Streamlined Energy and Carbon Reporting · UK
SECR: the complete guide for 2026
SECR — Streamlined Energy and Carbon Reporting — is not a filing you make: it is a set of disclosures inside a document you already file, the directors’ report.
This guide covers who is caught, what the section must contain, and why the SECR deadline is simply your accounts filing deadline.
It also covers the trap most guides miss: since April 2025 the SECR size test and the Companies Act size test are no longer the same.
What SECR is
A section of the annual report, not a submission
There is no SECR form, no SECR portal and no SECR regulator you send anything to.
The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 amended the accounts regulations so that certain companies put energy and emissions disclosures into the directors’ report.
The instrument was made on 6 November 2018 and applies to financial years beginning on or after 1 April 2019.
It replaced the CRC Energy Efficiency Scheme, which closed after the 2018–19 compliance year.
An LLP has no directors’ report, so its members prepare a separate energy and carbon report instead.
Either way the report goes to Companies House with the annual accounts, on the ordinary accounts timetable, which is why almost every question about the SECR deadline is really a question about the accounts filing deadline.
Three homes in the law
| Population | Where the duty sits |
|---|---|
| Quoted companies | SI 2008/410 Sch 7 Part 7 |
| Large unquoted companies | SI 2008/410 Sch 7 Part 7A |
| Large LLPs | SI 2008/1911 reg 12B |
Inserted by SI 2018/1155 regs 6, 7 and 10, in force 1 April 2019.
Who must comply
Three ways in, and only one has no size test
Quoted companies are in scope because they are quoted, at any size: Schedule 7 paragraph 15 applies Part 7 to every quoted company.
A quoted company is 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, under section 385 of the Companies Act 2006.
AIM is not the Official List, so a company on AIM is unquoted for SECR and faces the size test.
Large unquoted companies are caught when they fail the exemption in Schedule 7 paragraph 20B, which is met by satisfying two or more of: turnover not more than £36 million; balance sheet total not more than £18 million; not more than 250 employees.
Put the other way round, a company is in scope when it exceeds at least two of those limits, and a company sitting exactly on a limit has not exceeded it.
A change of size only counts when it lasts two consecutive financial years.
Large LLPs face the same figures under a different instrument, SI 2008/1911 regulation 12B, which switches paragraph 20B off for LLPs and carries its own table — see SECR for LLPs.
Everything else — partnerships that are not LLPs, sole traders, bodies that are not companies — sits outside the regime, though nothing stops anyone reporting voluntarily.
The limits, the group test and worked examples are on SECR thresholds, and the exemptions and reliefs on SECR eligibility.
SECR scope check · Sch 7 ¶15, ¶20A–20C · reg 12B
Answer the questions and the result appears here.
Applies SI 2008/410 Sch 7 ¶15(1), ¶20A–20C and SI 2008/1911 reg 12B as written. A company exactly on a limit has not exceeded it. A guide to the test, not advice on your figures.
The April 2025 divergence
Medium-sized for your accounts, still reporting under SECR
Everyone assumes the SECR threshold is the one in their accounts.
Since 6 April 2025, it is not.
SI 2024/1303 raised the Companies Act medium-sized limits for financial years beginning on or after 6 April 2025, from £36 million to £54 million turnover and from £18 million to £27 million balance sheet.
SECR’s own test in paragraph 20B writes £36 million, £18 million and 250 into its own table and never cross-refers to section 465, so the uplift could not reach it.
The uplifting instrument amended Parts 3 and 4 of Schedule 7 and left Part 7A alone, and DESNZ restated the £36 million / £18 million / 250 figures in its post-implementation review thirteen months later.
So a company reclassified from large to medium-sized for its accounts has not left SECR scope, and may have stopped reporting on the strength of an accountant’s note about a different test.
| Limb | Companies Act s.465 (accounts) | SECR Sch 7 ¶20B |
|---|---|---|
| Turnover | Not more than £54m | Not more than £36m |
| Balance sheet total | Not more than £27m | Not more than £18m |
| Employees | Not more than 250 | Not more than 250 |
| Moved on 6 April 2025? | Yes, by SI 2024/1303 | No |
What must be disclosed
Seven disclosures, and the list differs by type
The regulations never say “Scope 1” or “Scope 2”: they describe emissions by activity, and the Scope labels come from the government’s guidance and the GHG Protocol.
