Standards and reporting
UK carbon reporting requirements
UK carbon reporting requirements depend on the entity, reporting period and applicable route, with SECR disclosures, listing rules and procurement requests producing different outputs Quoted SECR Unquoted SECR Final listing rules Procurement policy.
Which carbon reporting task is actually required?
Identify the output first because annual energy/carbon disclosures, a procurement plan and an energy assessment are different tasks SECR fields CRP policy Energy assessment.
Module 01 / 04
Annual report
Establish the company or LLP route and financial year.
Module 02 / 04
Listing disclosure
Check the listing category, applicable rule and accounting period.
Module 03 / 04
Procurement plan
Read the named tender condition and relevant policy version.
Module 04 / 04
Voluntary request
Record the customer or management request and agreed basis.
Read the detailed guidance and evidence
The mandatory sustainability reporting guide covers the wider landscape, while this guide concentrates on carbon outputs and their evidence.
How do the principal outputs differ?
This route map summarises the different purposes without determining an individual entity’s scope.
| Record or decision | What to preserve | Why it matters |
|---|---|---|
| SECR company reporting | Directors’ report disclosures under the relevant Schedule 7 route | An inventory total alone is not the complete report Quoted Unquoted. |
| LLP energy and carbon report | Modified Companies Act reporting machinery | Use the LLP provisions rather than a company label Regulation 12B. |
| UK SRS listing disclosure | Relevant annual reporting under final FCA rules | Check application periods and reliefs PS26/19. |
| Procurement CRP | Published plan supporting an applicable tender condition | Read the contracting authority and policy scope PPN 006. |
How should SECR scope be established?
Check the quoted-company route or the applicable unquoted size-exemption test, retaining the entity and prior-year facts Quoted application Size exemption.
Module 01 / 04
Legal identity
Name the company or LLP whose reporting duty is being considered.
Module 02 / 04
Quoted status
Check the relevant legal classification rather than a loose listed label.
Module 03 / 04
Size history
Retain the measured figures and the applicable multi-year test.
Module 04 / 04
Group position
Check the parent/subsidiary and consolidation provisions separately.
Read the detailed guidance and evidence
Paragraph 20B contains its own unquoted-company exemption limits rather than simply adopting today’s general accounts size label Statutory test.
Group reports have additional inclusion and exclusion provisions, so the individual-company calculation cannot settle every group case Group treatment.
What changes between quoted and unquoted disclosures?
The operative provisions specify the report content rather than simply requiring a carbon footprint.
| Record or decision | What to preserve | Why it matters |
|---|---|---|
| Quoted emissions | Responsible activities including fuel combustion and facilities, plus purchased electricity, heat, steam or cooling | Read paragraph 15 and its qualifications Quoted fields. |
| Unquoted emissions | Responsible gas combustion and transport-fuel activity, plus purchased electricity | Keep the actual statutory wording visible Unquoted fields. |
| Energy quantity | An aggregate figure in kWh under the relevant route | Do not replace energy consumption with tonnes Quoted energy Unquoted energy. |
| Efficiency measures | Describe principal measures taken where the statutory condition applies | A future aspiration is not an action already taken Paragraph 20D(4). |
Can the same inventory boundary serve every request?
A corporate inventory may support several outputs, but each route’s geographic and group instructions still need their own reconciliation Quoted proportions Permitted geographic exclusions Group report.
Module 01 / 04
Operations
List the entities, sites and activities included in the working inventory.
Module 02 / 04
Geography
Identify the relevant UK, offshore and overseas records.
Module 03 / 04
Report route
Map the statutory disclosure boundary to those source records.
Module 04 / 04
Difference
Explain amounts included in one output but not another.
Read the detailed guidance and evidence
For an ordinary unquoted company, paragraph 20D(5)(b) permits exclusion of emissions and energy outside the UK rather than requiring every report to be UK-only Geographic wording.
The offshore-undertaking limb has its own UK-and-offshore-area wording and should not be collapsed into the ordinary-company summary Paragraph 20D(5)(a).
How could one fictional business prepare separate outputs?
