Definitive guide · UK SECR

Become a SECR Expert

The complete UK guide to Streamlined Energy and Carbon Reporting: practical “how-to” compliance for businesses, and authoritative technical depth for consultants and accountants.

Get the PDF guide →Start your carbon reporting

Plain-English + technical depth Updated June 2026 Reflects the Jan 2026 DESNZ review

Streamlined Energy and Carbon Reporting (SECR) is the UK's mandatory framework requiring qualifying companies and LLPs to disclose energy use, greenhouse gas (GHG) emissions and energy-efficiency actions within their annual reports. This guide covers who is in scope, exactly what to report and how, the penalties for getting it wrong, and how SECR fits alongside ESOS, the UK ETS and the new UK SRS.

TL;DR: the three things to know

What & who: SECR is the UK's mandatory energy and carbon disclosure regime under the Companies (Directors' Report) and LLPs (Energy and Carbon Report) Regulations 2018 (SI 2018/1155), in force for financial years beginning on or after 1 April 2019. It applies to all UK quoted companies, plus large unquoted companies and large LLPs meeting two of three thresholds (£36m turnover, £18m balance sheet, 250 employees), unless they are low energy users (40,000 kWh or less).
What you report & where: Energy use (kWh), Scope 1 & 2 GHG emissions (tCO₂e), at least one intensity ratio, methodology, prior-year comparatives and an energy-efficiency narrative, disclosed in the Directors' Report (or an LLP Energy and Carbon Report) and filed at Companies House. Quoted companies report globally; unquoted companies and LLPs report UK energy only.
Status in 2026: The regime is being retained with targeted reforms. The DESNZ January 2026 Post-Implementation Review found a benefit-cost ratio of 2.72 and recommended better alignment with the new UK Sustainability Reporting Standards (UK SRS), published for voluntary use on 25 February 2026.

A free guide from Periscope eco

Smart carbon intelligence for UK business

This guide is published by Periscope eco. Wherever the platform genuinely helps, we flag exactly how, in the violet boxes throughout. In short: Periscope Reporting captures Scope 1, 2 & 3 emissions at source through the year and exports an auditor-ready SECR pack with no year-end scramble, while Periscope Benchmarking shows how your numbers compare with your sector for boardrooms and tenders. Both are free to try.

Try Periscope free →See the SECR workflow

Key findings

SECR replaced the CRC Energy Efficiency Scheme and substantially widened mandatory reporting. DESNZ now estimates that approximately 19,900 quoted companies, large unquoted companies and large LLPs need to report under SECR (themselves or via a parent), of which around 14,000 must report the data themselves.
Company size thresholds for accounts rose by about 50% on 6 April 2025, but SECR thresholds did NOT change. They remain £36m / £18m / 250. Some companies now classed as “medium” for accounting purposes must still make SECR disclosures.
The FRC's September 2021 thematic review found that sampled companies largely met the minimum requirements but were weak on explaining methodology, boundaries, intensity-ratio choice and the extent of assurance.
ESOS and SECR are separate schemes with different qualification tests and timelines; ESOS Phase 4 compliance is due 5 December 2027. ESOS audit data can feed SECR.
The UK SRS (IFRS S1/S2-aligned) were published for voluntary use on 25 February 2026; the FCA is consulting on mandating them for listed companies from 2027. SECR continues in parallel for now.

1. SECR fundamentals

SECR requires qualifying companies and LLPs to disclose energy use, GHG emissions and energy-efficiency actions within their annual reports.

Legislative basis and commencement

SECR was created by SI 2018/1155. The Regulations came into force on 1 April 2019 and apply to financial years beginning on or after that date. They amend the Companies Act 2006, extending and replacing the earlier GHG-reporting obligation that had applied only to quoted companies since 2013, and adding wholly new obligations for large unquoted companies and large LLPs.

Policy background: replacing the CRC

SECR's introduction coincided with the abolition of the CRC Energy Efficiency Scheme, which was widely criticised as overly complex and applying to a comparatively small population. SECR was designed to simplify reporting while broadening it to a far larger number of entities, integrating energy and carbon disclosure into the existing annual-report cycle rather than running a standalone compliance scheme.

Purpose

Increase awareness of energy costs within organisations.
Provide data to inform the adoption of energy-efficiency measures (delivering both cost and carbon savings).
Support the UK's legally binding net zero by 2050 target and carbon budgets.
Improve transparency for investors and stakeholders, consistent with the TCFD recommendations.

