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Analysis & Commentary · Energy and carbon

SECR requirements: who reports, and what they report

Streamlined Energy and Carbon Reporting has applied to UK companies since April 2019.

This page sets out exactly who falls in scope, the thresholds that define a large company, what the report must contain, where it goes, the low-energy-user exemption, and how SECR sits alongside the new UK Sustainability Reporting Standards.

Updated 16 June 2026 · Independent analysis · SRS Report
£36m
Turnover threshold for a large company
CA 2006 s.465 [2]
£18m
Balance sheet total threshold
CA 2006 s.465 [2]
250
Employee threshold (meet 2 of the 3)
CA 2006 s.465 [2]
40,000 kWh
Low-energy-user exemption ceiling
SI 2018/1155 [1]
Start here

Who has to comply with SECR

SECR was introduced by the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, and applies to financial years beginning on or after 1 April 2019[1].

Three kinds of entity fall in scope: all quoted companies, large unquoted companies, and large LLPs[5].

For an unquoted company or LLP, “large” is defined by SECR’s own threshold table — not by the Companies Act 2006 size-category rules used for accounts.

An entity is large if it meets two or more of three tests — turnover above £36 million, a balance sheet total above £18 million, or more than 250 employees[2].

A “quoted company” is defined narrowly.

Under section 385 of the Companies Act 2006 it means a company whose equity is listed on a UK regulated market, an EEA regulated market, or admitted to the New York Stock Exchange or NASDAQ — so a company on AIM is not quoted, and is instead caught only if it meets the large-company thresholds[3].

The three SECR entity types and how they qualify
Entity typeHow it qualifiesWhat it reports
Quoted companyAny size; equity listed on Main Market, EEA, NYSE or NASDAQGlobal Scope 1 and 2 emissions and global energy use
Large unquoted companyMeets 2 of 3 (£36m turnover, £18m balance sheet, 250 staff)UK energy use and associated emissions
Large LLPSame 2-of-3 large testUK energy use and emissions in an Energy and Carbon Report
Watch the AIM trap. AIM companies are not “quoted” for SECR. They report under the large-unquoted rules — but only if they cross the size thresholds. See our SECR thresholds explainer for the qualifying mechanics.
The content

What a SECR report must contain

All in-scope entities must report five things: energy use, the associated greenhouse gas emissions, at least one intensity ratio, a narrative on energy-efficiency action taken in the year, and the methodologies used[6].

The scope of the figures differs by entity type.

Quoted companies report their global Scope 1 and 2 emissions and global energy use; large unquoted companies and LLPs report their UK energy use and the emissions associated with it[5].

After the first reporting year, prior-year comparatives must be given so a reader can see the trend[6].

The five mandatory SECR disclosures
DisclosureWhat it covers
Energy useAnnual quantity of energy consumed, in kWh, from gas, electricity and transport fuel
GHG emissionsAssociated emissions in tonnes of CO2 equivalent (Scope 1 and 2; plus a narrow mandatory transport-fuel Scope 3 limb for unquoted companies and LLPs)
Intensity ratioAt least one ratio, e.g. emissions per employee or per £m turnover
Energy-efficiency actionNarrative on the principal measures taken to improve efficiency in the year
MethodologyThe calculation methodologies used for energy and emissions

The government’s Environmental Reporting Guidelines set out the expected content, intensity-ratio options and example templates, and point reporters to the annual UK conversion factors for company reporting[6].

For a fuller walk-through of the figures, see our SECR carbon reporting guide.

The location

Where the disclosure goes, and by when

SECR is not a standalone filing.

For companies, the disclosure sits inside the Directors’ Report; for LLPs, it goes into a new document called the Energy and Carbon Report[1].

Because it travels with the annual report, there is no separate SECR deadline.

The content is filed at Companies House on the ordinary timetable in section 442 of the Companies Act 2006 — nine months after the year-end for private companies and LLPs, and six months for public companies[4].

A common error is to treat SECR as a six-month deadline for everyone. The six-month window applies to public companies; most large unquoted companies and LLPs have nine months under section 442[4].
The relief

The low-energy-user exemption

A large unquoted company or LLP that consumes 40,000 kWh or less of energy in the UK during the reporting period qualifies as a low energy user and is exempt from the detailed energy and carbon disclosures[1].

The exemption is not silent.

The entity must still state in its Directors’ Report or Energy and Carbon Report that it is a low energy user, and that this is why the information has not been given[5].

The 40,000 kWh threshold is assessed against all energy consumed in the UK — all forms of energy products, not only the narrower set of gas, electricity and transport fuel that the detailed SECR disclosures themselves cover[5].

The relationship

How SECR relates to UK SRS

SECR and the UK Sustainability Reporting Standards are separate obligations, and the government has confirmed both will continue side by side rather than being merged[5].

They differ in approach and location.

