SECR Reporting: A Practical Guide for UK Businesses
What is SECR reporting?
SECR, or Streamlined Energy and Carbon Reporting, is a UK requirement for large companies and LLPs to publish their annual energy use and carbon emissions in their annual reporting. It applies to financial years beginning on or after 1 April 2019, and the official rules sit in the government's environmental reporting guidelines.
SECR replaced the CRC Energy Efficiency Scheme and absorbed the older mandatory greenhouse gas reporting rules for quoted companies, according to Lucideon. The government estimated that around 11,900 companies would need to report.
The short version for most businesses:
Who: quoted companies, plus large unquoted companies and large LLPs incorporated in the UK.
What: UK energy use, the Scope 1 and 2 emissions that come from it, an intensity ratio, and the energy efficiency actions you took.
Where: in the Directors' Report, or in a separate Energy and Carbon Report for LLPs.
How often: every year, with last year's figures alongside after your first reporting year.
If your company is smaller than the thresholds, SECR is not mandatory for you. Customers, lenders and public sector buyers increasingly ask for the same data anyway, so the work is rarely wasted.
Who has to report under SECR? Thresholds explained
UK quoted companies, large unquoted companies and large LLPs must report. Quoted companies report on their global energy use and emissions. Large unquoted companies and LLPs report on their UK operations. The government guidance defines "large" by sections 465 and 466 of the Companies Act 2006, so you are large if you exceed two of these three tests:
Turnover: over £54m for financial years starting on or after 6 April 2025 (over £36m before that date)
Balance sheet total: over £27m from 6 April 2025 (over £18m before)
Average employees: over 250, which has not changed
The higher figures come from the 2024 amendment regulations, which raised the monetary thresholds but left the employee test alone. Some guidance still quotes the old £36m and £18m figures, so confirm your position with your accountant before you decide you are out of scope.
A few points catch people out:
Groups: a UK parent that meets the thresholds at group level must report, even if the parent alone would not. Subsidiaries that would not need to report on their own can be left out, according to Travers Smith.
LLPs: they do not file a Directors' Report, so they publish a separate Energy and Carbon Report.
Charities and not-for-profits: if they file reports with Companies House and meet the thresholds, they must report. Public bodies are not covered by SECR.
Everyone else: reporting is voluntary, though the government encourages it.
SECR reporting requirements: what to include
You must report six things: your UK energy use, the emissions it causes, an intensity ratio, your method, the efficiency actions you took, and last year's figures. Here is what each one involves.
UK energy use: annual kWh for, as a minimum, purchased electricity, gas and transport fuel.
Associated emissions: annual tonnes of CO2e from that energy, covering Scope 1 and Scope 2.
Intensity ratio: at least one ratio that puts emissions in context, such as tCO2e per £m turnover or per employee.
Methodology: the calculation method and the emission factors you used.
Energy efficiency action: a description of the measures taken during the year to improve efficiency.
Comparative data: the previous year's figures, from your second reporting year onwards.
The requirements are set out in the government's guidance for academy trusts, which follows the same 2018 Regulations, and in Bishop Fleming's summary.
Transport counts. It includes fuel used for business travel in vehicles the company does not own, such as employees' own cars, so mileage claims need to be captured.
Scope 3 is mostly optional. SECR does not require you to report wider Scope 3 emissions, but many companies include them voluntarily, especially where customers or tender questions ask for them.
Quoted companies go further. They report global energy use and emissions rather than UK only, and they must disclose their methodology.
SECR low energy use exemption (40,000 kWh)
Yes. If your organisation used 40,000 kWh of energy or less in the UK during the reporting period, you do not have to report, but you must say so. The academy trust guidance sets the test at more than 40,000 kWh, and Lucideon gives the same figure.
Two details matter:
Say it in the report. The Directors' Report should state that the company is a low energy user and has therefore left out the energy and carbon information, as Travers Smith explains.
Impracticality is a narrow route. Large unquoted companies can leave out information that is not practical to obtain, but they should record that they have done so. It is not a substitute for collecting data you could reasonably get.
Some sources describe the limit as 40MW or 40MWh. The correct unit is 40,000 kWh, which is 40 MWh. Check your own total across electricity, gas and transport fuel before relying on the exemption.
SECR guidance: how to calculate your emissions
SECR does not prescribe one calculation method, but it expects a recognised one, applied consistently and disclosed. In practice that means the GHG Protocol Corporate Standard and the UK government's annual conversion factors.
Use the government conversion factors. DESNZ publishes them each year for company reporting, and they cover fuels, electricity, travel and more. The 2026 edition cut the UK electricity factor by around 26%, partly because of a methodology change, according to Circular Ecology. Match the factor set to the year the activity took place, not simply the newest edition.
Watch your comparatives. Published factors are not revised after the fact, and users must decide whether to apply new factors to earlier years, as the Energy Managers Association notes. A fall in emissions caused only by a factor change should not be presented as an efficiency gain. Explain it in your methodology note.
Pick a method for electricity and say which. The government's guidance encourages the location-based method for organisations that do not report both ways, based on its March 2019 update. You may also show a market-based figure alongside it.
Set your boundary. Decide which legal entities, sites and vehicles are in scope, and keep that boundary the same each year unless there is a good reason to change it.
Choose an intensity ratio that fits your business. Tonnes of CO2e per £m of turnover suits most companies. Per employee, per square metre or per unit produced can work better where those are the real drivers of your energy use.
How to prepare your SECR report, step by step
Confirm you are in scope. Test your turnover, balance sheet total and average employees against the thresholds above, and check your group structure.
Define your boundary. List the entities, sites, fleets and leased assets you control, and record why anything is excluded.