An invented unquoted services company has already confirmed its reporting route and now commissions the reporting handover.
| Record or decision | What to preserve | Why it matters |
|---|---|---|
| Working inventory | Source-level UK and overseas records remain identifiable | Avoid deleting evidence merely because an output excludes it. |
| Annual-report extraction | The preparer maps the chosen geographic treatment and required energy/emissions fields | Retain the legal reasoning beside the selected figures. |
| Customer request | The customer asks for a wider group footprint | Label the different perimeter rather than reuse the annual-report total silently. |
| Procurement enquiry | A sales colleague requests a CRP for a particular tender | Check that separate condition before promising the annual report is sufficient. |
What belongs beside the emissions and energy figures?
Include the applicable methodology, emissions-intensity and comparative information rather than publishing unsupported headline totals Methodology Intensity Comparatives.
Module 01 / 04
Methodology
Identify the methods used for the statutory emissions and energy calculations.
Module 02 / 04
Intensity
Connect emissions to a quantifiable activity factor under the applicable provision.
Module 03 / 04
Comparative
Retain the prior-year information as required by the reporting route.
Module 04 / 04
Narrative
Explain the principal efficiency measures actually taken when relevant.
Read the detailed guidance and evidence
Paragraph 20G requires at least one emissions ratio linked to a quantifiable factor associated with the company’s activities Ratio requirement.
Paragraph 20H uses the preceding year’s information as disclosed rather than giving permission to replace it silently with a different perimeter Comparative wording.
How should omitted information be documented?
Distinguish a conditional relief from an unexplained blank or a conclusion that the entity has no reporting duty.
| Record or decision | What to preserve | Why it matters |
|---|---|---|
| Low energy | For unquoted companies, 40,000 kWh or less in the UK plus the required report statement | Do not omit the disclosure condition Paragraph 20D(7)(a). |
| Impracticable data | Identify the unavailable information and why it is not practical to obtain | Preserve the explanation required by the provision Paragraph 20D(6). |
| Quoted route | Read its separate relief wording and conditions | Do not transfer the UK qualifier from the unquoted limb Paragraph 15. |
| Group treatment | Retain the subsidiary-specific inclusion or exclusion decision | An internal group label is not the statutory analysis Paragraph 20E. |
What does UK SRS change for the work plan?
The FCA has finalised UK SRS reporting on a comply-or-explain basis for in-scope listed issuers, applying to accounting periods starting on or after 1 January 2027 Final rules.
Module 01 / 04
Published standards
Identify UK SRS S1 and S2 as the issued reporting framework.
Module 02 / 04
Rule application
Record the actual listing category and relevant accounting period.
Module 03 / 04
Transition
Check the reliefs against the issuer’s facts rather than assuming a single deadline.
Module 04 / 04
Coexistence
Keep separate report-field mappings until the applicable rules resolve them.
Read the detailed guidance and evidence
The issued standards and the rule requiring their use are different documents with different functions Published standards Listing rule application.
A final policy statement with a future application period does not make every private company an in-scope listed issuer.
What should a reporting brief ask an adviser to deliver?
Define the annual-report work and evidence handover explicitly before comparing service proposals.
| Record or decision | What to preserve | Why it matters |
|---|---|---|
| Scope conclusion | Named entity, financial year and primary legal basis | Who reviews the underlying entity facts? |
| Field schedule | Numbers, units, methodology, ratio, comparative and narrative | Which required fields are outside the quoted service? |
| Reconciliation | Source totals and reasons for differences between outputs | Can management reproduce the mapping? |
| Approval pack | Open issues, draft report text and review evidence | Is the pack ready for the actual approval process? |
How can the approved disclosure survive report production?
Keep the final disclosure connected to its approval rather than assuming a draft calculation is the signed report Section 419.
Module 01 / 03
Extract
Identify the approved numbers and wording.
Module 02 / 03
Version
Record subsequent editorial or calculation changes.
Module 03 / 03
Proof
Compare the publication proof with the approved disclosure.
What should be checked in the final proof?
