SECR reporting thresholds: two of three, as the law writes them

Streamlined Energy and Carbon Reporting is the UK duty on large companies and LLPs to put their energy use and greenhouse gas emissions in the annual report.

It was created by SI 2018/1155, made on 6 November 2018 after both Houses approved a draft, and applies to financial years beginning on or after 1 April 2019.

That instrument is an amending one, and its work is done: the rules now sit in Schedule 7 to SI 2008/410, which is the text to read and to quote.

Quoted companies had reported greenhouse gas emissions in the directors’ report since the 2013 regulations inserted Part 7 of Schedule 7.

The 2018 Regulations kept that population, widened what it reports, and extended a narrower duty to large unquoted companies and large LLPs.

So SECR has three populations, each caught by a different test and each owing a different package: quoted companies, large unquoted companies and large LLPs.

SECR is one of several carbon reporting requirements a UK business can meet; the others are mapped on the UK sustainability regulation timeline and on UK SRS compliance.

Paragraph 20B lists three conditions and none turns on sector (¶20B(2)).

A bank, a manufacturer, a retailer, a charitable company and an academy trust are all tested on the same three figures.

What changes by sector is the energy profile, not the test: an office-based business may sit under the 40,000 kWh relief, and an industrial one will not.

Legal form still matters, because only companies and LLPs appear in the text, and a quoted company is in scope at any size (¶15(1)).

Regimes that do carry sector or size tests of their own are mapped on the UK sustainability regulation timeline.

Part 7 applies to the directors’ report of any company that is a quoted company, with no turnover, balance sheet or employee test at all (Sch 7 ¶15(1)).

A quoted company with a handful of staff owes the same disclosures as the largest company on the Main Market.

The definition in section 385 is closed, and it is the part people misread.

AIM securities are not admitted to the Official List, in the London Stock Exchange’s own words, so an AIM company is unquoted for SECR.

That does not take an AIM company out of scope; it moves it to the unquoted route, where the size test decides and the narrower package applies.

The consequence runs both ways: a large AIM company reports its UK energy and transport fuel, not the quoted package.

What each population must disclose is set out further down this page, and whether SECR is mandatory for each is answered on its own page.

A UK limited liability partnership is caught on exactly the same figures: £36 million, £18 million and 250.

What changes is the route: regulation 12B of SI 2008/1911 applies modified versions of Companies Act sections 415, 415A, 416 and 419 to LLPs.

Because an LLP has no directors’ report, the members must prepare a separate energy and carbon report, signed by a designated member on behalf of all the members.

The threshold table sits in the modified section 415A, and the modified section 416 expressly leaves out paragraphs 20B and 20C, so citing ¶20B for an LLP cites a provision that does not apply to it.

The same two-year machinery applies, word for word, with “LLP” in place of “company”.

The content is the unquoted package: UK gas, transport fuel and electricity, energy in kWh, a ratio, the methodology, comparatives and the efficiency narrative.

An illustrative case: a partnership with £60 million of fees, 300 staff and an £8 million balance sheet exceeds two conditions and is in scope; the small balance sheet does not rescue it.

Some government guidance still describes the LLP test as “based on sections 465 and 466 of the Companies Act” (Environmental Reporting Guidelines); the figures printed beside that phrase are right, and the cross-reference is not.

For financial years beginning on or after 6 April 2025, SI 2024/1303 raised the Companies Act medium-sized limits to £54 million turnover and £27 million balance sheet total.

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

The uplift instrument did amend Schedule 7, but regulation 5(3) omits paragraphs 6 and 7 and Parts 3 and 4 only; Part 7A was left alone.

This was flagged in advance: the non-financial reporting review said the government “does not propose to change the threshold for Streamlined Energy and Carbon reporting before it has undertaken a full analysis of how this would impact carbon budgets”.

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

A company in that band can be reclassified as medium-sized, take the lighter accounts regime, and still owe a full SECR disclosure in the same report.

