SECR reporting requirements in the UK: what to report

A quoted company, a large unquoted company or a large LLP must disclose, each financial year, its greenhouse gas emissions in tonnes of CO2 equivalent, the energy behind them in kWh, at least one emissions intensity ratio, the methodologies used, the previous year’s figures from the second year onward, and a description of the principal energy efficiency measures taken if it took any.

The duties are in Schedule 7 to SI 2008/410: Part 7 for quoted companies and Part 7A for unquoted companies, applied to LLPs by SI 2008/1911 regulation 12B.

Direct emissions in tonnes of CO2e (¶15(2) for quoted companies, ¶20D(1) for unquoted companies and LLPs); emissions from purchased energy (¶15(3), ¶20D(2)); the underlying energy in kWh (¶15(3A), ¶20D(3)); for quoted companies, the UK and offshore proportions (¶15(3B)–(3C)); a description of the principal energy efficiency measures taken, if any (¶15(3D), ¶20D(4)); the methodologies (¶16, ¶20F); at least one intensity ratio (¶17, ¶20G); the previous year’s figures (¶18, ¶18A, ¶20H); and the period, if it differs from the financial year. Each paragraph is in Schedule 7 to SI 2008/410.

Yes, for a company or LLP within Schedule 7: the disclosures are content the law requires in the directors’ report, or in an LLP’s energy and carbon report, for financial years beginning on or after 1 April 2019.

Quoted companies report at any size; unquoted companies and LLPs report once they exceed two of £36 million turnover, £18 million balance sheet and 250 employees on the two-year rule.

A director who approves a non-compliant report knowingly or recklessly commits an offence under section 419 of the Companies Act 2006.

Large LLPs do.

Regulation 12B of SI 2008/1911 requires the members of an LLP that exceeds two of £36 million turnover, £18 million balance sheet and 250 employees, on the same two-year rule, to prepare an energy and carbon report on the Part 7A basis, approved by the members and signed by a designated member.

An LLP has no directors’ report, which is why it gets a separate document.

A quoted company reports under Part 7 of Schedule 7 at any size, on a worldwide basis, covering emissions from fuel combustion and facility operation and from purchased electricity, heat, steam and cooling, with the UK and offshore proportions.

An unquoted company reports under Part 7A only once over the size limits, may limit itself to UK energy, and covers gas, transport fuel and purchased electricity, including fuel for transport it pays for.

Both give energy in kWh, a ratio, methodology, comparatives and the efficiency narrative.

An unquoted company is exempt in a year in which it meets two or more of three conditions: turnover not more than £36 million, balance sheet total not more than £18 million, and not more than 250 employees. So it reports when it exceeds at least two of them.

After the first financial year the test runs over two consecutive years, so one year over the limits does not bring an exempt company in.

Quoted companies have no size test.

No. SI 2024/1303 raised the Companies Act medium-sized limits to £54 million turnover and £27 million balance sheet for financial years beginning on or after 6 April 2025, but it amended Schedule 7 only by omitting paragraphs 6 and 7 and Parts 3 and 4.

SECR’s own table in paragraph 20B(2) still reads £36 million, £18 million and 250, so a company can be medium-sized for its accounts and still in SECR.

No. Companies Act 2006 section 385 defines a quoted company by reference to the Official List, an EEA official listing, the New York Stock Exchange or Nasdaq, and AIM securities are not admitted to the Official List.

An AIM company is therefore unquoted: it reports only if it exceeds two of the three size limits, and then on the Part 7A basis — UK energy, including transport fuel it pays for.

It is a relief from disclosure, not an exemption from SECR.

A company that consumed 40,000 kWh of energy or less may leave out the figures only if the report states that it is not disclosing them for that reason.

For unquoted companies and LLPs the energy counted is energy consumed in the United Kingdom (paragraph 20D(7)(a)); the quoted-company relief in paragraph 15(5)(a) has no territorial words.

