The three categories in scope
SECR applies to three categories of organisation: quoted companies (of any size), large unquoted companies and large LLPs.
Quoted companies face no size test at all — a quoted micro-company is in scope; unquoted companies and LLPs are only caught once they count as large.
The "large" test: two of three conditions
An unquoted company or LLP is large for SECR if it meets at least two of these three conditions in the financial year:
For parent companies the test is applied to the group in aggregate: £36m net / £43.2m gross turnover, £18m net / £21.6m gross balance sheet, 250 employees.
The April 2025 divergence trap
In April 2025 the Companies Act section 465 size thresholds for accounts purposes moved from £36m to £54m turnover and from £18m to £27m balance sheet.
SECR's thresholds were not uprated.
Schedule 7 paragraphs 20B and 20C set their own figures and do not cross-refer to section 465 — they still read £36m / £18m / 250.
The practical consequence: a company that has moved down from large to medium-sized for accounts purposes can still be in SECR scope.
DESNZ restated the £36m / £18m / 250 test as current in its post-implementation review of SECR.
Exemptions
The main exemption is the low energy user route — but its wording differs by category:
- Unquoted companies and LLPs: 40,000 kWh or less in the United Kingdom, and the report must say the exemption is being used.
- Quoted companies: 40,000 kWh or less with no UK qualifier — measured on the same global basis they report on.
Eligibility is not the end of the question
Being in scope determines that you must disclose; what you must disclose differs between quoted companies (Schedule 7 Part 7) and unquoted companies and LLPs (Part 7A).
See our SECR requirements guide for the disclosure content, and SECR thresholds for the numbers in more depth.
For how SECR sits alongside the newer UK sustainability standards, see the SECR reporting guide on uksrs.org.uk.