Company
Normally the directors’ report. Strategic matters may be in the strategic report under section 414C(11).
Schedule 7 paragraph 1A requires the directors’ report to identify matters treated this way.The standards
Does it apply to you
Reporting under it
Start here
Dates and penalties
Doing it
What you must file
Doing it
Start here
Setting targets
Who and where
The UK duty
Doing it
The baseline
Europe
Reporting more widely
Carbon markets and trade
Packaging and net zero
Carbon accounting
Choosing
Carbon
Compliance and offsets
Software
Templates
Careers
SECR · the finished section
Turn your calculations into a clear annual disclosure. Start with the right reporting route, then assemble the figures, ratio, method and measures.
Use the labelled examples for structure and the model wording as a starting point. Your boundary, evidence and conclusions must be your own.
The layout
A SECR section reads best as one table followed by three short pieces of prose.
The table carries every number: energy by source, the emissions that follow from it, and the previous year beside each from the second reporting year onward.
For a quoted company, the comparative duty sits in two paragraphs — ¶18 for emissions and the ratio, ¶18A for the kWh figure, the UK proportions and the narrative — so a template built on ¶18 alone drops a year of energy data.
The ratio can sit under the table or inside it, and the methodology and efficiency paragraphs follow.
Any relief the company relies on is a sentence in the section itself, not a footnote elsewhere in the annual report.
The rows each reporter owes, and why, are set out paragraph by paragraph on the SECR requirements page.
| Block | What goes in it | Paragraphs |
|---|---|---|
| 1. Headline table | Energy in kWh by source, emissions in tCO2e, this year and last | ¶15(2)–(3C) / ¶20D(1)–(3); ¶18, ¶18A / ¶20H |
| 2. Intensity ratio | At least one ratio, with last year’s | ¶17 / ¶20G |
| 3. Methodology | Standard, factor set and year, boundary, estimates | ¶16 / ¶20F |
| 4. Energy efficiency | Principal measures taken in the year, if any; any relief statement | ¶15(3D) / ¶20D(4); ¶15(4)–(5) / ¶20D(6)–(7) |
Four disclosure parts
Four disclosure parts
Four disclosure parts
Four disclosure parts
Worked example
Every number below is invented to show the layout and the arithmetic.
None is a benchmark, and none was calculated from published conversion factors.
| Energy and emissions (UK) | Year to 31 December 2026 | Year to 31 December 2025 |
|---|---|---|
| Electricity, kWh | 1,240,000 | 1,310,000 |
| Gas, kWh | 820,000 | 870,000 |
| Transport fuel, kWh (fleet and reimbursed mileage) | 360,000 | 345,000 |
| Total energy, kWh (¶20D(3)) | 2,420,000 | 2,525,000 |
| Emissions: gas and transport fuel, tCO2e (¶20D(1)) | 238 | 249 |
| Emissions: purchased electricity, tCO2e (¶20D(2)) | 178 | 206 |
| Total emissions, tCO2e | 416 | 455 |
| Intensity: tCO2e per £m turnover (¶20G) | 9.9 (on £42m) | 11.4 (on £40m) |
The ratio, worked
416 tCO2e ÷ £42m turnover = 9.9 tCO2e per £m in 2026, against 455 ÷ £40m = 11.4 in 2025.
Some of that fall is the turnover rising, not the emissions falling — which is why the narrative should say what actually changed.
What the comparative hides
The electricity figure fell faster than electricity use.
These invented figures do not establish a factor effect. In a real report, quantify and explain activity and factor effects using the actual calculation.
The SECR reporting guide explains the 2026 factor change.
Second example
The same exercise for a fictional quoted group with sites outside the UK.
Every figure is invented; the point is the extra rows Part 7 asks for.
| Energy and emissions (worldwide) | Year to 31 March 2026 | Year to 31 March 2025 |
|---|---|---|
| Total energy, kWh (¶15(3A)) | 18,400,000 | 19,100,000 |
| …of which UK and offshore area (¶15(3C)) | 61% | 63% |
| Emissions from combustion of fuel and operation of facilities, tCO2e (¶15(2)) | 2,310 | 2,420 |
| Emissions from purchased electricity, heat, steam and cooling, tCO2e (¶15(3)) | 1,640 | 1,980 |
| Total emissions, tCO2e | 3,950 | 4,400 |
| …of which UK and offshore area (¶15(3B)) | 54% | 57% |
| Intensity: tCO2e per 1,000 tonnes of product (¶17) | 41.6 | 45.8 |
Three rows separate this table from the unquoted one: the proportion of energy and the proportion of emissions in the UK and offshore area, and a purchased-energy row that includes heat, steam and cooling.
