Sustainability recruitment · duties · checked 1 October 2026
SECR and ESOS reporting roles: who the law actually names
Neither SECR nor ESOS names a job title: SECR names companies and directors, and ESOS names undertakings and responsible officers.
That leaves the preparer open, so the employer decides which role gathers the figures and the law decides who approves and signs.
This page maps each duty to the person the instrument names and shows how to brief a role around what is left.
Is the duty there at all?
Test the size against both regimes
Enter group figures.
The panel applies the SECR exemption test and the ESOS qualification test separately, because they are different tests.
The two regimes use different tests, which is the first thing a brief gets wrong.
SECR is an exemption test: a company is outside the duty if it meets two or more of the “not more than” conditions in Schedule 7 paragraph 20B, so it is in scope when it exceeds at least two.
ESOS is a qualification test: regulation 4 catches an undertaking that employs at least 250 persons, or exceeds both money limbs.
A quoted company is in scope for SECR at any size, and an AIM company is unquoted for this purpose, so it faces the size test.
The SECR limits did not move when the Companies Act size limits rose on 6 April 2025, because Schedule 7 writes its own figures into its table.
A company can therefore be medium-sized for its accounts and still in scope for SECR on the same figures.
Which duties does the company’s size trigger?
SECR: in scope. In scope on these figures: 3 of the 3 limits are exceeded, and a company is exempt only if it meets two or more of the “not more than” conditions.
ESOS Phase 4: qualifies. A large undertaking on headcount alone (250 or more persons).
SECR: SI 2008/410 Sch 7 ¶20B(2) and Part 7.
ESOS: SI 2014/1643 reg 4, as the Environment Agency states it for Phase 4, tested on 31 December 2026.
The two tests differ and neither follows the Companies Act size limits.
After the first year the SECR status changes only when the new position holds for two consecutive financial years.
Group rules, gross and net figures and exclusions are not modelled.
Not legal advice.
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Who is named
The duty-to-title map, as the instruments write it
| Duty | Who the instrument names | Which role | Provision |
|---|---|---|---|
| SECR: energy and carbon figures and methodology | The company (the directors’ report) | Open: no job title named | Sch 7 Part 7 or Part 7A |
| SECR: approve the directors’ report | The board | Director | CA 2006 s.419 |
| SECR: sign the directors’ report | A director or the company secretary | Named by office, not title | CA 2006 s.419 |
| ESOS: collect energy data, plan the assessment | The participant | Open: no job title named | SI 2014/1643 |
| ESOS: review the assessment | A lead assessor from an approved register | A registered assessor, appointed by the participant | SI 2014/1643; EA guidance § 8 |
| ESOS: sign off and notify | Responsible officers | A director or a person exercising management control | SI 2014/1643 reg 30 |
| ESOS: action plan and progress updates | The participant; signed as above | Open for preparation; signed by responsible officers | SI 2014/1643 |
Where the instruments name nobody, the role is open, and the rows that name an office are the ones an employer cannot choose.
The preparer can be a sustainability manager, a carbon manager, an energy manager or an external adviser, and the instruments do not say which.
The approver cannot be chosen so freely: section 419 of the Companies Act 2006 gives approval to the board, and regulation 30 gives ESOS sign-off to responsible officers.
A chief sustainability officer recruitment may or may not be a director, so the title alone settles nothing.
SECR in detail
What the SECR preparer produces
A quoted company reports global Scope 1 and Scope 2 emissions, the underlying energy use, at least one intensity ratio and a narrative on energy efficiency action.
An unquoted company or LLP reports UK energy use and the related Scope 1 and 2 emissions, the transport-fuel element of Scope 3, an intensity ratio and a narrative.
The instrument that created the duty is SI 2018/1155, and the methodology is in the government’s environmental reporting guidelines.
DESNZ’s evaluation found the duty reached many more organisations than forecast, and its 2026 review recommends keeping it with amendments.
SECR carries no penalty of its own, and the Financial Reporting Council, not the old Conduct Committee, has been the enforcer for court applications since 6 May 2021 under section 456 of the Companies Act 2006.
The SECR reporting guide goes through the paragraphs.
SECR’s low-energy-user relief is 40,000 kWh or less, never 40 MWh, and it is a conditional disclosure relief, not an exemption from SECR.
The ESOS lead assessor is not required where total energy consumption is below 40,000 kWh, which is a different rule in a different instrument.
Sources: SI 2008/410 Part 7A · Environment Agency
ESOS in detail
What the ESOS preparer coordinates
ESOS is a four-yearly energy assessment, and Phase 4 runs from 6 December 2023 to a compliance date of 5 December 2027.
Qualification is fixed on 31 December 2026, even if the undertaking changes size afterwards.
The preparer coordinates the energy data, the lead assessor’s review and the notification, and the sign-off belongs to responsible officers.
SI 2026/701 added two reporting duties in Phase 4: the energy savings actually achieved in the period, and an explanation of any measures in the last action plan that were not implemented.
It also removed display energy certificates and Green Deal assessments as compliance routes, leaving the ESOS energy audit and ISO 50001.
Missing an action plan or progress update carries no penalty, but failing to carry out an audit can cost up to £50,000 plus £500 a day, capped at 80 days.
The Phase 4 compliance guide and the ESOS compliance guidance cover the steps, and the government’s scheme guidance is the primary reference.
