Domestic and micro business
No charge for unbilled consumption over 12 months old, unless the consumer was obstructive or manifestly unreasonable.
Supply licence condition 21BA.The standards
Does it apply to you
Reporting under it
Start here
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Doing it
What you must file
Doing it
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Who and where
The UK duty
Doing it
The baseline
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Software · utility bills, cited
Utility bill management software collects energy bills, checks them against meters and turns them into data.
For a UK company the bill is often the only record of a site’s energy, so it is where SECR and ESOS figures start. This page sets out what a tool must do with a bill, and checks one of yours against the meter.
What it does
It turns invoices into a ledger of energy that someone can report and an auditor can follow.
The finance team already pays the bills; the reporting team needs the kWh on them, by site and by period, with every estimated read visible.
The GHG Protocol Corporate Standard asks for completeness and transparency, which for bills means no missing months and no estimate presented as a reading.
The test of a tool is whether every kWh in a report can be traced to the bill it came from.
Bills from every supplier and site, by upload, portal or electronic data.
Reads against the meter, rates against the contract, periods against each other.
Estimated reads, gaps, overlaps and charges for old consumption.
Consumption split to the financial year, the ESOS reference period and the factor year.
kWh and emissions by site, with the bill behind every figure.
Your bill
Bill validation starts with one comparison: what the meter recorded against what the bill charges.
The tool beside this takes your own opening and closing reads and the bill’s kWh and rate, and shows the difference in kWh, in pounds and in reported emissions on the 2026 factor of 0.14396 kgCO2e/kWh from DESNZ Table 9.
It also flags a bill that reaches back more than 12 months, which matters for micro business sites under Ofgem’s backbilling rule.
A tool does the same across thousands of bills; the arithmetic is no harder, only the volume.
One electricity bill against the meter
Enter both reads and the billed kWh to compare.
Factor: DESNZ 2026 methodology paper, Table 9, consumed electricity 0.14396 kgCO2e/kWh. Backbilling: Ofgem, SLC 21BA.
Arithmetic on your own inputs; standing charges, VAT and the Climate Change Levy are left out. Nothing is stored or sent.
Backbilling
Not from domestic or micro business customers, in most cases.
Ofgem’s open letter on charge recovery restates that the backbilling requirements protect domestic and micro business consumers from being charged for unbilled consumption over 12 months old, except where the consumer behaved obstructively or manifestly unreasonably.
Its licence guide summarises SLC 21BA as preventing suppliers from backbilling for energy consumed more than 12 months before the bill, where the customer is not at fault.
For a larger company the rule does not apply, so a bill tool should flag old consumption as a contract question rather than a licence breach.
Either way, a late bill can change last year’s energy figure, and SECR asks for last year’s figure as disclosed, so the tool should record a restatement rather than overwrite.
No charge for unbilled consumption over 12 months old, unless the consumer was obstructive or manifestly unreasonable.
Supply licence condition 21BA.Outside SLC 21BA; the contract governs what can be recovered.
Check the contract’s billing and dispute terms.Half-hourly data
Settlement data gets more granular and final sooner, but the reporting rules do not change.
The MHHS Programme describes Milestone 16 as the cutover from the legacy 14-month settlement timetable to a four-month one, with a planned date of 2 July 2027 that it will defer if migration slips.
Ofgem approved an earlier replan of the programme in its CR022 decision, so the date is a plan, not a statute.
For reporting, half-hourly kWh are still converted on one DESNZ factor set a year, for activity mostly within that year, under ¶1.10 of the methodology paper.
Interval meter feeds are covered on energy monitoring software.
Half-hourly settlement
Half-hourly settlement
Half-hourly settlement
Half-hourly settlement
Into SECR and ESOS
SECR unit
kWhAnnual energy, ¶15(3A) and ¶20D(3)ESOS unit
kWh or £A common unit; CO2 is not oneESOS audit coverage
95%By energy units or energy spend, reg 25(2)40,000 kWh test
All energyNot only the fuels SECR reportsThe same bills feed both regimes, cut two different ways.
SECR asks for annual energy in kWh under ¶15(3A) of Schedule 7 for quoted companies and ¶20D(3) for unquoted companies, for the financial year the directors’ report covers.
ESOS asks for total energy over a 12-month reference period that begins no more than 12 months before the qualification date, under reg 22(5), in kWh or pounds, according to the Environment Agency’s Phase 4 guidance.
An ESOS audit must cover at least 95% of that total, and reg 25(2) lets the 95% be measured by energy spend, which is where bill data is strongest.
SECR’s relief for a company that consumed 40,000 kWh or less counts all forms of energy, under ¶20 as carried into Part 7A, and applies only if the report states that is the reason, under ¶15(5) or ¶20D(7).
A bill spanning December and January should be split, because DESNZ’s 2026 set is for activity falling entirely or mostly within 2026.
DESNZ also reissued its 2026 flat file in July 2026 to restore blanks it had shown as 0, according to its publication page, so a tool that imports factors should keep blanks as blanks.
The outputs owed are listed on energy reporting software.
Renewable tariffs
It changes one of the two Scope 2 figures, not both.
The location-based figure uses the grid factor whatever the tariff, and UK SRS S2 requires it under ¶29(a)(v) of the standard.
