who needs to report under SECR
Streamlined Energy and Carbon Reporting (SECR) applies to thousands of UK companies and LLPs, but determining whether an organisation is in scope can trip up even experienced finance teams. This guide sets out who must comply, how the scope criteria are assessed, how the 40 MWh low-energy provision affects reporting, and what to do next if your organisation qualifies.
SECR replaced the CRC Energy Efficiency Scheme in April 2019 and requires qualifying organisations to disclose UK energy use, greenhouse gas emissions and energy efficiency measures inside their annual directors' report. GreenKPO helps businesses confirm whether they qualify, then turns the requirement into a repeatable annual process: define the reporting boundary, gather the energy data, calculate emissions, document the methodology and keep evidence ready for Companies House and auditors.
Which organisations fall within SECR scope?
- Quoted companies – listed on the Main Market of the LSE, NYSE, NASDAQ or an equivalent EU market must report regardless of size, covering Scope 1, Scope 2 and, where practical, Scope 3 emissions.
- Large unquoted companies and LLPs – those meeting at least two of: turnover above £36 million, balance sheet total above £18 million, or more than 250 employees, assessed on a consolidated group basis.
- Organisations within the SECR scope – first establish whether the organisation falls within the SECR scope based on the applicable company and group criteria. The 40 MWh (40,000 kWh) low-energy provision is then considered when determining the reporting treatment for an organisation that is already in scope.
- Financial years beginning on or after 1 April 2019 fall within scope, so your first reporting date depends on your company's year-end.
What a compliant SECR disclosure should contain
A complete SECR disclosure inside the directors' report normally records UK energy use from gas, electricity and transport, total greenhouse gas emissions in tonnes of CO2e, at least one energy intensity ratio (such as emissions per employee or per square metre), the methodology used, and a narrative on energy efficiency actions taken during the year.
Group structures add complexity: parent companies must assess thresholds on a consolidated basis, so a small subsidiary can trigger reporting through its parent's combined turnover, balance sheet or headcount even if it wouldn't qualify alone.
Exemptions worth checking before you assume you qualify
Once an organisation has been established as being within SECR scope, its annual UK energy use should also be assessed. Where an in-scope organisation falls within the 40 MWh (40,000 kWh) low-energy provision, it may be required to include a low-energy statement rather than the full SECR disclosure. Companies qualifying as small or medium-sized under the Companies Act 2006 are excluded from SECR, and subsidiaries exempt from producing a directors' report under sections 394/394A generally sit outside direct SECR obligations, though their data may still feed a parent's consolidated report. Overseas companies without a UK-registered entity fall outside scope, but UK subsidiaries of overseas groups should assess whether they independently meet the applicable criteria.
Why getting this wrong is costly
Companies House can reject filings missing mandatory SECR content, delaying annual accounts and risking late filing penalties. Directors who sign off knowingly incomplete reports face personal liability and unlimited fines under section 419 of the Companies Act 2006. Beyond the legal exposure, investors, lenders and customers increasingly treat SECR disclosures as a governance signal, so gaps can affect financing terms, tenders and commercial relationships.
Common questions
- Does SECR apply to small companies?
No. Companies qualifying as small or medium-sized under the Companies Act 2006 are excluded, even if energy use is high. - How do I know if my subsidiary needs to report?
Check the consolidated group figures, not just the subsidiary's own accounts — thresholds are assessed across the whole group. - How does the 40 MWh low-energy provision work?
Once an organisation has been established as being within SECR scope, its annual UK energy use is assessed. The 40 MWh (40,000 kWh) level is relevant to the low-energy provision and should not be treated as a standalone test for whether SECR applies. UK gas, electricity and transport fuel energy use should be considered when assessing the organisation's energy use for the reporting year. - What happens if we miss the deadline?
Companies House can reject the directors' report, and directors risk personal liability and unlimited fines for knowingly deficient disclosures.
Unsure whether SECR applies to you?
Get a clear answer on your reporting obligations and a controlled process for meeting them every year.