Who needs to comply with SECR?

The 30-second test for who needs to comply with SECR

You are in scope for Streamlined Energy and Carbon Reporting if either of these is true:

1. You are a quoted company — equity listed on the LSE Main Market, an EEA regulated market, the New York Stock Exchange or NASDAQ. Size is irrelevant: if you are quoted, you report. (AIM is not a regulated market, so AIM-listed companies are tested as large unquoted companies instead.)
2. You are a large unquoted UK company or LLP — a company or limited liability partnership incorporated in the UK that meets two of these three thresholds in the financial year:

Hit two of the three and you must include an energy and carbon report inside the directors' report you already file at Companies House. That single disclosure covers both your energy use and your carbon emissions for the year. Prefer to skip the reading? The free SECR eligibility checker tells you where you stand in about 30 seconds.

How to count each SECR threshold

Getting these definitions right is where most self-assessments of the SECR thresholds go wrong:

• Turnover — annual turnover for the financial year; pro-rate it if the year is longer or shorter than 12 months.
• Balance sheet total — gross total assets, not net assets. Do not subtract liabilities first. This is the single most common error that makes a company think it is below the line when it is not.
• Employees — the average number of people employed during the year (sum the monthly headcount and divide by the number of months), not the headcount on one day.

The two-of-three rule means you can be well under one threshold and still be a large company that needs to report. A 90-person firm with £40M turnover and £20M of assets is in scope under the SECR reporting requirements, despite being nowhere near 250 employees.

Why these companies are asked to report

SECR exists to extend energy and carbon reporting across the UK economy and to push larger businesses to improve energy efficiency year on year. It was introduced by the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, replacing the older CRC Energy Efficiency Scheme with a single set of streamlined reporting obligations that sit inside mainstream financial reporting.

The logic is simple: when a company has to disclose its energy use and greenhouse gas emissions in its annual report, it pays closer attention to total energy consumption, finds energy efficiency measures worth taking, and reports the resulting savings the following year. SECR is overseen by the Department for Energy Security and Net Zero (DESNZ), with the technical methodology and environmental reporting guidelines set by DEFRA. It runs alongside the Energy Savings Opportunity Scheme, so many larger UK businesses face both sets of carbon and energy reporting — see our ESOS guide for how the two differ.

The two-year consistency rule

You do not average the figures across years, but the size category itself is sticky. After your first financial year, you generally only become large — 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 the test once is enough to put you in scope. Drop below the thresholds after years of reporting and you usually keep reporting for one more year before you can stop.

The 2025 trap that catches firms out

On 6 April 2025 the government raised the general Companies Act size thresholds — a medium-sized company is now one under £54M turnover and £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'."

So a company reclassified as medium-sized for ordinary accounts purposes can still need to comply with SECR. Do not use the new "large company" definition to rule yourself out. Apply the £36M / £18M / 250 tests directly — those are the only thresholds that decide whether the carbon reporting requirements fall on you.

SECR reporting requirements: what you have to report

Whichever category you fall into, the core SECR reporting requirements are the same and the energy and carbon information sits in your directors' report:

• UK energy use for the reporting period, in kWh — electricity, gas and transport fuel.
• Scope 1 and scope 2 greenhouse gas emissions, in tonnes of CO2 equivalent (tCO2e). This greenhouse gas reporting follows the DEFRA methodology.
• An intensity ratio — emissions against a metric you choose, such as tCO2e per £M turnover or per employee.
• A short narrative on the energy efficiency actions taken to reduce energy consumption during the year, plus the methodology behind the figures.

Scope 3 (your wider supply-chain) emissions are encouraged but not mandatory under SECR, unlike the emerging UK Sustainability Reporting Standards. Quoted companies report more than everyone else:

So a quoted business reports its global energy use and carbon emissions, while a large unquoted company or LLP reports UK energy use and emissions only. Both must include the energy and carbon information and describe the steps taken to improve energy efficiency. For the full mechanics see what is SECR, and the DEFRA conversion factors you need to turn raw consumption into emissions.

Groups and subsidiaries

For a group, the size test runs at the consolidated parent level, and a single group SECR report can cover the whole structure. A UK subsidiary that would otherwise need to report can opt out of producing its own 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 at Companies House.

A UK subsidiary of a non-UK parent cannot opt out on a foreign parent's report — responsibility for reporting stays with the UK entity. If your group structure is complex, a specialist can map the reporting scope for you.

Exemptions from SECR reporting

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

• Low energy users — a company or LLP using 40,000 kWh (40MWh) or less of UK energy in the reporting period can omit the energy and carbon figures and instead include a statement to that effect. This is the only common exemption.
• Impractical to obtain the information — genuine first-year edge cases only, with a plan to fix the data the following year.
• Seriously prejudicial disclosure — a high bar: real, material commercial harm, not merely that a figure might help a competitor.

Being reclassified as medium-sized under the 2025 Companies Act rules is not an exemption. If you meet two of the three SECR thresholds, you report.

When you have to file

There is no separate SECR submission and no portal. The energy and carbon report sits inside the directors' report and is filed with your annual accounts at Companies House, so the deadline is your accounts deadline:

• Private companies and LLPs — 9 months after the financial year-end.
• Public companies — 6 months after the financial year-end.

The figures must cover the same reporting period as the accounts. Work out your exact date with the SECR deadline calculator. Miss it and you face the same late-filing penalties as filing accounts late; and because the energy and carbon report is part of the statutory directors' report, leaving the required disclosure out, or filing a knowingly false one, is a criminal offence carrying unlimited director fines. That is why most firms get the energy use data and emissions right the first time rather than rush the disclosure.

What to do once you know you are in scope

The hard part is not deciding you are caught — it is producing a defensible disclosure that meets the reporting requirements. First-time filers routinely underestimate gathering accurate energy consumption data across multiple sites, applying the correct DEFRA conversion factors, and writing an energy efficiency narrative that satisfies the regulations without overclaiming. The job breaks down into four steps:

• confirming exactly which category you fall into and your filing deadline;
• collecting and quality-checking energy use across every UK site;
• calculating scope 1 and scope 2 emissions and a defensible intensity ratio;
• drafting the directors' report disclosure and energy efficiency narrative.

We do not file SECR reports ourselves. We match you with a vetted, IEMA-qualified SECR specialist who handles exactly that — so you get the right expert without spending weeks shortlisting consultants. The same data also forms the baseline for any later net zero strategy or carbon footprint work, so the effort is rarely wasted.

Still not sure? Check in 30 seconds

Answer four quick questions in the free SECR eligibility checker and a vetted, IEMA-qualified specialist will confirm whether you need to comply with SECR, your exact position and your filing deadline — free and with no obligation. You can also model timings with the deadline calculator or estimate your figures with the carbon calculator.