SECR requirements — the regulations, the disclosures and who has to report
Streamlined Energy and Carbon Reporting makes qualifying UK companies and LLPs publish their energy use, their greenhouse gas emissions and what they did about them — every year, inside the directors’ report [3].
The SECR reporting threshold is two of three: turnover of £36 million, a balance sheet total of £18 million, or 250 employees [5].
What SECR makes you disclose, in six items
Six things, every financial year, in the directors’ report.
Photo: Unsplash / Alexander AberoWhich SECR regulations actually create the duty
Four instruments, and the one everybody names is not the one that holds the wording.
The SECR regulations are the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 — SI 2018/1155 [3]. They are an amending instrument: almost nothing in them tells you what to disclose.
What they do is insert Part 7A into Schedule 7 of SI 2008/410 and rewrite Part 7 of it [5]. That is where the duty livesPart 7 paragraphs 15–18A for quoted companies; Part 7A paragraphs 20A–20K for large unquoted companies and LLPs. Every threshold, every disclosure and every exemption on this page is a paragraph in one of those two Parts. — not in SI 2018/1155, and not in the Companies Act.
This matters more than it sounds. Search “streamlined energy and carbon reporting regulations” and you land on SI 2018/1155, read forty lines of amending instructions, and never reach a disclosure requirement. Every paragraph number quoted on this page is a Schedule 7 paragraph, and that is why.
It also settles a common mistake: SECR does not amend Companies Act 2006 Schedule 7. It amends Schedule 7 to a set of 2008 accounts regulations that happens to carry the same number.
DESNZ has said it plans a 2026 consultation on streamlining energy and emissions reporting, covering clearer guidance, a standardised template and alignment with international standards [15]. As at 12 August 2026 it has not launched. Anyone telling you the template is coming this year is reading an intention, not a document.
One change is already announced, and it is to the container rather than the duty. The Written Ministerial Statement of 21 October 2025 sets out a Modernisation of Corporate Reporting programme that would remove the Directors’ Report altogether — while expressly keeping “some useful reporting requirements, including reporting on energy and emissions” and moving them elsewhere in the annual report [47]. So the place your SECR disclosures sit may change. The disclosures themselves are not being withdrawn.
The company that stopped being large and kept reporting
An illustrative case, built from two real instruments — not a real company.
A privately held UK manufacturer: turnover £41 million, balance sheet total £22 million, 180 employees.
In April 2025 the Companies Act size limits rose by roughly half, and the company’s auditors reclassified it from large to medium-sized [9].
Its finance director drew the obvious conclusion, and stopped preparing the energy and carbon section.
That was wrong, and the reason is a single regulation that did not get amended.
The instrument that raised the size limits — SI 2024/1303 — touches Schedule 7 in exactly one place, and it is not the SECR one. Regulation 5 omits paragraphs 6 and 7 and Parts 3 and 4 of the Schedule. Parts 7 and 7A are not mentioned [7].
The SECR test is written out in full inside Part 7A itself, at paragraphs 20B and 20C. It does not cross-refer to the Companies Act size tests, so raising those did nothing to it [5].
Thirteen months after the uplift took effect, DESNZ restated the SECR test in its own statutory review, in the present tense, at the old figures: “For unquoted companies and LLPs, ‘large’ is defined as meeting at least two of the following criteria: turnover of £36 million or more, balance sheet total of £18 million or more…” [16]
Between those two figures sits every company that is medium-sized for its accounts and a SECR reporter: turnover of £36–54 million, or a balance sheet total of £18–27 million.
No GOV.UK SECR page states this, because the page that would state it and the page that raised the limits belong to different departments.
Three kinds of organisation are in SECR scope, and they do not report the same thing
SECR names three populations. Two of them are tested for size; one is not.
From the second reporting year onward, every one of those six disclosures carries the previous year’s figure beside it [5].
SECR does not ask you to reduce anything. It asks you to measure it, publish it, and say what you did.
AIM companies are unquoted for this purpose
AIM is an exchange-regulated growth market, and AIM securities are admitted to trading on AIM rather than included in the FCA’s Official List.
So an AIM company is unquoted under s.385(3), and if it meets the size test it reports on the Part 7A basis — UK only, with the transport rule — not the global quoted basis [11].
This follows from s.385(2)(a) read with FSMA 2000 s.103(1). No GOV.UK page states it in terms, and we have not found one that does — it is a reading of the two provisions, and it is the reading the accounting profession applies.
What separates the quoted list from the unquoted list is not the number of items. It is the boundary: quoted companies draw a line round the world, everyone else draws one round the United Kingdom, and the disclosures then differ in ways covered in chapters 07 and 08.
Photo: Unsplash / Ricardo Gomez Angel
The SECR reporting threshold, and where it actually sits in law
Two of three. The regulation is drafted as an exemption, so it reads backwards from how everyone quotes it.
Paragraph 20B does not say “you are in scope if”. It says a company is exempt if it meets two or more of the following [5].
Meet two and you are exempt. Fail to meet two — which means you exceed at least two of the three — and you report.
The two-year rule cuts both ways
The exemption applies in a company’s first financial year if the conditions are met that year.
After that it needs the conditions met in the current year and the year before, or met in the current year with the company exempt last year, or met last year with the company exempt last year [5].
The practical effect is symmetrical: you generally have to fail the exemption two years running before you start reporting, and meet it two years running before you stop.
