SECR compliance checklist — every step you can't miss

This SECR checklist walks you through every step of a Streamlined Energy and Carbon Reporting filing, from confirming you are required to comply with SECR to auditor sign-off. It is the same internal QA pattern a specialist runs before a client filing, covering the carbon reporting requirements that apply to UK businesses under the energy and carbon reporting regulations. Work top to bottom — skip a stage and the next one quietly breaks.

Who needs to comply with SECR, and are there exemptions?

SECR was introduced for financial years beginning on or after 1 April 2019. It applies to large UK companies, large unquoted companies and limited liability partnerships (LLPs), and all quoted companies. You are in scope if you are a quoted company, or if you meet at least two of these three thresholds in the reporting year: turnover of £36M or more, balance sheet of £18M or more, or 250 or more employees.

Watch this wedge: the April 2025 Companies Act uplift moved the general "large" company definition to £54M turnover and £27M balance sheet, but the SECR thresholds did not move. A company that is now "medium" for accounts purposes can still have to report under SECR. Always test against £36M / £18M / 250, not the new accounts thresholds.

The main exemption: if you used 40,000 kWh or less of UK energy in the reporting period, you can make a low-energy statement instead of a full disclosure. Subsidiaries can be covered by a single group SECR report. See who needs SECR and check your status with the free SECR eligibility checker.

What must be reported under SECR?

The official SECR guidelines set out the data requirements in detail. Your SECR disclosure sits in the directors' report and covers UK energy use and carbon emissions for the year. At minimum you report: total UK energy consumption in kWh; scope 1 (direct) and scope 2 (indirect emissions from purchased electricity) greenhouse gas emissions in tonnes of CO₂e; at least one intensity ratio; the energy efficiency actions taken in the year; and the methodology used. Quoted companies also report global emissions and material scope 3 emissions such as business travel in owned or controlled transport.

Stage 1 — Confirm eligibility (week minus 12)

• Are you UK-incorporated and preparing a directors' report?
• Are you a quoted or listed company on the LSE main market, NYSE, NASDAQ or an EEA regulated market? In scope — skip the thresholds.
• Did you meet two of: £36M+ turnover, £18M+ balance sheet, 250+ employees in the reporting year?
• If part of a group: is the consolidated parent already preparing a group SECR report covering you?
• If using subsidiary opt-out: is the parent UK-incorporated and the report publicly filed?
• Did you use 40,000 kWh or less of UK energy? Low-energy statement only.

See who needs SECR for the detail.

Stage 2 — Scope the boundary (week minus 10)

• Operational control or financial control approach selected (operational is standard).
• Reporting boundary documented (UK only / UK + global).
• All UK sites identified — including leased, partially-occupied and offsite.
• All fleet vehicles identified including pool, lease and grey-fleet mileage.
• Methodology selected (GHG Protocol Corporate Standard is standard).
• Any exclusions documented with rationale.
• Quoted company: scope 3 business travel scoping confirmed.

Stage 3 — Collect 12 months of source data (weeks minus 10 to minus 6)

Electricity — half-hourly metered consumption for all UK sites (kWh); supplier invoices reconciled to meter data; REGO certificates collected if making market-based scope 2 claims.

Gas — mains gas consumption (kWh) for all sites; supplier invoices reconciled.

Transport — owned/leased fleet fuel cards (litres by fuel type); grey-fleet business mileage by vehicle type; quoted company: rental-car miles, employee-owned car business miles, taxi/rail/air for scope 3.

Refrigerants — F-gas registers (refrigerant top-up volumes by gas type); maintenance contracts checked for losses.

Other — generator fuel (red diesel, biodiesel); process emissions (manufacturing only); LPG and heating oil if used. Note any renewable energy generated or procured.

This is where total energy consumption and carbon data come together — the foundation for every later calculation, and the stage first-time filers underestimate most.

Stage 4 — Convert to emissions (week minus 5)

• DEFRA conversion factors for the data year downloaded (the 2025 set is current).
• Conversion methodology documented (kWh to kgCO₂e per source).
• All energy figures converted using the correct factor category.
• Scope 2: location-based emissions calculated (mandatory).
• Scope 2: market-based emissions calculated if you have REGO/PPA contracts.
• Refrigerant CO₂e calculated using GWP from the current IPCC AR (matching DEFRA usage).
• Totals checked against prior year — variance under 30% (or explained).

See scope 1 emissions and scope 2 emissions for the method, and the carbon calculator to sense-check totals.

Stage 5 — Choose and calculate the intensity ratio (week minus 4)

• At least one intensity ratio selected (tCO₂e per £M turnover / per FTE / per m² / per unit of production).
• Activity metric data confirmed by finance (turnover) or HR (FTE).
• Rationale for the ratio choice documented.
• Ratio calculated and double-checked.
• Prior-year ratio recalculated for comparability if the methodology changed.

Stage 6 — Draft the narrative section (week minus 3)

• Energy efficiency measures implemented during the year listed.
• Each action quantified (kWh or tCO₂e saved where possible).
• Forward-looking commitments included, linked to net zero where relevant.
• Broader strategy referenced (ESOS, ISO 50001, net zero, SBTi).
• Methodology statement and boundary statement drafted.
• Any restatements of prior year disclosed with rationale.

An energy efficiency action might be an LED retrofit, a heating controls upgrade, or fleet electrification. See the SECR report template for a worked example.

Stage 7 — Auditor sign-off and filing (weeks minus 2 to 0)

• Draft report shared with the external auditor.
• Auditor queries resolved.
• Director sign-off obtained.
• Energy and Carbon Report inserted into the directors' report.
• Final accounts and directors' report filed at Companies House by the deadline.
• Audit trail (source data, calculations, factor tables) archived for 6+ years.

The filing deadline is 9 months after the financial year-end for private companies and LLPs, and 6 months for public companies. See SECR filing deadlines and the deadline calculator.

How long should each stage take?

First-time filers should budget 8 to 12 weeks; repeat filers with established data pipelines need 3 to 4 weeks. Data collection is consistently the longest stage — the biggest first-year overrun is always stage 3.

What happens if you don't comply with SECR?

SECR is a legal reporting requirement under the Companies Act. A directors' report that omits the required energy and carbon information is non-compliant, which can mean the accounts are rejected at Companies House, director liability, and reputational damage with investors, lenders and procurement teams who now screen carbon disclosure.

How does SECR compare to ESOS and UK SRS?

SECR is an annual disclosure in your directors' report. ESOS is a separate energy audit obligation every four years — many companies in scope for one are in scope for both. The UK Sustainability Reporting Standards (UK SRS), based on UK SRS S1 and S2, are coming and will raise the bar on climate disclosure. Building a clean SECR data pipeline now makes the UK SRS transition far easier. See ESOS reporting and the glossary.

The benefits of SECR beyond compliance

Beyond compliance, rigorous carbon and energy reporting gives you a baseline to cut energy costs, target the highest-impact energy efficiency measures, shrink your carbon footprint, and demonstrate progress toward net zero. Smaller companies under the thresholds often choose to report voluntarily for exactly these reasons.

Get a specialist to run the checklist

If you'd rather have a specialist run all seven stages for you, we match you with a vetted, IEMA-qualified specialist who can take it end to end. Check your eligibility and we'll connect you — free and with no obligation.