The framework is operationalised through HM Government's Environmental Reporting Guidelines: Including SECR guidance (March 2019), originally published by BEIS and now maintained by DESNZ.

2. Who must comply

SECR applies to three categories of entity:

SECR scope at a glance
Entity type	In scope?	Reporting geography
Quoted companies (any size)	Always in scope	Global Scope 1 & 2 + global underlying energy
Large unquoted companies (UK incorporated)	In scope if large (two-of-three test)	UK energy & emissions only
Large LLPs	In scope if large (two-of-three test)	UK energy & emissions only (Energy and Carbon Report)

Definition of a quoted company

For SECR purposes (Companies Act 2006 s.385), a quoted company is UK-incorporated and has equity share capital officially listed on the Main Market of the London Stock Exchange, listed in an EEA state, or admitted to trading on the New York Stock Exchange or NASDAQ. AIM-listed companies are NOT quoted for this purpose. They fall in scope only as large unquoted companies if they meet the size test.

The “large” test: two of three thresholds

Companies Act 2006 ss.465–467 large qualifying thresholds for SECR (unchanged)
Criterion	Threshold (meet two or more)
Annual turnover (or gross income)	£36 million or more
Balance sheet total (gross assets)	£18 million or more
Average number of employees	250 or more

A two-year rule applies (s.465(2)): qualification only changes if the conditions are met, or cease to be met, for two consecutive financial years (subject to first-year rules).

Critical 2025 development: SECR thresholds did NOT change. SI 2024/1303 increased company size thresholds by roughly 50% for financial years beginning on or after 6 April 2025. SECR's thresholds were deliberately left at £36m / £18m / 250. Consequently, some companies and LLPs now classified as “medium-sized” for accounting purposes remain obliged to make SECR disclosures because they still breach two of the old large-company limits. Apply the SECR limits separately from the accounting size classification.

Group and subsidiary rules

Where a group prepares a group Directors' Report, it should include energy and carbon information for the parent and the subsidiaries in the consolidation.
A subsidiary that would not be in scope in its own right may be excluded from the group report (unlike ESOS, which is “one in, all in”).
A UK subsidiary that is itself in scope need not report separately if its data is already included in a UK parent's group report. Its own report should state this.
For group reporting, the 40,000 kWh low-energy-user threshold applies to the combined consumption of parent and subsidiaries.

Overseas parents and UK subsidiaries

SECR does not apply to non-UK incorporated entities. A UK subsidiary of an overseas parent reports in its own right, submitting its data to Companies House based on the requirements applicable to it as an individual entity. The overseas group's global figures are not pulled into the UK subsidiary's report.

Exemptions

Low energy users: an entity consuming 40,000 kWh (40 MWh) or less in the period need not provide the full disclosures, but must still calculate total energy use and state in the Directors' Report that it is exempt on this basis.
“Comply or explain” (impracticability): information that is not practical to obtain can be omitted provided the report states what is omitted, why, and the steps being taken to obtain it in future.
“Seriously prejudicial” exemption: information may be omitted where disclosure would be seriously prejudicial to the organisation's interests, again with a statement of what is omitted and why.

3. What must be reported

Reporting requirements by entity type
Disclosure element	Quoted company	Large unquoted / LLP
GHG emissions (Scope 1 & 2, tCO₂e)	Global	UK only
Underlying energy use (kWh)	Global	UK only (gas, purchased electricity, transport fuel)
Intensity ratio	At least one	At least one
Prior-year comparatives	Required (from 2nd year)	Required (from 2nd year)
Methodology	Required	Required
Energy-efficiency narrative	Required	Required (or state none taken)
UK & offshore proportion	Required (of energy use & emissions)	N/A (UK only)
Grey-fleet business travel (Scope 3)	Voluntary (encouraged)	Mandatory minimum Scope 3 element
Other Scope 3	Voluntary	Voluntary

The seven greenhouse gases

Emissions are reported in tonnes of carbon dioxide equivalent (tCO₂e) and cover all seven Kyoto Protocol gases: CO₂, methane (CH₄), nitrous oxide (N₂O), HFCs, PFCs, sulphur hexafluoride (SF₆) and nitrogen trifluoride (NF₃).

Scope definitions

Scope 1 (direct): emissions from sources you own or control: gas combustion in boilers/furnaces, company-owned vehicles, refrigerant leakage.
Scope 2 (energy indirect): emissions from purchased electricity, heat, steam and cooling consumed on-site but generated elsewhere.
Scope 3 (other indirect): all other indirect emissions from sources you do not own or control: supply chain, purchased goods, waste, commuting, business travel by means you do not operate. Scope 3 is voluntary under SECR for all entities, with one exception.