Growing companies get a year’s grace. Shrinking ones do not get to stop as soon as they would like.
How the headcount is counted
Not an average of the start and end of the year, and not full-time equivalents.
Paragraph 20B(3)(c) takes the number of persons employed under contracts of service in each month, adds those twelve numbers together, and divides by the number of months in the financial year [5].
A seasonal business with 400 staff for three months and 180 for nine averages 235, and that is the figure the test uses.
It is worth being explicit that this is not the test on your audit-exemption letter. £36m turnover, £18m balance sheet, 250 employees — Schedule 7 paras 20B and 20C, unchanged since 2019. £54m turnover, £27m balance sheet, 250 employees — Companies Act 2006 s.465, raised on 6 April 2025. Both apply to the same company in the same year, and they can give opposite answers.
Turnover and balance sheet totals are pro-rated where the financial year is not twelve months, on the same basis the Companies Act uses for its own size tests.
If you want the detail of where each figure comes from in your own accounts, that sits in the SECR reporting guide.
Do the SECR requirements apply to you?
Up to five questions, run against paragraphs 20B and 20C as drafted — including the two-year rule, which most summaries leave out.
Nothing is sent anywhere. The whole check runs in your browser.
If you are a parent company, answer for the group. Paragraph 20C tests aggregate figures, and you may use either the net or the gross column [5].
The SECR reporting requirements for a quoted company, paragraph by paragraph
The SECR reporting requirements for a quoted company are Part 7 of Schedule 7, and they are global. Every figure covers worldwide operations, with the UK share stated separately.
“Emissions” and “tonne of CO2 equivalent” are not defined in the schedule. Paragraph 20 imports them from the Climate Change Act 2008, sections 92 and 93(2) [4].
Boundary-setting for Scope 1 and 2 follows the GHG Protocol Corporate Standard [29], which is what the government guidance points to and what almost every UK reporter uses in practice.
The method itself is covered under GHG Protocol scopes and carbon accounting.
Photo: Unsplash / Nicholas Doherty
The SECR disclosure requirements for unquoted companies and LLPs, item by item
The SECR disclosure requirements for Part 7A reporters are UK only — and the emissions definition is materially narrower than the quoted one, which almost every summary blurs.
Read paragraph 20D(1) closely and the asymmetry is deliberate: a large unquoted manufacturer burning oil in a process it operates is outside the literal words of “combustion of gas, or… fuel for the purposes of transport”, where a quoted one burning the same oil is inside “combustion of fuel” [5].
The government guidance treats the unquoted energy figure as covering, at minimum, purchased electricity, gas and transport fuel — and most reporters disclose more than the minimum rather than defend the narrow reading [19].
Paragraph 20D(5) is permissive, not mandatory: an unquoted company with overseas operations may exclude them, and a company that would rather report globally is free to [5].
Where an LLP is concerned, the document is different and so is the signature: members approve it, a designated member signs it, and failing to prepare one is an offence by every person who was a member immediately before the end of the filing period [6].
The six SECR disclosures, one at a time
Every SECR disclosure below is a numbered paragraph of Schedule 7, and each one reads differently for a quoted company than for everyone else.
The six are not a checklist somebody drew up. They are the six sub-paragraphs the 2018 regulations inserted, in the order they appear, and the paragraph references are the ones an auditor will quote back at you.
Scope 1 — your direct emissions
In tonnes of CO2 equivalent · paras 15(2) and 20D(1)(a)
Emissions from sources the entity owns or controls. For a quoted company that is the whole worldwide footprint of activities for which it is responsible, with the UK and offshore share stated separately. For an unquoted reporter or LLP the definition is narrower as well as smaller: gas combustion and fuel consumed for transport purposes, not every direct source you can think of.
This is the figure most first-year reporters get wrong, because a group energy spreadsheet does not know where the control boundary runs.
Scope 2 — the energy you buy
Purchased energy emissions · paras 15(2) and 20D(1)(a)
Here the two populations genuinely diverge. A quoted company reports purchased electricity, heat, steam and cooling. An unquoted company or LLP reports purchased electricity and nothing else — so a district-heating bill that a listed neighbour must disclose does not enter your Scope 2 at all.
It is the single most common source of over-reporting we see in unquoted disclosures: a correct number, in the wrong regime.
Total energy consumed, in kWh
One aggregate figure · paras 15(3) and 20D(1)(b)
The pre-2019 mandatory greenhouse gas regime asked only for emissions. SECR’s genuine addition is energy in kilowatt hours — one aggregate number covering the energy behind the emissions you have just disclosed.
It is also the figure the 40,000 kWh exemption is tested against, and the one that reconciles most cleanly to an ESOS energy audit, which since July 2026 is expressed in the same unit.
At least one intensity ratio
Emissions over an activity measure · paras 16 and 20F
The regulations require a ratio expressing annual emissions against a quantifiable factor associated with the entity’s activities. They do not tell you which factor. Turnover, floor area, headcount, units produced, passenger kilometres — all are permissible, and the choice is a disclosure decision rather than an accounting one.
Two constraints are real: it must be emissions-denominated, not energy, and once chosen it should survive contact with next year’s comparative.
The methodology you used
Which standard, which factors · paras 17 and 20G
A single sentence naming the standard is not enough on its own. The disclosure that survives review names the methodology, the conversion factor set and its year, the organisational boundary, and any estimation applied where meter data was missing.
