SECR Eligibility: Who Qualifies and Who Is Exempt

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 is large for SECR if it exceeds at least two of these three thresholds in the financial year (Sch. 7 para 20B(2), an exemption test stated as "not more than" — a company sitting exactly on a limb has not exceeded it). Large LLPs face the identical numerical thresholds, but under a separate provision, SI 2008/1911 reg 12B, which expressly excludes ¶20B — LLPs file a wholly separate energy and carbon report rather than a directors’ report, with their own approval rule and their own offences, covered in full on how SECR applies to LLPs.

• Turnover: more than £36 million
• Balance sheet total: more than £18 million
• Employees: more than 250

For parent companies the test is applied to the group in aggregate, on the same exceeds-two-of-three basis: £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.

Low energy user relief

The main relief from disclosure is the low energy user route. It is not an exemption from SECR — it is relief from disclosure, conditional on the report stating the reason — and its wording differs by category:

• Unquoted companies and LLPs: 40,000 kWh or less in the United Kingdom, and the report must state that the information is not disclosed for that reason.
• Quoted companies: 40,000 kWh or less with no UK qualifier — measured on the same global basis they report on, and again conditional on stating the reason.