Which “transport” fuel is in scope

Your transport energy and emissions calculation should include:

Fuel used in company cars on business use;
Fuel used in fleet vehicles you operate on business use;
Fuel used in personal / hire cars on business use, the “grey fleet”, including fuel reimbursed via business-mileage claims (this is the one mandatory Scope 3 element for unquoted companies and LLPs);
Fuel used in private jets, fleet aircraft, trains, ships or drilling platforms you operate;
On-site transport such as forklift trucks.

Excluded (unless you actually operate the mode of transport): employee train, bus, plane, coach and taxi travel, and ordinary commuting paid for by the employee. The test is whether the journey is for work and whether the company purchases or reimburses the fuel. Vehicle ownership is irrelevant. Transport energy covers journeys that start, end, or both start and end in the UK.

4. How to report

Where the disclosures go

Companies: in the Directors' Report. Alternatively, where energy and carbon are of strategic importance, in the Strategic Report, with a cross-reference in the Directors' Report.
LLPs: in a separately prepared Energy and Carbon Report, approved by the members and signed by a designated member.
All are filed with the annual accounts at Companies House. Accounts cannot validly be filed without the required SECR content.

Reporting period and financial-year alignment

The reporting period should be 12 months and is encouraged (but not strictly required) to align with the financial year, to aid comparability. If the SECR period differs from the financial year, this must be stated. For an 18-month financial year, the SECR figures should still cover 12 months.

Conversion factors

Use the UK Government GHG Conversion Factors for Company Reporting, published each June by DESNZ. The 2026 factors were published on 11 June 2026; report on the set that corresponds to your reporting year. Two practical points:

The UK electricity (Scope 2) factor moves materially year on year as the grid decarbonises, it fell by about 15% in the 2025 dataset versus 2024, so reported emissions can change even when consumption is unchanged. Keep clear methodology notes and explain year-on-year movements.
UK suppliers generally quote natural-gas consumption in kWh on a Gross calorific value (Gross CV) basis, so use the Gross CV factor for gas by default unless your supplier states otherwise.

Methodologies

SECR does not prescribe a calculation methodology but recommends a widely recognised independent standard:

GHG Protocol Corporate Standard: the global gold standard for corporate carbon accounting;
ISO 14064-1:2018;
The CDSB framework and GRI guidelines are also referenced.

Whichever you use, the FRC expects the methodology to be clearly explained.

Location-based vs market-based (dual reporting)

For Scope 2 electricity, the GHG Protocol defines two methods:

Location-based: the average grid emission factor for the region, reflecting the physical electricity consumed. SECR's default preference where a company chooses not to dual report.
Market-based: the emission factor of the specific supply contract (green tariffs, REGOs, PPAs or supplier-specific rates), which can be zero where credible renewable instruments back 100% of consumption.

For renewable/green tariffs, REGOs and corporate PPAs, the guidance encourages dual reporting, disclosing both a location-based and a market-based figure. Green gas (biomethane/biogas) is treated the same way as renewable electricity (DESNZ confirmed this in September 2025).

Watch the REGO additionality debate. A green tariff backed only by separately purchased REGOs may not reflect the physical grid mix. Under the GHG Protocol, to claim a market-based zero the instruments must meet the Scope 2 Quality Criteria (valid exclusive certificates, temporal matching, geographic relevance). Disclose your basis clearly.

Choosing an intensity ratio

At least one ratio is required, comparing emissions to an activity or financial metric, e.g. tCO₂e per £m turnover, per FTE employee, per m² of floor area, per unit produced, per delivery, or per pupil (academies). Pick a metric that is meaningful for the sector, keep it consistent year on year, and ensure it can be recalculated from the figures disclosed elsewhere in the report.

How Periscope helps

Periscope Reporting attaches the emission factor, source note and supporting file to every figure, so your methodology is documented and audit-ready rather than reconstructed at year-end, directly addressing the FRC's most common criticism. It calculates your chosen intensity ratio (e.g. tCO₂e/£m) and the year-on-year movement automatically from the same records, so the comparatives always reconcile.

See how capture works →

5. Step-by-step compliance process

Confirm scope. Are you quoted? If not, do you meet two of the three large thresholds (£36m / £18m / 250) under the two-year rule? Consider group/subsidiary structure.

Define the organisational boundary. Choose financial control, operational control (most common) or equity share. List the sites and activities included and document the rationale; apply consistently each year.

