Who has to report under SECR
Streamlined Energy and Carbon Reporting (SECR) came into force on 1 April 2019 and applies to financial years starting on or after that date. It covers three groups of UK organisations:
- Quoted companies — all of them, regardless of size.
- Large unquoted companies — those meeting at least two of the three size tests below.
- Large LLPs — the same size tests, reported in a separate Energy and Carbon Report.
A company or LLP is "large" for SECR if it meets two or more of these criteria in the financial year:
| Test | Threshold |
|---|---|
| Turnover | £36 million or more |
| Balance sheet total | £18 million or more |
| Employees | 250 or more (average for the year) |
One point that catches people out: the Companies Act size thresholds for accounts purposes were uplifted for financial years beginning on or after 6 April 2025 (large became roughly £54m turnover / £27m balance sheet), but the SECR thresholds were not raised with them. The 2018 SECR regulations set their figures out directly, so £36m / £18m / 250 still applies. A company that is now "medium-sized" for accounts filing can still be in scope for SECR — check both sets of rules, not just your accounts classification.
Charitable companies, academy trusts and other incorporated not-for-profits are in scope if they meet the size tests. Unregistered organisations, ordinary partnerships and public bodies generally are not (public bodies have separate reporting regimes).
What must be reported
The disclosure requirements differ between quoted and unquoted organisations.
Large unquoted companies and LLPs
- UK energy use — at minimum, purchased electricity, gas and transport fuel (including business travel in company vehicles and employee-owned cars where the business pays for the fuel), in kWh.
- Associated greenhouse gas emissions — in tonnes of CO2 equivalent, converted using published conversion factors.
- At least one intensity ratio — emissions per unit of something meaningful to the business, such as tCO2e per £m turnover, per m² of floor area, or per unit of output.
- A narrative of energy-efficiency actions taken during the year, and their results where known. If nothing was done, you must say so.
- Methodology — a short statement of how the figures were calculated (most organisations cite the GHG Protocol and the government conversion factors).
- Prior-year comparison — required from the second reporting year onwards.
Quoted companies
Quoted companies report global Scope 1 and Scope 2 emissions, underlying global energy use, the proportion relating to the UK, an intensity ratio, energy-efficiency actions and methodology, again with prior-year comparisons.
Scope 3 reporting (supply chain, commuting, upstream fuel) remains voluntary under SECR, though the government encourages material Scope 3 disclosure and other frameworks increasingly expect it.
Where and when the report goes
SECR is not a separate submission to a regulator. The disclosures sit inside the Directors' Report within the annual report and accounts (or the Energy and Carbon Report for LLPs), filed at Companies House on the normal accounts timetable — typically nine months after the financial year end for a private company, six months for a public company. In practice that means your energy and carbon figures must be finalised, sense-checked and signed off on the same schedule as your statutory accounts, not left until "sustainability season".
Exemptions and group reporting
- Low energy users — if the organisation used 40,000 kWh or less in the reporting year, it can state that instead of making the full disclosures. The statement itself is still required.
- Subsidiaries — a UK subsidiary does not need to report in its own accounts if it is covered by a parent's group-level SECR disclosure. The parent's report should say which subsidiaries are included.
- Seriously prejudicial or impractical — narrow let-outs exist where disclosure would be seriously prejudicial or the information is not practical to obtain, but directors must state that they are relying on them, and they are rarely appropriate.
Common mistakes
- Missing transport fuel. Electricity and gas are usually captured; grey-fleet mileage and fuel-card spend are the classic gaps. If the business pays for the fuel, it counts.
- Using estimated billing without saying so. Estimated reads are acceptable if disclosed, but silently mixing estimates and actuals across years makes your comparison meaningless.
- Applying the wrong year's conversion factors. The government publishes updated factors every year — use the set matching your reporting year, and keep using a consistent approach year to year.
- An intensity ratio that moves for the wrong reasons. Turnover-based ratios swing with prices and inflation. Pick a denominator that reflects activity, and explain any restatement.
- A boilerplate efficiency narrative. "We continue to monitor our energy use" is not an energy-efficiency action. LED replacements, controls upgrades, heating schedule changes, survey programmes — say what was actually done.
- Leaving it to the accounts deadline. Chasing twelve months of invoices from multiple suppliers in the last fortnight before filing is where most errors are made.
How to prepare your data through the year
The organisations that find SECR painless treat it as a monthly habit, not an annual scramble:
- Build a meter and supply register. List every electricity and gas supply (MPANs and MPRNs), fuel account and vehicle, with the site and responsible owner for each.
- Collect consumption monthly. Log kWh from invoices or half-hourly data as it arrives, and flag estimated reads for follow-up rather than accepting them.
- Reconcile bills against metered data where you have it — billing errors are common, and SECR is only as good as the invoices behind it.
- Record efficiency actions as they happen, with dates and expected savings, so the narrative writes itself at year end.
- Convert and review quarterly. Applying conversion factors quarterly surfaces anomalies — a meter reading spike, a missing month — while they can still be fixed.
A spreadsheet can do all of this, but it tends to fall over across multiple sites and hands. A dedicated tool such as EnergyIQ keeps the meter register, monthly consumption and the year-on-year picture in one place and lays them out as an SECR report (on the Pro plan, supplier bills are also checked against your meter data), which gets you to a defensible SECR dataset faster — a head start on the disclosure, though the directors remain responsible for what the report says.
Whatever you use, keep the working papers. If an auditor or a stakeholder queries a figure two years later, you want the trail from invoice to disclosed kWh to be reproducible.
This guide is general information, not legal, tax or compliance advice. Rules change — always check the current official guidance for your situation.
Energy & Carbon is built for exactly this — see what it does or book a free demo.