SECR · the edges of the duty
SECR exemptions
There are two exemptions from SECR — being within the size limits, and being sheltered by a compliant group report (¶20B, ¶20A(2)).
Everything else is a relief from disclosure, and each relief works only if the report says it is being used (¶20D(6)–(7)).
Silence is not an exemption.
The short answer
No blanket exemption, and no silent one
Module 01 / 04
Reliefs
Module 02 / 04
Reliefs · 2
Module 03 / 04
Oversight
Module 04 / 04
Key point 04
Out of scope: the duty never arose.
No statement.
Exempt: a sheltered subsidiary.
No statement of its own.
Relieved: in scope, figures withheld.
A statement is the condition.
Read the detailed guidance and evidence
SECR has no general exemption and no single exemptions paragraph.
What it has is a size test that exempts most companies, a shelter for subsidiaries, and three reliefs from disclosure written into the duty itself (Sch 7 Part 7A).
The difference between those three things decides whether the directors’ report has to say anything.
An unquoted company or LLP that stays within two of the three size limits is simply out of scope and makes no statement.
An in-scope company that withholds figures under a relief must say so, and the statement is what makes the relief work.
Scope itself is tested on SECR reporting thresholds; this page is about the edges of it.
At a glance
The routes out, side by side
Four reliefs and the size exemption.
The right-hand column is the one most often missed.
Module 01 / 04
Within the size limits
Module 02 / 04
Group shelter
Module 03 / 04
40,000 kWh or less
Module 04 / 04
Seriously prejudicial
Read the detailed guidance and evidence
| Route | Who can use it | What it removes | What must still be stated | Provision |
|---|---|---|---|---|
| Within the size limits | Unquoted companies and LLPs within two of the three limits, year on year | The whole duty | Nothing | ¶20B; reg 12B |
| Group shelter | A subsidiary in a compliant group report | Its own SECR disclosure | Nothing of its own | ¶20A(2); ¶15(1A) |
| 40,000 kWh or less | Any in-scope entity under the line | The figures, ratio, methodology and efficiency narrative | That the information is not disclosed for that reason | ¶20D(7)(a); ¶15(5)(a) |
| Seriously prejudicial | Any in-scope entity, on the directors’ opinion | The information whose disclosure would be seriously prejudicial | That the information is not disclosed for that reason | ¶20D(7)(b); ¶15(5)(b) |
| Not practical to obtain | Any in-scope entity missing some data | Only what cannot practically be obtained | What is not included, and why | ¶20D(6); ¶15(4) |
All four reliefs presuppose that the entity is in scope: a quoted company under section 385, or an unquoted company or LLP over two of the limits.
Whether SECR applies at all is answered on is SECR mandatory?
Relief one
The 40,000 kWh low energy relief
Module 01 / 04
Reporting period
Module 02 / 04
Disclosure
Module 03 / 04
Reliefs
Module 04 / 04
Disclosure · 2
¶20D(7)(a), verbatim
“Nothing in sub-paragraphs (1) to (4) and paragraphs 20F and 20G requires the disclosure of information if— (a) the company consumed 40,000 kWh of energy or less in the United Kingdom during the period in respect of which the directors’ report is prepared, and the report states that the information is not disclosed for that reason”
Source: SI 2008/410 Sch 7 ¶20D(7)(a).
The quoted-company version, ¶15(5)(a), omits “in the United Kingdom”.
Read the detailed guidance and evidence
An in-scope company that consumed 40,000 kWh of energy or less in the period need not give its energy and carbon figures.
The condition is written into the same sentence: the report must state that the information is not disclosed for that reason.
For unquoted companies and LLPs the energy is counted “in the United Kingdom”; the quoted-company relief in ¶15(5)(a) has no territorial limit, so it runs on worldwide use.
The test counts all forms of energy consumed — the Schedule defines energy as all energy products (¶20, via ¶20K) — not only the gas, fuel and electricity an unquoted company must report.
Knowing you are under the line means having measured, so the relief does not remove the need for basic energy data.
The report is filed publicly, so the claim is visible to anyone who reads the accounts, and keeping the workings is sensible.