Test the 40,000 kWh exemption. Calculate gas + purchased electricity + transport fuel (for groups, the combined parent + subsidiaries figure).

Collect data. In order of preference: meter readings (incl. half-hourly) → supplier invoices → annual statements. For transport: fuel cards, fuel-purchase records, mileage/expense claims.

Convert transport data. Ideally use litres of fuel; otherwise convert mileage using vehicle-specific factors and the DESNZ factors. Deduct private mileage. Avoid double-counting EV charging already captured in building electricity.

Apply conversion factors. Calculate energy in kWh and emissions in tCO₂e using the latest DESNZ factors and your chosen methodology.

Handle data gaps. Where verifiable data is unavailable, use a reasonable estimate derived from verifiable data: pro-rating, comparable-period comparison, or benchmarking. Document assumptions.

Select intensity ratio(s) and compute prior-year comparatives. No comparative is required in your first year in scope.

Write the energy-efficiency narrative describing the principal measures taken in the year (or stating none were taken).

Place and file. Insert the disclosures into the Directors'/Strategic Report (companies) or Energy and Carbon Report (LLPs) and file with the annual accounts at Companies House.

Worked example: converting business mileage to energy and emissions

A diesel-only fleet travels 4,500,000 business miles. Using an “average car” activity factor of about 0.2949 kg CO₂e/mile gives ≈ 1,326,888 kg CO₂e. Dividing by a fuel-property factor of about 0.2611 kg CO₂e/kWh converts this to ≈ 5,081,525 kWh of energy use. This illustrates the standard mileage-to-energy route where litres of fuel are not directly recorded.

How Periscope helps across this workflow

The hard part of SECR is rarely the maths. It's owning the data, chasing missing evidence and handing over a defensible pack. Periscope Reporting is built around that chain:

Step 2 (boundary): set your periods, entities, sites and fleets once, so every record lands in the right place.
Steps 4–5 (data & transport): log energy, fuel and travel against the exact period, scope and asset that produced it, with fleet and grey fleet kept separate by design.
Step 7 (data gaps): automated guided links chase the finance, estates and operations colleagues who own each input, with no extra logins, no chasing by hand.
Step 10 (file): the SECR section, supporting schedules and methodology context export as a finished pack in DOCX, PDF, XLSX, CSV, JSON or HTML.

Open the SECR workflow →Try free

6. Nuances, pitfalls & difficulties

Landlord/tenant energy: responsibility follows who pays for and controls the energy. Sub-metering helps resolve apportionment.
Renewable energy & REGOs: use dual reporting and disclose the basis; do not simply declare Scope 2 zero on the strength of a labelled tariff.
EV charging: on-site charging is usually captured within building electricity (Scope 2). Report transport EV electricity separately only where sub-metered, then deduct it from the building total to avoid double counting.
Working from home: a Scope 3 category, voluntary under SECR, but increasingly tracked for net zero planning.
Off-grid sites, mid-year acquisitions/disposals, changes of financial year: pro-rate and document the treatment; keep the 12-month SECR figure intact even for an 18-month accounting period.
Verification / assurance: not mandatory, but recommended. If obtained, disclose its nature and extent.
Common errors: double-counting EV electricity; merging fleet vs grey-fleet figures; boilerplate efficiency narratives; intensity ratios that cannot be recalculated from the report; failing to update to the latest conversion factors.

How Periscope helps

Most of these pitfalls are spreadsheet problems, not calculation problems. Because Periscope Reporting captures every figure against its own scope, category and asset with the factor attached, the classic mistakes above (double-counted EV electricity, fleet and grey fleet merged into one total, intensity ratios that don't reconcile) are caught in the data structure rather than in a frantic year-end review. Live charts let you pressure-test the footprint before anything is filed.

7. Penalties & enforcement

There is no bespoke SECR monetary penalty regime. Enforcement runs through the general machinery of the Companies Act 2006:

FRC Corporate Reporting Review: the FRC reviews strategic reports, directors' reports and accounts (and, expressly, the Energy and Carbon Report of LLPs) for compliance. Authorised under s.456, it may apply to court for an order requiring directors to prepare a revised report; under s.459 it can require information. It has no power to fine, but the court can require directors to bear the costs of restatement personally.
Directors'/members' offences: under s.415 and s.419, a director (or LLP member) who approves a non-compliant report knowingly or recklessly, having failed to take reasonable steps to secure compliance, commits an offence punishable by an unlimited fine in England & Wales.
Companies House: non-compliant accounts may be rejected, and late-filed accounts attract the standard civil late-filing penalty.