Collect activity data. Gather a full year of electricity and gas bills or meter reads, fuel card data, fleet records and mileage claims. Start with the invoices you already hold.
Convert to kWh and tCO2e. Apply the conversion factors for the correct year and keep a record of every factor and source.
Calculate your intensity ratio. Divide total emissions by your chosen business measure.
Gather last year's figures. From your second reporting year, set the comparatives alongside the current year.
Describe your energy efficiency actions. Record the real measures taken during the year, such as LED upgrades, heating controls, fleet changes or a renewable tariff.
Write the disclosure. Include energy use, emissions, the intensity ratio, your methodology and the actions, then pass it to your finance team or auditors for the Directors' Report or Energy and Carbon Report.
Keep the evidence. Store the source data, calculations and factors so any figure can be traced if someone asks.
Most of the effort is in step 3. If your data is scattered across suppliers, sites and spreadsheets, start collecting it well before your year end.
SECR compliance: common mistakes to avoid
The mistakes that cause most trouble are data gaps and inconsistency, not complicated calculations. SECR sits inside your statutory reporting, so errors can reach auditors, directors and the public record. Ask your accountant what a defective report would mean for your directors.
Missing transport. Company cars, vans and employee-owned vehicles used for business travel all count as transport energy.
Using the wrong factor year. Mixing editions across sites or periods makes figures hard to defend.
Silent comparatives. From the second year, last year's figures must appear. If you changed method or boundary, restate or explain.
Unexplained estimates. Estimates are acceptable where data is missing, but state where you used them and how.
A drifting boundary. Adding or dropping sites without saying so makes the year-on-year story misleading.
Vague efficiency actions. "We care about the environment" does not describe action taken. Name the measure and the year it happened.
No audit trail. If you cannot trace a figure back to a bill, a meter read or a fuel record, it is hard to stand behind.
Forgetting the exemption statement. Low energy users still need to say that they are one.
Leaving it to year end. Supplier data, fuel card exports and mileage claims take time to chase. Collect quarterly instead.
How does SECR fit with ESOS, UK SRS and other frameworks?
SECR is one piece of a wider compliance picture, and the same activity data feeds most of the others. Collect it once and reuse it.
ESOS: mandatory for large UK undertakings, with its own thresholds that differ from SECR. Energy audit data can feed SECR, and SECR keeps energy tracking going between ESOS cycles.
UK SRS (S1 and S2): published on 25 February 2026 for voluntary use, with the timing of any mandatory requirement not yet set. It builds on the same Scope 1 and 2 data, with wider climate risk disclosure.
TCFD: a climate-related financial disclosure framework, now largely absorbed into the ISSB and UK SRS standards. It uses the same emissions inventory as its metrics.
SBTi: voluntary science-based target validation. It needs a full inventory, typically wider than SECR's scope.
CDP: a voluntary disclosure platform. Your Scope 1 and 2 figures answer a core part of the questionnaire.
PPN 006: the Carbon Reduction Plan requirement for suppliers to major central government contracts. A SECR-quality baseline supports the plan's emissions figures.
The UK SRS were published for voluntary use and are expected to become mandatory for some companies over time. HSF Kramer notes that the timing of any mandatory requirement has not yet been decided. SECR remains the live legal requirement today.
For SMEs bidding for public sector work, a clean SECR dataset is often the quickest route to a credible Carbon Reduction Plan.
SECR reporting FAQs
What does SECR stand for? Streamlined Energy and Carbon Reporting.
Who has to do SECR reporting? UK quoted companies, large unquoted companies and large LLPs. Large means exceeding two of three tests on turnover, balance sheet total and employees.
What are the SECR thresholds? For financial years starting on or after 6 April 2025, a company is large if it exceeds two of: £54m turnover, £27m balance sheet total and 250 employees. Earlier years used £36m and £18m.
Is SECR mandatory for SMEs? Not for companies below the thresholds. SMEs may still be asked for SECR-style data by large customers or in public sector tenders.
What is the SECR low energy use rule? Organisations using 40,000 kWh or less in the UK in the reporting period are exempt, but must state that they are low energy users.
Does SECR include Scope 3 emissions? Not in general. Required transport includes business travel in vehicles the company does not own, but wider Scope 3 reporting is voluntary.
Where is an SECR report published? In the Directors' Report for companies, or in a separate Energy and Carbon Report for LLPs, filed through the usual accounts process.
Do I need independent assurance? The regulations do not require it, although some companies choose to have their figures verified by firms such as PwC and others.
Do I have to report in my first year? The obligation applies to financial years in which you meet the thresholds, and from your second reporting year you must show comparatives. Start collecting data early so those figures exist.
How Combatting Carbon can help with SECR reporting
Combatting Carbon is UK carbon accounting and emissions reporting software built for SMEs, so you can turn scattered energy and fuel data into figures you can stand behind. Whether you are in scope for SECR or preparing for a customer or tender that expects the same data, the work starts in the same place: a clear boundary, reliable activity data and the right emission factors.
What that looks like in practice:
One place for your data. Bring electricity, gas, fleet and travel data together instead of chasing spreadsheets at year end.
Traceable figures. Every number links back to its source, so your methodology and audit trail are ready when your accountant or auditor asks.
Human review. Our approach combines software with expert checking, rather than relying on automated estimates alone.
Ready for tenders. The same dataset supports Carbon Reduction Plans and the sustainability questions in public sector bids.
If you want to know whether SECR applies to you, or you want to get your data in order before your next reporting year, get in touch with the Combatting Carbon team.
This article is general guidance, not legal or accounting advice. Check your own position with your accountant or auditor.
Sources
Checked 14 October 2026.