Do I have to report under SECR?

The two groups SECR catches

Streamlined Energy and Carbon Reporting was introduced by the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. It catches two distinct groups, and which group you fall into changes what you have to report.

The first group is all quoted companies. If your company is quoted, SECR applies regardless of size, and you report your global energy use and greenhouse gas emissions. There is no employee or turnover test to escape; being quoted is enough.

The second group is large unquoted companies and large LLPs. Here size is the test, and it is the standard Companies Act definition of “large”. You report your UK energy use and emissions, in the directors’ report (or, for a large LLP, in an energy and carbon report) filed with your annual accounts at Companies House.

The large-company test: two of three thresholds

You are a large company or LLP for SECR purposes if you meet at least two of these three thresholds:

The word to notice is two. You do not need to hit all three. A business with 300 employees and a £40 million turnover is caught even if its balance sheet is modest; a capital-heavy group can be caught on turnover and balance sheet with fewer than 250 staff. This two-of-three logic is exactly why so many large private groups are surprised to find themselves in scope — they never thought of themselves as “reporters”, but the arithmetic catches them.

The one exemption: low energy users

There is a single relief worth knowing. A low energy user — a company that consumes 40,000 kWh or less of energy in the reporting period — does not have to make the detailed SECR disclosure. But it is not a free pass to say nothing: a low energy user must state in its directors’ report that it qualifies as such. So even if you fall under the threshold, silence is not compliant; the exemption has to be claimed explicitly.

What you actually have to file if you are caught

If SECR applies, the disclosure is not a marketing paragraph; it has defined content and a hard deadline, because it sits inside the directors’ report and is filed with the accounts. For a large unquoted company reporting UK figures, it covers:

• UK energy use — as a minimum, electricity, gas and transport;
• the associated Scope 1 and Scope 2 greenhouse gas emissions, calculated using the UK government’s conversion factors for company reporting;
• at least one intensity ratio (emissions relative to a chosen business metric, such as tonnes of CO₂e per unit of turnover or per employee);
• a narrative on the energy-efficiency actions taken in the year; and
• the methodology used to calculate the figures.

Quoted companies report on the same lines but on a global rather than a UK basis. The detail of what goes where, and how to build it so it survives assurance, is covered on our SECR reporting page, and the mechanics of building the underlying numbers on the carbon footprint and baseline page.

Where SECR sits alongside the other duties

SECR is usually the first duty a company meets, but it is rarely the only one, and it is important not to confuse it with the others. Mandatory TCFD-aligned climate-related financial disclosure is a separate, higher-threshold regime under the 2022 Regulations, aimed at the very largest traded companies, banks and insurers, and at private companies and LLPs with more than 500 employees and turnover over £500 million — a different and higher bar than SECR, so being in SECR scope does not automatically put you in TCFD scope. The UK Sustainability Reporting Standards (UK SRS S1 and S2) are finalised for voluntary use but not yet mandatory, and we are careful to describe them as such rather than as law. And a Carbon Reduction Plan under PPN 006 is not a company-reporting duty at all but a procurement requirement for bidding on major public contracts — covered on the ESG for tenders and PQQs page.

Underpinning all of it is the statutory target, in the Climate Change Act 2008 as amended in 2019, to reach net zero by 2050. SECR is one specific report you file along the way to that destination; it is not the whole of ESG, and it is not a substitute for a plan. That is why we treat the disclosure and the net-zero roadmap behind it as two halves of the same job.

The companies that get caught by surprise

In practice, the businesses that come to us unsure whether SECR applies are rarely the obvious ones. A quoted company knows it reports. The surprises are large private groups: family-owned manufacturers, distribution businesses and services firms that have grown steadily and never thought of themselves as subject to carbon reporting, because they associate it with listed multinationals. The two-of-three arithmetic is what catches them. A profitable private company can cross the turnover and balance-sheet thresholds well before anyone internally has considered SECR, and the first time it surfaces is often when the auditors or the finance team notice the directors’ report is missing a required disclosure — sometimes uncomfortably close to the filing date.

Group structure adds a further wrinkle. The test is applied at the level required by the Companies Act, and a group that is large on a consolidated basis brings reporting obligations that individual subsidiaries, looked at alone, might appear to escape. Getting the boundary right — which entities are consolidated, which sites and meters fall inside it, and how a part-year or a mid-year acquisition is treated — is exactly the sort of detail that turns a seemingly simple threshold question into one worth checking properly rather than guessing.

Not sure which side of the line you fall?

The thresholds are precise, but applying them to a real group structure — with subsidiaries, mixed entities, part-years and acquisitions — is where it gets involved. Getting the answer right matters in both directions: reporting when you do not have to wastes effort, and failing to report when you should is a compliance exposure attached to your filed accounts. This is the first thing we do for any client, before we quote a programme: we tell you honestly whether SECR catches you, whether you are also in TCFD scope, and what a public tender would require of you. We would rather tell you a duty does not apply than sell you scope you do not need.