Illustratively, £45 million turnover, a £22 million balance sheet and 180 staff is medium-sized under section 465 and in scope of SECR.

Section 465’s exclusions in section 467 do not reach SECR either; they decide the accounts regime only.

Professional commentary reached the same reading at the time, for example PwC’s UK in brief on the size thresholds; the instrument is what settles it.

An in-scope company that consumed 40,000 kWh of energy or less in the period need not give the energy and carbon figures, provided the report states that the information is not disclosed for that reason.

It remains in scope; only the content is relieved, and a report that says nothing does not comply.

For unquoted companies and LLPs the line is measured “in the United Kingdom” (¶20D(7)(a)); for quoted companies it has no UK qualifier, so it runs on worldwide consumption and is harder to reach.

“Energy” in the test means all forms of energy product (Sch 7 ¶20, carried into Part 7A by ¶20K), which is wider than the three sources an unquoted company reports.

The figure is 40,000 kWh in the instrument; guidance that says “40 MWh” states the same number but also misstates the territorial limb, so quote the Schedule.

The relief switches off the emissions figures, the kWh total, the efficiency narrative, the methodology and the ratio.

It does not switch off the need to measure: you cannot say you are under 40,000 kWh without knowing that you are.

A second relief sits in the same sub-paragraph: disclosure may be withheld where, in the directors’ opinion, it would be seriously prejudicial to the company, again with a statement — and relying on it removes the group shelter for subsidiaries.

The other routes out are set side by side on the SECR exemptions page.

There is no single exemptions paragraph; there are five distinct routes, and they do different things.

The commonest by far is being within the size conditions, which is not an exemption you claim but one you have.

The practicality relief applies only “to the extent that it is practical for the company to obtain the information”, and the report must say what is missing and why (¶20D(6)).

Legal form decides the rest: only companies and LLPs appear in the text, so a body that is neither is outside the machinery rather than exempt from it.

A charitable company or an academy trust is tested like any other company, which is why the Department for Education publishes SECR guidance for academy trusts.

Each route is explained on SECR exemptions, and is SECR mandatory? covers the consequences of getting it wrong.

There is no separate SECR deadline.

The report is filed with the accounts, and the filing period is set by section 442: nine months for a private company, six for a public one.

The deadline does not move for a weekend or a bank holiday.

Late filing exposes each director to an offence under section 451, subject to a reasonable-steps defence, and the company to a civil penalty, set out in Companies House’s late filing penalties.

The full calendar, including how the first year works, is on the SECR deadline page.

The official SECR guidance is the Environmental Reporting Guidelines, last updated on 29 March 2019.

They predate the 2025 divergence by six years and still carry the section 465 cross-reference described above.

The 2026 post-implementation review recommends keeping SECR with amendments, and lists candidate areas for a planned consultation — guidance, a standard template, alignment with ISSB, CSRD and TCFD, light forward-looking elements and digital access — none of them decided.

No threshold change is proposed in the review.

The cost evidence runs higher than the design: about £140 million a year actual ongoing cost against roughly £26–31 million predicted, in the review’s own figures.

Energy is converted to emissions with the government’s conversion factors, matched to the year of the activity data: the 2026 set is for activity mostly within 2026.

A methodology statement that says “DESNZ factors” without a year is not a methodology.

The modernising corporate reporting consultation proposes abolishing the directors’ report, which would move where SECR sits; it does not propose to change who reports or what.

For further reading, ICAEW’s carbon and energy reporting page gathers the accounting-side material; the instrument remains the source.

The independent evaluation of 29 January 2026 counted 19,900 companies in scope against the 11,300 forecast, and estimated non-compliance at 14 to 23 per cent.

The 2026 post-implementation review of 26 May 2026 recommends retaining SECR with amendments.

DBT’s Modernising corporate reporting consultation proposes moving where SECR sits, not what it requires, and no consultation document on the scope thresholds had been published when this page was last checked on 1 October 2026.

Until that changes, the figures on this page are the law.