Only one narrow slice, and only for unquoted companies and LLPs.

Paragraph 20D(1)(b) covers emissions from the consumption of fuel for the purposes of transport, which the government guidance limits to transport where the organisation is responsible for purchasing the fuel — including employees’ own cars on business mileage it reimburses.

Quoted companies carry no transport-fuel limb, and no other Scope 3 category appears anywhere in Schedule 7.

There is no penalty in the SECR regulations or in Schedule 7.

A directors’ report that does not comply exposes the directors to the Companies Act 2006 section 419 offence if they knew or were reckless, and the FRC can apply to court under section 456 for an order to revise it.

Late filing of the accounts carries the ordinary Companies House civil penalty on the company.

Figures such as a £50,000 SECR fine have no basis in the legislation.

SECR has no deadline of its own.

The disclosure sits in the directors’ report, or for an LLP the energy and carbon report, so it is filed with the accounts: nine months after the end of the accounting reference period for a private company or LLP, six months for a public company, under section 442 of the Companies Act 2006.

No. DESNZ’s post-implementation review of 26 May 2026 recommends retaining SECR with amendments.

The FCA’s final rules, PS26/19 of 30 September 2026, require listed companies in five listing categories to report against UK SRS on a comply-or-explain basis from 2027; they do not touch SECR, which still applies to large unquoted companies and LLPs as well as quoted companies.

DESNZ has said it will consider how UK SRS data interacts with SECR to reduce duplication where possible.

In the directors’ report for a company, or in a separate energy and carbon report for an LLP. Companies Act 2006 section 414C(11) lets directors place matters required in the directors’ report in the strategic report instead where they consider them of strategic importance.

The government’s Modernising Corporate Reporting consultation proposes removing the directors’ report and letting companies place SECR anywhere in the first half of the annual report; that is a proposal, not law.

Streamlined Energy and Carbon Reporting.

It is the energy and greenhouse gas disclosure that SI 2018/1155 wrote into Schedule 7 to SI 2008/410 and into the LLP accounts regulations, for financial years beginning on or after 1 April 2019.

Three populations: every quoted company, at any size; unquoted companies that exceed two of £36 million turnover, £18 million balance sheet total and 250 employees on the two-year basis in paragraph 20B; and LLPs that exceed the same limits under SI 2008/1911 regulation 12B.

A subsidiary included in a compliant group report does not report separately.

Not as such.

UK SRS S1 and S2, published by the Department for Business and Trade on 25 February 2026, are voluntary standards.

Since the FCA’s final rules in PS26/19 of 30 September 2026, listed companies in UKLR 6, 14, 15, 16 and 22 must report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

No other UK entity is required to use them, and SECR is unaffected.

Not if, at the end of its financial year, it is a subsidiary undertaking included in a parent’s group report prepared for a year ending at the same time or earlier, and that report complies.

The shelter fails where the parent relied on the seriously prejudicial limb (paragraphs 15(5)(b) and 20D(7)(b)); a parent relying on the 40,000 kWh relief still shelters its subsidiaries.

The government’s greenhouse gas conversion factors for company reporting, published each year by DESNZ, chosen to match the year the energy was used, and named in the methodology statement.

The 2026 set was published on 11 June 2026 and its flat file was corrected on 31 July 2026; there is no longer a condensed set.

The UK electricity factor fell by about 26% between the 2025 and 2026 sets, partly because of a change of method, so year-on-year comparisons need a sentence of explanation.

Any ratio of annual emissions to a quantifiable factor associated with the company’s activities: paragraphs 17 and 20G prescribe no factor and require only one.

Turnover, floor area, headcount and units of output all satisfy the words.

The practical test is whether the same factor can be measured the same way next year, because the comparative duty makes the ratio a series.

No. ESOS and SECR are separate duties with different tests, clocks and outputs, and Schedule 7 does not mention ESOS.