The proportions only make sense because the base is worldwide; Part 7 gives a quoted company no permission to leave overseas sites out.
“Offshore area” is wider than the UK itself, so a company with installations in UK waters reports them in the UK-and-offshore share rather than as overseas.
A quoted company has no transport-fuel limb, so its grey fleet is absent here unless it chooses to add it, with a note saying so.
The ratio uses an output denominator, which suits a manufacturer better than turnover, and the next section shows how to work one.
SECR intensity ratio help
The ratio is the row reporters find hardest, because the regulations leave both the factor and the choice of how many ratios to the company.
The words are the same in paragraph 17 and paragraph 20G: “at least one ratio which expresses the company’s annual emissions in relation to a quantifiable factor associated with the company’s activities”.
So the numerator is always emissions, never energy, and the denominator can be anything the company can count: turnover, floor area, employees, tonnes produced, vehicle miles.
A useful test is whether the denominator moves when the activity that causes the emissions moves; turnover also moves with prices, which is why the manufacturer above uses output.
The calculator beside this text works the arithmetic from kWh to tonnes to a ratio, holding the DESNZ electricity factors for 2025 and 2026 and taking any fuel factor you type from the workbook.
Show the ratio with last year’s beside it, because ¶20H — and ¶18 for a quoted company — requires the previous year’s information as disclosed in the previous report.
If the denominator changes, keep last year’s ratio as disclosed and add a restated figure on the new basis beside it, with a sentence explaining why.
Intensity ratio · Sch 7 ¶17 and ¶20G
Fuels burned (gas, transport fuel), with the factor from the DESNZ 2026 workbook
Electricity 1,200,000 kWh × 0.13096 = 157.2 tCO2e · fuels 0 tCO2e
Illustrative input subtotal: 157.2 tCO2e · ratio 3.27 tCO2e per £m turnover
The same electricity on the 2025 factors would be 212.4 tCO2e.
State which set you used (¶16 / ¶20F), because the 2025 to 2026 change is partly a change of method, not only a cleaner grid.
Grid transmission and distribution losses on this electricity come to 15.6 tCO2e; DESNZ classes them as Scope 3, so they sit outside the Scope 2 figure unless you choose to report them separately.
Electricity factors from DESNZ’s 2025 and 2026 methodology papers, Table 9.
Any denominator the company can quantify will do; one ratio is the minimum.
A worked aid, not advice; nothing is saved.
This subtotal covers only the electricity and fuel inputs entered, not a complete SECR inventory. Fuel inputs here require kWh and a compatible per-kWh factor; use an appropriate method for other units and activities.
Explain the denominator
Explain the denominator
Explain the denominator
Explain the denominator
Model wording
The wording below is written for this page as a starting point; replace every bracket with your own facts, and delete anything that is not true of your company.
The last block follows the government’s stated preference for dual reporting of electricity, recorded on the guidelines page, with the location-based figure first.
“We have followed the GHG Protocol Corporate Accounting and Reporting Standard, using an operational control boundary that covers [the company and its UK subsidiaries].
Energy use is taken from supplier invoices and meter data, fleet fuel from fuel card records, and business mileage from expense claims.
Emissions are calculated using the UK Government greenhouse gas conversion factors for [2026], matched to the year in which the energy was used. [Two months of gas consumption at one site were estimated from the same months of the previous year.]”
“Emissions from purchased electricity fell by [x]% while consumption fell by [y]%.
[Describe the evidenced contribution from activity, factor, boundary and method changes]; we have [explained any additional restatement alongside the original comparative].”
“In the year we [replaced lighting at our two distribution sites with LED fittings and controls] and [moved six of our 20 vans to battery electric].
We estimate these measures [reduced electricity demand by around x kWh a year]. [No other principal measures were taken.]”
“The company took no principal measures to increase its energy efficiency in the financial year.”
“Emissions from purchased electricity are reported on a location basis, using grid-average factors.
