SECR Reporting: ESG Compliance

SECR is the reporting duty with a filing deadline attached

If you searched for help with ESG reporting in the UK, this is almost certainly the page you needed. Streamlined Energy and Carbon Reporting (SECR) is the duty that brings most mid-to-large companies through the door, because unlike the broader, softer parts of ESG it has a hard deadline: the disclosure goes into your directors’ report and is filed with your annual accounts at Companies House. There is a date, there is a statutory document, and there is a director responsible for its contents. That is what turns “we should probably do something about carbon” into “this is due with the accounts and nobody owns the numbers”.

SECR was introduced by the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, and it does two things a values statement on a website never can: it fixes exactly who must report and exactly what they must disclose. This page answers both precisely, because getting the scope question right is the single most valuable thing a specialist does — and it is the question most published content dodges with a vague “we can help with ESG”. We deliver the disclosure itself as a piece of work, prepared to stand up to scrutiny and, where you want it, to independent assurance. It is the centre of the wider ESG compliance programme we run, sitting on the carbon baseline beneath it and feeding the net-zero roadmap that follows.

Who legally has to report under SECR

Most published guidance never answers this precisely, which is why so many companies are genuinely unsure whether it applies to them. Here is the exact position, verified against the gov.uk environmental reporting guidelines as at 2 July 2026. Two groups are caught.

Quoted companies. All quoted companies are in scope and report their global energy use and greenhouse gas emissions — not just their UK operations. If your company is listed, SECR applies regardless of size.

Large unquoted companies and large LLPs. These report their UK energy use and emissions. “Large” is the standard Companies Act test: you are caught if you meet at least two of three thresholds — 250 or more employees, turnover of more than £36 million, and a balance-sheet total of more than £18 million. It is the two-of-three that catches people out. A private group can cross the line on employees and turnover while its balance sheet sits below the threshold, and still be fully in scope, because two of the three is enough. Plenty of substantial private businesses cross that line after a good year or an acquisition without ever having thought of themselves as “reporters”, and that is exactly where the surprises start. This distinction — quoted companies report globally, large unquoted companies and LLPs report their UK footprint — is fundamental, and we establish which side of it you sit on before anything else.

There is one relief worth knowing. A low energy user — a company that consumes 40,000 kWh or less in the reporting period — is exempt from the detailed 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. We will tell you honestly if that is where you sit, rather than build you a full inventory you do not need. For a fuller walk-through of the scope test, our guide to who has to report under SECR works through the thresholds with worked examples.

What a SECR disclosure actually contains

SECR is not a free-text paragraph about how much you care. It is a defined content set, and that is precisely why a sustainability page on your website does not satisfy it. For a large unquoted company or LLP, the disclosure that goes in the directors’ report (or an energy and carbon report for a large LLP) covers a specific list:

• UK energy use — the total energy consumed across electricity, gas and transport, expressed in kWh.
• Scope 1 and Scope 2 greenhouse gas emissions — direct emissions from sources you own or control, and indirect emissions from the energy you buy. If you are unsure of the distinction, our explainer on Scope 1, 2 and 3 emissions sets it out in plain English.
• At least one intensity ratio — your emissions normalised against a business metric such as turnover, floor area or units of output, so the figure can be compared year on year and against peers.
• A narrative on energy-efficiency actions taken in the reporting year — the concrete measures, not aspirations.
• The methodology used to calculate the figures — which standard and which emissions factors.

Quoted companies report the same categories but on a global basis, and must also disclose the underlying global energy use. After your first reporting year, the comparison with the previous year’s figures is required, which is one more reason a baseline built properly the first time pays off — you are updating a like-for-like series, not reinventing it. The substance of every one of these figures is a Scope 1 and 2 carbon footprint, which is why the carbon baseline is the real starting point, and why we build the disclosure on the UK government conversion factors and the GHG Protocol Corporate Standard — the official data and the recognised methodology that make the numbers defensible rather than estimated.

SECR, TCFD and UK SRS are not the same thing — and it matters

One of the most common and costly mistakes a company makes is treating SECR, TCFD-aligned disclosure and UK SRS as one obligation. They are three distinct things, with three different scopes and three different legal statuses, and getting them straight is central to knowing what you actually have to do. The distinction is worth stating carefully, because most content online blurs it.

SECR is the mandatory disclosure described above — energy and Scope 1 and 2 emissions in the annual accounts — and its “large” thresholds are the 250-employee, £36 million-turnover, £18 million-balance-sheet test. Mandatory TCFD-aligned climate-related financial disclosure, under the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022, is a separate and additional duty for the very largest companies, banks and insurers — including private companies and LLPs with more than 500 employees and turnover over £500 million, and AIM companies with more than 500 employees. That is a different and higher threshold from SECR, which is exactly why a company can be firmly caught by SECR while sitting well below the TCFD-aligned threshold. Conflating the two leads companies either to over-report, doing expensive climate-scenario work they are not required to, or to under-report, missing a duty they are actually caught by.

