SECR reporting thresholds

The three SECR entity types

SECR does not have one population. It has three, and they are caught by different tests and owe different things.

The rest of this page follows that order: who is caught, on what figures, and what each of the three then owes.

If you already know which of the three you are, the checker further down takes your own numbers.

Quoted companies — every one of them, at any size

A quoted company is in SECR scope with no size test at all.

A quoted company with four employees and £2 million of turnover owes the same disclosures as one with forty thousand employees.

Section 385(2) defines "quoted" narrowly, and the definition is the part people get wrong:

• equity share capital on the FCA Official List under Part 6 of the Financial Services and Markets Act 2000 — in practice the Main Market of the London Stock Exchange;
• equity share capital officially listed in an EEA State;
• admission to dealing on the New York Stock Exchange;
• admission to dealing on Nasdaq.

AIM is not on that list. Neither is the Aquis Growth Market.

An AIM company is therefore unquoted for SECR — which does not put it out of scope, it puts it on route 2, where the size test decides and the lighter UK-only package applies.

Why does the quoted route exist at all?SECR did not create it. Quoted companies had reported greenhouse gas emissions since the Companies Act 2006 (Strategic Report and Directors’ Report) Regulations 2013, and SI 2018/1155 kept that population and extended a lighter duty outward to large unquoted companies and LLPs.

Read next: what each of the three must disclose — the quoted package is materially wider than the other two, and the difference is not the one most summaries describe.

Large unquoted companies — where the two-of-three test bites

This is the population the thresholds were written for, and the one this page is mostly about.

It covers private companies, family businesses, private-equity portfolio companies, UK subsidiaries of overseas parents, holding companies inside UK groups — and, as chapter 02 explained, AIM-admitted companies.

The statute reaches them by an unusual route, and the route matters.

Paragraph 20B does not say "this Part applies to large companies". It says a company is exempted if it satisfies two or more of three conditions: turnover not more than £36 million, balance sheet total not more than £18 million, employees not more than 250.

Read the two together and the practical test is the one in the hero — exceed two of the three and you are in.

But the exemption framing decides the boundary, and the boundary is where the published summaries diverge from the statute.

If your figures land within a percent or two of a line, this is worth taking advice on rather than taking from a table — including ours.

Read next: how each of the three figures is measured, and then the preceding-year rule, which decides more borderline cases than the figures do.

Large LLPs — the same figures, a differently named document

A UK limited liability partnership meeting the same two-of-three test is in scope on the same figures: £36 million, £18 million, 250.

What changes is where the disclosure goes and who signs it.

Regulation 12B of SI 2008/1911 applies Companies Act sections 415, 415A, 416 and 419 to LLPs with modifications.

It renames the document an energy and carbon report — or a group energy and carbon report — and requires signature by a designated member rather than a director.

The content is the large-unquoted package: UK energy use in kWh, the emissions the unquoted route catches, an intensity ratio, the methodology, the prior-year comparative and a narrative on energy efficiency measures taken in the year.

Large LLPs are common in law, accountancy, financial advisory, asset management and consulting — sectors whose balance sheets are small relative to turnover, which means the turnover and employee conditions usually decide the case rather than the balance sheet one.

The FRC treats the LLP energy and carbon report as reviewable material in the same way as a directors' report — see who actually enforces this.

SECR criteria — put your own figures in

This runs the paragraph 20B logic on your numbers, including the boundary rule and the preceding-year rule that most tables leave out.

Nothing is sent anywhere; it computes in the page.

SECR reporting thresholds, in the order the regulation applies them

The SECR reporting thresholds are not applied all at once. Paragraph 20B works through them in a sequence, and knowing the sequence is what settles a borderline year.

Once scope is settled, the SECR deadline guide sets out when the report is actually due, and the best software for SECR reporting in the UK covers the systems that produce the figures.

Each figure, and how it is actually measured

Turnover — more than £36 million

Turnover on the same basis as the statutory accounts.

Where the financial year is not twelve months, the £36 million is proportionately adjusted — a nine-month period is tested against £27 million, not £36 million.

Balance sheet total — more than £18 million

Balance sheet total means the aggregate of the amounts shown as assets — gross, before liabilities are deducted.

Reading it as net assets is the single most common way a company convinces itself it is out of scope when it is not.

Average number of employees — more than 250

The monthly average across the financial year, on the Companies Act basis: the number of persons employed under contracts of service in each month, totalled and divided by the number of months.

It is a headcount, not a full-time equivalent, which usually pulls part-time-heavy businesses towards scope rather than away from it.

The qualifying rule that carries last year forward

A company that crosses two thresholds for the first time does not automatically start reporting that year.

Paragraph 20B(1)(b) keeps the exemption alive in three separate limbs, and one of them is a straightforward one-year lag: an entity that was exempt last year and met the conditions last year stays exempt this year.

The practical effect is symmetry: a single unusual year moves nothing in either direction.

One case is not lagged at all. In a company's first financial year, paragraph 20B(1)(a) applies the conditions to that year alone — so a newly incorporated company that exceeds two thresholds immediately is reporting immediately.