That matters because the quoted and unquoted lists are genuinely different.
| Disclosure | Quoted companies (Part 7) | Unquoted companies and LLPs (Part 7A) |
|---|---|---|
| Energy use, in kWh | Worldwide total, with the proportion relating to the UK and offshore area (¶15(3A)–(3C)) | Gas, transport fuel and purchased electricity; energy used outside the UK may be excluded (¶20D(3), (5)) |
| Emissions from the entity’s own activities | Activities it is responsible for, including combustion of fuel and operation of any facility (¶15(2)) | Combustion of gas and consumption of fuel for transport (¶20D(1)) |
| Emissions from purchased energy | Electricity, heat, steam or cooling bought for own use (¶15(3)) | Electricity bought for own use, including for transport (¶20D(2)) |
| Intensity ratio | At least one ratio of emissions to a quantifiable factor (¶17) | The same (¶20G) |
| Methodology | The methodologies used (¶16) | The same (¶20F) |
| Energy efficiency | Principal measures taken in the year (¶15(3D)) | Principal measures, if any were taken (¶20D(4)) |
| Prior-year comparatives | From the second year (¶18 and ¶18A) | From the second year (¶20H) |
Quoted companies report worldwide, and the unquoted-company list is closed where the quoted list is illustrative.
Unquoted companies and LLPs may exclude energy and emissions outside the UK: an option in paragraph 20D(5), not a requirement.
The unquoted list includes fuel used for transport, which most people would file under Scope 3 — in practice the grey fleet, and the element most often missed.
Most reports calculate with the GHG Protocol Corporate Standard and the 2026 UK Government conversion factors, published by DESNZ on 11 June 2026.
Nothing in either Part requires assurance, a target or a transition plan.
The paragraph-by-paragraph duty is set out on SECR requirements, and a worked section on SECR reporting.
When it is due
Your accounts deadline is your SECR deadline
Section 442 of the Companies Act 2006 gives a private company nine months after its accounting reference date and a public company six.
An LLP has nine months under the LLP accounts regulations.
A private company with a 31 December 2025 year end had to file by 30 September 2026; with a 31 March 2026 year end, by 31 December 2026.
A deadline that falls on a weekend or a bank holiday does not move, as Companies House’s own late filing penalties guidance says.
Miss it and the penalty is the ordinary section 453 civil penalty on the company: £150 to £1,500 for a private company, £750 to £7,500 for a public one, doubled if the previous year’s accounts were also late.
There is no separate SECR penalty and no separate SECR extension.
Companies House announced on 9 June 2026 that accounts filing changes arrive in April 2028, including software-only iXBRL filing and the end of abridged accounts; the nine- and six-month periods are in section 442 itself.
First accounts, shortened periods and worked examples are on SECR deadlines.
Deadline calculator · CA 2006 ss.442–443
Accounts, with the SECR disclosures, due by
Computed as 9 months after the accounting reference date, running month end to month end.
Companies Act 2006 s.442(2)–(3) and s.443; LLPs under SI 2008/1911 reg 17. Does not apply a shortened period (s.442(4)) or an extension (s.442(5)).
Is SECR going away?
No — and the government’s own review says so
The claim that SECR is being phased out and replaced by UK SRS is widespread, and it is wrong.
The 2026 post-implementation review recommends retaining the SECR requirements with amendments.
It warns that “removing SECR would risk reversing gains in transparency and board level accountability, particularly among privately owned companies and LLPs where voluntary disclosure is less consistent”.
When UK SRS was published, the government committed only that DESNZ “will consider how energy and emissions data reported by an entity using UK SRS interacts with the SECR requirements, with a view to reducing unnecessary duplication where possible” — in its response to the UK SRS consultation.