From 2026 the factor year matters more than it did, because comparatives drawn on different factor vintages will move for reasons that have nothing to do with your energy use.
What you did about your energy efficiency
Principal measures taken in the year · paras 18 and 20H
The only qualitative item of the six. It asks for the principal measures taken during the financial year to increase energy efficiency — and if the entity took none, the report has to say that it took none.
That is the sentence people leave out, and it is the one omission a reader can detect without any of your data.
From the second reporting year onward each of the six carries the previous year’s figure beside it, which is why the methodology statement in item 05 is worth writing properly the first time.
The one Scope 3 category unquoted reporters cannot leave out
It is usually called the grey fleet rule, and the shorthand is wrong in a way that matters.
Paragraph 20D(1)(b) covers emissions from “the consumption of fuel for the purposes of transport”, and paragraph 20K defines that as consumption by an aircraft, road-going vehicle, train or vessel on a journey that starts, ends, or both starts and ends in the United Kingdom [5].
The paragraph opens with the words that do the real work: emissions “resulting from activities for which the company is responsible”.
The government guidance turns that into a single test — “only transport where the organisation is responsible for purchasing the fuel is required for mandatory reporting” [19].
So the accurate statement is narrower than the one in circulation: business travel in employee-owned or rented vehicles where the organisation pays for the fuel is mandatory, and an employee who claims nothing is out of scope.
It is the only Scope 3 category SECR compels, and it is compelled only for unquoted reporters and LLPs — a quoted company reporting globally is not required to include it at all [4].
Wider Scope 3 remains voluntary under SECR, which is a different question from whether it is voluntary under other regimes — see Scope 3 emissions.
Photo: Unsplash / Nick Fewings
The SECR intensity ratio: one, emissions-denominated, and yours to choose
The whole legal requirement is a single sentence, and reading it carefully saves a lot of argument.
Paragraphs 17 and 20G say the report must state “at least one ratio which expresses the company’s annual emissions in relation to a quantifiable factor associated with the company’s activities” [4] [5].
One thing the regulations do not require, and the guidance does: year-on-year consistency in the denominator.
Changing it every year breaches no paragraph of Schedule 7, and makes the comparative the same paragraphs demand meaningless — which is why auditors and the FRC treat it as a reporting quality problem rather than a legal one [19].
DESNZ has flagged this drafting looseness itself: its 2026 review lists clarifying guidance on eligibility and site inclusion among the refinements to be explored in a planned consultation [16].
Reporters who also expect to fall under UK SRS S2 generally keep one intensity metric across both, so the two disclosures do not tell investors different stories about the same year.
Photo: Unsplash / Nikola Jovanovic
The SECR energy efficiency narrative, and the sentence you cannot omit
The only prose disclosure in SECR, and the one most often reduced to a paragraph of intentions.
Paragraphs 15(3D) and 20D(4) require a description of the principal measures taken during the financial year to increase energy efficiency [4].
Both paragraphs end with the words “if any”, and that is the clause people misread.
It does not permit silence. It permits the answer “none” — stated, in the report [19].
That last point is the one worth acting on, because it turns a narrative obligation into a by-product of work you may already be doing — see chapter 20 and the ESOS energy audit guide.
The SECR methodology statement, conversion factors, and why 2026’s comparatives will look wrong
Paragraphs 16 and 20F make the method a disclosure in its own right. In 2026 that paragraph has more work to do than usual.
The methodology statement identifies the standard followed, the conversion factor set used, and the assumptions applied to fill data gaps [4].
The factor set almost every UK reporter uses is the government’s own, published by DESNZ with Defra [21].
The 2026 set was published on 11 June 2026 and last updated on 31 July 2026 [20].
The comparability problem, and what to write about it
The 2026 set carries a substantial reduction in UK location-based electricity factors, driven partly by grid decarbonisation and partly by a methodology change that cuts the data lag from two years to one [20].
We are not printing a percentage here. The figure circulating for the reduction originates in DESNZ’s Major Changes Report and we have it only through secondary summaries, so it is stated qualitatively until we can cite the primary document directly.
The consequence for SECR is structural rather than technical: paragraphs 18, 18A and 20H require last year’s figure beside this year’s, and a large fall in the electricity factor cuts a Scope 2 figure without anybody changing behaviour [5].
A reader comparing the two years without being told will read an efficiency programme that did not happen.
The methodology paragraph is where you say so, and DESNZ’s standing policy leaves that choice with you: previously published factors are not revised, and it is for the user to decide whether to restate prior years [21].
Match the factor set to the year the activity happened, not the year you prepare the report, and the rest follows — the mechanics are in carbon accounting, and most reporters automate the join with carbon reporting software.
Worth knowing when you rely on it: the Environmental Reporting Guidelines are the only official SECR methodology guidance, they were last updated on 29 March 2019, and they are attributed to a department that no longer exists [1].
They predate the April 2025 accounts uplift and they predate UK SRS entirely.
Photo: Unsplash / name_gravity
The four SECR exemptions, and the statement each one still requires
Three of the four remove the numbers and leave a sentence behind. Only one is silent, and it is not the one people use.
15(5)(a) Low-energy user — 40,000 kWh or less. Removes the figures, the methodology and the intensity ratio. The report must state that the information is not disclosed for that reason. The territorial scope of the test differs between quoted and unquoted reporters — see chapter 15.