Then there is UK SRS. The UK Sustainability Reporting Standards (UK SRS S1 and S2) are the UK’s version of the ISSB’s global baseline. The government has finalised them and made them available for voluntary use — the gov.uk guidance was last updated on 25 February 2026 — but has not made them mandatory. Government and the Financial Conduct Authority are still considering whether to require certain UK entities to report against them, and the FCA consulted on UK Listing Rule amendments, with that consultation closing on 20 March 2026. So the honest position, as at 2 July 2026, is that UK SRS is finalised, voluntary and under active consideration, but not law. Anyone telling you it is already compulsory is overstating it. Our guide to what UK SRS and the ISSB standards mean for UK companies sets the timeline out in full. We build your SECR disclosure on the duty that binds you now, structured so that a later move to UK SRS is an extension rather than a rebuild — which is also where the ESG strategy and governance layer earns its keep.

Delivered, not templated — and built to survive assurance

The wedge between a SECR disclosure that protects a company and one that exposes it is quality, and quality comes from how it is built. A template produces the generic “we are passionate about sustainability” paragraph that wins no tenders and satisfies no auditor. A free online checker can tell you a rule might apply, but it cannot build your Scope 1 and 2 baseline from your actual meter and fuel data, produce a disclosure to the defined content structure, or write it so it stands up when someone checks the working. What protects the business is a delivered disclosure with defensible numbers behind it.

We prepare the disclosure to be assurance-ready from the outset, whether or not you take assurance this year. That means a clear methodology, the official conversion factors, and a documented data trail — the difference between a report that is straightforward to assure under ISAE 3000 or, for the greenhouse gas figures specifically, ISAE 3410, and one that becomes a last-minute scramble because the numbers cannot be traced. The direction of travel across the market is towards more assurance, not less, as investors, lenders and boards increasingly ask for it, so building the disclosure to that standard now is cheaper than retrofitting it later.

It also keeps the company clear of the two real exposures. The first is statutory: SECR is part of the directors’ report, a document filed with your accounts, so a late or non-compliant filing is a company-law failure and the directors are responsible for its contents. The second is commercial and reputational: a vague or unquantified disclosure can be challenged in a transaction, undermine a bid, or attract scrutiny under the CMA’s Green Claims Code if it drifts into misleading territory. A quantified, methodologically sound disclosure is both better compliance and a stronger competitive position — which is the whole argument for treating it as delivered work rather than a box-ticking paragraph bolted on when the accounts are already late.

How SECR connects to the rest of your programme

SECR rarely arrives on its own. The company that has to file it usually also needs the baseline beneath it, the plan that improves next year’s numbers, and — increasingly — a Carbon Reduction Plan to keep winning work. The disclosure sits at the centre of a connected programme, and doing the pieces in the right order is what keeps the whole thing efficient:

• The carbon footprint and baseline provides the Scope 1 and 2 figures, the intensity ratio and the location-based and market-based Scope 2 numbers the disclosure reports.
• The net-zero roadmap turns the target into costed, sequenced actions — energy efficiency first, then on-site solar or a PPA treated honestly as a Scope 2 lever — so next year’s disclosed numbers actually improve.
• The Scope 3 and supply-chain work extends the picture into the value chain, which SECR does not mandate in full but which your largest customers and public buyers increasingly demand.
• The ESG strategy and materiality layer sets the boundary and the governance the disclosure assumes, and makes a later UK SRS move an extension rather than a rebuild.

Because carbon reporting is now a commercial gateway as well as a compliance duty, the SECR disclosure is also the number that a Carbon Reduction Plan under PPN 006 starts from — the plan a supplier needs to bid for major central-government contracts, and increasingly the sort of evidence that anchor institutions in Manchester, Birmingham and Leeds build into their selection questionnaires. A defensible SECR disclosure is therefore not only what keeps your accounts compliant; it is the foundation of your eligibility to win work. For the tender side of that picture, our guide to what ESG tenders and PQQs actually ask for sets out where SECR figures and a Carbon Reduction Plan fit into a bid.

Getting started

The first step is a short readiness conversation, not a hard sell. We will tell you precisely whether SECR applies to your company — quoted, large unquoted, or below the threshold — what your disclosure has to contain, and when it is due relative to your accounts. If TCFD-aligned disclosure also catches you, we will say so; if UK SRS is on your radar, we will tell you honestly where that stands. From there the work is scoped on your group structure, your sites and whether a baseline already exists, never priced off a menu, because a headline figure would mislead you. Use the enquiry form below to book that conversation; we respond within one working day.

Government sources, verified 2 July 2026: the UK government environmental reporting guidelines including SECR (gov.uk), the UK government greenhouse gas conversion factors for company reporting (gov.uk), and the UK Sustainability Reporting Standards guidance (gov.uk).