On a market basis, using contractual instruments assessed against the applicable GHG Protocol Scope 2 quality criteria, they were [x] tCO2e.”
Write what happened
Write what happened
Write what happened
Model wording for each relief
Three of the four reliefs work only if the report says it is using them, so each needs a sentence of its own.
Adapt the wording, entity terminology and facts to your actual reporting route; check the paragraph so that a reader, or the FRC, can see which provision is being relied on.
“The company consumed 40,000 kWh of energy or less [in the United Kingdom] during the financial year, and the energy and carbon information is not disclosed for that reason.”
“It was not practical to obtain energy consumption data for [two leased offices where the landlord holds the meters].
Their energy use and emissions are not included in the figures above.”
“In the opinion of the directors, disclosure of [the energy information for the X division] would be seriously prejudicial to the interests of the company, and it is not disclosed for that reason.”
“The figures cover energy consumed and emissions arising in the United Kingdom.
Energy and emissions outside the United Kingdom are excluded, as paragraph 20D(5) of Schedule 7 permits.”
The low-energy bracket matters: an unquoted company or LLP counts only UK energy, while a quoted company counts all of it.
A parent relying on the seriously-prejudicial limb should know that its group report then no longer shelters its subsidiaries, each of which must report for itself.
Omit with an explanation
Omit with an explanation
Omit with an explanation
Omit with an explanation
Build the row list
The builder lists the rows for a quoted company, an unquoted company or an LLP, and adds the sentence each relief requires.
Three reliefs are said aloud: information not practical to obtain, consumption of 40,000 kWh or less, and disclosure that would be seriously prejudicial.
The fourth, the subsidiary shelter, is silent, because the Part simply does not apply to a subsidiary covered by a compliant group report.
That shelter fails if the parent relied on the seriously-prejudicial limb, so a parent should decide on that limb with its subsidiaries in mind.
The low-energy statement replaces the numbers, not the section; a company that qualifies and says nothing has not used the relief.
For a group, the parent’s report may leave out any subsidiary that would not have had to disclose the information itself, and the transport-fuel row for an unquoted reporter follows the guidance test of who pays for the fuel.
SECR disclosure builder · Schedule 7
In the directors’ report, row by row:
An indicative reading of SI 2008/410 Sch 7 Parts 7 and 7A.
Not legal advice.
Check the row list
Check the row list
Check the row list
Check the row list
Placement
The default home is the directors’ report, approved by the board and filed at Companies House with the accounts.
Section 414C(11) of the Companies Act 2006 lets the strategic report “contain such of the matters otherwise required … to be disclosed in the directors’ report as the directors consider are of strategic importance to the company”.
Schedule 7 paragraph 1A requires the directors’ report to identify the matters placed in the strategic report under section 414C(11).
An LLP has no directors’ report, so its section is a separate energy and carbon report under regulation 12B.
DESNZ’s 2026 review heard that the lack of a prescribed template causes inconsistent placement and formatting, and a standard template is among the areas it may consult on.
Separately, the government proposes abolishing the directors’ report altogether, which would let companies place SECR anywhere in the first half of the annual report; that is a consultation proposal, not law.
| Route | When it fits |
|---|---|
| Directors’ report | The default for every company |
| Strategic report, cross-referenced | Where the directors consider energy and carbon of strategic importance (s.414C(11)) |
| Energy and carbon report | In-scope LLPs, approved by the members and signed by a designated member |
Normally the directors’ report. Strategic matters may be in the strategic report under section 414C(11).
Schedule 7 paragraph 1A requires the directors’ report to identify matters treated this way.Separate energy and carbon report, approved by members and signed by a designated member.
Apply regulation 12B, including its approval modifications.Building the numbers
The calculation engine behind most SECR tables is the government’s conversion factor workbook, which the 2026 methodology paper says is for activity data falling mostly within the year it is named for.
A single-site company can build the table in a spreadsheet; multi-site groups often use carbon reporting software, and the SECR reporting software page sets out what such a tool must hand back.
If the concern is the calculations rather than the layout, the tests for the tool that does them are in our guide to carbon accounting software, and the method itself is in the GHG Protocol guide.
Filed accounts at Companies House are the best free source of real SECR disclosure examples; the sister reference srsreport.co.uk keeps a line-by-line SECR reporting template of its own.