20A(2) Subsidiary included in a parent’s group report. Three cumulative conditions: a subsidiary undertaking at year end, included in the parent’s group report, and that report covers a financial year ending at the same time as or before the subsidiary’s. This is the only one of the four that requires no statement.
20D(7)(b) Seriously prejudicial. Where disclosure would, in the opinion of the directors — or, for an LLP, the members — be seriously prejudicial to the interests of the entity. The report must state that the information is not disclosed for that reason.
20D(6) Not practical to obtain. A partial carve-out, and the heaviest surviving obligation of the four: the report must state what information is not included and why. It excuses the missing item, never the section.
An entity that qualifies for an exemption and simply omits the section is still non-compliant.
The exemption removes the numbers. It never removes the section.
The trap inside the subsidiary exemption
Paragraphs 15(1A) and 20A(2) only work where the parent’s group report complies other than in reliance on paragraph 15(5)(b) or 20D(7)(b) [5].
Those are the seriously-prejudicial limbs.
So a parent that withholds its energy and carbon figures on seriously-prejudicial grounds cannot use that group report to relieve its subsidiaries, and every qualifying subsidiary underneath it has to report in its own right.
A parent relying on the 40,000 kWh de minimis instead can, because limb (a) is not excluded [4].
It is one clause, it is in both Parts, and it decides how many sets of accounts in a group carry an energy and carbon section.
Model omission wording for each of the four sits in the SECR report template.
Test the low-energy user exemption against the wording that applies to you
The two limbs of the de minimis are worded differently, and almost every guide states the unquoted one as though it were universal.
Paragraph 20D(7)(a) — unquoted companies and LLPs — reads “consumed 40,000 kWh of energy or less in the United Kingdom”.
Paragraph 15(5)(a) — quoted companies — reads “consumed 40,000 kWh of energy or less”, with no territorial qualifier at all [4].
A quoted company using 30,000 kWh in the UK and 50,000 kWh abroad cannot claim it. An unquoted company in exactly the same position can.
How a group meets the SECR requirements, and which subsidiaries drop out
A parent tests itself on aggregate group figures, then reports for the group — but it is not obliged to sweep in everything underneath it.
Paragraph 20C applies the size test to the group’s aggregate turnover, balance sheet total and headcount, and lets the parent satisfy any requirement on either the net or the gross figure [5].
Where the parent prepares a group directors’ report, paragraphs 15A and 20E govern what goes in it.
Those paragraphs also contain the relief most groups need: a group report may exclude information relating to a subsidiary that would not itself have been required to disclose it [4].
So a large group does not have to chase the energy consumption of a dormant subsidiary, or of one small enough to be exempt in its own right.
Where a UK subsidiary is owned by an overseas parent, the group report that relieves it has to be one of the reports Schedule 7 names — a group directors’ report of a quoted or unquoted company, or an LLP’s group energy and carbon report [5].
An overseas parent’s own sustainability report, however comprehensive, is not one of them.
SECR has no deadline of its own, and that is the point
The disclosure travels inside the annual report, so the SECR deadline is the accounts deadline — and missing one misses both.
Companies Act 2006 s.442(2) gives a private company nine months from the end of the accounting reference period, and a public company six [12].
LLPs file within nine months, on the same basis as private companies [37].
Which window applies is fixed by the company’s status immediately before the end of the accounting reference period, so a company that lists in the final week of its year is already on the six-month clock [12].
Nothing in the Economic Crime and Corporate Transparency Act shortens the nine- and six-month windows.
The reforms are about format and content, and they start on 1 April 2028 [33].
One related change is genuinely unsettled: a proposed limit on shortening the accounting reference period more than once every five years. Companies House has been reported as confirming it and as pausing it; the transitional provisions are unpublished. We are stating it as unsettled rather than picking a side, because shortening the period currently buys three extra months under s.442(4) and that is worth knowing accurately.
The filing-window detail, including first accounts and shortened periods, sits with the SECR section hub.
From year end to filed accounts, in five moves
How SECR is enforced, and the £50,000 penalty that does not exist
There is no SECR regulator, no SECR fine and no SECR register. The honest answer is worth more than a scary one.
DESNZ describes the enforcement model in its own statutory review as light-touch: it relies on the Companies Act placement of the disclosure and on Financial Reporting Council review, with no dedicated civil sanctions [16].
Nothing in the SECR regulations — SI 2018/1155 and Schedule 7 — creates a fine, a penalty, an inspection power or a register [3].
What does apply
The £50,000 figure has no source
A cluster of commercial sites states that the FRC’s Conduct Committee can impose civil penalties of up to £50,000 for SECR non-compliance, and issue a public censure.
No provision of SI 2018/1155, Schedule 7 or Companies Act 2006 Part 15 confers any such power [3].
The FRC’s route to a defective directors’ report is s.456 — an application to the court for revision, under which the court may order directors to pay costs, which is not a penalty and carries no cap [14].
Its fining and censure powers sit in the Audit Enforcement Procedure and the Accountancy Scheme, which bite on statutory auditors and member-firm accountants, not on reporting companies [31].
DESNZ’s own review says there are no dedicated civil sanctions, which settles it [16].
Every site making the claim is a consultancy or software blog, and not one of them cites a source. The £150–£7,500 range those same pages quote is real — it is the late-filing scale above, which has nothing to do with what the disclosure says.
