SECR: The Complete Guide 2026
Streamlined Energy and Carbon Reporting is not a filing you make. It is a handful of paragraphs inside a document you already file — the directors’ report. This guide covers who is caught, what has to be in it, when it is due, and why the threshold that decides it is no longer the same threshold as your accounts.
A section, 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 must put energy and emissions disclosures into the directors’ report.
That report goes to Companies House with the annual accounts, on the ordinary accounts timetable, and it is judged by the ordinary accounts rules.
Which is why almost every question that starts “when is the SECR deadline” is really a question about Companies Act 2006 section 442.
Three ways in, and only one has no size test
Quoted companies are in scope because they are quoted. There is no turnover test, no headcount test and no exemption for being small.
Large unquoted companies and large LLPs get there a different way: they have to fail the size exemption in Schedule 7 paragraph 20B.
Everything else — charities, partnerships that are not LLPs, small and medium companies — sits outside the regime, though nothing stops them reporting voluntarily.
Full detail is in the SECR thresholds guide.
Seven things, and the list differs by type
The regulations never say “Scope 1” or “Scope 2”. They describe emissions by activity, and the Scope mapping comes from the Government’s Environmental Reporting Guidelines rather than from the law itself.
That distinction matters more than it sounds, because the quoted and unquoted lists are genuinely different: quoted companies report globally and must split out the UK and offshore proportion, while unquoted companies and LLPs may confine themselves to the UK.
Most companies calculate using the GHG Protocol Corporate Standard with the 2026 UK Government conversion factors published by DESNZ on 11 June 2026.
Worked detail is in SECR reporting.
Medium-sized for your accounts. Still reporting under SECR.
SI 2024/1303 uprated the Companies Act size limits for financial years beginning on or after 6 April 2025 — medium-sized moved from £36m to £54m turnover, and from £18m to £27m balance sheet.
SECR’s own thresholds sit in Schedule 7 paragraphs 20B and 20C, they set their own figures, and they do not cross-refer to section 465.
They were not touched. They still read £36 million, £18 million and 250 employees.
DESNZ confirmed as much in its Post-Implementation Review of 26 May 2026, which restates the £36m / £18m / 250 test as current.
So a company that was reclassified from large to medium-sized for accounts purposes has not left SECR scope, and may have quietly stopped reporting on the strength of an accountant’s note about a different test.
Five regimes, one data set
SECR is rarely the only thing asking for this data.
DESNZ asked in-scope businesses how easily their SECR data could be re-used for the other regimes they report under, and the answers are the strongest argument for building the data collection properly once.
ESOS is the closest neighbour and the most commonly confused: it uses a completely different size test, on an OR/AND structure rather than two-of-three, and its Phase 4 qualification date is 31 December 2026, with notification due by 5 December 2027.
The Environment Agency published the full ESOS Phase 4 guidance on 30 July 2026, implementing SI 2026/701: two compliance routes, an action plan due 5 December 2028 and three progress updates on 5 December 2029, 2030 and 2031.
It did not change the ESOS thresholds, so alignment with SECR remains a Phase 5 question.
Being in SECR scope tells you nothing about whether you are in ESOS scope, and the reverse is equally true.
No. And now there is a primary source that says so.
The claim that SECR is being phased out and replaced by UK SRS is widespread, and it is wrong.
The statutory Post-Implementation Review published on 26 May 2026 recommends retaining SECR with amendments, and warns in terms that removing it “would risk reversing gains in transparency and board level accountability, particularly among privately owned companies and LLPs”.
The populations barely overlap in any case. The FCA’s CP26/5 proposal would catch 515 listed companies. SECR catches roughly 19,900 entities, the overwhelming majority of which are unquoted and would not be touched by UK SRS at all.
The comparison is set out in full at SECR vs UK SRS.
Cited for
Cited against
Six things a compliant SECR section contains
Every one of these is either required by Schedule 7 or is the thing an auditor asks about first.
The regulations offer relief in three places — a low energy user under 40,000 kWh, information that is not practical to obtain, and information whose disclosure would be seriously prejudicial — but every one of them is a state-it exemption.
The report has to say positively that the information is not disclosed and why. Silently omitting the section is not compliance with an exemption; it is non-compliance.
Four and a half times the predicted cost
When SECR was designed, the impact assessment put the ongoing cost to business at £31 million a year.
The Post-Implementation Review puts the actual figure at £140 million a year in 2025 prices, and the total cost to business across 2019–2025 at roughly £3 billion.
It also finds the regime worth keeping: a benefit–cost ratio of 2.72 and a net present social value of £5.1 billion, on average energy savings of about 8 TWh a year, which the review converts to 1.7 MtCO₂e.