SECR is a rule-based regime that prescribes specific disclosures in the Directors’ Report; quoted companies carry no Scope 3 limb, while large unquoted companies and LLPs carry a narrow, mandatory transport-fuel Scope 3 duty.

UK SRS is judgement-based and materiality-driven, sits in the Strategic Report, and does extend to Scope 3[6].

The April 2025 changes to Companies Act size thresholds did not amend the SECR thresholds.

An entity may therefore move down a Companies Act size category yet remain firmly in SECR scope[2].

For the wider picture, see our UK SRS requirements page, and our analysis of how ESOS and SECR differ for the same business.

For hands-on delivery, a specialist SECR consultancy can build the figures and draft the disclosure.

For ongoing reference, our dedicated SECR guidance hub at secr.quest tracks SECR deadlines, thresholds and FAQs.

Common questions

SECR requirements: frequently asked questions

Who has to comply with SECR?

SECR applies to three types of entity: all quoted companies (of any size), large unquoted companies, and large limited liability partnerships. An unquoted company or LLP is "large" if, in a financial year, it exceeds two or more of three tests — turnover above £36 million, balance sheet total above £18 million, or more than 250 employees — under SECR’s own, self-contained threshold table, which does not cross-refer to the Companies Act size limits. The regime took effect for financial years beginning on or after 1 April 2019.

What is a "quoted company" for SECR purposes?

Under section 385 of the Companies Act 2006, a quoted company is one whose equity share capital is officially listed on the Main Market of a UK regulated market, on an EEA regulated market, or admitted to dealing on the New York Stock Exchange or NASDAQ. Crucially, a company admitted only to AIM is not a "quoted company" for these purposes, so AIM companies fall under the large-unquoted rules instead if they meet the size thresholds.

What must a SECR report contain?

In-scope entities must report energy use, the associated greenhouse gas emissions, at least one intensity ratio, a narrative on energy-efficiency action taken during the year, and the methodologies used. Quoted companies report global Scope 1 and 2 emissions and global energy use; large unquoted companies and LLPs report their UK energy use and associated emissions. Prior-year comparatives are required after the first year.

Where does the SECR disclosure go?

For companies, the SECR disclosure sits in the Directors’ Report; for LLPs, in a new Energy and Carbon Report. There is no separate SECR filing deadline — the content is filed with the annual report and accounts at Companies House under the ordinary timetable in section 442 of the Companies Act 2006 (nine months after year-end for private companies and LLPs, six months for public companies).

Is there a low-energy-user exemption?

Yes. A large unquoted company or LLP that consumes 40,000 kWh or less of energy in the UK during the reporting period qualifies as a low energy user and is exempt from the detailed disclosures. It must, however, state in its Directors’ Report or Energy and Carbon Report that it is a low energy user and that is why the information is not given.

How does SECR relate to UK SRS?

SECR and UK SRS are separate obligations and the government has confirmed both will continue side by side. SECR is a rule-based regime sitting in the Directors’ Report; quoted companies carry no Scope 3 limb at all, while large unquoted companies and LLPs carry a narrow, mandatory transport-fuel Scope 3 duty. UK SRS is a judgement-based, materiality-driven framework that sits in the Strategic Report and extends more broadly to Scope 3. The April 2025 changes to Companies Act size thresholds did not amend the SECR thresholds, so entities can move down a Companies Act size category yet remain in SECR scope.

SECR requirements — Streamlined Energy and Carbon Reporting in the UK
SECR Requirements · SRS Report
Related analysis
SECR thresholdsThe large-company test in detail, the two-year qualifying rule, and how groups assess scope.Streamlined Energy and Carbon ReportingThe full SECR guide — origins, scope, content and the reporting workflow.ESOS and SECR comparedWhy the two regimes use different thresholds, scope and enforcement for the same business.
Sources & primary references
  1. The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (SI 2018/1155) — legislation.gov.uk · The SECR Regulations; effective for financial years beginning on or after 1 April 2019
  2. SI 2008/410, Schedule 7, Part 7A, paragraph 20B — the SECR large-company exemption test — legislation.gov.uk · Self-contained £36m / £18m / 250 test; does not cross-refer to Companies Act 2006 s.465, so the 6 April 2025 uplift of s.465 to £54m/£27m did not move it
  3. Companies Act 2006, section 385 — quoted and unquoted companies — legislation.gov.uk · Definition of "quoted company" (Main Market, EEA regulated market, NYSE, NASDAQ)
  4. Companies Act 2006, section 442 — period allowed for filing accounts — legislation.gov.uk · Filing timetable: 9 months (private/LLP) and 6 months (public) after year-end
  5. Streamlined Energy and Carbon Reporting (SECR) — government guidance — GOV.UK · Scope, thresholds and the 40,000 kWh low-energy-user exemption
  6. Environmental Reporting Guidelines: including SECR guidance — GOV.UK / DESNZ · Reporting content, intensity ratios, methodology and example templates
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