In short
SECR requires qualifying UK organisations to disclose their energy use, emissions and efficiency actions in their annual report. It sits in the directors' report, which means auditors, lenders, investors and clients running supplier due diligence all see it.
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Who has to report
Status: LawThe scope test sits in the Companies Act 2006 and the 2018 Regulations, and applies to three groups.
- Quoted companies of any size that prepare a directors' report.
- Large unquoted companies meeting two of the three thresholds below.
- Large LLPs meeting the same test, reporting via an energy and carbon report.
| Threshold | Figure |
|---|---|
| Annual turnover | £36m or more |
| Balance sheet total | £18m or more |
| Employees | 250 or more |
Meeting any two of the three brings a large unquoted company or LLP into scope. All quoted companies are in scope regardless of size. A low energy user exemption applies below 40,000 kWh in the reporting period.
This is not the ESOS test
Status: LawSECR is two of three. ESOS is 250 or more employees on its own, or both financial thresholds together. They are different tests with different figures, and confusing them is the commonest error in this area.
The same company can be inside one regime and outside the other. Check your group’s position against both rather than assuming one answers for the other.
What has to be disclosed
| Element | Detail |
|---|---|
| Energy use | UK energy consumption, and offshore where relevant, across electricity, gas and transport fuel for the reporting year. |
| Emissions | Scope 1 and Scope 2 greenhouse gas emissions. Scope 3 is voluntary but increasingly expected by customers and lenders. |
| Intensity ratio | At least one intensity metric, for example emissions per employee, per square metre or per unit of turnover, so performance can be compared year on year. |
| Efficiency actions | A narrative of the energy efficiency measures taken during the year. |
| Prior year and methodology | The previous year’s figures for comparison, and the methodology used. |
Where it usually goes wrong
- It is left to the last minute. The data spans a full financial year and several fuel types, and assembling it the week before sign-off produces estimates and gaps rather than a clean disclosure.
- The intensity ratio is chosen badly. A poorly chosen metric can make an improving business look static, or hide a real problem. It should reflect how the business actually scales.
- The efficiency narrative says nothing. A paragraph of intent with no measures and no numbers is visible as such to the people reading it.
- The conversion factors are wrong for the year. Emissions factors are published annually and the correct year’s set has to be used, not last year’s.
What a good disclosure does
It reports the required figures accurately, chooses an intensity ratio that reflects the business, and describes measures that actually happened with the numbers attached.
Where performance moved the wrong way, it says so and explains why. A disclosure that only ever improves is one nobody believes.
Questions
Who has to comply with SECR?
All quoted companies preparing a directors' report, plus large unquoted companies and LLPs meeting two of three thresholds: turnover of £36m or more, a balance sheet total of £18m or more, and 250 or more employees.
What must a SECR disclosure contain?
UK energy use, Scope 1 and Scope 2 emissions, at least one intensity ratio, a narrative of efficiency actions taken, and the prior year figures with the methodology used.
Is there an exemption for low energy users?
Yes. An exemption applies where consumption is below 40,000 kWh in the reporting period.
Is SECR the same as ESOS?
No. SECR is two of three thresholds. ESOS is 250 or more employees alone, or both financial thresholds together.
Sources and verification
- Verified as at
- Primary source
- Companies Act 2006 sections 465 to 466; Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, SI 2018/1155
- Reviewed by
- Omnium
Figures in this sheet were current at the verification date above. Regulated charges reset each April. If you are relying on a figure, check the source or ask us.
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