SECR FAQ: the questions people ask, answered

Streamlined Energy and Carbon Reporting is the UK’s mandatory energy and carbon disclosure framework for quoted companies, large unquoted companies and large LLPs. It was created by SI 2018/1155, in force on 1 April 2019, and requires disclosure of energy use, greenhouse gas emissions, an intensity ratio and energy efficiency action inside the directors’ report, or for an LLP a separate energy and carbon report.

SECR is not filed separately: it sits inside the directors’ report, which is part of a company’s annual accounts, so the deadline is the accounts filing deadline under section 442 of the Companies Act 2006 — nine months after the accounting reference date for private companies and LLPs, six months for public companies. For a private company with a 31 December 2025 year end, the accounts carrying SECR were due at Companies House by 30 September 2026.

Quoted companies are in scope at any size. Large unquoted companies are in scope where they exceed at least two of three limits — turnover above £36 million, balance sheet total above £18 million, more than 250 employees — under Schedule 7 paragraph 20B of SI 2008/410, a self-contained test that did not move when the Companies Act size limits rose in April 2025. Large LLPs face the same limits under SI 2008/1911 regulation 12B.

No. DESNZ’s post-implementation review of 26 May 2026 recommends retaining the SECR requirements with amendments. When UK SRS was published, the government committed DESNZ only to consider how UK SRS data interacts with SECR, with a view to reducing unnecessary duplication where possible — a review commitment, not a phase-out.

The unquoted-company and LLP duty has not been amended since it came into force on 1 April 2019. What has moved around it: the Companies Act size limits rose in April 2025 without moving SECR’s test; DESNZ’s review of 26 May 2026 recommends retaining SECR with amendments; the modernising corporate reporting consultation of 7 September 2026 proposes moving the SECR disclosures out of the abolished directors’ report; and DESNZ intends to consult on SECR and ESOS later in 2026. None of the proposals is law.

They are separate. UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 and are voluntary standards. 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. SECR continues alongside for quoted companies, and remains the only one of the two that applies to large unquoted companies and LLPs.

It differs by population. Large unquoted companies and LLPs report a closed list — the combustion of gas, fuel consumed for transport, and electricity purchased for their own use — and may exclude energy used outside the UK. Quoted companies report an open list of emissions from activities they are responsible for, including combustion of fuel and operation of any facility, plus purchased electricity, heat, steam or cooling, worldwide, with the UK and offshore proportion stated.

The regulations describe emissions by activity, not by Scope. For unquoted companies and LLPs: combustion of gas and consumption of transport fuel, and purchased electricity. For quoted companies: activities including combustion of fuel and operation of any facility, and purchased electricity, heat, steam and cooling. Quoted companies have no Scope 3 limb; unquoted companies and LLPs carry only fuel consumed for transport.

Paragraph 20D(6) applies the disclosure duties only to the extent it is practical to obtain the information, but where it is not, the report must state what information is not included and why. Estimating from proxies such as floor area or working days is a methodology choice, and the methodology statement should say what was estimated and how.

Yes. The regulations require the report to state the methodologies used, not to use a particular one. Most name the GHG Protocol Corporate Standard with the UK Government conversion factors. Keep the method consistent year to year, and explain any change.

Divide total reported emissions by a quantifiable factor associated with the business. Common choices are tonnes of CO2e per £ million of turnover, per average employee, per square metre of floor area, or per unit of output. The regulations require at least one ratio and leave the choice to the company; pick one that will still mean something in the comparative years.

Most reports use the UK Government greenhouse gas conversion factors published by DESNZ each June. The 2026 set was published on 11 June 2026, and DESNZ says each year’s factors are for activity data falling entirely or mostly within that year. The 2026 electricity factor uses a new methodology, so a fall in electricity emissions between 2025 and 2026 is partly a methodology change.

The SECR regulations do not specify a method for electricity emissions. A location-based figure uses the grid-average factor; a market-based figure reflects contracts such as renewable certificates. Whichever is reported, say which it is and apply it consistently.

If the company took any measures to increase its energy efficiency in the year, the report must describe the principal measures. Examples include LED lighting, building management system upgrades, more efficient equipment, behaviour-change programmes and on-site renewables. Quantify the savings where possible.

Listed companies in scope of the FCA’s final rules (PS26/19) report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reporting in 2028. A company may use a one-year relief for Scope 3 and a two-year relief for non-climate UK SRS S1 matters, stating that it is doing so. UK SRS S2 asks for more than SECR — governance, strategy, risk management and Scope 3 — and the FCA rules add a statement of whether a transition plan exists, so the data work starts before the first period.

Yes, as a foundation. SECR’s energy and Scope 1 and 2 data feed UK SRS S2’s emissions metrics, but UK SRS S2 also asks for Scope 3 across the GHG Protocol categories, climate-related risks and opportunities, and governance and strategy disclosures. DESNZ has committed to consider how UK SRS data interacts with SECR, to reduce unnecessary duplication where possible.

Large unquoted companies and LLPs — outside the FCA’s listing rules — keep their SECR duty unchanged, and UK SRS is voluntary for them. They may still see customers or investors ask for UK SRS-style data.