SECR penalties — what happens if you fail to file?

What SECR is, in one line

Streamlined Energy and Carbon Reporting (SECR) requires large companies to disclose their UK energy use, greenhouse gas emissions and an intensity ratio inside the Directors' Report, alongside the energy efficiency actions taken in the reporting period. It is an annual reporting obligation filed with your accounts at Companies House. In practice the disclosure pulls together your total energy use across electricity, gas and transport (including business travel), the resulting greenhouse gas emissions, an intensity ratio, and a short narrative on the energy efficiency measures taken. Energy from renewable energy sources is reported too, and any energy savings you have achieved are worth setting out. Get the underlying energy consumption data right and the disclosure is straightforward; leave it to the last minute and that is where penalties start.

Who must report under SECR — and why the thresholds matter

SECR applies to all quoted companies, plus large unquoted companies and LLPs. You are required to report if you meet two of three thresholds: turnover of £36M or more, a balance sheet total of £18M or more, or 250 or more employees.

Watch this trap. The April 2025 Companies Act uplift moved the general "large" company definition up to £54M turnover and £27M balance sheet, but the SECR thresholds stayed at £36M / £18M / 250 employees. So a company now classed as "medium" for ordinary accounts purposes can still be fully in scope for SECR — and exposed to every penalty on this page. Confirm your position with the free SECR eligibility checker before you assume you are out.

What you actually have to disclose

An incomplete disclosure is itself a penalty risk, so knowing the required content matters. For most large UK unquoted companies and LLPs, the SECR report covers UK energy use (electricity, gas and transport fuel), the associated carbon emissions, an intensity ratio that puts those emissions in context, and a narrative on energy efficiency. Quoted companies report global energy use and emissions on top. Scope 1 and scope 2 emissions are mandatory; scope 3 — wider supply-chain or carbon footprint figures — remains voluntary. To quantify any of this, start with the free carbon calculator and our carbon footprint guidance; scope 3 emissions support is available when you go further.

The legal basis — section 415, Companies Act 2006

SECR disclosures sit inside the Directors' Report. Under section 415 of the Companies Act 2006, directors must prepare a Directors' Report that complies with the disclosure requirements — including the SECR disclosures on energy use and carbon emissions. If those disclosures are missing or materially deficient, the directors have committed an offence. This is not a soft "best practice" expectation; it is statute.

Director liability — unlimited fines

The penalty is a fine, and on indictment that fine is unlimited. Every director in office at the time is personally liable, and there is no due-diligence defence — directors are responsible whether or not they personally drafted the report. The fine attaches to the individual, not just the company, which makes failure to comply with SECR a genuine personal exposure rather than an abstract corporate one.

Companies House — late-filing penalties

If you delay the accounts to get SECR right, you trigger civil penalties on the whole accounts filing. These stack on top of the criminal exposure above, and they double if you also filed late the previous year.

Remember the filing window: SECR is filed with your accounts, due nine months after the financial year end for private companies and LLPs, and six months for public companies. Work back from that date with the free SECR deadline calculator.

The Financial Reporting Council

The Financial Reporting Council (FRC) reviews corporate reporting through its Corporate Reporting Review function and explicitly checks Directors' Reports for SECR compliance. The FRC can require the company to remediate, restate comparatives in the next accounts, publish the case, or refer it for enforcement. A public FRC challenge is a reputational event in its own right, separate from any financial penalty.

Auditors

External auditors have a duty under ISA 720 (UK) to read the Directors' Report and flag material inconsistencies or misstatements. A weak or missing SECR section — wrong energy consumption figures, a missing intensity ratio, or no narrative on energy efficiency actions — can be challenged before sign-off, and an unresolved issue can lead to a modified audit opinion.

The reputational cost — usually the biggest

SECR disclosures are public and downloadable. Investors, lenders, ESG ratings agencies and large customers read them; a missing or weak disclosure signals poor governance and costs you ESG points. For most companies this reputational hit dwarfs the direct fine. Done well, the same disclosure works the other way: clear reporting of your total energy use, your greenhouse gas emissions and the steps taken to improve energy efficiency demonstrates transparency. A compliant, well-evidenced SECR report — backed by genuine energy savings and renewable energy adoption — reads as good governance to the same investors and lenders who would have penalised a gap.

Common SECR reporting mistakes that lead to penalties

• Assuming you are out of scope because you dropped below the new "large" company size — when the SECR thresholds did not change.
• Gathering energy data too late to meet the reporting deadline.
• Leaving out the intensity ratio or the energy efficiency narrative.
• Mixing up the reporting period or scope so the figures do not reconcile to your energy bills.
• Treating SECR as optional because Companies House does not pre-vet it.

How to avoid SECR fines

The reliable way to meet SECR requirements is to start early and get the numbers right first time. Engage a specialist a few months before your deadline: they confirm whether SECR applies to you, gather accurate data — often from an energy audit of your sites — calculate your energy use and greenhouse gas emissions defensibly, and draft the disclosure so it passes auditor review. The same exercise surfaces savings and supports wider carbon management, so the work pays for itself beyond avoiding a fine. Most UK businesses that fall foul of the rules do so because the data was rushed, not because they set out to dodge them.

We don't file your accounts or employ in-house consultants. We match you with vetted, IEMA-qualified SECR specialists who do this work day in, day out — so you get the right person for your sector and size, not a generic box-ticker. It is free to talk and there is no obligation. Try the free tools first — the eligibility checker, the deadline calculator and the carbon calculator — then get in touch when you want a specialist.