The Regulatory Policy Committee rated the review green on 15 May 2026.
Your accounts deadline is your SECR deadline
Nine months after the accounting reference date for a private company or an LLP, six months for a public company, under section 442.
Miss it and the penalty is the ordinary Companies House late filing penalty — £150 to £1,500 for a private company, £750 to £7,500 for a public one, doubled if you were late in the preceding year too.
There is no separate SECR penalty, and no separate SECR extension.
Companies House confirmed on 9 June 2026 that its accounts filing reforms arrive in April 2028. They change format and content — software-only iXBRL filing, the end of abridged accounts — not the nine-month and six-month periods.
More worked examples at SECR deadlines.
SECR in full
What is SECR?
Streamlined Energy and Carbon Reporting is the UK’s mandatory energy and carbon disclosure framework for large companies and LLPs. It was made on 6 November 2018 by SI 2018/1155 and came into force on 1 April 2019, having effect for financial years beginning on or after that date.
It replaced the Carbon Reduction Commitment Energy Efficiency Scheme and folded climate disclosure into the statutory accounts rather than running it as a standalone return.
SECR applies to quoted companies, large unquoted companies and large LLPs, and requires disclosure of energy consumption, greenhouse gas emissions and energy efficiency actions within the directors’ report.
Who must comply with SECR?
Three categories of organisation are in scope.
What must be disclosed?
The requirements differ between quoted companies (Part 7) and unquoted companies and LLPs (Part 7A). The seven elements below are the practical checklist.
| Disclosure | Quoted companies | Unquoted companies & LLPs |
|---|---|---|
| Energy consumption in kWh | Global total, with the UK and offshore proportion stated separately | UK only, from gas combustion, transport fuel and purchased electricity |
| Emissions from own activities (Scope 1) | Combustion of fuel and operation of any facility, in tCO₂e | Combustion of gas and consumption of transport fuel, in tCO₂e |
| Emissions from purchased energy (Scope 2) | Electricity, heat, steam and cooling purchased for own use | Electricity purchased for own use, including for transport |
| Intensity ratio | At least one ratio expressing annual emissions against a quantifiable factor associated with the entity’s activities | |
| Methodology | The methodologies used to calculate the figures disclosed | |
| Energy efficiency actions | A description of the principal measures taken in the year, where measures were taken | |
| Prior year comparatives | Required from the second year of reporting onwards | |
| Scope 3 emissions | Voluntary | Voluntary, except transport fuel, which is captured by paragraph 20D(1)(b) |
The regulations never use the words “Scope 1”, “Scope 2” or “Scope 3”. They describe emissions by activity. The Scope mapping is a convention imported from the GHG Protocol and the Government’s own guidance, not a statutory term — which is why the unquoted list captures transport fuel that most people would file under Scope 3.
DESNZ describes it as “a small amount of Scope 3 emissions from business travel”. In practice that is the grey fleet, and it is the element most often missed.
SECR deadlines in 2026
SECR is not filed separately. It sits inside the directors’ report, which forms part of the annual accounts, so the deadline is the standard Companies House accounts-filing deadline under Companies Act 2006 section 442. For detailed calculations and worked examples, see the complete SECR deadlines guide.
SECR carries no penalty regime of its own. Late filing of the SECR-bearing accounts triggers the standard Companies House late filing penalties under Companies Act 2006 section 453.
SECR and UK SRS interaction
The UK sustainability reporting standards were published on 25 February 2026 by the Department for Business and Trade, as UK SRS S1 and UK SRS S2. They are voluntary.
Current position, July 2026
- SECR remains mandatory for its existing scope
- UK SRS S1 and S2 published 25 February 2026, voluntary use only
- FCA consultation CP26/5 opened 30 January 2026 and closed 20 March 2026
- The FCA Policy Statement has not been published; the FCA still says autumn 2026
- DESNZ recommends retaining SECR with amendments
Proposed, 2027 onwards
- FCA rules proposed to come into force 1 January 2027
- Around 515 listed companies would be required to comply, of about 600 affected
- Approximately 90 of the 515 are non-UK incorporated
- Most SECR-scope entities are unquoted and outside the proposal entirely
- A 2026 consultation on streamlining energy and emissions reporting is planned but not yet launched
Implementation
- Scope assessment — determine whether SECR applies, using the SECR thresholds guidance, and check it against the current Schedule 7 figures rather than your accounts classification.
- Data collection — establish processes for energy consumption and emissions data across sites and business units.
- Methodology selection — choose a calculation approach using the SECR guidance, and record it, because the methodology itself is a required disclosure.
- Intensity ratio design — select a business metric that will still make sense in three years, since comparatives are required from year two.
