Streamlined Energy and Carbon Reporting (SECR): Does it apply to your business?

Understanding the scope, exemptions and disclosure requirements for UK companies.

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If your business meets at least two of the (between the dates of the old threshold applying), you are likely to fall within the scope of SECR and must include energy and carbon disclosures in your annual report.

What is Streamlined Energy and Carbon Reporting (SECR?)

In 2019, the UK Government introduced the Streamlined Energy and Carbon Reporting (SECR) regulations, extending the scope to all large companies and broadening the disclosure requirements.

The aim is to increase transparency around energy use and carbon emissions, while encouraging organisations to improve energy efficiency.

Does SECR apply to your business?

SECR applies to:

Quoted companies of any size that are already subject to mandatory GHG reporting
Unquoted companies incorporated in the UK that meet the definition of ‘large’ under the Companies Act 2006 (both registered and unregistered companies)
Large Limited Liability Partnerships (LLPs), which must prepare and file an Energy and Carbon Report

The definition of “large” for SECR aligns with the former large company thresholds under the Companies Act 2006. A company, LLP or group is in scope if it exceeds at least two of the following three thresholds in the last two financial years:

£36m annual turnover
£18m balance sheet total (gross assets)
250 employees

It is worth noting that this definition differs from the thresholds used under the ESOS Regulations.

Importantly, if a UK entity meets the criteria, reporting is required regardless of whether an overseas parent has published disclosures including the UK entity.

Are there any exemptions?

Yes. SECR includes exemptions for:

Low energy users

Quoted companies consuming less than 40,000 kWh globally
Unquoted companies or LLPs consuming less than 40,000 kWh in the UK

Where total energy consumption is below 40,000 kWh for the reporting period, detailed disclosure is not required.

Qualifying subsidiaries

If a subsidiary’s energy and carbon information is included in a group-level SECR report of a UK parent company, it does not need to report separately in its own accounts.

How does group reporting work?

For groups, the parent company must report the combined figures for itself and all qualifying subsidiaries.

If a subsidiary is large enough to fall within scope in its own right (for example, as a large unquoted company or LLP), the group-level SECR report must include its information.

However, where a subsidiary would not fall within scope on a standalone basis, it can generally be excluded from the group report, unless its data is significant or otherwise relevant.

This area can be more nuanced than it first appears, particularly where group structures are complex or where subsidiaries operate overseas.

What needs to be disclosed?

SECR requires disclosure of energy use and associated greenhouse gas emissions, typically split into:

Scope 1 – Direct emissions

Fuel use from transport where the journey begins or ends in the UK
Combustion of natural gas

Scope 2 – Indirect emissions

Electricity purchased and used for operations (excluding energy sold on)

Scope 3 – Other indirect emissions (limited requirement under SECR)

Energy use and related emissions from business travel in rental cars or employee-owned vehicles where the company is responsible for purchasing the fuel

In addition, companies must disclose:

At least one intensity metric (for example, tonnes of CO₂e per full-time equivalent employee) to allow year-on-year comparison
The methodologies used in calculating emissions
Details of energy efficiency action taken during the year

What about voluntary disclosures?

Some organisations choose to go beyond the minimum SECR requirements. This may include:

Wider Scope 1 emissions, such as additional fuel use, refrigerants or manufacturing emissions
Broader Scope 3 reporting, covering upstream and downstream energy use
Enhanced narrative explaining transition plans or wider sustainability strategy

While voluntary, this can support stakeholder expectations and align with wider ESG reporting objectives.

Why SECR matters

SECR is increasingly linked to wider sustainability reporting requirements, investor expectations and procurement standards.

For many businesses, the real challenge is not producing the figures, but ensuring the data is complete, consistent and supported by robust methodology. Early planning, clear responsibility within the business and good quality record keeping can make a significant difference.

If you are unsure whether SECR applies to your organisation, or whether your current disclosures are sufficient, it is worth reviewing your position before your next reporting deadline.

We always recommend that you seek advice from a suitably qualified adviser before taking any action. The information in this article only serves as a guide and no responsibility for loss occasioned by any person acting or refraining from action as a result of this material can be accepted by the authors or the firm.

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