SECR deadline — when must you file?

The short answer — 9 months or 6 months

The SECR filing deadline depends on entity type. Private companies and LLPs must file 9 months after their financial year-end. Public companies (PLCs) must file 6 months after their financial year-end. The rule comes from Companies Act 2006 section 4421, which governs filing of the annual report and accounts with Companies House — the document containing SECR disclosure.

The distinction between private and public company status is set by Companies Act 2006 section 410. A company is public if its certificate of incorporation states that it is a public company and the requirements of section 4 are met. Any other company (other than an unlimited company) is private. LLPs are governed by separate but parallel filing rules under the Limited Liability Partnerships Act 2000 and associated regulations, with the same 9-month filing window applied via the LLP equivalent provisions.

No separate SECR deadline

SECR does not have its own statutory deadline. The SECR Regulations 20184 (SI 2018/1155) inserted energy and carbon disclosure requirements into the Directors' Report (for companies, under Companies Act 2006 sections 416-4195) and the LLP Energy and Carbon Report. Both documents form part of the annual report and accounts.

Practical consequences:

• SECR content is filed at the same time as the rest of the annual report and accounts — no separate SECR submission process
• The filing deadline is set by Companies Act 2006 section 442 [1] for the entire filing, not by SECR-specific rules
• Companies cannot file annual accounts and submit SECR content separately at a later date
• If the annual report is filed late, the SECR content is also late — civil penalties under section 453 [3] apply to the entire filing
• Companies House publishes the entire annual report (including SECR content) on its public register

The DBT Environmental Reporting Guidelines7 set out methodology expectations for SECR content preparation, but the timing question is governed entirely by Companies Act 2006 filing provisions1.

Companies Act 2006 section 442

Section 442 of the Companies Act 20061 sets the filing period for annual accounts and reports. The basic structure:

• Private companies — 9 months after the end of the relevant accounting reference period [1]
• Public companies — 6 months after the end of the relevant accounting reference period [1]
• LLPs — 9 months under the parallel LLP filing framework, mirroring the private company rule

The "accounting reference period" is typically the company's financial year. A company with a financial year ending 31 December 2025 has an accounting reference period ending 31 December 2025; the filing deadline for a private company is 9 months after that date — i.e., 30 September 2026.

Section 442 also addresses1:

• First accounting period — the filing deadline is the later of (a) 21 months after incorporation for private companies / 18 months for PLCs, or (b) 3 months after the end of the accounting reference period
• Changes to accounting reference period — affect the deadline calculation; specifically, where a financial year is extended, the filing deadline may be 3 months after the extended period ends, if later than the standard 9/6 months
• Treatment where the calculated deadline falls on a non-business day — the deadline does not automatically extend to the next business day under section 442; entities should file in advance to avoid timing risk

Private companies and LLPs — 9 months

For private companies (Companies Act 2006 section 410) and LLPs, the filing deadline is 9 months after the financial year-end1. This covers the vast majority of UK SECR-reporting entities — large unquoted companies (in scope of SECR4 via the two-of-three test) and large LLPs are typically private entities.

Common financial year-end deadlines for private companies and LLPs:

• 31 December → file by 30 September the following year
• 31 March → file by 31 December the following calendar year
• 30 June → file by 31 March the following calendar year
• 30 September → file by 30 June the following calendar year

The 9-month window provides time for year-end accounting, audit, Directors' Report preparation including SECR content, board approval, and electronic filing with Companies House. The DBT Environmental Reporting Guidelines7 recommend starting SECR data collection at least 3 months before the filing deadline to allow for data validation and methodology documentation.

Public companies (PLCs) — 6 months

For public companies as defined in Companies Act 2006 section 410, the filing deadline is 6 months after the financial year-end1. PLCs include all UK Main Market listed companies and many AIM-listed companies (though AIM admission alone does not change PLC status — what matters is the original company designation).

Common financial year-end deadlines for PLCs:

• 31 December → file by 30 June the following year
• 31 March → file by 30 September the same year
• 30 June → file by 31 December the same year
• 30 September → file by 31 March the following year

The compressed 6-month window reflects the greater public interest in PLC financial information and is consistent with FCA Listing Rules requirements for listed entities. For UK Main Market listed PLCs, the FCA also requires publication of the annual report within 4 months of financial year-end under DTR 4.1, which is tighter than the Companies Act filing deadline.

PLCs in scope of FCA CP26/5 from 1 January 2027 will need to also file UK SRS S2 content within the NFSIS in the Strategic Report — produced and filed alongside the rest of the annual report, within the same 6-month statutory window1.

First accounting period

Newly incorporated companies have a longer first-period filing window1:

• Private company — later of (a) 21 months after incorporation, or (b) 3 months after the end of the first accounting reference period
• Public company — later of (a) 18 months after incorporation, or (b) 3 months after the end of the first accounting reference period

This addresses the practical issue that new companies often have a longer-than-12-month first financial period. A company incorporated in January 2025 with a December 2025 financial year-end (an 11-month first period) would have its standard filing deadline by 30 September 2026. A company incorporated in January 2025 with a December 2026 financial year-end (a 23-month first period) would have its filing deadline 21 months after January 2025 — October 2026.

SECR content is required from the first financial year ending after 1 April 20194. New companies meeting SECR thresholds in their first period must include SECR content from the first Directors' Report or Energy and Carbon Report.

Shortened or extended financial periods

Companies may change their accounting reference date, shortening or extending the financial period. The filing deadline adjusts1:

Shortened period

Where a financial year is shortened (e.g. ending earlier than originally registered), the filing deadline is the later of (a) 9 months for private / 6 months for PLC after the new shorter period ends, or (b) 3 months after the date of the change notification to Companies House. This prevents companies from manipulating filing deadlines by repeatedly shortening their financial year.

