SECR compliance: step-by-step obligations guide

SECR reporting requirements — what must be disclosed

The SECR reporting requirements are set by SI 2018/1155, effective for financial years beginning on or after 1 April 2019. Large unquoted companies and LLPs disclose UK energy and emissions; quoted companies disclose on a global Scope 1 and 2 basis.

Six disclosure elements make up the core SECR requirements under SI 2018/1155:

• Annual energy consumption in kWh — UK electricity, gas and transport fuel for unquoted companies and LLPs; global energy for quoted companies
• Scope 1 and Scope 2 greenhouse gas emissions — UK-based for unquoted entities and LLPs, global for quoted companies
• At least one intensity ratio — for example tCO₂e per £m turnover, per employee, or per m²
• The methodology used — the DBT Environmental Reporting Guidelines point to the GHG Protocol Corporate Standard as the typical reference
• Prior-year comparatives for energy, emissions and intensity figures (from the second reporting year onwards)
• An energy-efficiency narrative — the principal actions taken in the year, or an explicit statement that none were taken

The disclosure sits in the Directors’ Report for companies and the Energy and Carbon Report for LLPs, filed with the annual accounts at Companies House — methodology detail is in the DBT Environmental Reporting Guidelines.

Who is caught is a separate question — the SECR thresholds guide covers the £36m / £18m / 250-employee two-of-three test, and the SECR exemptions guide covers the 40,000 kWh low energy user relief and the other statutory reliefs.

SECR compliance for group companies and subsidiaries

Group structures raise their own SECR compliance questions that a single-entity read of the two-of-three test doesn’t answer. Companies Act 2006 section 466 lets the test be applied on a net or a gross basis: net thresholds are the familiar £36m turnover, £18m balance sheet and 250 employees; gross thresholds are £43.2m turnover and £21.6m balance sheet, with the 250-employee test unchanged. A group is “large” — and therefore in SECR scope — if it exceeds at least two of the three thresholds under either the net or the gross measure.

Qualification also doesn’t reset every year. Companies Act 2006 section 467

keeps a company or group in its existing size category unless the qualifying conditions fail for two consecutive financial years — so a subsidiary that dips below the thresholds for a single year stays in SECR scope, and one that grows into scope needs two consecutive qualifying years before reporting becomes mandatory.

Where a subsidiary genuinely cannot obtain energy data from an overseas parent or fellow group company, SI 2018/1155 allows the practicality exemption — the Directors’ Report must state what has been omitted and the steps taken to obtain it — alongside the separate “seriously prejudicial” exemption directors can invoke for genuinely commercially sensitive data.

Both routes require an explicit statement in the disclosure rather than silent omission; the SECR exemptions guide covers the full set of reliefs, including the low energy user exemption above.

Where to find official SECR guidance

Official SECR guidance sits in three places. The legal requirements themselves are set out in SI 2018/1155; the methodology — including the GHG Protocol reference basis — is set out in the DBT Environmental Reporting Guidelines, first published March 2019 and updated periodically; and the emission factors used to convert energy data into Scope 1 and 2 figures come from the DESNZ GHG Conversion Factors, republished each June.

Disclosure quality is monitored centrally as well as set by statute.

The FRC’s 2025 thematic review of climate-related financial disclosures examined SECR reporting by AIM-listed and large private companies alongside wider Strategic Report content, and its Annual Review of Corporate Reporting is the best single source for how the regulator is currently reading the SECR disclosure requirements in practice.

For the qualification mechanics in full and the filing deadline itself, see the SECR thresholds guide and the SECR deadline guide — this page focuses on the compliance process once you already know you’re in scope.