The market-based figure under the GHG Protocol Scope 2 Guidance uses the supplier’s contractual instruments, which in Great Britain are usually REGOs.
So a bill tool should store the tariff and its certificates beside the kWh, not replace the kWh with a zero.
One bill, two Scope 2 figures
One bill, two Scope 2 figures
One bill, two Scope 2 figures
One bill, two Scope 2 figures
Before you sign
Each question beside this names the rule it comes from and what a passing answer looks like.
Run them on a year of your own bills, including an estimated read, a late bill and a period that crosses the year end.
DESNZ’s evaluation measured a mean £7,100 a year and about 94 hours of staff time per SECR complier, so the time a tool removes is the honest measure of its value.
Nothing on this page is a rating, ranking or recommendation of any product.
Utility bill demo questions · tick the ones you need
The pass tests are our reading of the cited provisions.
Nothing you tick is stored or sent.
An order of work
Four kinds of bad bill
Four kinds of bad bill
Four kinds of bad bill
Four kinds of bad bill
In short
The energy figures in the annual report are only as good as the bills they come from.
| What is true | What it means for a tool |
|---|---|
| SECR asks for annual energy in kWh. | Every bill is cut to the financial year and its estimates flagged. |
| ESOS accepts kWh or pounds, and 95% coverage by spend. | Bill data can carry ESOS where meters are thin. |
| Backbilling over 12 months is barred for micro businesses only. | Old consumption is flagged; larger sites go to the contract. |
| Half-hourly settlement is planned for 2 July 2027. | Better data, the same annual reporting factor. |
| A late bill can change last year. | Restate beside the disclosed figure; never overwrite it. |
Next, list the energy figures you owe on energy reporting software.
Frequently asked
Software that collects energy and water bills, checks them against meters and contracts, and turns the consumption on them into data.
For a UK reporter the useful output is a kWh figure by site and period that can feed SECR, ESOS and a carbon inventory, with every estimate visible.
Yes.
SECR asks for annual energy in kWh and the emissions from it; bills are often the only record for sites without interval meters.
The bill has to be cut to the reporting period, its estimated reads flagged, and each kWh converted on the DESNZ factor for the year the energy was used.
A supplier billing for consumption that was not billed at the time.
Ofgem’s supply licence condition 21BA stops suppliers charging domestic and micro business consumers for unbilled consumption more than 12 months old, unless the consumer behaved obstructively or manifestly unreasonably.
Larger business customers are outside it; their contract governs.
An industry programme moving electricity settlement to half-hourly data.
Its Milestone 16, the cutover from a 14-month to a four-month settlement timetable, has a planned date of 2 July 2027; the programme says the date can be deferred if migration slips.
Yes.
The Environment Agency’s Phase 4 guidance says total energy consumption must be in a common unit, either an energy unit such as kWh or energy spend in pounds sterling.
CO2 is not an energy unit.
Audit coverage of 95% can likewise be measured by energy units or energy spend under reg 25(2).
Each part on the factor set for its own activity year.
DESNZ says the 2026 factors are for activity data falling entirely or mostly within 2026, so a December-to-January bill is split, not converted on whichever set is current.
Often both.
Meters give consumption; bills give what was charged, which is what the accounts hold.
The auditor’s view of a SECR figure is easier when the kWh reconciles to the energy costs in the accounts.
A renewable tariff affects a market-based Scope 2 figure through the certificates behind it, usually REGOs in Great Britain.
The location-based figure, which UK SRS S2 requires, uses the grid factor regardless of tariff.
DESNZ’s evaluation measured a mean ongoing cost of £7,100 a year per complier and about 94 hours of internal staff time, with 56% paying for some outside help.
Bill handling is a large share of those hours for multi-site companies.
It still has to know its total.
SECR’s relief lets a company that consumed 40,000 kWh or less leave the figures out only if the report says that is why, and the test counts all forms of energy, not only the fuels SECR reports.
It can, and the Environmental Reporting Guidelines encourage reporting on water and waste as key impacts, but no SECR line asks for them.
Keep them separate from the energy figures a regime requires.
No. This page is built from Ofgem’s licence rules, the MHHS programme, SECR, ESOS and the DESNZ factors, each cited to its source. It names, ranks and prices no product.
Sources
Every rule on this page traces to the source listed here.
No backbilling for consumption over 12 months old, for domestic and micro business consumers.
SLC 21BA in summary.
M16, cutover to a four-month settlement timetable, planned for 2 July 2027.
The programme replan.
SECR: annual energy in kWh, the 40,000 kWh relief and comparatives as disclosed.
Government SECR guidance.
The 12-month reference period for total energy consumption.
Audit coverage of not less than 95%, by energy units or energy spend.
Total energy in kWh or £ spend; CO2 is not an energy unit.
One factor set a year.
The July 2026 flat-file reissue restoring blanks shown as 0.
Factors for activity mostly within the year; consumed electricity 0.14396.
Completeness, consistency and transparency.
A mean £7,100 a year and about 94 hours of staff time per complier.
Retain with amendments.
The certificates behind a renewable tariff.
What a supplier must disclose about its fuel mix.
Location-based and market-based methods.