Governance, sign-off and the director’s exposure are covered on SECR compliance.
Photo: Unsplash / Noah Buscher
What the government’s own review of the SECR regulations found after seven years
Two documents, five months apart, and no page on the SECR search results has caught up with either.
DESNZ published an independent evaluation on 29 January 2026 and its statutory Post-Implementation Review on 26 May 2026 [17] [15].
We are not publishing an average cost of compliance per business. The figure in circulation is the annual aggregate divided by the population, and we could not find it stated anywhere in the review. A derived number presented as a government figure is how bad figures enter circulation, and this page has just spent a chapter on one.
Read together, the two documents describe a regime that works economically, is unevenly complied with, and has never been enforced against anybody.
Is SECR being replaced by UK SRS? The government has answered that
Twice, in 2026, and both times the answer was no.
DBT published the final UK SRS S1 and S2 on 25 February 2026, available for voluntary use, with no legal obligation to apply them [24].
Its government response to the consultation commits only to a review of overlap: “DESNZ will consider how energy and emissions data reported by an entity using UK SRS interacts with the SECR requirements, with a view to reducing unnecessary duplication where possible.” [23]
Three months later the PIR went further, and it is the sentence to quote: “On balance, the recommendation is to retain SECR requirements with amendments… SECR continues to provide important value as a statutory baseline for transparency, investor scrutiny and board level accountability.” [16]
The two populations barely overlap.
The FCA’s proposals in CP26/5 touch a few hundred listed issuers, with a policy statement expected in autumn 2026; SECR’s 19,900 are overwhelmingly unquoted companies and LLPs that sit entirely outside them [25].
So the claim that SECR is being phased out next year is not a forecast the government has made, and it contradicts the only two statements it has published on the subject.
What is coming is a consultation on streamlining energy and emissions reporting, which the PIR says is planned for 2026 and which had not launched as of 2 August 2026 [16].
How the two regimes line up in detail is covered under UK sustainability reporting and UK carbon reporting requirements.
What is actually on the calendar for the SECR regulations — and what is only proposed
Nine entries. Four are law, one is today’s status, and four are expectations that no instrument yet supports. The distinction is the whole point of this section, and most pages on these terms do not draw it.
The chapter above answers whether SECR is being replaced. This is the calendar that answer sits on — deliberately excluding the dates already on the filing rail above, so nothing here repeats.
Photo: Unsplash / Paula Prekopova
SECR and ESOS: two tests, one energy dataset — and they do not agree
SECR is two of three. ESOS is the employee test alone, or both financial tests together. Same company, different answers.
The Environment Agency published its ESOS Phase 4 guidance on 30 July 2026, four days before this page was verified, stating the thresholds in sterling: an annual turnover in excess of £44 million and a balance sheet total in excess of £38 million, or 250 or more employees [27].
The government considered aligning the ESOS thresholds with SECR’s and did not proceed, so the divergence is deliberate.
Run your three figures through both and see which regimes you are in.
Why the ESOS dataset is now the natural source for the SECR narrative
There is no legal link between the two regimes. Since 22 July 2026 there is a much better practical one.
SI 2026/701 came into force on that date and changed three things that matter to a SECR reporter [28].
DESNZ measured the reuse directly: businesses found reusing SECR data across ESOS, TCFD-aligned reporting and Carbon Reduction Plans “easy” in 40–71% of cases depending on the scheme [16].
It also flagged the failure mode, which is worth quoting when someone proposes running the two exercises separately: “slight variations in definitions, scope and assurance can produce multiple reported numbers for the same year” [16].
The timing makes the point on its own: ESOS Phase 4 qualification falls on 31 December 2026 and notification on 5 December 2027, so a December year-end SECR reporter is building both datasets in the same twelve months.
The two regimes side by side are compared on ESOS vs SECR, and the audit itself under ESOS requirements.
If your company or LLP exceeds two of £36 million turnover, £18 million on the balance sheet and 250 employees, you publish your energy, your emissions, an intensity ratio, your method and what you did about it — in the directors’ report, every year, whatever your accounts call you.
The bottom line · Photo: Unsplash / Li-An Lim
Knowing what you must disclose is the easy half. The other half is where each number comes from.
Work through a SECR disclosure, step by step Or start from the SECR report template
Photo: Unsplash / Zbynek Burival
SECR requirements in reference form
The same regime, restated for lookup rather than reading — thresholds, disclosures, exemptions, ratios, deadlines, then the FAQs and every source.
The SECR requirements — the short reference
Streamlined Energy and Carbon Reporting requires qualifying UK organisations to disclose annual energy use, greenhouse gas emissions and energy efficiency actions in their directors’ report [2].
The framework came into force for financial years beginning on or after 1 April 2019 under the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 [3].
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.
SECR does not amend Companies Act 2006 Schedule 7, which is a common error worth avoiding: it amends Schedule 7 to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008, and inserts a new Part 5A into the LLP accounts regulations [6].
The Companies Act connection is the enabling power, at s.416(4) [10].
For background on the wider regime see our SECR overview and reporting guide.
SECR qualification thresholds
An unquoted company or LLP is in scope when it exceeds any two of the three criteria below, on the two-year basis in paragraphs 20B and 20C [5].
The test is applied at the level of the reporting entity, but a UK parent of a qualifying group reports 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 — see ESOS vs SECR for the full comparison.