The Environmental Reporting Guidelines describe the test as “40MWh or less in the UK, including offshore area”; the number is the same, but quote the Schedule for the wording.
Relief two
The seriously prejudicial relief
Module 01 / 04
Oversight
Module 02 / 04
Reliefs
Module 03 / 04
Oversight · 2
Module 04 / 04
Oversight · 3
A group report that relies on this relief does not shelter the parent’s subsidiaries.
Each subsidiary that is itself in scope must then report on its own account.
Read the detailed guidance and evidence
The directors may withhold the energy and carbon information if, in their opinion, disclosing it would be seriously prejudicial to the interests of the company (¶20D(7)(b)).
As with the low energy relief, the report must state that the information is not disclosed for that reason.
The judgement is the directors’, and it is theirs to defend: they approve the directors’ report as a whole under section 419.
A record of the specific prejudice identified, and of the board’s reasoning at approval, is the obvious protection.
The consequence most people miss is in ¶20A(2): a subsidiary is sheltered only by a group report that complies “other than in reliance on paragraph 20D(7)(b)”.
The FRC’s Corporate Reporting Review reviews directors’ reports, and a relief that is claimed on the face of the report is part of what it reads.
Relief three
The not practical to obtain qualification
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Disclosure
Module 02 / 04
Disclosure · 2
Module 03 / 04
Disclosure · 3
Module 04 / 04
Key point 04
¶20D(6), verbatim
“Sub-paragraphs (1) to (4) and paragraphs 20F and 20G apply only to the extent that it is practical for the company to obtain the information in question; but where it is not practical for the company to obtain some or all of that information, the report must state what information is not included and why.”
Source: Sch 7 ¶20D(6); quoted companies, ¶15(4).
Read the detailed guidance and evidence
This is a qualification on the duty, not a way out of it: the company discloses everything it practically can, and names what it cannot.
The report must state what information is missing and why.
Illustrative cases are a mid-year acquisition with no energy records, a site where the landlord holds the meter data, or missing fuel records in a first reporting year.
What counted as not practical in year one is harder to argue in year three, because by then the company has had time to put measurement in place.
Groups
The group shelter, and its four conditions
Module 01 / 04
A subsidiary undertaking at the end of the f
Module 02 / 04
Included in the group report of a parent und
Module 03 / 04
The group report is for a year ending at the
Module 04 / 04
The group report complies without relying on
| Condition in ¶20A(2) | What fails it |
|---|---|
| A subsidiary undertaking at the end of the financial year | Sold, or acquired after the year end |
| Included in the group report of a parent undertaking | Owned but left out of the consolidated figures |
| The group report is for a year ending at the same time or earlier | A parent year end after the subsidiary’s |
| The group report complies without relying on ¶20D(7)(b) | A parent that withheld figures as seriously prejudicial |
Read the detailed guidance and evidence
A subsidiary that is in scope in its own right is outside Part 7A only if all four conditions in paragraph 20A(2) hold.
Ownership is not inclusion: the subsidiary must actually be in the parent’s group report.
In practice most UK groups disclose once, at parent level, covering the group members.
The parent itself is tested on group figures, net or gross, under paragraph 20C, and a group report brings in quoted subsidiaries on the fuller Part 7 basis (¶20E).
The shelter moves where the SECR content appears, not when accounts are due: each subsidiary still files its own accounts on its own section 442 deadline.
The filing mechanics are on the SECR deadline page.
Geography
UK energy only: a boundary, not an exemption
Module 01 / 04
Reporting boundary
Module 02 / 04
40,000 kWh line
Module 03 / 04
Exclusions
Module 04 / 04
Key point 02
| Unquoted company or LLP | Quoted company | |
|---|---|---|
| Reporting boundary | May exclude energy and emissions outside the UK — ¶20D(5) | No territorial limit; UK and offshore share stated — ¶15(3B)–(3C) |
| 40,000 kWh line | Counted in the UK — ¶20D(7)(a) | Counted worldwide — ¶15(5)(a) |
Read the detailed guidance and evidence
Unquoted companies and LLPs may exclude energy and emissions outside the United Kingdom from their figures (¶20D(5)).