The January 2026 Post-Implementation Review estimated actual SECR non-compliance at roughly 14–23%, more prevalent among private companies and LLPs. Strengthening enforcement is among its reform recommendations.

8. Interactions with other schemes

ESOS (Energy Savings Opportunity Scheme)

A separate mandatory energy-audit scheme run in four-year phases by the Environment Agency, using a different qualification test (250+ employees, OR turnover over £44m AND balance sheet over £38m) on a “one in, all in” group basis. Phase 4 qualification date is 31 December 2026 and the compliance deadline is 5 December 2027. ESOS audit and transport data, and the resulting action plans, can directly support SECR.

UK ETS (Emissions Trading Scheme)

A cap-and-trade scheme covering power, energy-intensive industry and aviation. Aviation free allocation ended on 1 January 2026; domestic maritime (ships 5,000 GT and above) enters from 1 July 2026, and waste incineration from 2028. Verified ETS emissions data can support SECR Scope 1 reporting for installations.

Climate Change Agreements (CCA)

Sector-level voluntary energy-efficiency agreements granting Climate Change Levy discounts for energy-intensive industries. CCA monitoring data can feed SECR.

Mandatory Climate-related Financial Disclosure (TCFD-aligned)

The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 require TCFD-aligned disclosures for accounting periods beginning on or after 6 April 2022: for traded, banking and insurance companies, AIM companies and high-turnover companies with more than 500 employees, and large private companies/LLPs with 500+ employees and turnover over £500m. SECR data forms the Metrics & Targets component.

UK SRS / ISSB

The UK Sustainability Reporting Standards (UK SRS S1 and S2), the UK's endorsement of IFRS S1 and S2, were published for voluntary use on 25 February 2026. The FCA is consulting on requiring listed companies to report against UK SRS for periods beginning on or after 1 January 2027. UK SRS goes well beyond SECR, adding governance, strategy, scenario analysis, risk management and material Scope 3. Build emissions data once, to UK SRS quality, and reuse it.

CSRD / ESRS

The EU's Corporate Sustainability Reporting Directive applies a double-materiality model and is relevant to UK groups with significant EU operations or EU-listed securities. Map SECR/UK SRS data to ESRS E1 to avoid duplication.

PPN 06/21 (now PPN 006): Carbon Reduction Plans

Suppliers bidding for central-government contracts above £5m per year must publish a board-approved Carbon Reduction Plan committing to net zero by 2050 and reporting Scope 1, Scope 2 (in line with SECR) and a defined subset of Scope 3. The NHS requires a CRP regardless of contract value. SECR data underpins the CRP.

SBTi and net zero commitments

Voluntary, but increasingly investor- and customer-driven. SECR provides the emissions baseline against which science-based targets are set. Bundled REGOs may not count toward SBTi progress without additionality evidence.

How Periscope helps

Many of these adjacent demands (PPN 006 carbon reduction plans, public and private tenders, investor and customer questionnaires) ask not just for your number but for how it compares. Periscope Benchmarking scores your carbon performance against your sector and shows your percentile, drawn from the same dataset behind your SECR report, so you can walk into a boardroom or tender with credible, shareable comparisons. It's free to start.

Explore Benchmarking →

9. Scheme comparison table

How the main UK energy/carbon reporting regimes compare
Scheme	Who is in scope	What is reported	Where / how	Key timing
SECR	Quoted companies (any size); large unquoted companies & LLPs (2 of: £36m / £18m / 250)	Energy (kWh), Scope 1 & 2 (tCO₂e), intensity ratio, methodology, efficiency narrative, comparatives	Directors'/Strategic Report or LLP Energy & Carbon Report; filed at Companies House (public)	Annual, with the accounts; FY from 1 Apr 2019
ESOS	Large undertakings: 250+ employees OR (£44m turnover AND £38m balance sheet); group one-in-all-in	Energy audits of buildings, processes & transport (at least 95% of energy); action plans	Notified to the Environment Agency; not public (action plans are published)	4-yearly; Phase 4 deadline 5 Dec 2027
UK ETS	Power, energy-intensive industry, aviation; maritime from Jul 2026; waste from 2028	Verified emissions; surrender of allowances	UK ETS registry; permits & allowances	Annual surrender; cap declines over time
TCFD / CFD Regs 2022	Large companies/LLPs (500+ employees & £500m turnover; traded/banking/AIM 500+)	TCFD-aligned: governance, strategy, risk, metrics & targets	Non-financial & sustainability statement in the Strategic Report	FY from 6 Apr 2022
UK SRS (IFRS S1/S2)	Voluntary now; FCA consulting for listed companies	Full sustainability/climate disclosure incl. material Scope 3, scenario analysis	Annual report (financial filing)	Published 25 Feb 2026 (voluntary); mandatory from 2027 (proposed)
PPN 006 (06/21)	Suppliers bidding for central-gov contracts over £5m/yr; NHS (any value)	Carbon Reduction Plan: Scope 1, 2 & subset of Scope 3; net zero by 2050	Published on supplier website; pass/fail in procurement	From 30 Sep 2021; updated annually