The same energy data can feed both, and since Phase 4 an ESOS report must estimate the savings achieved from each measure in kWh, which is useful evidence for the SECR efficiency narrative.

SECR exempts an unquoted company that meets two or more of three “not more than” limits: £36 million turnover, £18 million balance sheet, 250 employees.

ESOS brings in an undertaking with at least 250 employees, or with turnover in excess of £44 million and a balance sheet total in excess of £38 million together.

A company with 300 staff, £20 million turnover and a £10 million balance sheet is in ESOS and exempt from SECR; one with £40 million turnover, a £20 million balance sheet and 100 staff is the reverse.

The only government guidance is the Environmental Reporting Guidelines, including Streamlined Energy and Carbon Reporting requirements, published in March 2019 and last updated on 29 March 2019. It is not statutory.

Where it and Schedule 7 differ — its “40 MWh” shorthand and its description of the LLP threshold are two examples — the schedule governs.

Schedule 7 does not require it.

The purchased-energy duties cover electricity, and for quoted companies heat, steam and cooling, bought by the company for its own use, and energy an employee buys for their own home is not bought by the company.

A company may report home-working emissions voluntarily; DESNZ’s conversion factors include a homeworking set for that purpose.

Only if they are companies or LLPs within Schedule 7.

SECR reaches quoted companies, unquoted companies and LLPs, and nothing else.

An academy trust, which is a company, is caught only as a large unquoted company; a body that is not a company is outside SECR, whatever other reporting applies to it.

About 19,900, according to DESNZ’s independent evaluation of 29 January 2026, restated in the post-implementation review of 26 May 2026.

That is 76% more than the 11,300 the 2018 impact assessment forecast.

Figures of around 12,000 still in circulation are close to the old forecast, not the measured population.

No. No paragraph of Part 7 or Part 7A mentions assurance or verification, and the government guidelines say there is no statutory requirement to have the environmental information audited.

The auditor’s ordinary duty under section 496 of the Companies Act 2006 is to report whether the directors’ report is consistent with the accounts and prepared in accordance with the law, which is not assurance over the emissions data.

None to the law since SI 2018/1155 took effect on 1 April 2019; Part 7A carries no later amendment.

What changed in 2026 is the evidence and the agenda: the evaluation (29 January), the post-implementation review recommending retention with amendments (26 May), the Modernising corporate reporting consultation proposing to move SECR out of the abolished directors’ report (7 September, closing 30 November 2026), and DESNZ’s stated intention to consult on SECR and ESOS later in 2026.

Yes, if they are quoted companies under section 385 of the Companies Act 2006 — on the Official List, officially listed in an EEA state, or admitted to dealing on the New York Stock Exchange or Nasdaq.

Part 7 of Schedule 7 has required it since financial years ending on or after 30 September 2013, and since 2019 the same section also carries an energy figure, the UK and offshore proportions and the efficiency narrative.

AIM companies are not quoted for this purpose.

Under SECR, quoted companies, and unquoted companies and LLPs that exceed two of £36 million turnover, £18 million balance sheet and 250 employees.

Separately, the largest companies make climate-related financial disclosures under section 414CB of the Companies Act 2006, listed companies in five UKLR categories report against UK SRS on a comply-or-explain basis from 2027, and bidders for major government contracts may be asked for a carbon reduction plan under PPN 006. Each duty has its own test.

Not unless they are quoted.

An unquoted company is exempt while it meets two or more of the “not more than” limits of £36 million turnover, £18 million balance sheet and 250 employees, so small companies are outside SECR.

Because the Companies Act limits rose in April 2025 and SECR’s did not, a company can be medium-sized for its accounts and still in SECR.

For financial years beginning on or after 1 April 2019.

The quoted-company greenhouse gas duty in Part 7 is older, dating from financial years ending on or after 30 September 2013; SI 2018/1155 extended it with an energy figure and added Part 7A for unquoted companies and the energy and carbon report for LLPs.