Streamlined Energy and Carbon Reporting: what SECR requires

SECR is not a free-standing scheme with its own portal or register.

It is a set of disclosure paragraphs that SI 2018/1155 inserted into the rules on what a directors’ report must contain, made under the Companies Act 2006.

For companies, the duties sit in Schedule 7 to SI 2008/410: Part 7 for quoted companies and Part 7A for large unquoted companies.

For LLPs, which have no directors’ report, regulation 12B of SI 2008/1911 requires the members to prepare a separate energy and carbon report.

SECR replaced the CRC Energy Efficiency Scheme, which was revoked on 1 October 2018 and closed after its 2018–19 compliance year.

It is annual and backward-looking: it asks what energy you used and what you emitted, not what you plan to do.

The four-yearly energy audit regime that often catches the same organisations is covered in our ESOS compliance guide, and our sister reference site uksrs.org.uk has a full ESOS Phase 4 guide.

The SECR threshold is drafted as an exemption, not as a qualifying test.

Paragraph 20B exempts a company that meets two or more of three conditions: turnover not more than £36 million, balance sheet total not more than £18 million, and not more than 250 employees.

Turned round, an unquoted company is in scope when it exceeds at least two of those figures.

A company at exactly £36 million of turnover meets the exemption limb, so it has not exceeded it.

Paragraph 20C applies the same shape to a parent, on aggregate group figures, and lets it use either the net or the gross figure.

Both paragraphs carry carry-over rules for a company whose size changes from one year to the next, so read the full text before relying on a single year’s figures.

The 2025 uplift did not move SECR

The Companies Act size limits rose to £54 million and £27 million for financial years beginning on or after 6 April 2025.

SECR’s table is self-contained and never cross-refers to them, and the uplift instrument’s regulation 5(3) amended other parts of Schedule 7 while leaving Part 7A alone.

So since 6 April 2025 a company can be medium-sized for its accounts and still in scope for SECR on the same figures.

The government’s own Environmental Reporting Guidelines say the LLP definition of “large” is based on sections 465 and 466 of the Companies Act, which was true by coincidence in 2019 and now points at the wrong numbers.

The £36 million, £18 million and 250 figures printed beside that cross-reference are the ones that match the law.

There are two low-energy reliefs, and they differ.

A quoted company may withhold the figures if it consumed 40,000 kWh of energy or less in the period, under ¶15(5)(a), with no territorial qualifier.

An unquoted company or LLP may do so if it consumed 40,000 kWh or less in the United Kingdom, under ¶20D(7)(a).

The energy counted for the test is all energy, not only the gas, electricity and transport fuel an unquoted company reports, so other fuels can take a business over the line.

Neither relief lists the prior-year comparison duties, so read the paragraphs before assuming everything falls away.

The intensity ratio

Paragraphs 17 and 20G require at least one ratio that expresses the company’s annual emissions against a quantifiable factor associated with its activities.

The law prescribes no ratio and no denominator: revenue, floor area, headcount or units of output all satisfy it.

It is an emissions ratio, so an energy-per-square-metre figure alone does not meet the duty.

Assurance

The Environmental Reporting Guidelines state that there is no statutory requirement to have environmental information audited, and recommend voluntary assurance as best practice.

The auditor of the accounts reports only whether the directors’ report is consistent with the accounts and prepared in line with the law.

SECR has no deadline of its own, because the disclosures travel with the directors’ report.

Under section 442 of the Companies Act 2006, a private company files its accounts within nine months of the end of its accounting reference period, and a public company within six months.

Companies House says a deadline that falls on a Sunday or bank holiday does not move.

The regulations themselves create no fine.

A director who approves a directors’ report knowing that it does not comply, or reckless as to whether it does, commits an offence under section 419.

For LLPs, regulation 12B carries equivalent offences across to the energy and carbon report.

The FRC, authorised since 6 May 2021, can apply to court for a defective report to be revised, but its Corporate Reporting Review procedures record that it has resolved every case so far without a court order.

DESNZ’s post-implementation review calls enforcement light-touch, with no dedicated civil sanction regime.