10. Recent & upcoming developments

October 2023: DESNZ call for evidence on Scope 3 reporting and the future of the SECR regime.
April 2025: accounting size-threshold uplift (SI 2024/1303). SECR thresholds were unchanged, so some newly “medium” companies still report under SECR.
June 2025: 2025 GHG conversion factors published by DESNZ, with a ~15% fall in the electricity factor.
11 June 2026: 2026 GHG conversion factors published by DESNZ, the current set for 2026 reporting.
25 February 2026: UK SRS S1 and S2 published for voluntary use; FCA consulting on mandatory adoption for listed companies from 2027.
January 2026, DESNZ Post-Implementation Review: retain SECR with targeted reforms. Strong value for money (benefit-cost ratio 2.72; net present social value about £5.1bn over 2019–2025), with recommendations to improve ISSB/TCFD alignment, clarify boundaries, consider forward-looking elements, provide templates, strengthen enforcement and explore centralised data access.

Direction of travel. Expect SECR to remain in place in the near term, but to be progressively harmonised with UK SRS to reduce duplication. Treat suggestions that SECR will be “merged into” UK SRS, or that Scope 3 will become mandatory, as commentary, not confirmed government policy.

FAQ

11. Comprehensive FAQ

The questions advisers and finance teams ask most often.

Do dormant companies have to report under SECR?

A dormant company has no significant accounting transactions and, in practice, will not have consumed energy. If it has, it would still test against the low-energy-user exemption (40,000 kWh or less). A dormant company that is not large and is not quoted is out of scope; if technically in scope but a low energy user, it simply states the exemption.

We were large last year but not this year. Do we still report? (The two-year rule)

SECR uses the Companies Act 2006 size definition, which includes a two-year rule (s.465(2)): a change in qualification only takes effect once the conditions are met (or cease to be met) for two consecutive financial years (subject to first-year rules). So a single year below the thresholds does not automatically take you out of scope. Track your figures across consecutive years.

Can we exclude a subsidiary from group reporting?

Yes. A subsidiary that would not be in scope of SECR in its own right may be excluded from the group report. But a subsidiary large enough to be in scope on a standalone basis must be included. This is more flexible than ESOS, which is 'one in, all in'.

What intensity metric should we use?

At least one ratio relating emissions to an activity or financial metric: commonly tCO₂e per £m turnover or per full-time-equivalent employee, but sector-specific metrics (per m², per unit produced, per delivery, per pupil) are often more meaningful. Choose one that is relevant, keep it consistent year on year, and make sure it can be recalculated from the figures in the report.

Do we need third-party verification or assurance?

No. Assurance is not mandatory under SECR. It is recommended as best practice, and where obtained you should disclose its nature and extent. The FRC found assurance was rarely explained and flagged this as an area for improvement.

Do unquoted companies report overseas energy use?

No. Large unquoted companies and LLPs report only UK energy use and the associated emissions. Only quoted companies report globally. Overseas energy can be reported voluntarily.

How do we handle missing data?

Use a reasonable estimate derived from verifiable data: pro-rating part-period data, comparing with a comparable period, or benchmarking. Under 'comply or explain' you may omit information that is genuinely impractical to obtain, but you must state what is omitted, why, and the steps you are taking to obtain it in future.

Is there an official template?

No prescribed statutory template exists, a gap repeatedly highlighted by stakeholders and in the 2026 Post-Implementation Review. The March 2019 Environmental Reporting Guidelines provide worked examples and a recommended structure, and clearer templates are among the PIR's reform recommendations.

Do charities and not-for-profits report?

Yes, if a charitable company meets the large two-of-three test. It reports in a combined directors'/trustees' report. A charity that is a public body is out of scope.

Do academy trusts report?

Yes, if large (assessed at multi-academy-trust level). They typically use tCO₂e per pupil as the intensity ratio. DfE guidance for academy trusts was updated in July 2025.

Do public bodies report?

