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Energy and carbon EWSNI

SECR reporting (Streamlined Energy and Carbon Reporting)

SECR reporting requires UK quoted companies, and unquoted companies and LLPs that exceed two of three tests (turnover over £36 million, balance sheet over £18 million, more than 250 employees), to disclose energy use, the related greenhouse gas emissions and an intensity ratio in their annual report. The April 2025 rise in Companies Act size thresholds did not change these SECR tests.

Reviewed against official sources on . 8 minute read. Regulators: Companies House, Financial Reporting Council, DESNZ (policy).

At a glance

Who must comply
UK quoted companies, plus unquoted companies and LLPs that exceed at least two of the three SECR size tests in the financial year.
Thresholds
Two or more of: turnover over £36m, balance sheet over £18m, more than 250 employees. Exempt if energy use is 40,000 kWh or less.
Next key date
30 November 2026: consultation closes on moving SECR out of the directors' report. DESNZ plans an SECR and ESOS reform consultation later in 2026.
Regulator
Companies House receives filings; the FRC and Secretary of State can act on defective reports. DESNZ owns the policy.
Maximum penalty
Criminal offence for directors or LLP members: an unlimited fine on indictment. Courts can order a defective report revised at directors' expense.
Where to do it
In your annual report (directors' report, or LLP energy and carbon report), filed at Companies House.

This probably applies to you if

  • Your company's shares are on the UK official list, officially listed in an EEA state, or traded on the NYSE or Nasdaq
  • Your unquoted company or LLP has turnover over £36 million and a balance sheet total over £18 million
  • Your unquoted company or LLP has more than 250 employees and exceeds either financial test
  • Your group exceeds the tests on combined figures (£36m net or £43.2m gross turnover; £18m net or £21.6m gross balance sheet)
  • You used more than 40,000 kWh of energy in the reporting year

What is SECR reporting?

SECR reporting is a legal duty to publish your energy use and greenhouse gas emissions in your annual report each year. It applies to UK quoted companies and to larger unquoted companies and limited liability partnerships (LLPs), for financial years starting on or after 1 April 2019.

SECR is a disclosure duty, not a reduction target. You must report:

  • how much energy you used, in kWh
  • the emissions linked to that energy, in tonnes of CO2 equivalent (tCO2e)
  • at least one intensity ratio
  • the method you used
  • the main energy efficiency measures you took in the year

Companies put this in the directors' report. LLPs prepare a separate energy and carbon report and file it with their accounts. The rules sit in the Companies (Directors' Report) and LLP (Energy and Carbon Report) Regulations 2018, which amended company and LLP accounting rules.

Who must report under SECR: the current thresholds

You must report if you are a quoted company, or an unquoted company or LLP that is not exempt on size. You are exempt only if you meet at least two of: turnover of £36 million or less, balance sheet total of £18 million or less, and 250 employees or fewer.

Type of organisation In scope if… Coverage
Quoted company Always (unless a low energy user) Global energy and emissions
Unquoted company Two or more of: turnover over £36m, balance sheet over £18m, more than 250 employees UK energy and emissions
LLP Same tests as unquoted companies UK energy and emissions
Group (parent) Same tests on combined figures: £36m net or £43.2m gross turnover; £18m net or £21.6m gross balance sheet Parent and in-scope subsidiaries

The April 2025 threshold change does not apply to SECR

For financial years beginning on or after 6 April 2025, the Companies Act limits for a medium-sized company rose to £54 million turnover and £27 million balance sheet. SECR does not use those limits. Its own tests are written into Schedule 7, Part 7A of the accounts regulations and into the LLP regulations, and they were not amended. The government's September 2026 consultation describes SECR scope as using the "previous large definition" of £36 million turnover.

Watch out: A company now classed as medium-sized for its accounts can still be caught by SECR. Test against £36m, £18m and 250 employees, not the new Companies Act figures.

Two-year rule, groups and quoted status

  • Your exempt status only changes once you meet (or fail) the tests in two consecutive years.
  • A subsidiary is exempt if its parent's group report covers it.
  • "Quoted" means shares on the UK official list, officially listed in an EEA state, or traded on the NYSE or Nasdaq. Companies traded only on AIM are not on the official list, so they are unquoted.

What to include in your SECR report

The disclosures differ slightly between quoted companies and everyone else. From your second year of reporting you must also show the previous year's figures.

Disclosure Quoted companies Unquoted companies and LLPs
Energy use (kWh) Global, plus the UK and offshore share UK; gas, electricity and transport fuel as a minimum
Emissions (tCO2e) Global scope 1 and 2: fuel combustion, facilities, and purchased electricity, heat, steam and cooling UK emissions from gas, purchased electricity and transport fuel
Intensity ratio At least one At least one
Methodology Required Required
Energy efficiency action Principal measures taken in the year Principal measures taken in the year

Transport counts

Include fuel for company cars, fleet vehicles, and personal or hire cars used for business, including business mileage claims, where you are responsible for buying the fuel. Flights, taxis and trains you do not operate are not part of the mandatory figure.

