SECR requirements: every disclosure, and where the law puts it

An in-scope report must state energy use in kWh, the greenhouse gas emissions arising from it in tonnes of CO2 equivalent, at least one intensity ratio expressing emissions against a quantifiable factor, the methodologies used, and the principal measures taken to improve energy efficiency, with prior-year figures after the first year. Quoted companies report emissions and energy worldwide and state the UK proportion; large unquoted companies and LLPs report gas, transport fuel and purchased electricity and may exclude energy used outside the UK.

The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, SI 2018/1155. They amended Part 7 and inserted Part 7A of Schedule 7 to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 (SI 2008/410), and inserted regulation 12B into the LLP Regulations (SI 2008/1911). They apply to financial years beginning on or after 1 April 2019.

With the annual accounts. A private company or LLP files nine months after the end of its accounting reference period and a public company six months (Companies Act 2006 s.442; SI 2008/1911 reg 17). There is no separate SECR filing and no separate SECR deadline.

An unquoted company or LLP that does not exceed two of £36 million turnover, £18 million balance sheet total and 250 employees is outside SECR. Inside it, there are three reliefs, each of which requires the report to say it is being used: energy consumption of 40,000 kWh or less (in the UK for unquoted companies and LLPs), disclosure that would in the directors’ opinion be seriously prejudicial, and information it is not practical to obtain. A subsidiary included in a compliant group report is also relieved of reporting in its own right.

No. SECR requires publication of the information; it does not require assurance, verification or certification, and no government body approves SECR providers or issues certificates. The company’s auditor states whether the directors’ report is consistent with the accounts, which is not assurance over the emissions data.

The content is the same as a large unquoted company’s, on the same £36m / £18m / 250 figures, but the route and the document differ. Regulation 12B of the LLP Regulations applies modified Companies Act sections to LLPs, and because an LLP has no directors’ report its members prepare a separate energy and carbon report, approved by the members and signed by a designated member, and deliver it to the registrar with the accounts.

For a company, the directors’ report containing it must be approved by the board and signed on the board’s behalf by a director or the company secretary (Companies Act 2006 s.419(1)). For an LLP, the energy and carbon report is approved by the members and signed on behalf of all of them by a designated member.

No. No paragraph of Schedule 7 requires a target or a transition plan; DESNZ’s 2026 review describes SECR as backward-looking, with no forward targets or transition plans. Climate-related financial disclosures and UK SRS are separate regimes with their own scope.

The government’s Environmental Reporting Guidelines, including SECR guidance, published in March 2019 and last updated on 29 March 2019. It is guidance, not law, and it differs from the regulations in places: it states the low-energy threshold as 40 MWh and adds an offshore limb, and it describes the LLP threshold by reference to Companies Act sections that have since moved. Where the two differ, the regulations govern.