processes, buildings and any other purpose — so up to four.
Are the ESOS and SECR thresholds being aligned?
No alignment has been announced.
SI 2026/701, the 2026 ESOS amendments, did not change the ESOS qualification test, and SECR’s thresholds have not changed since 2019.
The government has said DESNZ intends to consult on SECR and ESOS later in 2026; nothing has been proposed yet.
Is an ESOS report published?
Not in full.
The ESOS report and evidence pack stay with the participant, and the notification goes to the Environment Agency, which publishes selected data — for Phase 4, only the combined kWh saving from the new savings-achieved table.
A SECR section, by contrast, is published in full in the filed accounts.
Can one energy dataset serve both ESOS and SECR?
Yes, and that is the main practical link between them.
Both now measure energy in kWh, and ESOS Phase 4 requires an estimate of savings achieved per measure, which is the evidence a SECR efficiency narrative needs.
The boundaries differ — ESOS covers the whole UK group on its qualification date, SECR the reporting company or group for its financial year — so the dataset needs both cuts.
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 Energy Savings Opportunity Scheme Regulations 2014, SI 2014/1643
The ESOS duties: qualification (Sch 1 via reg 15), phases (reg 4), penalties (Part 8).
- legislation.gov.ukSI 2014/1643, Schedule 1 — the large undertaking test
At least 250 employees, or turnover in excess of £44m and balance sheet in excess of £38m.
- legislation.gov.ukSI 2014/1643, Part 8 — civil penalties
Five penalties, £500 a working day capped at 80 working days where it applies.
- legislation.gov.ukESOS (Amendment) Regulations 2023, SI 2023/1182
Raised the significant-consumption share in reg 25(2) from 90% to 95%.
- legislation.gov.ukESOS (Amendment) Regulations 2026, SI 2026/701
In force 22 July 2026: kWh estimates, achieved savings, DECs and GDAs removed.
- GOV.UK (Environment Agency)How to comply with ESOS phase 4
Phase 4 dates, routes, transport scope and sign-off.
- GOV.UK (Environment Agency)Energy Savings Opportunity Scheme (ESOS) — guidance
The scheme hub.
- legislation.gov.ukSI 2018/1155 as made — contents
The instrument that created SECR.
- legislation.gov.ukSI 2008/410, Schedule 7 Part 7A
The SECR size test (¶20B) and duties (¶20D).
- legislation.gov.ukSI 2008/410, Schedule 7 Part 7
Quoted companies in SECR at any size.
- GOV.UK (DESNZ, Defra, BEIS)Environmental reporting guidelines, including SECR requirements
The SECR guidance, last updated 29 March 2019.
- GOV.UK (DBIST)Modernising corporate reporting — consultation document, ¶¶149–150
SECR’s location to move; DESNZ to consult on SECR and ESOS later in 2026.