Who Has to Report Under SECR? The Thresholds, Explained

If you have landed here, you are almost certainly asking a genuinely uncertain question: does Streamlined Energy and Carbon Reporting actually apply to my company? It is the most common question a compliance specialist gets, and it is the one most published guidance answers with a vague “it depends” or a promotional “we can help with ESG”. This guide gives the precise answer instead, sourced from the UK government’s environmental reporting guidelines and verified as at 2 July 2026, because getting the scope question right is the single most valuable thing you can do before spending a penny on a report.

The short version: two groups are caught

Streamlined Energy and Carbon Reporting — SECR — is a mandatory disclosure of your energy use and greenhouse gas emissions that goes into your directors’ report and is filed with your annual accounts at Companies House. It was introduced by the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. It catches two distinct groups, and the distinction between them matters:

• All quoted companies. If your company is quoted, SECR applies regardless of size, and you report your global energy use and emissions — not just your UK operations.
• Large unquoted companies and large LLPs. These report their UK energy use and emissions. “Large” is a specific Companies Act test, set out below.

That is the whole of it at the top level. The complexity — and the reason so many companies are unsure — lives entirely in the word “large”, so that is where the rest of this guide concentrates.

The “large company” test: two of three thresholds

For the second group, you are classed as large — and therefore caught by SECR — if you meet at least two of these three thresholds:

• 250 or more employees
• turnover of more than £36 million
• a balance-sheet total of more than £18 million

The load-bearing phrase is at least two of three. It is not “all three”, and it is not “any one”. This is precisely where companies get caught out. A private group can be well over the line on employees and turnover while its balance sheet sits comfortably below £18 million — and it is still fully in scope, because two of the three is enough. Equally, a highly capital-light business with a big turnover but fewer than 250 staff and a small balance sheet meets only one threshold and is not large on that basis at all.

Plenty of substantial private businesses cross this line after a strong trading year or an acquisition without ever having thought of themselves as “reporters”. The disclosure is then due with the accounts, there is a director responsible for its contents, and — more often than not — nobody in the business owns the numbers. That is the exact scenario this guide exists to head off.

The number that catches people out: it is not three thresholds, it is two of three — 250 employees, £36m turnover, £18m balance sheet. Cross any two and you are a large company for SECR, whichever two they are.

Quoted versus large unquoted: global versus UK

The quoted-versus-unquoted split is not a technicality; it changes the size of the job. A quoted company reports on a global basis — its worldwide energy consumption and greenhouse gas emissions — because the listing brings the whole group into scope. A large unquoted company or LLP reports only its UK energy use and emissions. For a business with significant overseas operations, that difference is the difference between a UK-only inventory and a worldwide one, and it has to be established at the very start, because it defines the reporting boundary that everything else is built on.

This is also the first place a generalist gets it wrong. Treating a large unquoted company as if it had to report globally inflates the work and the fee; treating a quoted company as if it only had to cover the UK under-reports and leaves the disclosure defective. Establishing which of the two groups you sit in — and, for a group, which entities consolidate into the figures — is the first thing a specialist does. Our SECR reporting service starts precisely there, and our dedicated do I need to report under SECR page walks the decision through step by step.

The one relief: the low energy user exemption

There is a single, narrow relief worth knowing about. A low energy user — a company or LLP that consumes 40,000 kWh or less across the reporting period — does not have to make the detailed SECR disclosure. But it is not off the hook entirely: it must still state in its directors’ report that it qualifies as a low energy user. In other words, the exemption removes the detailed inventory, not the obligation to say something.

Forty thousand kilowatt-hours is a genuinely low figure — a small office, not a business with any real estate or energy footprint — so this relief applies to a narrow band of companies that are technically large on the financial thresholds but barely consume energy. If that is where you sit, an honest specialist will tell you so and prepare the short statement, rather than build you a full greenhouse gas inventory you do not need. That honesty is the point: the goal is the correct disclosure for your position, not the largest possible engagement.

