Reporting Requirements
SECR Requirements: Thresholds, Disclosures, Scope (2026)
Complete reference to the Streamlined Energy and Carbon Reporting thresholds, mandatory disclosures, Scope 1 and 2 coverage, intensity metrics and the 40 MWh low-energy user exemption.
SECR Requirements Overview
1 Streamlined Energy and Carbon Reporting (SECR) requires qualifying UK organisations to disclose annual energy use, greenhouse gas emissions and energy efficiency actions in their Directors' Report. The framework came into force for financial years beginning on or after 1 April 2019 under 2 the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018.
Three groups are in scope: quoted UK companies of any size, large UK-incorporated unquoted companies, and large LLPs. The disclosure obligations differ between quoted and unquoted reporters in both geographic scope and scope of emissions covered.
For background on the wider regime see our SECR overview, and for the step-by-step preparation methodology see the SECR reporting guide.
Qualification thresholds
4 The SECR regulations adopt the Companies Act 2006 "two of three" size test as it stood when SECR commenced. An unquoted company or LLP is in scope when it satisfies any two of the three criteria below for two consecutive financial years.
The test is applied at the level of the reporting entity, but a UK parent of a qualifying group must report on the group as a whole even where the parent alone would not meet the thresholds. ESOS qualification uses different turnover and employee tests, so being in scope for one regime does not automatically mean scope for the other.
Annual turnover
£36 million or more in the reporting year. This SECR threshold sits at the boundary between medium and large companies under the pre-April 2025 Companies Act definition and remains the SECR test.
Balance sheet total
£18 million or more in gross assets at the balance sheet date. Measured before deduction of liabilities, consistent with Companies Act 2006 size tests.
Average employees
250 or more employees calculated on a monthly average basis across the financial year, including all UK and overseas staff of the reporting entity.
Turnover threshold
Annual turnover above which an unquoted UK company or LLP is treated as large for SECR purposes when combined with one of the other two criteria
Quoted company scope
All UK-incorporated quoted companies are in scope for SECR regardless of size. A quoted company is one whose equity share capital is listed on the London Stock Exchange Main Market, an EEA-regulated market, the New York Stock Exchange or NASDAQ. AIM-listed companies are NOT quoted for these purposes and fall under the unquoted large-company rules instead.
Mandatory disclosures: quoted companies
5 Quoted companies must produce a global disclosure covering worldwide operations. The disclosure extends the pre-existing Mandatory Greenhouse Gas Reporting requirements that applied from 2013, layering on energy use and efficiency-narrative obligations.
All six elements below must appear in the Directors' Report or, where the company elevates the content, cross-referenced from the Strategic Report.
Global Scope 1 and Scope 2 emissions
Annual greenhouse gas emissions from activities the company is responsible for worldwide, including fuel combustion (Scope 1) and purchased electricity, heat, steam and cooling (Scope 2), reported in tonnes CO2 equivalent.
Underlying global energy use
Total energy consumption in kWh used to calculate the disclosed emissions, covering all operations globally rather than UK-only activity.
At least one intensity ratio
An emissions intensity metric appropriate to the business, such as tCO2e per £million turnover, per employee or per unit of production output.
Methodology statement
Disclosure of the calculation methodology used, typically referencing the GHG Protocol Corporate Standard and DESNZ/Defra conversion factors for company reporting.
Energy efficiency narrative
A description of the principal energy efficiency actions taken during the reporting period. If no actions were taken, this must be explicitly stated.
Prior-year comparatives
Previous-year figures for emissions, energy use and intensity ratio from the second reporting year onward to demonstrate trend performance.
Quoted companies should align Scope 1 and Scope 2 boundary-setting with 6 the GHG Protocol Corporate Standard and use the latest UK Government conversion factors published by DESNZ. Methodology covering GHG Protocol scopes and carbon accounting fundamentals sets out the calculation approach in more detail.
Mandatory disclosures: large unquoted companies and LLPs
Large unquoted companies and large LLPs report on UK activity only, but with a wider Scope 3 element than quoted reporters. The geographic boundary covers the UK mainland plus the UK offshore area where applicable.
LLPs prepare an Energy and Carbon Report attached to their accounts rather than amending the Directors' Report.
UK energy use (kWh)
Total annual energy consumption in the UK and UK offshore area covering, as a minimum, purchased electricity, gas combustion and transport fuel where the organisation is directly supplied with fuel.
UK Scope 1 and Scope 2 emissions
Greenhouse gas emissions resulting from the disclosed UK energy use, reported in tonnes CO2 equivalent and split or aggregated by scope according to the methodology applied.
Transport-related Scope 3
Emissions from business travel in employee-owned vehicles (grey fleet) and rental cars where the organisation purchases the fuel — a quirk unique to unquoted SECR reporters.
At least one intensity ratio
An emissions intensity metric relevant to UK operations, commonly tCO2e per £million UK turnover, per UK employee or per square metre of UK floor area.
Methodology statement
The calculation approach used for energy and emissions, with reference to recognised standards such as the GHG Protocol and the UK Government conversion factors.
Energy efficiency narrative and comparatives
Principal energy efficiency actions taken during the financial year plus prior-year comparatives for energy and emissions from year two onward.
Energy types in scope
At minimum the UK energy figure must include: total purchased electricity, gas consumed as fuel, and transport fuel where the organisation is directly supplied. Many reporters use carbon reporting software to aggregate utility invoices, fleet card data and mileage claims into a single SECR-ready dataset.