Choosing an intensity ratio

Pick a ratio that fits your activity and keep it consistent, such as tCO2e per £1 million turnover, per square metre of floor space, or per tonne of product.

The SECR 40MWh low energy user exemption

If you used 40,000 kWh (40 MWh) or less in the reporting period, you do not need to make the detailed SECR disclosures. You must still say in your report that you are not disclosing the information for that reason.

  • Unquoted companies and LLPs: count UK energy (including the offshore area) from gas, electricity and transport.
  • Quoted companies: count energy across the group.

Few organisations big enough to meet the size tests fall below 40 MWh, so check your figures before relying on it. Separately, directors can leave out information that would be "seriously prejudicial" to the company, and quoted companies can omit information that is not practical to obtain. Both require a statement explaining the omission.

Methodology and conversion factors

You must state the methodology you used. The government's environmental reporting guidelines recommend a recognised standard such as the GHG Protocol Corporate Standard or ISO 14064-1:2018.

To convert energy into emissions, most businesses use the UK government conversion factors, which DESNZ updates every year. The 2026 set is now available. Use factors that match your reporting period and say which set you used.

Good practice for a defensible report:

  1. Use meter readings and invoices rather than estimates where you can, and explain any estimates.
  2. Keep the same organisational boundary as your financial statements.
  3. Reuse data you already collect: you can cite ESOS data as a source, and UK ETS or climate change agreement monitoring can feed in, but check the boundaries match.
  4. Keep workings so your auditors and the FRC can follow them.

SECR penalties and enforcement

SECR is enforced through company law, not an environmental regulator. Breaches can be criminal offences for directors or LLP members, and the Secretary of State or the FRC's Conduct Committee can go to court over a defective report.

Breach Consequence
Directors fail to prepare a directors' report Offence: a fine on indictment (unlimited), or up to the statutory maximum on summary conviction
Directors approve a report they know, or are reckless about, not complying Same as above
LLP members fail to prepare, or approve a non-compliant, energy and carbon report Offence: a fine (unlimited in England and Wales; up to the statutory maximum on summary conviction in Scotland and Northern Ireland)
Defective directors' report Court can order a revised report, with costs payable by the directors who approved it

The government's 2026 post-implementation review found compliance generally high but uneven, with gaps among private companies and LLPs, and enforcement light-touch.

How SECR relates to ESOS and UK SRS, and what may change

SECR often overlaps with ESOS, but the two schemes do different jobs and use different size tests.

SECR ESOS Phase 4
What you do Annual disclosure in your annual report Energy assessment and audits every four years, plus action plans
Size test Two of: over £36m turnover, over £18m balance sheet, over 250 employees 250+ employees, or over £44m turnover and over £38m balance sheet
Enforced by Company law (Companies House, FRC, courts) Environment Agency and other UK regulators

UK SRS

The UK Sustainability Reporting Standards, UK SRS S1 and S2, were published on 25 February 2026 for voluntary use. The FCA's final rules require in-scope listed companies to report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. SECR continues to apply alongside. See our sustainability reporting guide.

Reforms: proposed, not law

  • A May 2026 post-implementation review recommended keeping SECR with amendments, such as a standard template and clearer guidance.
  • The "Modernising corporate reporting" consultation (7 September to 30 November 2026) proposes abolishing the directors' report and letting companies place SECR disclosures anywhere in the first half of the annual report.
  • DESNZ has said it intends to consult on SECR and ESOS reform later in 2026.

Until new legislation is made, report under the current rules.

How it differs across the UK

E England

SECR applies in the same way across the UK because it sits in UK-wide company law. Summary fines for LLP members are unlimited in England and Wales.

W Wales

Same rules as England. Companies registered in England and Wales file with Companies House in the usual way.

S Scotland

Same SECR rules and thresholds. On summary conviction, fines for LLP members are capped at the statutory maximum in Scotland.

NI Northern Ireland

Same SECR rules and thresholds. On summary conviction, fines for LLP members are capped at the statutory maximum in Northern Ireland.

Key dates

  • DESNZ consultation on SECR and ESOS reform expected (later in 2026)

    SECR reporters and ESOS participants EWSNI Proposed

  • Consultation closes: Modernising corporate reporting (includes proposal to move SECR disclosures out of the directors' report)

    Companies, LLPs, investors and advisers wishing to respond EWSNI

  • FCA UK SRS disclosure rules apply to listed companies (accounting periods beginning on or after this date)

    In-scope UK-listed issuers, including SECR quoted companies EWSNI

  • SECR: public companies with a 31 December 2026 year end file accounts and directors' report at Companies House

    Public companies (deadline is 6 months after year end) EWSNI Annual

  • SECR: private companies and LLPs with a 31 December 2026 year end file accounts and SECR disclosures at Companies House

    Private companies and LLPs (deadline is 9 months after year end) EWSNI Annual

Dates marked “Proposed” are announced or consulted on but not yet law. See the full deadlines calendar.

