Question 1

Who has to comply with SECR?

Accepted Answer

SECR applies to all UK quoted companies, large unquoted companies, and large LLPs. A large unquoted company or LLP meets at least two of three thresholds: turnover £36M or more, balance sheet £18M or more, or 250 or more employees.

Question 2

Are small and medium-sized companies exempt?

Accepted Answer

Small companies, yes. But the SECR thresholds (£36M / £18M / 250) did not rise with the 6 April 2025 company-size uplift, so a company now classed as medium-sized can still be in SECR scope. Test against £36M / £18M / 250 directly.

Question 3

We are an LLP — do the same rules apply?

Accepted Answer

Yes. Large LLPs meeting two of the three thresholds file an Energy and Carbon Report alongside their annual accounts, with the same content requirements as a large unquoted company.

Question 4

Does SECR apply to AIM-listed companies?

Accepted Answer

AIM is not a regulated market, so AIM-listed companies are not 'quoted' for SECR. They are assessed as unquoted companies and are in scope only if they meet the large-company thresholds.

Question 5

How does SECR work for a group of companies?

Accepted Answer

The size test is applied at the consolidated parent level. A UK subsidiary can be exempted from its own SECR disclosure if its parent prepares a group SECR report covering it, the subsidiary's directors' report contains the required opt-out statement, and the group report is on the public record.

Question 6

We are a UK subsidiary of an overseas parent — do we file SECR?

Accepted Answer

If the UK subsidiary meets the SECR thresholds in its own right, yes — the UK entity files its own SECR disclosure. The overseas parent has no UK SECR obligation, and a UK subsidiary cannot use a non-UK parent's report to opt out.

Question 7

Are academy trusts and other not-for-profits in scope?

Accepted Answer

SECR applies by legal form and size, not by sector. An academy trust is a company limited by guarantee, so it is assessed as an unquoted company against the £36M / £18M / 250 tests. Charitable and not-for-profit companies are treated the same way — there is no blanket exemption.

Question 8

When is the SECR filing deadline?

Accepted Answer

Private companies and LLPs file 9 months after their financial year-end; public companies (PLCs) file 6 months — regardless of whether they are quoted. The SECR disclosure sits in the directors' report, filed at Companies House with the accounts.

Question 9

How long should we allow to prepare a SECR report?

Accepted Answer

For a first-time filer with reasonable data, 8 to 10 weeks is a comfortable timeline; where data is fragmented, allow longer. Data collection usually takes longer than the reporting work, so start early.

Question 10

What happens if we miss the SECR deadline?

Accepted Answer

SECR sits inside the directors' report, so non-filing falls under Companies Act 2006 — director liability, Companies House late-filing penalties on the whole accounts, and an auditor flag, plus reputational risk.

Question 11

What must we report in our SECR disclosure?

Accepted Answer

At minimum: total UK energy consumption (kWh), Scope 1 and Scope 2 emissions (tCO₂e), an intensity ratio, and a narrative on methodologies and energy-efficiency actions. Quoted companies report global figures, not just UK.

Question 12

Is Scope 3 mandatory under SECR?

Accepted Answer

No. Scope 3 is voluntary under SECR. Many companies include selected categories such as business travel and employee commuting to signal maturity, but the full 15 GHG Protocol categories are not required.

Question 13

Which emissions factors do we use?

Accepted Answer

The DEFRA UK Government GHG Conversion Factors, published annually in June. Apply the factors that correspond to the reporting year being disclosed and document the factor version in your methodology.

Question 14

What is the low-energy-user exemption?

Accepted Answer

If your total UK energy use in the reporting year is 40,000 kWh or less, you can claim the low-energy-user exemption and omit the full disclosure. You must still include a director-signed statement in your directors' report confirming you qualify.

Question 15

Are there any other SECR exemptions?

Accepted Answer

Two further narrow exemptions exist, each needing a director-signed statement: where it is not practical to obtain the information (a genuine first-year edge case with a plan to fix it), and where disclosure would be seriously prejudicial (a high bar — material commercial harm).

Question 16

Are there specific SECR penalties?

Accepted Answer

There is no standalone SECR fine. Non-compliance is a Companies Act 2006 breach — omitting SECR makes the directors' report non-compliant under section 415, a criminal offence with unlimited fines on every director.

Question 17

Can our auditor reject the SECR section?

Accepted Answer

Yes. Auditors read the directors' report under ISA 720 (UK) and check the SECR disclosure for completeness and consistency. Common problems include a missing intensity ratio, inconsistent year-on-year boundaries, and undocumented assumptions.

Question 18

Can a specialist take over from our current SECR provider?

Accepted Answer

Yes. Switching is common. The specialist we match you with reviews your last filing for methodology and boundary consistency, documents the bridge from your previous provider's approach, and handles the next cycle.

SECR reporting — frequently asked questions

Eligibility

Groups, subsidiaries and overseas parents

Deadlines

Scope of reporting

Exemptions

Penalties and auditors

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