The modernising corporate reporting consultation proposes abolishing the directors’ report, which would move where SECR disclosures sit, and says DESNZ intends to consult on SECR and ESOS later in 2026.
Neither is law, and every statement of the SECR duty on this site is a statement of current law.
On UK SRS, the FCA’s final rules (PS26/19, 30 September 2026) require listed companies in scope to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
That finalises CP26/5, which estimated around 600 listed companies would be affected, against about 19,900 entities in SECR’s scope; the FCA’s reporting requirements page covers the listing-rule side.
The comparison is set out in full at SECR vs UK SRS, and the broader standards are covered by our sister reference at UK SRS compliance.
SECR: in force, unchanged since 1 April 2019.
DESNZ post-implementation review (26 May 2026): retain with amendments.
Modernising corporate reporting (7 September 2026): a consultation, closing 30 November 2026.
UK SRS: FCA final rules for listed companies, comply-or-explain from 2027.
What it costs, and what it achieved
More entities, higher costs, and still worth keeping
The independent evaluation published by DESNZ on 29 January 2026 found about 19,900 quoted companies, large unquoted companies and large LLPs that need to report.
Most, about 14,000, must report the data themselves and cannot rely on a parent company’s disclosure, and the evaluation’s machine-read accounts data suggests a further 1,300 claim the low energy user relief.
The 2018 impact assessment behind the original SECR consultation had forecast 11,300 in scope.
The review’s summary compares an actual ongoing cost of £140 million a year with £31 million predicted at policy design stage, both in 2025 prices.
It puts the total cost to business across 2019–2025 at approximately £3 billion.
It still finds the regime worth keeping, on monetised benefits of £8.1 billion against those costs.
The Regulatory Policy Committee rated the review fit for purpose on 15 May 2026.
The review also found businesses could re-use SECR data for other schemes “easily” in 40–71% of cases, depending on the scheme — the strongest argument for building the data collection once.
The neighbouring regimes
SECR is rarely the only thing asking for this data
The Energy Savings Opportunity Scheme is the closest neighbour and the most often confused.
It uses a different size test, built as “either / or” rather than two of three, so being in SECR scope tells you nothing about ESOS and the reverse is equally true.
The Environment Agency’s Phase 4 guidance sets a qualification date of 31 December 2026, notification by 5 December 2027, an action plan by 5 December 2028 and progress updates due on 5 December 2029, 2030 and 2031.
Our sister reference covers ESOS meaning and requirements and ESOS Phase 4 compliance, and sets ESOS against SECR side by side.
On this site, ESOS vs SECR compares the tests and ESOS and SECR reporting shows how one data set can serve both.
The largest companies also make climate-related financial disclosures in the strategic report, a separate regime with a different population that SECR does not import.
Our sister reference keeps its own SECR guide alongside its UK SRS coverage.
| SECR | ESOS Phase 4 | |
|---|---|---|
| Size test | Exceed two of £36m / £18m / 250 | At least 250 employees, or turnover over £44m and balance sheet over £38m |
| What it asks | Annual disclosure in the accounts | Four-yearly energy assessment |
| Next date | Your accounts deadline | Qualification date 31 Dec 2026; notify by 5 Dec 2027 |
Implementation
Six things a compliant SECR section rests on
Scope
Confirm the entity is in scope against the current Schedule 7 figures, not the accounts classification, and record the test for the audit file.
Data
Collect energy use for gas, electricity and transport fuel across every site and business unit, monthly rather than in a year-end scramble.
Methodology
Choose a calculation approach and write it down, because the methodology itself is a required disclosure.
Intensity ratio
Pick a denominator that will still make sense in three years, since comparatives are required from year two.
Reliefs
If any relief is used — low energy, impracticable, seriously prejudicial — say so in the report, with the reason.
Review
SECR does not require assurance, but the auditor reads the section for consistency with the accounts.
Common failure points are data from multiple sites, methodology drift from year to year, an intensity ratio that stops meaning anything, and forgetting that transport fuel is in scope for unquoted companies.