Where SECR sits in the wider stack — and what it is not

SECR is one duty in a stack of overlapping UK reporting obligations, and conflating it with the others is a common and costly mistake. Three distinctions are worth drawing clearly:

• SECR is not TCFD-aligned disclosure. Mandatory climate-related financial disclosure under the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 is a separate, additional duty for the very largest companies, banks and insurers — plus private companies and LLPs with more than 500 employees and turnover over £500 million. That is a different and much higher threshold than SECR’s. A mid-large company can easily be caught by SECR while sitting well outside TCFD-aligned disclosure.
• SECR is not UK SRS. The UK Sustainability Reporting Standards (UK SRS S1 and S2) — the UK’s version of the ISSB global baseline — have been finalised for voluntary use (the gov.uk guidance was last updated on 25 February 2026) but are not yet mandatory. Government and the Financial Conduct Authority are still considering whether to require certain entities to report against them. Anyone telling you UK SRS is already compulsory is overstating it.
• SECR is not “an ESG page on the website”. SECR is a defined content set inside a statutory document. A values statement about how much you care about sustainability does not satisfy it — and, if it strays into unquantified claims, it can be a liability under the CMA’s Green Claims Code rather than an asset.

If the difference between SECR, ESG and net zero is what you are really trying to pin down, our Scope 1, 2 and 3 emissions explained guide sets out the measurement side, and the whole ESG compliance programme is built around getting the scope question right before anything else.

What being “in scope” actually commits you to

Establishing that SECR applies is the start, not the end. Once you are in scope, the disclosure in the directors’ report (or an energy and carbon report for a large LLP) has to contain a specific list: your UK energy use across electricity, gas and transport; your Scope 1 and Scope 2 greenhouse gas emissions; at least one intensity ratio; a narrative on the energy-efficiency actions taken in the year; and the methodology used. After your first reporting year, you also have to show the previous year’s figures for comparison. Those emissions figures are calculated using the UK government’s official conversion factors for company reporting — the same dataset every compliant disclosure relies on — which is why the numbers have to come from a properly built carbon footprint and baseline rather than being estimated at the last minute.

The practical consequence is that the work behind an in-scope SECR disclosure is a genuine data exercise, not a paragraph. That is manageable when it is planned around your filing deadline, and painful when it is discovered a fortnight before the accounts are due. Do not confuse SECR with the Energy Savings Opportunity Scheme (ESOS) either — ESOS is a related but separate mandatory energy-audit scheme for large undertakings, with its own timetable, and it catches many of the same businesses without being the same obligation.

Common scenarios — worked through

Because the two-of-three test is where the uncertainty lives, a few concrete illustrations make it clearer:

• A manufacturer with 280 staff, £42m turnover and a £12m balance sheet. Two thresholds met (employees and turnover), balance sheet below £18m. Large, and in scope — the sub-threshold balance sheet does not save it.
• A consultancy with 90 staff, £48m turnover and a £6m balance sheet. Only one threshold met (turnover). Not large on that basis, not caught by the large-unquoted route.
• A listed company of any size. Quoted, therefore in scope regardless, reporting on a global basis.
• A property group of 260 staff, £30m turnover and a £40m balance sheet. Two thresholds met (employees and balance sheet), turnover below £36m. Large, and in scope.

These are illustrative, and the test looks at the position across the two preceding financial years rather than a single snapshot, so a business that has only just crossed the line usually has a qualifying period before the duty applies. That window is the right moment to build the baseline calmly, rather than scrambling once the disclosure is already due.

Find out where you sit — before you commit to anything

The honest first step is to establish which side of every line your company falls on: quoted or unquoted, large or not, global or UK, low energy user or not. That answer alone tells you whether you have a filing obligation this year, and how big the job behind it is. We give you that answer straight — including telling you if SECR does not apply to you yet, and showing you what your customers’ tenders are likely to ask for anyway.

If you would like that read on your own numbers, book an ESG readiness call and we will reply within one working day with an honest assessment and, where a programme is warranted, a scoped proposal. To go deeper first, start with our SECR reporting hub, the wider UK ESG compliance service, or see how the picture plays out regionally — for example ESG compliance in Manchester, anchored to the Greater Manchester 2038 net-zero target.

Government sources, verified 2 July 2026: the UK government’s environmental reporting guidelines including SECR and the UK government greenhouse gas conversion factors for company reporting.