SECR guide 2026
Streamlined Energy and Carbon Reporting is the sustainability disclosure that actually bites for large UK companies and LLPs. It is mandatory whatever happens to European rules, it sits in the accounts your auditors sign, and around one in five organisations that should be reporting still are not. This guide sets out who must report, what to disclose, how to do it properly, and what the government review in May 2026 means for you.
PEF Consulting Partners provides independent SECR reporting consultancy for UK companies and LLPs, from scope confirmation through data, controls and the disclosure itself. Our leadership served as compliance and enforcement lead on Ofgem’s Energy Bills Support Scheme, so we approach SECR as a controlled reporting process that has to survive audit, not a paragraph written the week before filing. Written by Christopher Fagan, updated September 2026.
Streamlined Energy and Carbon Reporting came into force for financial years beginning on or after 1 April 2019 under the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. It requires large UK organisations to publish their energy use, the greenhouse gas emissions that go with it, an intensity ratio and the energy efficiency action they have taken, inside their annual report. It replaced the older Carbon Reduction Commitment and extended mandatory carbon reporting from listed companies to large private companies and LLPs.
The point that matters for boards is simple. SECR is not a sustainability statement. It is part of the statutory annual report, approved by the directors and filed at Companies House, and the same standard of evidence applies to it as to the rest of that document.
Three groups are in scope.
Quoted companies. Any UK incorporated company whose equity share capital is listed on the FCA Official List, an EEA official list, the New York Stock Exchange or NASDAQ. There is no size test.
Large unquoted companies. A UK company that meets at least two of these three tests in the financial year: turnover of £36 million or more, balance sheet total of £18 million or more, or 250 employees or more (monthly average).
Large LLPs. The same two of three test applied to limited liability partnerships.
A quick self check. Answer yes to two of the three size tests, or you are quoted, and SECR applies to you. If you sit in a group, the test is applied to the parent on a consolidated basis and the parent reports for the group, with subsidiaries that would themselves qualify able to rely on the group disclosure if it covers them.
From 6 April 2025 the Companies Act size limits for a large company rose to £54 million turnover and £27 million balance sheet. SECR did not move with them. The 2024 amendment regulations changed the accounts thresholds but left the SECR provisions in Parts 7 and 7A of the Directors’ Report regulations untouched, so the SECR tests remain £36 million, £18 million and 250 employees. The practical consequence is that a company can now be medium sized for its accounts and still be in scope for SECR. We have seen finance teams assume they had dropped out. They had not.
An organisation that used 40,000 kWh or less in the year is exempt from the detailed disclosure, but must still state in the report that it is a low energy user. For unquoted companies and LLPs the test is UK energy only. For quoted companies it is global energy. In practice almost any organisation large enough to be in scope will use more than 40 MWh, so treat this as a statement to make rather than a way out.
The content differs between quoted and unquoted reporters, and getting the wrong template is the commonest error we see.
Quoted companies report global energy use in kWh, global scope 1 and scope 2 emissions in tonnes of CO2 equivalent, the proportion that relates to the UK and offshore area, at least one intensity ratio, the methodology used, a comparison with the prior year from the second year onwards, and a description of the principal energy efficiency measures taken in the year.
Large unquoted companies and LLPs report UK energy use in kWh covering electricity, gas and transport fuel, the scope 1 and scope 2 emissions from that energy, plus the emissions from transport where the organisation pays for the fuel, at least one intensity ratio, the methodology, the prior year comparison from year two, and the energy efficiency narrative. Scope 3 beyond that transport line is voluntary.
Every reporter should use a recognised methodology. The government’s Environmental Reporting Guidelines and the annual UK greenhouse gas conversion factors published by the Department for Energy Security and Net Zero are the default, and stating that you have used them satisfies the methodology requirement. Choose an intensity ratio that a reader can use to compare you over time, for example tonnes of CO2e per £ million of turnover, per full time employee, per square metre or per unit of output, and keep it consistent year on year.
For companies the disclosure sits in the Directors’ Report. For LLPs it sits in a separate Energy and Carbon Report attached to the annual report. Either way it is filed with the accounts at Companies House on the normal accounts timetable, nine months after the year end for a private company or LLP and six months for a public company. There is no separate SECR deadline and no separate SECR filing. If your accounts are late, your SECR is late.
The October 2025 corporate reporting modernisation statement proposed removing the Directors’ Report as a container while explicitly keeping the energy and emissions reporting requirement and moving it elsewhere in the annual report. The place on the page may change. The duty will not.
The figures below are illustrative and rounded, for a large unquoted manufacturer with £60 million turnover, 320 employees, three UK sites and a small van fleet. They are produced with the government conversion factors for the reporting year.
Energy use in the year: electricity 2,400,000 kWh, natural gas 3,100,000 kWh, transport fuel 410,000 kWh. Total UK energy 5,910,000 kWh.
Emissions: scope 1 from gas combustion and the fleet, 690 tCO2e. Scope 2 from purchased electricity on the location based method, 500 tCO2e. Total 1,190 tCO2e.
Intensity ratio: 19.8 tCO2e per £ million of turnover.
Energy efficiency measures: LED lighting completed across two sites, compressed air leak survey and repairs, and a fleet telematics trial, with the estimated saving stated where it was measured.
