SECR thresholds: who reports, really

Quoted companies report under SECR at any size. An unquoted company or LLP is exempt for a financial year if it meets at least two of three conditions: turnover not more than £36 million, balance sheet total not more than £18 million, and not more than 250 employees (SI 2008/410 Schedule 7 paragraph 20B; SI 2008/1911 regulation 12B for LLPs). Turned round, you are in scope if you exceed at least two of the three, and a change of size only counts once it has lasted two consecutive financial years.

No. SI 2024/1303 raised the Companies Act size thresholds by about half for financial years beginning on or after 6 April 2025, so a company is now large for its accounts only above £54 million turnover and £27 million balance sheet total. SECR did not move, because Parts 7 and 7A of Schedule 7 carry their own threshold table and never cross-referred to the Companies Act size sections. The Explanatory Memorandum to SI 2024/1303 says the Regulations "do not affect" the SECR requirements. A company reclassified as medium-sized for its accounts can therefore still owe SECR disclosures.

More than. Paragraph 20B(2) lists the exemption conditions as "not more than £36 million", "not more than £18 million" and "not more than 250" employees, so a company exactly on a figure still meets that condition. DESNZ's 2026 post-implementation review writes the test as "£36 million or more", which is wider than the regulation at the boundary; where the two differ, the statutory instrument governs.

Paragraph 20B(1) decides each year by looking at the preceding year too. After a company's first financial year, it is exempt if it meets the conditions in that year and the one before, or if it meets them in one of the two years and was exempt the year before. So one year over the thresholds does not bring an exempt company into scope, and one year back under them does not take an in-scope company out. In its first financial year a company is tested on that year alone.

There is a relief from disclosure, not an exemption from SECR. An unquoted company or LLP that consumed 40,000 kWh of energy or less in the United Kingdom in the period, and a quoted company that consumed 40,000 kWh or less (with no UK limit), need not give the energy and emissions figures, but the report must state that the information is not disclosed for that reason. Silence is non-compliance. "Energy" means all forms of energy products, which is wider than the gas, electricity and transport fuel an unquoted company has to report.

No. Section 385 of the Companies Act 2006 defines a quoted company as one whose equity share capital is on the official list, officially listed in an EEA State, or admitted to dealing on the New York Stock Exchange or Nasdaq. AIM is not the official list, so an AIM company is tested as an unquoted company on the £36m / £18m / 250 route and, if it is in scope, reports the unquoted disclosure set of UK energy use.

Usually, in its own right. The subsidiary exemption in paragraph 20A(2) works only where the subsidiary is included in a group directors' report or group energy and carbon report that itself complies with Schedule 7, and a parent incorporated outside the UK prepares neither. So a UK subsidiary that exceeds two of the three thresholds, taking the two-year rule into account, reports for itself whatever its parent publishes elsewhere.

Not on its own. Turnover is only one of three conditions, and you need to meet two of them. Even then, the paragraph 20B(1) machinery means an in-scope company is exempt again only once the conditions are met in two consecutive financial years.

Large LLPs are, on the same £36m / £18m / 250 figures and the same two-year machinery, through regulation 12B of the LLP Regulations (SI 2008/1911) rather than through Schedule 7 paragraph 20B. An LLP has no directors' report, so its members prepare a separate energy and carbon report, approved by the members and signed on their behalf by a designated member.

DESNZ measured it for the first time in its 2026 evaluation and post-implementation review. The mean ongoing cost is £7,100 a year per complier: about 94 hours of internal staff time, worth roughly £2,500, plus external costs that 56% of compliers incur. The 2018 impact assessment had predicted about £2,300. Across the economy, the review puts first-year costs at £270 million and £140 million a year afterwards.

The regulations themselves have not changed since they came into force on 1 April 2019. DESNZ's 2026 post-implementation review recommends keeping SECR with amendments, which it says "do not represent final decisions"; the government's Modernising corporate reporting consultation (7 September 2026) proposes moving the SECR disclosures out of the directors' report without changing the duty; and DESNZ has said it intends to consult on SECR and ESOS later in 2026.

SECR has no sector test. Scope turns on listing status and on size, so a bank and a manufacturer of the same size face the same duty. What differs by sector is the volume of the disclosure: an energy-intensive business has more gas, electricity and transport fuel to measure and more to say in its energy-efficiency narrative.

SECR has no deadline of its own. The energy and carbon report sits in the directors' report and is filed with the annual accounts: nine months after the year end for a private company or an LLP and six months for a public company, under section 442 of the Companies Act 2006. A 31 December 2026 year end at a private company therefore means filing by 30 September 2027.

Every quoted company, at any size, under Schedule 7 Part 7 to SI 2008/410; unquoted companies, including AIM companies, that exceed at least two of £36m turnover, £18m balance sheet total and 250 employees; and LLPs on the same figures under SI 2008/1911. A subsidiary included in a parent's compliant group report need not report itself. Public bodies that are not companies are outside SECR.

No. SECR creates a disclosure duty in the annual report, not a certificate, and no body is authorised to certify SECR compliance. The information is not audited, though the auditor reads the directors' report for consistency with the accounts. Some companies buy independent assurance over their figures voluntarily.

Two things take an organisation out of SECR: not exceeding two of the three size limits, for an unquoted company or LLP, and, for a subsidiary, having its figures in a compliant group report of its UK parent. Three reliefs then let an organisation in scope leave information out, each with a statement in the report: using 40,000 kWh or less in the year, disclosure that would be seriously prejudicial to its interests, and information that is not practical to obtain.

No. The FCA's final rules in PS26/19 replace its TCFD-aligned listing rule for listed companies from 2027; they do not amend Schedule 7 to SI 2008/410. The government's 2026 post-implementation review recommended retaining SECR with amendments, and a consultation on streamlining energy and emissions reporting is planned but has not opened. A listed company in both regimes reports under both.

Paragraph 20B(3) fixes it. Turnover is proportionately adjusted where the financial year is not twelve months long; the balance sheet total is the aggregate of the assets shown in the balance sheet, with no deduction for liabilities; and employees are the monthly average of persons employed under contracts of service, counted as people, not full-time equivalents.

No size thresholds. The FCA's UK SRS rules reach listed companies by listing category, UKLR 6, 14, 15, 16 and 22, whatever their size, on a comply-or-explain basis from periods beginning on or after 1 January 2027. The FCA considered and rejected a size threshold. No threshold for private companies has been proposed, so an unlisted company over the SECR limits has no UK SRS duty.

No. The qualifying conditions in paragraph 20B(2) of Schedule 7 are "not more than" 250 employees, £36m turnover and £18m balance sheet total. A company with exactly 250 employees satisfies that condition, so it has not exceeded it. To be in scope an unquoted company must exceed at least two of the three.