Treat any example as structure only: your boundary, figures and efficiency measures have to be your own, and there is no statutory requirement to have the figures audited.
The SECR overview explains the regime in the round.
From workbook to report
From workbook to report
From workbook to report
From workbook to report
Assemble the disclosure
An illustrative drafting process; preparation dates follow your financial year and applicable filing timetable.
One year to the next
Before approval
A complete-looking template can still be wrong if its boundary, method or explanations do not match the records.
The worked examples above are fictional. Keep the final figures, narrative and approval grounded in your own evidence.
Final checks
Final checks
Final checks
Frequently asked
No. Schedule 7 to SI 2008/410 prescribes what the section must contain, not how it is laid out, and the government’s 2019 Environmental Reporting Guidelines offer example disclosures that are guidance only.
DESNZ’s 2026 review lists a standardised disclosure template among the areas for a planned consultation, but nothing has been decided.
For an unquoted company or LLP: emissions from gas and transport fuel, emissions from purchased electricity, the energy behind both in kWh, at least one emissions intensity ratio, the methodology, a description of the principal energy efficiency measures if any were taken, and the previous year’s figures from the second year.
A quoted company adds heat, steam and cooling, reports worldwide, and states the UK and offshore proportions.
There is no statutory Excel template.
The DESNZ conversion factors are published as a workbook that most reporters use to calculate their figures, and many companies keep their meter readings, fuel records and mileage claims in a spreadsheet, but the disclosure itself is a short table and prose in the directors’ report.
In other companies’ filed accounts: a qualifying company’s report may provide an example; check scope and any applicable exemption, and the accounts are free to view at Companies House.
The 2019 Environmental Reporting Guidelines also contain example disclosures.
Use them for structure; the figures, boundary and narrative must be your own.
One that reflects what drives the company’s emissions and that it can repeat next year.
Tonnes of CO2 equivalent per £ million of turnover is common and works across sectors; floor area suits property-heavy estates and output suits manufacturers.
The regulations require at least one emissions ratio and leave the denominator to the company.
Yes.
Section 414C(11) of the Companies Act 2006 lets the strategic report contain matters otherwise required in the directors’ report where the directors consider them of strategic importance.
Schedule 7 paragraph 1A requires the directors’ report to identify matters placed in the strategic report this way.
An in-scope LLP uses a separate energy and carbon report.
A statement that the energy and emissions information is not disclosed because the company consumed 40,000 kWh of energy or less in the period — in the United Kingdom, for an unquoted company or LLP. Leaving the section out without that statement is not the relief; the statement is what makes the omission lawful.
The regulations require a description of the principal measures only if the company took any, so a nil statement is not strictly required by the text.
It is still worth one sentence saying no measures were taken, so that a reader does not take silence for an omission.
A short section, usually headed “Streamlined energy and carbon reporting”, containing a table of energy in kWh and emissions in tonnes of CO2e for this year and last, at least one intensity ratio, a paragraph on methodology naming the conversion factor year and boundary, and a paragraph on the principal energy efficiency measures taken.
A quoted company adds the proportions relating to the UK and offshore area.
The comparative duty asks for last year’s information as disclosed in the previous report, so that figure should appear.
Nothing prevents a company adding a restated figure beside it — for example after a boundary change or a change of intensity denominator — with a sentence explaining the difference.
Show the location-based figure, and add a market-based figure where supported by contractual instruments meeting the applicable Scope 2 quality criteria.
The government’s guidance prefers dual reporting and encourages organisations that report one figure to use the location-based method; a market-based figure alone is not what it asks for.
Sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Quality criteria for contractual instruments used in market-based accounting.
Directors’ report identifies matters placed in the strategic report under section 414C(11).
The instrument behind the section; it prescribes content, not format.
The quoted-company rows, ¶¶15–19A.
The unquoted rows, ¶¶20D–20J, and the reliefs in ¶20D(6)–(7).
Why an LLP’s section is a separate report.
Directors may place directors’-report matters of strategic importance in the strategic report.
The official guidance and its example disclosures; last updated 29 March 2019.
The minimum energy sources and the transport-fuel test.
The factor set named in the model methodology statement.
Factors match the year of the activity data.
The method most reporters name.
Names the lack of a standard template as a cause of inconsistent placement and format.