Extended period

Where a financial year is extended (e.g. ending later than originally registered), the filing deadline is the later of (a) 9 months for private / 6 months for PLC after the new longer period ends, or (b) 3 months after the date of the change notification. Companies may extend their financial year by up to 6 months but may not do so more than once every 5 years (except in specific circumstances).

SECR content covers the actual financial period — a 14-month financial year produces 14 months of SECR data; a 9-month financial year produces 9 months. The intensity ratio calculation should reflect the actual period for comparability. GHG Protocol guidance recommends normalizing annual metrics where reporting periods are non-standard.

Group consolidation timing

For groups with multiple UK entities, SECR consolidation timing follows the parent company's filing deadline:

• Parent company files its consolidated annual report including consolidated SECR content within 9 months (private parent) or 6 months (public parent) of group year-end [1]
• Subsidiary companies meeting SECR thresholds in their own right may be exempt from separate SECR disclosure if the parent's consolidated report covers them [4]
• Subsidiary companies file their own annual accounts within their own filing deadline (based on their own entity type), even where SECR exemption applies
• Cross-border groups need to coordinate UK subsidiary filing with parent jurisdiction reporting cycles — UK filing deadlines are not affected by overseas parent reporting timetable

The DBT Environmental Reporting Guidelines7 recommend that groups document the entity-level vs group-level disclosure approach in their methodology note, including how subsidiary exemption is applied and which entities are included in consolidated SECR figures.

Civil penalties for late filing

Companies House applies automatic civil penalties under Companies Act 2006 section 4533 for late filing of annual accounts and reports. SECR content forms part of the late filing; penalties apply to the entire annual filing rather than to the SECR content specifically.

Penalty scale (current)6

• Up to 1 month late — Private company / LLP: £150; PLC: £750
• 1 to 3 months late — Private company / LLP: £375; PLC: £1,500
• 3 to 6 months late — Private company / LLP: £750; PLC: £3,000
• Over 6 months late — Private company / LLP: £1,500; PLC: £7,500

Penalties are doubled where a company files late in two consecutive financial years6. A PLC that files 3-6 months late in two consecutive years would face a penalty of £6,000 in the second year (£3,000 × 2). The doubling provision incentivises companies to file on time even after a first late filing.

Beyond civil penalties, Companies Act 2006 section 4512 creates a criminal offence for directors who fail to take all reasonable steps to secure timely filing — applying to both ongoing failures and to specific late filings. Director disqualification under the Company Directors Disqualification Act 1986 is possible in cases of persistent default. Directors should treat the filing deadline as a personal compliance obligation.

Annual June emission factor refresh

DESNZ / DEFRA publish updated GHG Conversion Factors each June8. The factors translate energy consumption (in kWh, litres, etc.) into greenhouse gas emissions (in tonnes CO₂e). Choice of factor year affects calculated emissions and intensity ratios.

Practical guidance:

• For the SECR reporting period beginning in 2025, most companies use the June 2025 conversion factors [8]
• For the SECR reporting period beginning in 2026, most companies use the June 2026 conversion factors
• Methodology notes should disclose the factor year used [7]
• Companies with March year-ends may need to consider whether to use prior or current year factors; consistency within a reporting period is more important than choice of factor year
• Year-on-year factor changes are typically minor (1-3%) but cumulative effect over multiple years can be meaningful for trend analysis

The factor publication schedule does not affect the SECR filing deadline1 — companies file when their statutory deadline arrives, using whichever factor year their methodology specifies. Companies sometimes interpret the June refresh as a filing trigger; it is not.

SECR deadline vs ESOS deadline

SECR4 and ESOS are two separate regimes with different deadlines:

• SECR — annual; filing deadline tied to Companies Act 2006 s.442 [1] (9 months private / 6 months PLC); filed with Companies House as part of annual report
• ESOS — four-yearly cycle; Phase 4 qualification 31 December 2026 and compliance deadline 6 December 2027; notification submitted to Environment Agency separately from Companies House filing

An entity in scope of both regimes faces both deadlines. The annual SECR filing recurs every year (with its 9 or 6 month deadline); the ESOS Phase 4 deadline is a fixed point (6 December 2027) regardless of the entity's financial year-end. ESOS Phase 5 will begin a new cycle thereafter.

The deadlines are not coordinated. ESOS work cannot substitute for SECR disclosure; ESOS audit findings may inform SECR energy efficiency narrative but do not satisfy the SECR filing obligation.

SECR deadline vs UK SRS deadline

Both SECR4 and UK SRS S2 are annual disclosure regimes filed with the annual report. Both deadlines align — they are governed by the same Companies Act 2006 section 4421 filing window because both sit within the annual report and accounts.

For a PLC with a 31 December year-end in scope of FCA CP26/5 from 1 January 2027:

• Financial year-end: 31 December 2027
• SECR content prepared and filed in the Directors' Report [5] within 6 months — by 30 June 2028
• UK SRS S2 content prepared and filed in the NFSIS within the Strategic Report — same deadline, 30 June 2028 [1]
• Both filed as part of the same annual report submission to Companies House

The aligned deadline means UK SRS S2 implementation cannot rely on a delayed reporting relief — UK SRS S2 [where the IFRS S2 first-year delayed reporting relief was removed in the UK amendments] must be published with the financial statements. SECR content has always been published with financial statements under section 4421, so the practical effect for SECR is unchanged. For UK SRS S2 first-time reporters, the alignment is a hard constraint requiring full preparation within the standard reporting cycle.

Frequently asked questions