If · ListingListed on a UK market?
If · SizeLarge under SECR — 2 of 3?
If · EnergyESOS qualification?
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 [11].
AIM-listed companies are not quoted for these purposes and fall under the unquoted large-company rules instead.
Mandatory SECR disclosures: quoted companies
Quoted companies must produce a global disclosure covering worldwide operations [2].
The disclosure extends the pre-existing Mandatory Greenhouse Gas Reporting requirements that applied from 2013, layering on energy use and efficiency-narrative obligations [34].
All six elements below must appear in the directors’ report or, where the company elevates the content, be cross-referenced from the strategic report.
Quoted companies should align Scope 1 and Scope 2 boundary-setting with the GHG Protocol Corporate Standard [29] and use the latest UK Government conversion factors published by DESNZ [21].
Methodology covering GHG Protocol scopes and carbon accounting fundamentals sets out the calculation approach in more detail.
Mandatory SECR 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 [5].
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 [6].
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.
The SECR reporting threshold for energy: 40,000 kWh or less
A company that consumed 40,000 kWh of energy or less during the reporting period may state that the information is not disclosed for that reason. The limb is inclusive — 40,000 kWh exactly still qualifies — and it is relief from disclosure, not exemption from SECR [2].
For large unquoted companies and LLPs the test is UK consumption; for quoted companies paragraph 15(5)(a) carries no territorial qualifier, so the test is total consumption [4].
The test runs wider than what you must report. Paragraph 20 defines “energy” as all forms of energy products — combustible fuels, heat, renewable energy, electricity, or any other form of energy — and paragraph 20K carries that definition into Part 7A. So the 40,000 kWh test counts every form of energy consumed, not only the electricity, gas and transport fuel that paragraph 20D makes you disclose. The March 2019 GOV.UK guidance states it the narrow way; the instrument governs.
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.
Other narrow exemptions
A “seriously prejudicial” exemption is available where directors believe disclosure would harm the entity’s commercial interests, and the report must say that information has been omitted on that ground.
Subsidiaries whose data is included in a UK parent’s consolidated SECR report do not need to report separately, provided the parent’s report does not itself rely on the seriously-prejudicial limb.
Where information is genuinely not practical to obtain, it may be excluded — but the report must state what is omitted and why.
SECR exemptions
Four SECR exemptions exist, and three of the four require a statement in the report rather than silence [5].
An entity that qualifies for an exemption and says nothing is still non-compliant — the exemption only removes the numbers, never the section.
Exemption statements sit in the same place as the disclosures they replace — see where each element goes in our SECR report template, which includes model omission wording.
SECR intensity ratios
Every SECR disclosure must include at least one emissions intensity ratio, expressing tCO2e against a denominator that reflects business activity [4].
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.
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.
SECR 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 [2].
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.
SECR deadlines
There is no standalone SECR filing deadline.
The disclosure travels with the annual report and accounts, so SECR deadlines are simply the Companies House accounts filing deadlines for the entity type [12].
Miss the accounts deadline and the SECR disclosure is late with it — attracting the same automatic late-filing penalties [22].
Because the deadline is annual and immovable, most reporters lock the SECR data cut, conversion-factor selection and narrative drafting into the wider accounts production timetable — the practical sequencing is covered across the guides in the SECR section hub.
SECR requirements — frequently asked questions
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.
SECR’s threshold is drafted as an exemption, not a size test. Schedule 7 paragraph 20B(2) exempts an unquoted company that satisfies two or more of: turnover not more than £36 million, balance sheet total not more than £18 million, and not more than 250 employees. A company is in scope when it exceeds at least two of those limbs. These figures sit 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.
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.
A company that consumed 40,000 kWh of energy or less during the reporting period may state that the information is not disclosed for that reason. The limb is inclusive, and it is relief from disclosure rather than exemption from SECR: the report must carry that statement, and silently dropping the section is non-compliance. The territorial limb differs between the two reliefs — paragraph 20D(7)(a) counts energy consumed in the United Kingdom for unquoted companies and LLPs, while paragraph 15(5)(a) for quoted companies carries no UK qualifier. And “energy” in the test means all forms of energy products under paragraphs 20 and 20K, so it runs wider than the electricity, gas and transport fuel that paragraph 20D makes you disclose.
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.
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.
Yes, and since 6 April 2025 this is a common position. SI 2024/1303 raised the Companies Act medium-sized ceiling to £54m turnover and £27m balance sheet but amended Schedule 7 in only one place, which is not Part 7 or Part 7A. A company with turnover between £36m and £54m, or a balance sheet total between £18m and £27m, can therefore be medium-sized for accounts purposes and a SECR reporter at the same time.
SI 2018/1155 amends Schedule 7 to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 (SI 2008/410), adding Part 7A for unquoted companies and amending Part 7 for quoted companies, and inserts a new Part 5A into the LLP accounts regulations (SI 2008/1911). It does not amend Companies Act 2006 Schedule 7, which deals with parent and subsidiary undertakings.
No. A quoted company under Companies Act 2006 s.385(2) is one whose equity share capital is on the FCA’s Official List, officially listed in an EEA state, or admitted to dealing on the New York Stock Exchange or Nasdaq. AIM securities are admitted to trading on AIM rather than included in the Official List, so an AIM company is unquoted and applies the Part 7A size test and disclosure list.