Penalties and enforcement

BreachPenaltyApplies in
SECR: directors failing to prepare a directors' reportCriminal offence: a fine on conviction on indictment (unlimited), or up to the statutory maximum on summary convictionEWSNISource
SECR: approving a directors' report that does not comply, knowingly or recklesslyCriminal offence: a fine on conviction on indictment (unlimited), or up to the statutory maximum on summary convictionEWSNISource
SECR (LLPs): members failing to prepare, or approving a non-compliant, energy and carbon reportCriminal offence: a fine (unlimited in England and Wales; up to the statutory maximum on summary conviction in Scotland and Northern Ireland)EWSNISource
SECR: defective directors' reportCourt can order a revised report, with costs and expenses payable by the directors who approved the defective reportEWSNISource

Compliance checklist

Where to do it: official services

The law behind this

Questions people ask

What are the SECR thresholds in 2026?

An unquoted company or LLP must report under SECR if it has at least two of: turnover over £36 million, a balance sheet total over £18 million, and more than 250 employees. Groups use combined figures, with gross limits of £43.2 million and £21.6 million. Quoted companies must report whatever their size. These thresholds did not change when the Companies Act size limits rose in April 2025.

Did the April 2025 company size threshold changes affect SECR?

No. For financial years beginning on or after 6 April 2025, the Companies Act limits for medium-sized companies rose to £54 million turnover and £27 million balance sheet. SECR uses its own fixed tests in the accounts regulations and the LLP regulations, and those were not amended. A company now classed as medium-sized for its accounts can therefore still have to make SECR disclosures.

What is the SECR 40MWh exemption?

If you used 40,000 kWh (40 MWh) of energy or less in the reporting period, you do not need to make the detailed SECR disclosures. Unquoted companies and LLPs count UK energy from gas, electricity and transport; quoted companies count energy across the group. You must still state in your report that the information is not disclosed for that reason.

Which emissions scopes do you report under SECR?

Quoted companies report global scope 1 and scope 2 emissions. Unquoted companies and LLPs report UK emissions from gas, purchased electricity and transport fuel. That covers most scope 1 and 2 emissions, plus business travel in employee-owned or hire cars where you pay for the fuel. Wider scope 3 emissions, such as your supply chain, are voluntary under SECR.

Where do SECR disclosures go in the annual report?

Companies include SECR in the directors' report, which is filed at Companies House with the accounts. LLPs prepare a separate energy and carbon report, approved by the members, signed by a designated member and filed with the accounts. The government has proposed abolishing the directors' report and letting companies place SECR anywhere in the first half of the annual report, but that is not yet law.

Is SECR being replaced by UK SRS?

Not at the moment. UK SRS S1 and S2 were published on 25 February 2026 for voluntary use, and the FCA will require in-scope listed companies to report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. SECR still applies alongside them. A May 2026 government review recommended keeping SECR with amendments, and DESNZ intends to consult on reforms later in 2026.

Terms used in this guide

Quoted company
A company whose equity shares are on the UK official list, officially listed in an EEA state, or admitted to dealing on the NYSE or Nasdaq.
Unquoted company
Any company that is not a quoted company, including companies whose shares are traded only on AIM.
Low energy user
A company or LLP that used 40,000 kWh or less in the reporting period. It states this instead of making detailed SECR disclosures.
Intensity ratio
A figure relating your emissions to a measure of activity, such as tCO2e per £1 million turnover or per square metre.
Scope 1 emissions
Direct emissions from fuel you burn and facilities you operate, including company vehicles.
Scope 2 emissions
Indirect emissions from electricity, heat, steam or cooling you buy for your own use.
Energy and carbon report
The separate report an in-scope LLP prepares and files with its accounts to make SECR disclosures.
Conversion factors
Emission factors published each year by DESNZ for converting energy use and activity data into tCO2e.

Full glossary

Sources

  1. Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008, Schedule 7 Part 7A (unquoted companies)
  2. Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008, Schedule 7 Part 7 (quoted companies)
  3. LLP (Accounts and Audit) Regulations 2008, Part 5A (energy and carbon report)
  4. Environmental reporting guidelines, including SECR — DESNZ (PDF)
  5. SECR post-implementation review 2026 — DESNZ
  6. Modernising corporate reporting: consultation document (paras 149–150 on SECR)
  7. Modernising corporate reporting, Annex A: October 2025 legislative changes
  8. Companies Act 2006, section 465 (medium-sized company thresholds)
  9. Companies (Accounts and Reports) (Amendment and Transitional Provision) Regulations 2024, regulation 2
  10. FCA PS26/19: Aligning listed issuers' sustainability disclosures with international standards
  11. Government conversion factors for company reporting — DESNZ
  12. Companies Act 2006, sections 415, 419 and 456

Reviewed 14 October 2026. If you spot something out of date, email info@thamesenvironment.com.

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