That word is “may”: UK-only is an option for them, not an instruction.
Quoted companies have no such option and report without a territorial limit, stating what proportion relates to the UK and offshore area.
The UK boundary acts as a structural relief for unquoted groups with large operations abroad.
It also means an unquoted company can be under 40,000 kWh in the UK and use the low energy relief while its worldwide use is far larger.
An AIM company is unquoted for this purpose, so it has the UK boundary and the UK-measured line; the route by route package is on SECR reporting thresholds.
The misreadings
What “exempt” does not mean
Module 01 / 04
Reliefs
Module 02 / 04
Key point 02
Module 03 / 04
Oversight
Module 04 / 04
Oversight · 2
“Low energy users are exempt from SECR.”
They are in scope and relieved on a statement.
“Our parent owns us, so we are exempt.”
Only inclusion in a compliant group report shelters.
“We are medium-sized now.”
SECR does not use the accounts size test.
“We report under UK SRS instead.”
UK SRS does not replace SECR.
Read the detailed guidance and evidence
None of the reliefs permits silence.
The low energy, seriously prejudicial and not-practical routes each require a statement identifying what is omitted and on what basis.
The directors’ report is filed publicly at Companies House, so an omission with no statement is visible to anyone who checks.
An unsupported relief claim is a directors’ report compliance problem, not merely an environmental one, because the directors approve the report under section 419.
The consequences of getting it wrong are set out on is SECR mandatory?
Out of scope
Who is simply out of scope
Module 01 / 04
Unquoted company within two of £36m, £18m, 2
Module 02 / 04
LLP within the same limits
Module 03 / 04
Quoted company, any size
Module 04 / 04
Charitable company or academy trust
| Entity | Position |
|---|---|
| Unquoted company within two of £36m, £18m, 250 | Out of scope, year on year |
| LLP within the same limits | Out of scope (reg 12B) |
| Quoted company, any size | Never out on size |
| Charitable company or academy trust | Tested like any other company |
| A body that is neither a company nor an LLP | Outside the machinery |
Read the detailed guidance and evidence
Out of scope is not the same as exempt: an entity outside SECR has no SECR obligation and makes no statement.
For an unquoted company or LLP that means staying within two of the three limits in paragraph 20B, or the LLP twin in regulation 12B, on the year-on-year rule.
A quoted company cannot be out of scope on size: section 385 and paragraph 15(1) put every one in.
Only companies and LLPs appear in the text, so there is no separate charity, academy or public-body category either way.
A charitable company or an academy trust is tested like any other unquoted company, which is why the Department for Education publishes SECR guidance for academy trusts.
An entity under the thresholds may still report voluntarily in the SECR format, and the guidelines’ methodology applies equally to it.
The same kind of scope question for the UK standards is answered on UK SRS thresholds.
2025
Becoming medium-sized is not a SECR exit
Module 01 / 04
SECR, Sch 7 ¶20B
Module 02 / 04
Accounts, from April 2025
Module 03 / 04
Key point 01
Module 04 / 04
Key point 02
| Test | Turnover | Balance sheet | Employees |
|---|---|---|---|
| SECR, Sch 7 ¶20B | £36m | £18m | 250 |
| Accounts, from April 2025 | £54m | £27m | 250 |
Read the detailed guidance and evidence
SI 2024/1303 raised the Companies Act medium-sized limits to £54 million turnover and £27 million balance sheet for financial years beginning on or after 6 April 2025.
SECR’s figures in paragraph 20B did not move, because Part 7A carries its own table and was not touched.
A company reclassified as medium-sized for its accounts has not thereby left SECR.
Companies with turnover between £36 million and £54 million, or a balance sheet between £18 million and £27 million, are the ones at risk of dropping the disclosure by accident.
Commentary noted the point when the uplift landed, for example PwC’s UK in brief; the full analysis is on SECR reporting thresholds.
UK SRS
No exemption via UK SRS
Module 01 / 04
Reliefs
Module 02 / 04
Listed categories
Module 03 / 04
Proposal
Module 04 / 04
Key point 04
SECR: the directors’ report, every year, for companies in scope.