For large unquoted companies and LLPs, yes, but only where the organisation pays for the fuel — including where it reimburses business mileage claims. The test in paragraph 20D(1) is emissions from activities for which the company is responsible, and the government guidance states that only transport where the organisation is responsible for purchasing the fuel is required. An employee who claims nothing is out of scope, and taxis, rail travel and scheduled flights are not required.
There is no penalty specific to SECR. DESNZ’s 2026 Post-Implementation Review describes the enforcement model as light-touch with no dedicated civil sanctions. What applies is the Companies Act framework: approving a directors’ report that does not comply is an offence under s.419 where a director knew or was reckless, the FRC can apply to the court under s.456 for an order to revise a defective report, and late filing carries the Companies House civil penalty on the company. The claim that the FRC can fine a company up to £50,000 for SECR non-compliance has no basis in the regulations.
SECR has no deadline of its own. Because the disclosure sits inside the directors’ report, the deadline is the Companies House accounts filing deadline: nine months after the financial year end for a private company or LLP, six months for a public company. A 31 December 2026 year-end private company therefore files by 30 September 2027. Nothing in the Economic Crime and Corporate Transparency Act shortens these windows; the accounts reforms begin on 1 April 2028.
No. DBT’s February 2026 government response commits only to considering how UK SRS energy and emissions data interacts with SECR, with a view to reducing unnecessary duplication. DESNZ’s Post-Implementation Review of 26 May 2026 goes further and recommends retaining SECR with amendments, describing it as a statutory baseline for transparency, investor scrutiny and board-level accountability. UK SRS S1 and S2 are currently voluntary.
19,900, according to DESNZ’s 2026 Post-Implementation Review, which records 76% more companies and LLPs in scope than the 11,300 predicted in the 2018 Impact Assessment. Figures of around 12,000 still in wide circulation are close to that original forecast rather than to the measured population.
Not where it is a subsidiary undertaking at the year end, its energy and emissions are included in a parent’s group report, and that group report covers a financial year ending at the same time as or before the subsidiary’s. There is one catch: the exemption does not apply if the parent’s group report relies on the seriously prejudicial limb. A parent using the 40,000 kWh de minimis can still relieve its subsidiaries.
The UK Government GHG conversion factors for company reporting, published by DESNZ with Defra, matched to the year the activity occurred rather than the year the report is prepared. The 2026 set was published on 11 June 2026 and its flat file republished on 31 July 2026 to correct values wrongly reported as zero rather than left blank; the full set was not revised. The 2026 set carries a substantial reduction in UK electricity factors, which will affect year-on-year comparatives and should be explained in the methodology statement.
No — they are separate regimes with different tests, different deadlines and different outputs, and there is no provision in Schedule 7 that mentions ESOS. The link is practical: from Phase 4, SI 2026/701 requires ESOS estimates in kWh and adds a duty to estimate energy savings actually achieved by measure, which is a natural evidence base for the SECR energy efficiency narrative. DESNZ found businesses could reuse SECR data across schemes easily in 40–71% of cases.
SECR uses a two-of-three test: £36m turnover, £18m balance sheet, 250 employees. ESOS Phase 4 uses 250 or more employees on its own, or an annual turnover in excess of £44m combined with a balance sheet total in excess of £38m. The tests can give opposite answers: 300 employees with £20m turnover is in ESOS and out of SECR, while £40m turnover and £20m balance sheet with 100 employees is in SECR and out of ESOS.
There are two routes in. A quoted company is eligible on status alone, with no size test, under paragraph 15(1) of Schedule 7. A large unquoted company or LLP is eligible on size: it fails the exemption in paragraph 20B (or 20C for a parent on group figures) if it exceeds two or more of £36 million turnover, £18 million balance sheet total and 250 employees, on the two-year basis those paragraphs set out. The SECR criteria are not the Companies Act criteria — since 6 April 2025 the accounts test is £54 million and £27 million, and SECR was left where it was.
There is no statutory guidance. The government document is Environmental reporting guidelines: including Streamlined Energy and Carbon Reporting guidance, published in March 2019 and not revised since; the GOV.UK landing page for SECR points at it. Everything binding is in the legislation itself — SI 2008/410 Schedule 7 Part 7 for quoted companies and Part 7A for large unquoted companies and LLPs. DESNZ has said it intends a 2026 consultation covering clearer guidance and a standardised template, and as at 12 August 2026 that consultation has not launched.
The 2019 guidelines carry illustrative wording, and the FRC publishes a SECR taxonomy for tagging the figures, but there is no official model disclosure and no template with legal status. In practice the disclosures that survive review share a shape: the six required items in the order Schedule 7 lists them, each with its prior-year comparative from year two, the methodology and conversion-factor year named, and a single sentence on energy efficiency measures — or a sentence saying there were none. Our SECR report template follows that order.
Not as a general duty — and not none either. SECR is a Scope 1 and Scope 2 regime, but unquoted companies and LLPs must include emissions from business travel in vehicles the entity does not own where the entity pays for the fuel, which is a Scope 3 category under the GHG Protocol. So grey fleet mileage is mandatory for unquoted reporters under paragraphs 20D(1)(b) and 20K, while the other fourteen Scope 3 categories are voluntary. Quoted companies may disclose Scope 3 voluntarily; nothing in Part 7 requires it.