The government’s SECR guidance still dates from March 2019; what it gets right and where it has aged is covered on SECR guidance.
Common audit findings and where outside help is worth having are on SECR compliance, and every question we are asked is on the SECR FAQ.
For outside help, our sister sites have independent guides to sustainability consultancy for SECR compliance, carbon consultancy for emissions calculations and net zero consultancy for transition planning beyond compliance.
Their editorial home is sustainabilityreportingstandards.co.uk, which also keeps a UK SRS FAQ.
To talk a specific question through, you can book a free 15-minute call.
Key dates
SECR from 2019 to today
The 2019 text of Part 7A is the text in force today.
Everything since has been around it: a new enforcement body, a new accounts size test, a review, a consultation and the FCA’s UK SRS rules.
The Schedule 7 text on legislation.gov.uk carries one amendment note against Part 7A: its insertion by SI 2018/1155 in 2019.
Enforcement runs through the Companies Act: an offence for directors who approve a non-compliant directors’ report, and FRC review of published reports, with no SECR-specific penalty.
How that works in practice is set out on SECR enforcement.
- 1 Apr 2019SECR in force
For financial years beginning on or after this date.
- 6 May 2021The FRC becomes the authorised body
For court applications about defective reports (SI 2021/465).
- 6 Apr 2025Companies Act limits rise
SECR’s own £36m / £18m / 250 test does not move.
- 29 Jan 2026DESNZ evaluation
About 19,900 in scope.
- 26 May 2026Post-implementation review
Retain with amendments.
- 7 Sep 2026Modernising corporate reporting
Consultation proposes moving the SECR disclosures.
- 30 Sep 2026FCA PS26/19
UK SRS comply-or-explain for listed companies from 2027.
Frequently asked
SECR, answered
When is the SECR deadline in 2026?
SECR is not filed separately. It sits inside the directors’ report (for an LLP, the energy and carbon report), which is delivered with the annual accounts, so the SECR deadline is the accounts filing deadline under section 442 of the Companies Act 2006: nine months after the accounting reference date for a private company or an LLP, six months for a public company. A private company with a 31 December 2025 year end had to file by 30 September 2026; one with a 31 March 2026 year end has until 31 December 2026.
What is the SECR reporting threshold?
Quoted companies have no threshold: they report at any size. An unquoted company or an LLP is in scope when it exceeds at least two of three limits: turnover of more than £36 million, a balance sheet total of more than £18 million, and more than 250 employees. The law writes this as an exemption, met by staying at or under two of the three, and a change of size counts only when it lasts two consecutive years.
Who must comply with SECR?
Three populations: quoted companies of any size, large unquoted companies, and large LLPs. The quoted-company duty is in Schedule 7 Part 7 to SI 2008/410, the unquoted-company duty in Part 7A, and the LLP duty in regulation 12B of SI 2008/1911. A company on AIM is unquoted for this purpose.
How does SECR interact with UK SRS?
They are separate regimes. UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026, and the FCA’s final rules (PS26/19, 30 September 2026) require listed companies in scope to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. Those are listing rules; SECR’s duties sit in Companies Act regulations and continue for quoted companies, large unquoted companies and large LLPs.
Is SECR being phased out?
No. The statutory post-implementation review published by DESNZ on 26 May 2026 recommends retaining the SECR requirements with amendments, and warns that removing SECR would risk reversing gains in transparency and board-level accountability. A consultation on SECR and ESOS is promised later in 2026, and the government’s modernising corporate reporting consultation proposes to move where the SECR disclosures sit, not to remove them.
Do the 2025 Companies Act threshold changes take my company out of SECR scope?
Not on their own. SI 2024/1303 raised the Companies Act medium-sized limits to £54 million turnover and £27 million balance sheet for financial years beginning on or after 6 April 2025. SECR’s test in Schedule 7 paragraph 20B writes its own figures of £36 million, £18 million and 250 employees and does not cross-refer to the Companies Act, so it did not move. A company can be medium-sized for its accounts and still in scope for SECR.
