Who needs to comply with SECR?

The three categories in scope

SECR captures three types of UK organisation. You only need to fit one to be in scope.

Quoted companies

A quoted company — equity listed on the LSE Main Market, an EEA regulated market, the New York Stock Exchange or NASDAQ — is in scope regardless of size. AIM-listed companies are not quoted for these purposes, because AIM is not a regulated market; they are assessed as unquoted companies.

Large unquoted companies

A UK unquoted company is "large", and in scope, if it meets two or more of these in the financial year:

Large LLPs

Large LLPs meeting two of the same three thresholds file an Energy and Carbon Report alongside their accounts, with the same content requirements.

The 2025 change that catches companies out

On 6 April 2025 the government raised the general Companies Act size thresholds — a medium-sized company is now one under £54M turnover / £27M balance sheet. The SECR thresholds did not move. They remain £36M / £18M / 250, and the government's own Sustainability Reporting Guidance confirms SECR "no longer aligns with the definition of 'large'."

The trap: a company now reclassified as medium-sized under the Companies Act can still be in scope for SECR. Don't use the new "large company" definition to rule yourself out — apply the £36M / £18M / 250 tests directly.

How the size test works over time

You never average the figures across years. But the Companies Act applies a two-consecutive-years consistency rule to your size category: after your first financial year, you generally only become — or stop being — "large" once you have met (or failed) the test for two consecutive years. In a company's very first financial year, meeting it once is enough.

Groups and subsidiaries

For groups, the test runs at the consolidated parent level. A UK subsidiary that would otherwise be in scope can opt out of producing its own SECR report if its parent prepares a group SECR report that covers it, the subsidiary's directors' report contains an opt-out statement, and the group report is on the public record. A UK subsidiary of a non-UK parent cannot opt out using a foreign parent's report.

The exemptions

Even if you are in scope, three narrow exemptions can apply — each needs a director-signed statement:

• Low energy users — 40,000 kWh or less of UK energy in the year. You still include a statement confirming it.
• Impractical to obtain the information — genuine first-year edge cases only, with a plan to fix it next year.
• Seriously prejudicial disclosure — a high bar: material commercial harm, not merely "it would help a competitor".

Not sure? Check in 30 seconds

Answer four quick questions with our SECR eligibility checker, then a vetted, IEMA-qualified specialist will confirm your exact position and filing deadline — free and with no obligation.