- Report integration — draft the section using the SECR reporting guide and place it in the directors’ report.
- Assurance — decide whether external verification is needed; SECR does not require it, but auditors will read the section.
Common failure points are data collection across multiple sites, methodology drift year on year, choosing an intensity ratio that stops being meaningful, and forgetting that transport fuel is in scope for unquoted companies.
For companies needing outside help: sustainability consultancy for comprehensive SECR compliance, carbon consultancy for emissions calculations, net zero consultancy for transition planning beyond compliance, and SECR compliance for implementation support. On the energy audit side, understanding ESOS meaning and requirements and ESOS Phase 4 compliance matters because the two regimes share source data and nothing else.
SECR, answered
For the full set, see the complete SECR FAQ.
SECR isn’t filed separately — it sits inside the directors’ report, which is part of a company’s annual accounts. The deadline is therefore the standard Companies House accounts-filing deadline: nine months after the accounting reference date for private companies, six months for public companies, under Companies Act 2006 section 442. For a private company with a 31 December 2025 year-end, the SECR-bearing accounts are due at Companies House by 30 September 2026.
Three categories of organisation are in scope. Quoted companies are in scope by virtue of being quoted, with no size test. Large unquoted companies and large LLPs qualify if they meet at least two of three size tests in the financial year: turnover of £36 million or more, balance sheet total of £18 million or more, or 250 or more employees on average over the year.
Note that these figures sit in Schedule 7 to SI 2008/410 and were not changed by the 2024 uprating of the Companies Act size limits, so they are now lower than the medium-sized thresholds used for your accounts.
SECR remains in force as of July 2026 alongside the UK Sustainability Reporting Standards published 25 February 2026 by DBT. UK SRS is voluntary. The FCA has proposed making UK SRS S2 mandatory from 1 January 2027 for approximately 515 primary-listed companies, but its Policy Statement has not yet been published and the FCA still expects it in autumn 2026. For the great majority of SECR-scope organisations — large unquoted companies and LLPs — UK SRS is not a direct obligation.
No. The Government’s response to the UK SRS consultation (25 February 2026) committed DESNZ to “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”. That is a review commitment, not a phase-out.
The statutory Post-Implementation Review published on 26 May 2026 goes further: it recommends retaining the SECR requirements with amendments, and states 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”.
Not on their own. SI 2024/1303 raised the Companies Act size limits for financial years beginning on or after 6 April 2025 — medium-sized moved to £54 million turnover and £27 million balance sheet. SECR’s size exemption in Schedule 7 paragraphs 20B and 20C sets its own figures of £36 million and £18 million and does not cross-refer to section 465, and those figures were not amended.
A company that has become medium-sized for accounts purposes can therefore still be in SECR scope, and DESNZ restated the £36m / £18m / 250 test as current in its Post-Implementation Review of 26 May 2026.
Only the size exemption works that way. The low energy user exemption, the impracticability exemption and the seriously prejudicial exemption are all “state it” exemptions: the wording of Schedule 7 paragraph 20D requires the report to say that the information is not disclosed and why.
A directors’ report that simply omits the disclosures, without stating the reason, is not relying on an exemption.
The UK Government conversion factors published annually by DESNZ. The current set is the 2026 factors, published on 11 June 2026. Most companies apply them within the GHG Protocol Corporate Standard, and the combination is what the methodology disclosure normally describes.
Not if the subsidiary is included in a group report that itself complies, and that group report is for a parent financial year ending at the same time as or before the subsidiary’s. There is one carve-out worth knowing: a parent that relied on the seriously prejudicial exemption cannot shelter its subsidiaries under paragraph 20A(2).
Every figure, to its primary source
Last verified 27 July 2026. Where a source has been superseded, the superseding document is the one cited.
The rest of the guide
SECR thresholds
The size tests in full, the two-year qualification rule, group and subsidiary treatment, and how the 2025 Companies Act uprating changed the picture.
TimingSECR deadlines
When SECR-bearing accounts are due, worked examples by year end, extensions, and the Companies House penalty bands.
DisclosureSECR reporting
What goes in the section, how to structure it, choosing an intensity ratio, and the methodology statement.
How toSECR guidance
Step-by-step implementation, data collection, conversion factors, and the practical decisions a first-time reporter faces.
SupportSECR compliance
Assurance, common audit findings, and where outside help is worth paying for.
ComparisonSECR vs UK SRS
Two regimes, two populations. What overlaps, what does not, and what the FCA has and has not decided.
AnswersSECR FAQ
Short answers to the questions that come up most, each traced to the paragraph of Schedule 7 that settles it.
NeighbourESOS vs SECR
Different size tests, different deadlines, shared source data. Which one you are in, and why it is possible to be in one and not the other.