No. Public bodies are out of scope, though they may have other obligations such as the Greening Government Commitments. Note that not all organisations delivering public services are public bodies.

Our parent is overseas (e.g. NYSE-listed). What do we report?

A UK entity in scope reports in its own right to Companies House, based on the requirements that apply to it as an individual entity. You do not pull in the overseas group's global figures.

We buy a 100% renewable tariff. Can we report Scope 2 as zero?

Not straightforwardly. Reporting renewable electricity is not mandatory, and the guidance encourages dual reporting: a location-based figure (grid average) and a market-based figure (the green contract). Be transparent about how the energy is generated and supplied; a labelled tariff alone, backed only by purchased REGOs, may not justify a clean zero.

Does green gas (biomethane/biogas) have to be reported?

DESNZ confirmed in September 2025 that green gas is treated as renewable energy, so the same rules as renewable electricity apply: not currently mandatory to include, but dual reporting is recommended if you do.

Does ESOS compliance mean we automatically comply with SECR?

No. They are separate schemes with different qualification tests and outputs (ESOS is a private energy audit; SECR is a public annual disclosure). But many entities are in both, and ESOS audit and transport data can be reused for SECR.

Is a 'large company' the same under ESOS and SECR?

No. SECR uses the Companies Act 'large company' definition (two of: £36m turnover / £18m balance sheet / 250 employees). ESOS uses 'large undertaking' (250+ employees, OR turnover over £44m AND balance sheet over £38m). The tests produce different scope outcomes.

Do we report employee home-working emissions?

Not mandatory: home working is Scope 3, which is voluntary under SECR. It is encouraged for net zero planning.

Do we need prior-year comparatives in our first year?

No. Comparatives are required from the second mandatory reporting year. You may provide them voluntarily in year one.

Who signs the LLP report?

An LLP prepares an Energy and Carbon Report, which must be approved by the members and signed on behalf of all members by a designated member, and filed with the accounts.

How do we treat company EVs charged on site?

On-site EV charging is usually captured within building electricity (Scope 2). Report transport EV electricity separately only if it is sub-metered, and then deduct it from the building total to avoid double counting.

What happens if we don't comply?

There is no SECR-specific fine. Enforcement runs through the Companies Act: the FRC can apply to court (s.456) to require a revised report; directors or members who approve a non-compliant report can commit an offence under ss.415/419 punishable by an unlimited fine; and Companies House can reject accounts and apply late-filing penalties.

12. Practical resources

HM Government Environmental Reporting Guidelines: Including SECR guidance (March 2019): the official BEIS/DESNZ guidance (GOV.UK).
SI 2018/1155: the core legislation (legislation.gov.uk).
UK Government GHG Conversion Factors for Company Reporting: published annually each June by DESNZ (the 2026 set was published on 11 June 2026).
GHG Protocol Corporate Standard and ISO 14064-1:2018: recommended methodologies.
FRC Thematic Review: SECR (8 September 2021), findings on methodology, boundaries, intensity ratios and assurance.
DESNZ SECR evaluation and 2026 Post-Implementation Review (GOV.UK).
ICAEW guidance on company size, the directors' report and TCFD/CFD reporting.

What the FRC's 2021 thematic review actually said. Sampling 27 entities, the FRC concluded that while reports largely complied with the minimum statutory requirements, more was needed to make disclosures understandable and relevant, and the extent of any third-party assurance was inadequately explained in most cases. Its expectations: present information clearly; explain methodologies; reconcile and explain the choice of intensity ratio; describe the extent of any assurance; describe principal energy-efficiency initiatives in the current and comparative periods; and clearly explain major commitments such as net zero targets.

13. How Periscope eco helps you become SECR-compliant

Periscope eco is a UK carbon-intelligence platform built around the real reporting workflow, not just a calculator. Two tools share one carbon dataset, so the story you tell your auditor and the story you tell your board start from the same source of truth.

Periscope Reporting: every emission captured, every report ready

Periscope Reporting is emissions capture and carbon reporting for UK sustainability and finance teams. It removes the year-end scramble by building your dataset from live operations throughout the year:

Scope 1, 2 & 3 capture at source: activity is recorded against scope, category and the asset that produced it, so all three scopes share one structured model instead of scattered spreadsheets.
Evidence stays attached: every figure carries its conversion factor, source note and supporting file, addressing the FRC's call for clearly explained methodology.
Automated chasing: guided links reach the finance, estates and operations colleagues who own each input; contributors submit figures and evidence without needing a full login, while ownership and status stay visible to your team.
Auditor-ready SECR export: the disclosure section, supporting schedules and methodology context generate from your live dataset, with portable outputs in DOCX, PDF, XLSX, CSV, JSON and HTML.
Automatic intensity ratios and year-on-year comparatives: calculated from the same records, so the numbers in your narrative always reconcile with the underlying schedules.