Medium-sized for your accounts, still reporting under SECR

From financial years beginning on or after 6 April 2025, the Companies (Accounts and Reports) (Amendment and Transitional Provision) Regulations 2024 raised the ordinary Companies Act size tests by roughly half.

"Large" for accounts purposes moved to £54 million turnover and £27 million balance sheet total.

The SECR figures did not move. They are still £36 million and £18 million.

This was deliberate, not an oversight. The Department for Business and Trade said so in terms in its non-financial reporting review: it did not propose to change the SECR threshold before analysing the effect on carbon budgets, and listed it separately for that reason.

The band that matters runs from £36m to £54m of turnover and £18m to £27m of balance sheet total.

An entity in it can be reclassified as medium-sized for its accounts, take the reduced disclosure that comes with that, and still owe a full SECR disclosure in the same directors' report.

This is confirmed in professional commentary as well as in the instrument's own silence — PwC's UK in brief 2025-19 records that the Schedule 7 thresholds were left unchanged.

SECR legislation — which instrument actually says what

Search for SECR legislation and you will get commentary rather than law. Here is the chain, in the order it operates.

Three consequences follow from that structure, and each of them is a place where secondary summaries go wrong.

• Part 7A carries its own figures. There is no cross-reference to section 465 anywhere in it, which is why the 2024 uplift passed it by.
• The enabling chain is section 415, not section 416 alone. Section 415 imposes the duty to prepare a directors' report; section 416(4) is the regulation-making power; section 419 governs approval and signature.
• For LLPs the instrument is different again — regulation 12B of SI 2008/1911, which applies the Companies Act machinery with modifications.

Nothing enacted in 2025 or 2026 has changed the Part 7A figures. The legislation.gov.uk revision note on paragraph 20A still records its last amendment as 1 April 2019.

SECR reporting requirements — the seven things a report has to carry

Once an entity is in scope, the SECR reporting requirements are the same seven items for every route. What differs between the routes is how wide each item reaches.

1. Energy consumption in kWh — the aggregate for the financial year.
2. Scope 1 emissions in tonnes of CO₂ equivalent.
3. Scope 2 emissions in tonnes of CO₂ equivalent.
4. At least one intensity ratio expressing emissions against a quantifiable factor associated with the entity's activities.
5. The methodologies used to calculate items 1 to 3.
6. The prior-year comparative for items 1 to 4 — relieved in the first year the information is given, and only then.
7. A narrative on the principal measures taken in the financial year to increase energy efficiency.

Item 7 is a narrative requirement with no minimum length in the regulation, and it is the one most often reduced to a sentence. It is also the only item that describes what the business actually did.

Item 4 has no prescribed ratio. The regulation asks for "at least one" — see the guidance chapter for what that means in practice and how the arithmetic works.

What must be disclosed, route by route

This is where quoted and unquoted genuinely part company, and the difference is narrower and stranger than "global versus UK".

Quoted companies

Scope 1 covers emissions from the combustion of fuel and the operation of any facility — the full Scope 1 boundary.

Scope 2 covers the purchase of electricity, heat, steam or cooling.

The basis is global, and the report must additionally state what proportion of the energy figure relates to energy consumed in the United Kingdom and the offshore area.

Large unquoted companies and large LLPs

Scope 1 is narrower than most summaries admit: emissions from the combustion of gas, and from the consumption of fuel for the purposes of transport. That is the whole of it.

Scope 2 is narrower still: the purchase of electricity only. Purchased heat, steam and cooling are not caught on this route.

The figures may exclude emissions and energy consumed outside the United Kingdom.

Where an entity is also inside UK SRS S2, the climate disclosures there are prepared on a different basis and do not discharge the SECR items — see the two regimes together.

Groups — aggregation, and the exemption a subsidiary can rely on

A parent company is tested on group figures under paragraph 20C, and the paragraph gives two alternatives for each financial condition.

The gross alternatives are routinely omitted from published summaries, and they are the difference between reporting and not for a group with material intra-group trading.

When a subsidiary can stay out of it

Under paragraph 20A(2), a subsidiary is outside Part 7A only if all of the following hold:

• it is a subsidiary undertaking at the end of the financial year;
• it is included in the parent's group report — not merely owned by the parent;
• that group report is for a period ending at the same time as, or before, the subsidiary's year end;
• the group report complies with the relevant Part without relying on the "seriously prejudicial" let-out.

The last condition is the one that catches people: a parent that withheld its own figures as commercially prejudicial cannot shelter its subsidiaries behind that report.

What the group report has to cover

Paragraph 20E extends the requirements to the parent and its subsidiary undertakings included in the consolidation that are quoted companies, unquoted companies or LLPs.

A quoted subsidiary inside the group must be brought in on the fuller Part 7 basis, not the lighter unquoted one.

Information a subsidiary would not itself have had to report may be excluded.

The Department's own evaluation notes a gap here: there is no requirement to state which subsidiaries are included in a consolidated figure, which makes group disclosures hard to compare year on year.