UK SRS under PS26/19: the annual financial report, comply or explain, for listed companies in UKLR 6, 14, 15, 16 and 22.
Read the detailed guidance and evidence
Preparing for or reporting against UK SRS does not exempt anyone from SECR; UK SRS S1 and S2, published on 25 February 2026, do not repeal it.
Under the FCA’s final rules of 30 September 2026, listed companies in scope report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
The consultation, CP26/5, had proposed making UK SRS S2 mandatory; the final rules did not, and none of it touches SECR.
Companies in both regimes comply with both — see SECR and UK SRS, and ESOS vs SECR for the other energy regime with its own thresholds.
The SECR regulations themselves are SI 2018/1155, operating through Part 15, Chapter 5 of the Companies Act and, for LLPs, the LLP regulations.
Frequently asked
SECR exemptions: the questions people ask
What are the exemptions from SECR?
There is no blanket exemption.
An unquoted company or LLP within two of the three size limits is exempt from the duty altogether.
A subsidiary included in a compliant group report is outside it.
An entity that is in scope can also rely on three reliefs from disclosure: the 40,000 kWh low energy relief, the seriously prejudicial relief and the practicality qualification. Each of those three needs a statement in the report.
What is the SECR low energy user exemption?
It is a relief from disclosure, not an exemption from SECR.
An in-scope company that consumed 40,000 kWh of energy or less in the period need not give the energy and carbon figures if the report states that the information is not disclosed for that reason.
For unquoted companies and LLPs the consumption is measured in the United Kingdom; for quoted companies it has no UK qualifier.
Does a low energy user still have to say anything?
Yes.
The relief only applies if the report states that the information is not disclosed because of it.
A report that simply omits the figures does not use the relief; it fails to comply.
Are subsidiaries exempt from SECR?
A subsidiary is outside the SECR duty only if all four conditions in Schedule 7 paragraph 20A(2) hold: it is a subsidiary at the year end, it is included in its parent’s group report, that report is for a year ending at the same time or earlier, and the report complies without relying on the seriously prejudicial relief.
Ownership alone is not enough.
What does "seriously prejudicial" mean under SECR?
The directors may withhold the energy and carbon information if, in their opinion, disclosing it would be seriously prejudicial to the interests of the company, and the report says that is why.
Using it has a cost: a group report that relies on it cannot shelter the parent’s subsidiaries, so each must report itself.
Is my company exempt from SECR now it is medium-sized?
Not on that ground.
The April 2025 uplift moved the Companies Act medium-sized limits to £54 million turnover and £27 million balance sheet, but SECR keeps its own figures of £36 million, £18 million and 250 in Schedule 7 paragraph 20B.
A company can be medium-sized for its accounts and still in SECR.
Who is completely out of SECR?
An unquoted company or LLP that stays within two of the three size limits, applied year on year, is out of scope and makes no statement.
A body that is neither a company nor an LLP is outside the machinery altogether.
A quoted company is never out of scope on size.
Is there an exemption from the SECR filing deadline?
No, because SECR has no deadline of its own.
Any relief statement sits in the directors’ report or LLP energy and carbon report and is filed with the accounts on the Companies Act 2006 section 442 deadline.
Does reporting under UK SRS exempt a company from SECR?
No. UK SRS S1 and S2 do not replace SECR, and listed companies reporting against UK SRS under the FCA’s final rules on a comply-or-explain basis still prepare their SECR disclosures in the directors’ report.
Prepare the evidence
SECR exemptions: from a requirement to a reporting pack
Use this preparation sequence alongside the detailed requirements on this page.
An editorial workflow, not a statutory schedule.
- Stage 0101
Scope decision
Record the quoted status, size conditions, group position and applicable exemptions.
- Stage 0202
Activity record
Collect the energy and fuel records needed for the applicable disclosure route.
- Stage 0303
Emissions methods
Keep the factor versions, boundaries and calculation methods with the activity data.
- Stage 0404
Reporting comparison
Prepare the applicable intensity ratio and comparative information.
- Stage 0505
Efficiency narrative
Describe the energy efficiency measures actually taken.