Periscope Benchmarking: know exactly where you stand

Periscope Benchmarking turns your SECR data into competitive context:

Sector-relative carbon health score and percentile ranking, so you can see how you compare with your market.
Competitor and supplier comparison: useful for tenders, PPN 006 carbon reduction plans, and investor or customer questionnaires.
Free to start, shareable reports: credible numbers you can take into a boardroom or bid.

Built for businesses, finance teams and consultants

Build the dataset once. Export whenever reporting needs it.

Sustainability managers run one model from collection to disclosure; finance and compliance teams start from structured, traceable records rather than another workbook handoff; and ESG consultants standardise collection and review across every client while owners stay responsible for their own inputs.

Try Periscope free →See the SECR workflow

Recommendations

Stage 1: confirm your position (now)

Test scope against the unchanged £36m / £18m / 250 SECR thresholds. Do not assume the April 2025 accounting uplift removes you.
Map your group structure and decide which entity reports and at what level.
Confirm whether the 40,000 kWh low-energy-user exemption applies (and still state it if so).
Trigger to escalate: if you are within ~10% of any two thresholds, growing by acquisition, or have complex landlord/tenant arrangements, treat yourself as likely in scope and build data systems now.

Stage 2: build a repeatable data architecture

Integrate energy and fuel data capture into monthly procurement and accounts-payable cycles; deploy sub-metering for significant assets.
Standardise transport data: prefer litres of fuel via fuel cards; otherwise convert mileage with vehicle-specific factors. Separate fleet from grey fleet and deduct private mileage.
Adopt the GHG Protocol, use the latest DESNZ conversion factors, and document methodology and organisational boundary in full.
Periscope Reporting gives you this data architecture out of the box: capture at source, evidence attached, automated chasing and a one-click SECR export. See the workflow →

Stage 3: report to a higher standard

Use dual reporting for renewable tariffs/REGOs/PPAs and disclose the basis.
Choose a meaningful, consistent intensity ratio that can be recalculated from the report.
Write a specific, non-boilerplate efficiency narrative tied to quantified actions; disclose any assurance obtained.

Stage 4: future-proof for UK SRS

Build emissions data once, to UK SRS quality, and reuse it across SECR, TCFD/CFD, PPN 006 and voluntary disclosures.
Begin closing the gap on material Scope 3, governance and scenario analysis ahead of any mandatory UK SRS adoption.

Caveats

Forward-looking reform is not yet law. Statements that SECR will be “merged into” UK SRS, that Scope 3 will become mandatory, or that intensity ratios will be standardised reflect commentary and the direction of the 2026 PIR's recommendations, not confirmed government commitments. The PIR's stated position is to retain SECR with targeted reforms.
Attribution of energy savings is uncertain. DESNZ reported SECR-attributable savings of about 4.5% in 2020, 6.2% in 2021 and 4.9% in 2022, but treats the 2022 figure cautiously given attribution challenges. The 2.72 benefit-cost ratio is the central estimate.
Scope numbers evolve. Earlier estimates put the SECR population at around 11,900; DESNZ's 2026 analysis estimates approximately 19,900 entities in scope, of which around 14,000 must report directly.
Always check primary sources. Conversion factors change annually; guidance and thresholds can change. This guide is informational and not a substitute for advice from a qualified adviser or the official GOV.UK guidance.

Where Periscope eco fits

From the rules to a board-ready report.

Knowing the regime is one thing; producing the numbers every year is another. Periscope eco turns this guide into a few hours of work, not a consulting engagement.

Connect your energy data for automatic Scope 1 & 2 (and relevant Scope 3) calculations on the latest DESNZ factors.
A report-ready SECR output for your Directors' Report, with intensity ratios and prior-year comparatives built in.
Year-on-year tracking, auditor-ready, and no carbon expertise required.

Start your carbon reporting →See the SECR workflow

Get the full guide as a PDF

Enter your email and we’ll send you the complete “Become a SECR Expert” guide as a printable PDF, ready to share with your finance, estates and sustainability teams.

From the regulations to a report

Make next year's SECR report effortless.

Capture your energy data once and Periscope keeps it auditor-ready, with the numbers on demand whenever reporting needs them.

Start free →Download the guide