Low energy users — the 40,000 kWh line

An entity that is in scope but consumed 40,000 kWh of energy or less in the reporting period is relieved of the disclosures — provided it says so.

The relief is not silence. The report must state that the information is not disclosed for that reason.

There is a distinction here that almost every published summary flattens, and it runs the wrong way for the larger population.

What the relief covers, on either route: the emissions figures, the aggregate kWh, the energy efficiency narrative, the methodology statement and the intensity ratio.

What it does not cover: the obligation to have measured the energy in the first place. You cannot state that you are under 40,000 kWh without knowing that you are.

A second, quite separate relief sits alongside it in the same sub-paragraphs: disclosure may be withheld where the directors consider it would be seriously prejudicial to the interests of the entity, again with a statement to that effect. As chapter 13 explains, relying on that one has consequences for subsidiaries.

More on the other routes out: the SECR exemptions guide.

SECR exemptions and exclusions, ranked by how often they apply

There is no single exemptions provision. There are five distinct routes out, and they do quite different things.

Two categories that are commonly described as exempt are better described as out of scope from the start: entities that are not UK companies or LLPs at all, and entities whose legal form falls outside the Companies Act machinery.

Charities, academy trusts, NHS trusts and university-owned companies each need checking against their own legal form rather than assumed out — the Department has published separate SECR guidance for academy trusts precisely because the answer is not obvious.

Where the disclosure sits in the annual report

For companies: inside the directors' report.

Not the strategic report, and not a standalone sustainability report — although nothing prevents the same figures also appearing there.

The chain is section 415 (the duty to prepare it), section 416(4) (the power to prescribe contents), Schedule 7 to SI 2008/410 (the contents themselves) and section 419 (approval and signature).

For LLPs: an energy and carbon report, signed by a designated member.

The statutory auditor's role is the ordinary one for a directors' report — confirming consistency with the financial statements, not auditing the emissions figures. SECR requires no third-party assurance of the numbers themselves.

Timing follows the accounts, not a separate SECR calendar — see the SECR deadline.

Who enforces this, and what actually happens

Stated plainly, because the published commentary is unreliable here: SECR has no penalty regime of its own.

There is no SECR regulator, no civil penalty schedule and no fine calculated by reference to the scheme. There is nothing equivalent to the Environment Agency's civil sanctions under ESOS.

What exists is the ordinary Companies Act machinery, and it points at directors personally rather than at the company.

The authorised person is the Financial Reporting Council, under SI 2021/465.

In practice the FRC's Corporate Reporting Review team is what an entity actually encounters, and its remit expressly includes the strategic report, the directors' report and — for LLPs — the energy and carbon report.

The realistic consequence of a defective SECR disclosure is correspondence and a corrected disclosure in the following year, not a prosecution.

SECR guidelines — one document, unrevised since 2019

The official SECR guidelines are chapter 2 of the Department's Environmental Reporting Guidelines — a 152-page PDF whose SECR content is roughly one chapter, last updated 29 March 2019.

It has therefore never addressed the 2025 divergence in chapter 09, because it predates it by six years.

That is not a criticism of the document. It is the reason a reader needs something current alongside it.

Two things have moved since, and both are recent enough to matter.

The intensity ratio, worked

The regulation asks for "at least one ratio which expresses the entity's annual emissions in relation to a quantifiable factor associated with its activities". It prescribes nothing further.

So the arithmetic is trivial and the judgement is not: the denominator has to be something the business would recognise as a measure of its own activity.

Whichever denominator you choose, the same one has to appear next year, or the comparative stops meaning anything.

SECR and ESOS — two schemes, two tests, one energy dataset

They are frequently discussed together and they qualify entirely differently.

The practical consequences of that difference:

• A company with 300 employees and £20m turnover qualifies for ESOS on the employee test alone, and fails the SECR two-of-three test on one condition.
• A company with £40m turnover and £20m balance sheet, 80 employees exceeds two SECR conditions and is in SECR — and fails ESOS, because the ESOS financial route needs both of its higher figures.
• Plenty of entities are in both, and a few are in neither despite feeling large.

Where both apply, the energy data collection is the same exercise done once. ESOS audit output is a legitimate source for the SECR energy figure, provided the reporting periods are reconciled.

Full comparison: ESOS and SECR side by side. ESOS Phase 4 qualification: ESOS Phase 4 thresholds.

SECR and UK SRS — continuing alongside, not replaced

The UK Sustainability Reporting Standards were published on 25 February 2026.

Nothing in them replaces or overrides SECR, and the published standards do not say that they do.

An entity inside both prepares both. The SECR figures are an input to the S2 climate disclosures; they are not a substitute for them, and the boundaries are drawn differently.

For private companies the position is still open — the extension of UK SRS beyond listed companies is a matter for consultation rather than a settled rule, and it is the thing to watch on this page.

More: SECR and UK SRS · UK SRS for private companies · UK SRS reporting guidance.

If you are in scope, this is the sequence

Not a score, and not a maturity model — SECR defines neither. An order, and the reason each step comes where it does.

Three figures. Two of them. One year, and the year before it.

What to check before this year's directors' report