Reporting threshold and the 40 MWh exemption
7 Organisations consuming less than 40 MWh (40,000 kWh) of energy in the UK during the reporting period qualify for the SECR de minimis exemption. The 40 MWh figure covers electricity, gas and transport fuel combined and represents roughly the annual consumption of two average British homes.
The exemption is from the detailed numerical disclosure only — it is NOT an exemption from SECR itself. The Directors' Report must include a statement that the entity is a low-energy user and that the energy and carbon report has been omitted on that basis.
Low-energy user threshold
Annual UK energy consumption below which a reporter may claim the SECR de minimis exemption, subject to making a low-energy user statement in the Directors' Report
Other narrow exemptions
A "seriously prejudicial" exemption is available where directors believe disclosure would harm the entity's commercial interests — the FRC treats this as exceptional, applicable to acquisitions, restructuring or acute commercial sensitivity. Subsidiaries whose data is included in a UK parent's consolidated SECR report do not need to report separately. UK branches of overseas entities that themselves have no UK operations may rely on the low-energy user route.
Intensity ratios
Every SECR disclosure must include at least one emissions intensity ratio, expressing tCO2e against a denominator that reflects business activity. The choice of denominator is not prescribed; reporters select what best represents their operations and supports comparability over time.
Most reporters publish two or more ratios — typically one financial and one operational — to support different reader needs. Common choices are summarised below.
Financial intensity
tCO2e per £million of turnover — the most widely used metric and useful for cross-company benchmarking within sectors.
Headcount intensity
tCO2e per full-time-equivalent employee — appropriate for office-based service businesses where headcount drives consumption.
Floor area intensity
tCO2e or kWh per square metre of occupied floor area — standard for property, retail and hospitality portfolios.
Production intensity
tCO2e per tonne of product, per unit manufactured or per MWh generated — used by industrial, manufacturing and energy companies.
Intensity ratios should be calculated on the same boundary as the headline emissions figure and disclosed with prior-year comparatives from year two onward. Reporters aligning with UK SRS S2 climate disclosures or broader sustainability reporting often retain the same intensity metric across regimes to avoid investor confusion.
Energy efficiency narrative
SECR requires a description of the principal energy efficiency actions taken during the reporting period. The narrative is mandatory: where no actions have been taken the report must say so explicitly rather than omitting the section.
Good-practice narratives identify the specific intervention, the part of the business affected, the expected or measured energy or emissions saving, and any link to a wider net-zero strategy. 8 The government guidance encourages reporters to connect SECR actions to ESOS audit recommendations where applicable, creating a continuous improvement loop between the ESOS energy audit cycle and annual SECR disclosure.
Suggested content
Typical efficiency actions disclosed include: LED lighting retrofits, building management system upgrades, HVAC controls, fleet electrification, behavioural change programmes, on-site renewable generation, and supplier switching to renewable electricity tariffs. Each should be quantified where possible — even directional indication of savings adds credibility.
What are the SECR reporting requirements for UK companies?
SECR requires quoted companies, large unquoted UK-incorporated companies and large LLPs to disclose annual energy use, Scope 1 and Scope 2 greenhouse gas emissions, at least one intensity ratio, methodology, prior-year comparatives and a narrative of energy efficiency actions taken.
Quoted companies report globally; unquoted companies and LLPs report UK-only data.
Disclosures sit in the Directors' Report or, for LLPs, an Energy and Carbon Report.
What is the SECR reporting threshold?
A company qualifies as 'large' for SECR if it meets at least two of three criteria: annual turnover of £36 million or more, balance sheet total of £18 million or more, or 250 or more employees.
These thresholds are set in the SECR regulations themselves and were NOT changed by the April 2025 Companies Act 2006 size threshold uplift.
Quoted companies are in scope regardless of size.
What are the SECR disclosure requirements for quoted versus unquoted companies?
Quoted companies must report global Scope 1 and Scope 2 emissions plus underlying global energy use.
Large unquoted companies and LLPs report UK energy use and associated emissions only, but must additionally include transport-related Scope 3 emissions from employee-owned vehicles and rental cars where the organisation purchases the fuel.
Both must disclose an intensity ratio, methodology, comparatives and energy efficiency actions.
What is the 40 MWh low-energy user exemption under SECR?
Organisations that consume less than 40 MWh of energy across the UK during the reporting period qualify for the de minimis exemption from detailed SECR reporting.
They are not exempt from disclosure entirely — the Directors' Report must explicitly state that the company is a low-energy user and the SECR data has been omitted on that basis.
The 40 MWh test covers electricity, gas and transport fuel combined.
Where must SECR disclosures appear in the annual report?
Companies must include SECR disclosures within the Directors' Report element of the annual financial statements filed with Companies House.
LLPs prepare an equivalent Energy and Carbon Report.
Many entities elevate the content into the Strategic Report alongside related climate disclosures, which is permitted provided cross-references are clear.
Did the April 2025 Companies Act size threshold changes affect SECR?
No.
The April 2025 uplift to Companies Act 2006 size limits (small thresholds rising to £15m turnover and large thresholds to £54m turnover) does not alter SECR scope.
The SECR Regulations 2018 specify their own standalone £36m turnover and £18m balance sheet thresholds, so qualifying organisations continue to be assessed using the original SECR criteria regardless of their Companies Act size classification.
Related guides & references
What Is SECR?
Introduction to the Streamlined Energy and Carbon Reporting framework
SECR Reporting Guide
Step-by-step methodology for preparing your annual SECR disclosure
SECR Compliance
Penalties, enforcement and governance arrangements for SECR
ESOS Scheme
How Energy Savings Opportunity Scheme audits feed SECR data
UK Carbon Reporting Requirements
Overview of all mandatory UK carbon reporting regimes