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.