The regulations require at least one ratio of annual emissions to a quantifiable factor associated with the entity’s activities, and leave the factor open. The four in common use are tonnes of CO2e per £million of turnover, per square metre of floor area, per full-time-equivalent employee, and per unit produced or delivered. Turnover is the most frequently chosen and the most easily distorted by inflation or a disposal; floor area is the most stable for property-heavy reporters. The requirement is that the ratio is emissions-denominated, not energy-denominated, and that you can repeat it next year.
Three duties sit side by side and none replaces another. SECR is an annual disclosure of energy and emissions in the directors’ report, under SI 2008/410 Schedule 7 as inserted by SI 2018/1155. ESOS is a four-yearly energy audit with a named regulator, the Environment Agency, with Phase 4 qualification on 31 December 2026 and notification by 5 December 2027. UK SRS S1 and S2 were published in February 2026 for voluntary use, with the FCA proposing mandatory S2 for listed companies from 1 January 2027 — a proposal on which no Policy Statement has yet been published. A company can be in all three, and the same energy dataset feeds all three.
SECR glossary
SECR requirements — the official sources
Every figure on this page traces to one of these. Where the pages currently ranking for these terms link a source, we link it too; where they do not, we have added the primary document they summarise.
- Environmental reporting guidelines including SECR guidance — GOV.UK, last updated 29 March 2019
- Streamlined Energy and Carbon Reporting guidance — GOV.UK
- The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (SI 2018/1155) — legislation.gov.uk
- SI 2008/410, Schedule 7 Part 7 — quoted companies
- SI 2008/410, Schedule 7 Part 7A — unquoted companies
- SI 2018/1155 regulation 10 — the LLP energy and carbon report
- SI 2024/1303 regulation 5 — the only provision amending SI 2008/410
- The Companies (Accounts and Reports) (Amendment and Transitional Provision) Regulations 2024 (SI 2024/1303) — in force 6 April 2025
- Companies Act 2006 s.465 — medium-sized companies
- Companies Act 2006 — UK Parliament
- Companies Act 2006 s.385 — quoted and unquoted companies
- Companies Act 2006 s.442 — period allowed for filing accounts
- Companies Act 2006 s.419 — approval and signing of directors’ report
- Companies Act 2006 s.456 — application to court in respect of defective accounts or reports
- 2026 Post-Implementation Review of the SECR regulations 2018 — DESNZ, 26 May 2026
- 2026 Post-Implementation Review — full text (PDF)
- Streamlined Energy and Carbon Reporting (SECR) regulations: evaluation — DESNZ, 29 January 2026
- RPC Opinion: SECR post-implementation review — Regulatory Policy Committee, 15 May 2026
- Environmental Reporting Guidelines including SECR guidance (PDF, March 2019)
- Greenhouse gas reporting: conversion factors 2026 — DESNZ, 11 June 2026, updated 31 July 2026
- Government conversion factors for company reporting — DESNZ/Defra collection
- Late filing penalties — Companies House, updated 16 January 2026
- Government response to the consultation on UK Sustainability Reporting Standards — DBT, 25 February 2026
- UK Sustainability Reporting Standards — GOV.UK / DBT
- CP26/5 — aligning listed issuers’ sustainability disclosures with international standards — FCA
- Comply with the Energy Savings Opportunity Scheme (ESOS) phase 4 — Environment Agency, 30 July 2026
- How to comply with the Energy Savings Opportunity Scheme (ESOS) phase 4 — detailed guidance
- The Energy Savings Opportunity Scheme (Amendment) Regulations 2026 (SI 2026/701) — in force 22 July 2026
- GHG Protocol Corporate Accounting and Reporting Standard — WRI / WBCSD
- Companies House
- Financial Reporting Council — corporate reporting review
- United Kingdom jurisdictional snapshot — IFRS Foundation (PDF)
- Economic Crime and Corporate Transparency Act: outline transition plan for Companies House
- The Companies Act 2006 (Strategic Report and Directors’ Report) Regulations 2013 (SI 2013/1970) — the mandatory GHG reporting predecessor
- Department for Energy Security and Net Zero
- Department for Business and Trade
- The Companies (Late Filing Penalties) and Limited Liability Partnerships (Filing Periods and Late Filing Penalties) Regulations 2008 (SI 2008/497)
- Environment Agency — the ESOS regulator in England
- CRC Energy Efficiency Scheme — GOV.UK collection; the scheme SECR replaced
- FRC taxonomies, including the SECR taxonomy — Financial Reporting Council
- Streamlined Energy and Carbon Reporting — consultation and government response — BEIS
- Average gas and electricity use explained — Ofgem; context for the 40,000 kWh threshold
- Task Force on Climate-related Financial Disclosures
- Energy Savings Opportunity Scheme (ESOS): guidance — GOV.UK
- Corporate sustainability reporting — European Commission
- Carbon and greenhouse gas reporting requirements — House of Commons Library, CBP-9888
- Modernisation of Corporate Reporting — Written Ministerial Statement HCWS973 — UK Parliament, 21 October 2025; energy and emissions reporting expressly retained
Verified against primary sources on 2 August 2026. The DESNZ Post-Implementation Review was published on 26 May 2026 and the Environment Agency’s ESOS Phase 4 guidance on 30 July 2026; both are reflected throughout this page. One figure is deliberately not printed here — the percentage reduction in the 2026 UK electricity conversion factor — because we have it only through secondary summaries of DESNZ’s Major Changes Report.