Briefing the role
Write the owner into the brief
Three sentences in a brief remove most of the ambiguity: which regimes apply, who prepares each and who signs.
For pay, the Home Office going rate for the nearest occupation is £37,200 for SOC 2152, and the salary guide shows how far to rely on it.
The ESG reporting manager guide and the head of sustainability guide take the reporting cycle and the remit from here, and the hub lists the rest.
Frequently asked
SECR and ESOS roles, answered
Who is responsible for SECR in a company?
The company, through its directors.
SECR sits in the directors’ report, which the board approves and a director or the company secretary signs under section 419 of the Companies Act 2006.
The regulations name no job title for the preparer, so a company decides who gathers the figures.
Who signs off ESOS?
Responsible officers.
The assessment, the action plan and each progress update must be signed off by directors or equivalent and submitted through the online service, and a responsible officer is a director or a person exercising management control.
A lead assessor reviews the assessment but does not sign for the company.
Does a company need a dedicated SECR or ESOS manager?
No rule requires one.
Both regimes impose duties on the undertaking and name only directors and responsible officers as signatories, so a company can use an energy manager, a sustainability manager, a finance team or an external adviser to prepare the work.
Who is in scope for SECR?
A quoted company at any size, and a large unquoted company or LLP. An unquoted company is outside the duty only if it meets two or more of the “not more than” conditions: turnover not more than £36 million, balance sheet total not more than £18 million, and not more than 250 employees, in Schedule 7 paragraph 20B(2).
An AIM company is unquoted for SECR.
Who qualifies for ESOS Phase 4?
An undertaking that employs at least 250 persons, or whose annual turnover exceeds £44 million and whose annual balance sheet total exceeds £38 million, tested on 31 December 2026.
Both money limbs must be exceeded, group aggregation applies, and the ESOS test differs from the SECR test.
What are the penalties for getting ESOS wrong?
Civil penalties include up to £50,000 plus £500 for each working day, capped at 80 days, for failing to undertake an energy audit, and up to £5,000 plus £500 per working day, capped at 80 days, for failing to notify.
There is no penalty for failing to submit an action plan or progress update, though the Scheme Administrator publishes the failure.
Is there a penalty for getting SECR wrong?
There is no SECR-specific penalty in the regulations.
SECR is part of the directors’ report, so the general rules on defective reports apply, and the Financial Reporting Council has been the authorised person for applications to court since 6 May 2021.
Are SECR and ESOS being merged?
No. The ESOS Phase 4 amendments in SI 2026/701 did not change the qualification thresholds, and alignment of the SECR and ESOS thresholds remains deferred to Phase 5.
DESNZ’s 2026 SECR review recommends retaining SECR with amendments, and a streamlining consultation is planned, not decided.
What is the ESOS Phase 4 deadline?
Notification of compliance is due by 5 December 2027, the Phase 4 compliance date.
Qualification is a snapshot on 31 December 2026, and the action plan is due by 5 December 2028.
Can the same person do both SECR and ESOS?
Yes, and many companies do, because both draw on energy data.
The boundaries differ: SECR is annual, in the accounts, for a quoted company worldwide and for an unquoted one in the UK, while ESOS is a four-yearly assessment of energy, not carbon, for the whole undertaking.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- legislation.gov.ukSI 2008/410 Sch 7 ¶20B
The SECR size test for unquoted companies: exempt if two or more “not more than” conditions are met.
- legislation.gov.ukSI 2008/410 Sch 7 Part 7A
The energy and carbon report for large unquoted companies.
- legislation.gov.ukSI 2018/1155: Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018
The instrument that created SECR.
- GOV.UKEnvironmental reporting guidelines, including mandatory greenhouse gas emissions reporting guidance
Government methodology guidance for SECR and greenhouse gas reporting.
- DESNZ2026 Post-Implementation Review of the SECR Regulations 2018
Recommends retaining SECR with amendments; a streamlining consultation is planned, not decided.
- DESNZIndependent evaluation of SECR (29 January 2026)
19,900 organisations measured in scope.
- GOV.UKStreamlined energy and carbon reporting
Government SECR guidance collection.
- legislation.gov.ukCompanies Act 2006 s.419
Approval and signature of the directors’ report.
- legislation.gov.ukCompanies Act 2006 s.442
Time allowed for filing accounts: nine months for a private company, six for a public one.
- legislation.gov.ukSI 2014/1643: The Energy Savings Opportunity Scheme Regulations 2014
The scheme regulations.
- legislation.gov.ukSI 2014/1643 reg 4
Who is a large undertaking.
- legislation.gov.ukSI 2014/1643 reg 30
Responsible officers and the sign-off.
- legislation.gov.ukSI 2026/701: ESOS (Amendment) Regulations 2026
Phase 4 changes, including energy savings achieved and the third progress update.
- Environment AgencyHow to comply with ESOS Phase 4
Milestone dates, qualification, lead assessor, sign-off.
- GOV.UKEnergy Savings Opportunity Scheme (ESOS)
The scheme guidance hub.
- Home OfficeImmigration Rules Appendix Skilled Occupations
The going rate for SOC 2152: £37,200 on a 37.5-hour week.
- Office for National StatisticsStandard Occupational Classification 2020
Unit group 2152, Environment professionals.
- legislation.gov.ukCompanies Act 2006 s.250
“Director” includes any person occupying the position of director, by whatever name called.