Prior year comparison: total energy down 4 percent and intensity down 6 percent against the restated prior year, with the reason for the restatement explained.
That is the whole disclosure. It fits on a page. What makes it defensible is not the length, it is whether the 5,910,000 kWh can be traced to invoices and meter reads, whether the conversion factors are the right year, and whether the same boundary was used last year.
Using the accounts thresholds rather than the SECR thresholds and wrongly concluding you are out of scope. Reporting global figures as an unquoted company or UK only figures as a quoted one. Changing the intensity ratio each year so nothing is comparable. Missing transport fuel where the company pays for it. Using conversion factors from the wrong year. Estimating energy from spend rather than from consumption data. Writing a warm paragraph about sustainability instead of naming the principal efficiency measures actually taken, or failing to say plainly that none were taken. And the most expensive one, assembling the numbers by hand in the last fortnight before the accounts are signed, with no controls and no audit trail.
You will find websites claiming a £50,000 SECR penalty. There is no such figure in any statutory instrument. SECR has no dedicated regulator and no dedicated civil sanction. What exists is the ordinary machinery of the Companies Act: it is an offence for directors to approve a Directors’ Report that does not comply with the requirements where they knew or were reckless as to whether it complied, an offence to fail to prepare the report at all, and the court can order a defective report to be revised at the directors’ cost. Late accounts attract the usual Companies House penalties, which scale up to £7,500. The real exposure for most boards is reputational and audit driven, not a fixed fine, and that exposure is growing as sustainability data gets assured.
On 26 May 2026 the Department for Energy Security and Net Zero published its post implementation review of the SECR regulations. Its conclusion was to retain SECR with targeted amendments to improve effectiveness, reduce duplication and improve coherence with other reporting. The review found that far more organisations are in scope than was forecast when the rules were made, that a meaningful proportion of eligible organisations publish no emissions data at all, with the gaps concentrated among private companies and LLPs, and that the regime has delivered net social value well in excess of its cost.
The review recommended better alignment of definitions and metrics with international standards including the ISSB standards, the EU directive and the TCFD framework, and the government has said it will consider how energy and emissions data reported under the UK Sustainability Reporting Standards, published for voluntary use in February 2026, interacts with SECR to reduce duplication. Any actual amendment will go through the wider Modernising Corporate Reporting consultation later in 2026. Nothing has changed yet. The sensible reading is that SECR is here to stay, that its data will increasingly be expected to reconcile with any UK SRS disclosure you make, and that the organisations still not reporting are the ones the review has just made visible.
We confirm scope and the entities covered, which is straightforward for most and genuinely tricky for groups, joint ventures and organisations near the thresholds. We build the energy and emissions data from invoices, meter data and fleet records with a boundary and a method you can repeat every year. We draft the disclosure so it satisfies the regulations without over engineering it. And we put controls around the process so that next year it is a two week exercise with an audit trail, not a scramble. Where an organisation also faces CSRD, double materiality or UK SRS, we make sure the SECR numbers and those disclosures tell the same story.
If you are close to a threshold, in a group structure, or have never reported and the review has made you nervous, a short SECR review, fixed fee agreed up front, will tell you exactly where you stand before your next accounts are signed.
For a quick first estimate of your emissions, try our free business carbon footprint calculator.
Streamlined Energy and Carbon Reporting is the UK framework, in force since April 2019, that requires quoted companies and large unquoted companies and LLPs to report their energy use and greenhouse gas emissions in their annual report.
UK energy use covering at least gas, electricity and transport fuel, the related greenhouse gas emissions, at least one intensity ratio, the previous year’s figures, the methodology used and a description of the energy efficiency action taken in the year. Quoted companies report global energy use and emissions.
A large unquoted company or LLP must report if it meets at least two of: 250 or more employees, turnover of £36 million or more, and a balance sheet total of £18 million or more. Organisations that used 40,000 kWh or less in the year do not have to disclose the figures but must say so.
The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, which added the requirements to the directors’ report rules under the Companies Act 2006.
Very possibly yes. The 2025 uplift to £54 million turnover and £27 million balance sheet changed the accounts thresholds only. The SECR tests are still £36 million, £18 million and 250 employees, two of three.
If the parent reports on a consolidated basis and its disclosure covers you, a subsidiary that would qualify in its own right can rely on the group report. If the parent is overseas or does not report, the UK subsidiary that qualifies must report itself.
No. ESOS is a four yearly energy audit obligation run by the Environment Agency with its own thresholds and penalties. SECR is annual disclosure in your accounts. Many organisations are in both, and ESOS audit data is a useful source for the SECR efficiency narrative.
Not by law. But it sits inside the annual report, your auditors read it for consistency with the accounts, and if you also report under UK SRS or to a lender or customer, assurance expectations are rising. Building it as an assurable process now is cheaper than rebuilding it later.
There is no SECR specific fine. Non compliance is dealt with under the Companies Act provisions on defective and missing Directors’ Reports, plus ordinary late filing penalties. The commonly cited £50,000 figure has no legal source.
A short review, fixed fee agreed up front, confirms your scope, checks your last disclosure against the regulations and tells you what to fix before the next accounts are signed. Straight answers, no obligation.