SECR thresholds: who reports, really

The SECR test looks simple — two of £36m turnover, £18m balance sheet, 250 employees. The complication arrived in April 2025, when the Companies Act size thresholds rose 50% but SECR scope deliberately did not move. The result: a cohort of newly 'medium-sized' companies that still owe carbon disclosures, and widespread bad advice saying otherwise.

The scope test, precisely

SECR — Streamlined Energy and Carbon Reporting — was created by the 2018 Regulations and applies to financial years beginning on or after 1 April 2019^[1]. Three populations are in scope. Quoted companies, of any size, must report global emissions. Unquoted companies and LLPs must report if they are “large”, defined by meeting at least two of three criteria in the reporting year: turnover of £36 million or more, balance sheet total of £18 million or more, or 250 or more employees^[1][2].

The exemptions are narrow. An organisation consuming 40,000 kWh or less of UK energy in the period is a “low energy user” — it must say so in its report, but escapes the detailed disclosures^[1][6]. Information may be omitted where it is not practical to obtain, or — rarely invoked — where disclosure would be seriously prejudicial to the organisation’s interests^[1].

April 2025: the size uplift that didn’t move SECR

For financial years beginning on or after 6 April 2025, the Companies (Accounts and Reports) (Amendment and Transitional Provision) Regulations 2024 raised the general Companies Act size thresholds by roughly 50%: a company is now “large” for accounts purposes only above £54 million turnover and £27 million balance sheet^[3]. Tens of thousands of companies moved down a size category, shedding reporting and audit obligations accordingly.

SECR did not follow. The 2024 Regulations preserved SECR’s application on the previous thresholds — so companies and LLPs that are now medium-sized for accounts purposes, but were large under the old test, remain within SECR^[3][4]. The FRC’s threshold-change summary makes the point explicitly^[4], yet it is routinely missed: a company told by its accountant that it has “become medium-sized” will naturally assume its energy and carbon disclosures lapsed too. They did not.

The practical risk sits with companies in the band between the old and new thresholds — turnover £36–54 million or balance sheet £18–27 million, with under 250 employees. They are medium-sized for accounts, large for SECR, and disproportionately likely to drop the disclosure by accident. Directors’ reports are filed publicly; the omission is checkable.

What in-scope organisations actually publish

Disclosure tiers differ by population. Quoted companies report global Scope 1 and 2 greenhouse gas emissions, underlying global energy use, at least one intensity ratio, and a narrative of energy-efficiency action taken in the year^[1][6]. Large unquoted companies and LLPs report UK (and offshore-area) energy use across electricity, gas and transport fuel, the associated Scope 1 and 2 emissions, an intensity ratio, the methodology used, and efficiency actions^[1][6]. After the first reporting year, prior-year comparatives are required. Scope 3 remains voluntary under SECR — one of the clearest gaps between SECR and what UK SRS S2 contemplates^[7].

The 2026 post-implementation review

DESNZ’s 2026 post-implementation review of the SECR regulations examined whether the regime has delivered transparency and board-level accountability, drawing on an independent evaluation^[5]. The review situates SECR within a reporting landscape that has changed fundamentally since 2018 — TCFD-aligned rules, and now UK SRS^[7]. Our reading: the question on the table is no longer whether SECR works in isolation, but whether the UK keeps three overlapping carbon-disclosure regimes once UK SRS reporting becomes mandatory for its first cohorts. Consolidation pressure is real; timing is unannounced. Companies should plan on SECR continuing through at least the current and next reporting cycles.

SECR thresholds — frequently asked questions