SECR deadline

A private company has nine months from the end of its financial year to file its accounts and reports at Companies House, and its SECR disclosures go with them.

A public company has six months.

The private and public distinction is the one in section 4: a public company is registered as one; any other limited company is private.

It is not the quoted and unquoted distinction that decides SECR scope under section 385, so an unquoted public company still has six months.

An LLP files its energy and carbon report with its accounts within nine months under the modified section 442.

The period is not discretionary, and a date that falls on a weekend or bank holiday stays where it is.

Section 442 sets the period allowed for delivering accounts and reports, and it is the whole of the SECR timing rule.

Section 443 fixes the arithmetic: the period ends on the corresponding date in the appropriate month, unless the year ended on the last day of a month.

A year ending on the last day of a month gives a deadline on the last day of the appropriate month, whether or not the dates correspond.

So a private company with a 30 April year end files by 31 January, not 30 January.

A 4 April year end gives a private company 4 January.

An extension on application is possible, but it cannot take the deadline beyond twelve months after the end of the period.

Most SECR reporters are private: large unquoted companies and LLPs caught by the two-of-three size test.

For them the SECR disclosures file with the accounts within nine months of the year end.

For an LLP the document is the energy and carbon report required by regulation 12B, approved by the members and signed by a designated member.

The designated members must deliver it to the registrar with the accounts, unless the LLP is under the thresholds and has no duty to prepare it.

The nine months have to hold the year-end close, the conversion, the audit of the accounts, drafting and board approval.

A newly incorporated company whose first accounting period runs longer than twelve months gets a longer first deadline.

It is nine months (private) or six months (public) from the first anniversary of incorporation, or three months after the end of the period, whichever is later (s.442(3)).

SECR content is required from the first financial year in which the company is in scope; there is no first-year exemption.

A new company over two thresholds in its first year reports in its first directors’ report, because the first year is judged on that year alone.

What the first year does relieve is the comparative: there is no previous year to show.

A parent includes group SECR figures in its group directors’ report and files it on the parent’s own deadline.

A subsidiary is outside the SECR duty only if it is included in a compliant group report for a year ending at the same time as, or before, its own (Sch 7 ¶20A(2)).

That shelter changes where the SECR content appears, not when the subsidiary’s accounts are due.

The shelter fails if the parent withheld figures as seriously prejudicial, and the subsidiary must then report itself on its own deadline.

The routes out, and the statement each needs, are on SECR exemptions.

DESNZ publishes the government conversion factors each year; the 2026 set was published on 11 June 2026 and last updated on 31 July 2026.

The rule is to match the factor year to the activity-data year, not to the publication or filing year.

A company reporting calendar 2026 in 2027 therefore uses the 2026 factors, published half-way through the year they describe.

The publication date is sometimes read as a filing trigger; it is not, and the report is due on the Companies Act date whatever the factor calendar.

The methodology statement should name the factor set and its year; “government factors” without a year is not a methodology.

Scope 1 and 2 boundaries are the GHG Protocol’s constructs, explained on our GHG Protocol page and at ghgprotocol.org.