These editorial production checks address errors introduced after technical review.
| Record or decision | What to preserve | Why it matters |
|---|---|---|
| Labels | Units, scopes and reporting period | Prevent a correct number receiving the wrong heading. |
| Narrative | Method, relief explanation and measures | Preserve qualifications during editing. |
| Comparatives | Current and prior-year columns | Keep the applicable comparative visible Paragraph 20H. |
How should the report be approved and handed over?
Preserve management’s reporting decisions and the appropriate approval process rather than treating an exported PDF as completed governance Board approval LLP modifications.
Module 01 / 04
Review
Resolve missing fields and investigate unexplained movements.
Module 02 / 04
Approval
Present the actual disclosure text and outstanding judgements to the authorised reviewers.
Module 03 / 04
Publication
Check that the final report contains the approved figures and explanations.
Module 04 / 04
Retention
Keep the source mapping and reviewer decisions for the next cycle.
Read the detailed guidance and evidence
The reporting consultancy guide and carbon software guide help distinguish those services.
The carbon accounting guide follows a boundary decision through activity data, calculation and a reviewable inventory.
The CBAM software buyer guide provides tests for import records, supplier evidence, version control and usable reporting exports.
Use the carbon reduction plan guide to check the procurement reporting basis and evidence rather than treating every net-zero document as the required output.
The Scope 1 emissions guide develops source identification and a fictional calculation record rather than relying on a final total alone.
How can the work be organised?
This nine-step sequence is an editorial workflow rather than a statutory timetable.
- 101
Identify the request
Obtain the actual report, tender or recipient instruction and its purpose. - 202
Confirm the entity
Check legal identity, quoted status and group facts with an appropriate reviewer. - 303
Fix the period
Record the financial year or relevant application period for that specific route. - 404
Read the provision
Retain the current operative requirement and the scope conclusion. - 505
Map the fields
Identify every required number, method, comparative and narrative field. - 606
Collect and reconcile
Connect the required perimeter to source records and calculation working. - 707
Document reliefs
Record the conditions, explanation and report statement where a relief is used. - 808
Review and approve
Resolve outstanding decisions before the appropriate report approval. - 909
Publish and retain
Check the final version and preserve the evidence for the next cycle.
Frequently asked
Questions people ask
Must every UK business publish a carbon report?
No, because the statutory and regulatory routes have specific scope tests and a procurement CRP depends on the applicable request.
Does an LLP use the company directors’ report route?
The LLP duty operates through the modified energy and carbon report provisions in regulation 12B.
Is SECR simply a Scope 1 and 2 footprint?
No, because the applicable route also specifies energy, methodology, intensity and other report content.
Is the unquoted disclosure always UK-only?
Paragraph 20D permits the relevant overseas exclusions, so the geographic treatment should be documented rather than presented as a universal UK-only command.
Does ESOS replace annual carbon reporting?
No, because its energy-consumption assessment is a different task from the annual report disclosures.
Is a Carbon Reduction Plan universally required by law?
No, because PPN 006 concerns relevant procurements by in-scope authorities rather than imposing an across-the-board company reporting duty.
Sources
Primary sources
Primary provisions and official owner guidance checked on 26 October 2026; historical and draft resources are labelled in the guide.
- UK legislationSchedule 7 paragraph 15: quoted-company disclosures
- UK legislationSchedule 7 paragraph 20B: unquoted size exemption
- UK legislationSchedule 7 paragraph 20D: unquoted report fields and reliefs
- UK legislationSchedule 7 paragraph 20E: group report
- UK legislationSchedule 7 paragraph 20F: methodology
- UK legislationSchedule 7 paragraph 20G: emissions intensity
- UK legislationSchedule 7 paragraph 20H: comparatives
- UK legislationRegulation 12B: LLP energy and carbon reports
- UK legislationCompanies Act section 419: board approval and signature
- FCAPS26/19: final UK SRS listing rules and application period
- DBTUK SRS S1 and S2: published standards
- UK legislationESOS regulation 22: total energy consumption
- Cabinet OfficePPN 006: policy, application and Annex A template