- Stage 0606
Publication record
Check the disclosure location and the accounts approval timetable.
Read the applicable instrument: SI 2008/410 Schedule 7, paragraph 20B — the size exemption
A practical brief
An evidence pack, with a clear review trail
Ask for a pack that lets the next reviewer retrace the scope decision, follow the evidence and understand the limitations.
This describes a useful handover; it does not certify compliance or establish that a vendor or adviser delivers it.
Module 01 / 04
Applicability record
Write down the entity, reporting route and relevant period, including why the route applies.
Module 02 / 04
Evidence register
Attach each reported figure or statement to its source, method, version and limitations.
Module 03 / 04
Review trail
Name the preparer, reviewer, open questions and decisions taken before publication.
Module 04 / 04
Usable handover
Retain the working files and unresolved actions so the next reporting cycle can reuse the evidence.
View the preparation diagram
- Prepare01
Create the traceable pack
Keep the input records, calculation files and narrative together.
- Challenge02
Resolve questions before publication
Record the assumptions challenged and any limitations still unresolved.
- Retain03
Make the next cycle reproducible
Keep the approved version and the actions carried forward.
Continue your research
Related guides, one question at a time
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- legislation.gov.ukSI 2008/410 Schedule 7, paragraph 20B — the size exemption
Exempt on two or more of: turnover not more than £36m, balance sheet not more than £18m, not more than 250 employees; the year-on-year limbs.
- legislation.gov.ukSI 2008/410 Schedule 7, paragraph 20C — the group exemption for parents
- legislation.gov.ukSI 2008/410 Schedule 7, paragraph 20A — the subsidiary shelter
¶20A(2): four conditions, the last excluding a group report that relied on ¶20D(7)(b).
- legislation.gov.ukSI 2008/410 Schedule 7, paragraph 20D — unquoted disclosures and reliefs
¶20D(5) UK-only option; ¶20D(6) practicality; ¶20D(7)(a) 40,000 kWh in the UK; ¶20D(7)(b) seriously prejudicial.
- legislation.gov.ukSI 2008/410 Schedule 7, paragraph 15 — quoted company duties and reliefs
¶15(1A) subsidiary shelter; ¶15(4) practicality; ¶15(5)(a) 40,000 kWh with no UK qualifier; ¶15(5)(b) seriously prejudicial.
- legislation.gov.ukSI 2008/410 Schedule 7, paragraph 20E — group reports
- legislation.gov.ukSI 2008/410 Schedule 7, Part 7A
- legislation.gov.ukSI 2008/410 Schedule 7, ¶20 and ¶20K — the definition of energy
“All forms of energy products” — the 40,000 kWh test runs on all of them.
- legislation.gov.ukSI 2008/1911, regulation 12B — LLPs
- legislation.gov.ukSI 2008/1911 — LLP accounts and audit regulations
- legislation.gov.ukSI 2018/1155 — the SECR Regulations
In force 1 April 2019.
- legislation.gov.ukSI 2024/1303 — the 2025 company size uplift
Did not touch Part 7A.
- legislation.gov.ukCompanies Act 2006, section 385 — quoted companies
- legislation.gov.ukCompanies Act 2006, section 419 — approval of the directors’ report
- legislation.gov.ukCompanies Act 2006, section 442 — filing periods
- legislation.gov.ukCompanies Act 2006, Part 15 Chapter 5 — the directors’ report
- DESNZ, Defra and BEISEnvironmental Reporting Guidelines, including SECR requirements
The guidance’s own low-energy wording (“40MWh… including offshore area”) differs from the SI; the SI governs.
- Department for Energy Security and Net ZeroIndependent evaluation of SECR, 29 January 2026
- Department for EducationStreamlined Energy and Carbon Reporting (SECR) for academy trusts
- Financial Reporting CouncilCorporate Reporting Review — overview
- Department for Business and TradeUK SRS S1 and UK SRS S2
- Financial Conduct AuthorityPS26/19 — UK SRS on a comply-or-explain basis
- Financial Conduct AuthorityCP26/5 — the consultation PS26/19 finalised
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