Can we leave the SECR section out if an exemption applies?
Only the size exemption works that way. The low energy user relief (40,000 kWh or less), the relief for information that is not practical to obtain and the relief for seriously prejudicial information all require the report to say what is not disclosed and why. A report that silently omits the disclosures is not relying on a relief.
Which emissions factors should we use?
Most reports use the UK Government greenhouse gas conversion factors published by DESNZ. The 2026 set was published on 11 June 2026, and DESNZ says each year’s set is for activity data falling entirely or mostly within that year, so match the factor year to the year the energy was used, not the year you file.
Does SECR apply to subsidiaries?
An unquoted subsidiary does not report itself if it is included in its parent’s group report, prepared for a parent financial year ending at the same time as or before its own. The shelter is lost where the parent relied on the seriously prejudicial relief.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- legislation.gov.ukSI 2018/1155 — the Companies (Directors’ Report) and LLPs (Energy and Carbon Report) Regulations 2018
The instrument that created SECR; made 6 November 2018, in force 1 April 2019.
- legislation.gov.ukSI 2008/410, Schedule 7 — Parts 7 (quoted companies) and 7A (unquoted companies)
The disclosure duties, reliefs and definitions.
- legislation.gov.ukSI 2008/410, Schedule 7, paragraph 20B — the unquoted-company size exemption
“Not more than” £36 million, £18 million and 250, two or more to be met; the consecutive-year rule.
- legislation.gov.ukSI 2008/1911, regulation 12B — the LLP energy and carbon report
The LLP duty, its own size table and its own offences.
- legislation.gov.ukSI 2024/1303 — Companies (Accounts and Reports) (Amendment and Transitional Provision) Regulations 2024
The April 2025 uplift of the Companies Act size limits, which did not reach Schedule 7 Part 7A.
- legislation.gov.ukCompanies Act 2006, section 465 — companies qualifying as medium-sized
£54 million / £27 million / 250 from 6 April 2025 — the accounts test, not the SECR test.
- legislation.gov.ukCompanies Act 2006, section 385 — quoted and unquoted companies
The definition that makes an AIM company unquoted.
- legislation.gov.ukCompanies Act 2006, section 442 — period allowed for filing accounts
Nine months private, six months public: the SECR deadline.
- legislation.gov.ukCompanies Act 2006, section 453 — civil penalty for failure to file accounts and reports
- Companies HouseLate filing penalties
The penalty bands, and the rule that a weekend deadline does not move.
- Companies HouseCompanies House to bring in changes to accounts filing from April 2028 (9 June 2026)
Software-only iXBRL filing and the end of abridged accounts.
- DESNZ2026 Post-Implementation Review of the SECR Regulations 2018
Published 26 May 2026: retain with amendments; cost and benefit figures; data re-use.
- DESNZStreamlined Energy and Carbon Reporting (SECR) regulations: evaluation
Published 29 January 2026 (ICF and IFF Research): about 19,900 in scope, 14,000 reporting themselves.
- Regulatory Policy CommitteeRPC opinion on the SECR post-implementation review
RPC-DESNZ-26154-PIR(1), 15 May 2026: fit for purpose.
- GOV.UKEnvironmental Reporting Guidelines, including SECR guidance
The March 2019 guidance, still the current edition.
- DESNZGreenhouse gas reporting: conversion factors 2026
Published 11 June 2026.
- GHG ProtocolCorporate Accounting and Reporting Standard
The methodology most SECR reports name.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026.
- Department for Business and TradeGovernment response to the consultation on UK SRS
The DESNZ commitment to consider SECR/UK SRS duplication.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards
Published 30 September 2026: UK SRS on a comply-or-explain basis from 2027.
- Financial Conduct AuthorityCP26/5: the consultation PS26/19 finalises
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Published 7 September 2026; ¶149 would move the SECR disclosures, ¶150 promises a SECR and ESOS consultation.
- Environment AgencyHow to comply with ESOS phase 4
The ESOS size test and Phase 4 dates.
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