General SECR Questions
When is the SECR deadline in 2026?
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.
What is the SECR reporting threshold?
Three categories of organisation are in scope:
- Quoted companies are in scope by virtue of being quoted, with no size test
- Large unquoted companies qualify if they meet at least two of three Companies Act 2006 size tests: turnover of £36 million or more, balance sheet total of £18 million or more, or 250 or more employees on average over the year
- Large LLPs use the same size tests as unquoted companies
How does SECR interact with UK SRS?
SECR remains in force as of May 2026 alongside the new UK Sustainability Reporting Standards published 25 February 2026 by the Department for Business and Trade.
UK SRS S2 (climate disclosures) becomes proposed mandatory from 1 January 2027 for approximately 515 primary-listed companies. For the great majority of SECR-scope organisations — large unquoted companies and LLPs — UK SRS is not yet a direct obligation.
Is SECR being phased out?
Not yet. The government's response to the UK SRS consultation (25 February 2026) committed DESNZ to 'consider how the SECR requirements interact with UK SRS with a view to reducing unnecessary duplication where possible'. This is a review commitment, not a phase-out announcement. SECR itself remains the active mandatory framework for large UK companies and LLPs in 2026.
Scope and Qualification
Do overseas subsidiaries need to report under SECR?
No. SECR only applies to UK-incorporated entities. Overseas subsidiaries of UK companies are not directly subject to SECR requirements, even if their UK parent company is in scope.
However, UK companies may choose to include their global operations in SECR reporting for completeness, though this is not required by the regulations.
Can companies voluntarily adopt SECR?
Yes. Companies below the SECR thresholds can voluntarily adopt SECR reporting standards. This is sometimes done to:
- Prepare for potential future obligation
- Align with customer or investor expectations
- Integrate with broader ESG reporting frameworks
- Support sustainability strategy implementation
What about companies that are just below the threshold?
Companies just below the SECR thresholds are not required to report but should monitor their qualification status annually. If they cross the thresholds in future years, SECR reporting becomes mandatory.
Many companies close to the thresholds choose to prepare internally for SECR compliance even if not yet required, to avoid rushed implementation if they subsequently qualify.
How is the 250 employee threshold calculated?
The 250 employee threshold is calculated as the average number of persons employed by the company during the financial year. This includes:
- Full-time employees
- Part-time employees (counted as fractions based on working time)
- Directors who are also employees
- Seconded employees working for the company
Contractors, consultants, and agency workers are typically excluded from the count unless they have employee status.
Data and Reporting Requirements
What energy consumption must be reported?
SECR requires reporting of total UK energy consumption in kilowatt hours (kWh), covering:
- Electricity: All UK premises and facilities
- Natural gas: All UK sites with gas supply
- Transport fuels: UK vehicle fleet (petrol, diesel)
- Other fuels: Heating oil, LPG, biomass, district heating
The key principle is UK energy consumption only — overseas operations are excluded unless voluntarily included.
What greenhouse gas emissions must be calculated?
SECR requires disclosure of:
- Scope 1 emissions: Direct emissions from company-owned sources (combustion in owned boilers, vehicles, industrial processes)
- Scope 2 emissions: Indirect emissions from purchased electricity, steam, heating, and cooling
Scope 3 emissions (other indirect emissions) are not required under SECR but are increasingly reported voluntarily and will be required under UK SRS S2 from 2027.
What if we don't have all the energy data?
The government guidance requires companies to make reasonable efforts to obtain energy consumption data. Where data is not available:
- Estimate using alternative data: Pro-rata calculations based on floor area, working days, or other proxies
- State the limitation: Clearly disclose what data is estimated and why
- Improve for next year: Put systems in place to capture missing data going forward
Complete data absence without reasonable estimation efforts may not meet SECR compliance requirements.
Can companies use different methodologies?
Companies can choose their calculation methodology but must:
- Use a consistent methodology year-on-year
- Clearly describe the methodology in the SECR report
- Follow recognized standards (GHG Protocol Corporate Standard is most common)
- Use appropriate emission factors (UK Government factors recommended)
Changes to methodology should be clearly disclosed with explanation of the reason for change.
Compliance and Penalties
What are the penalties for non-compliance?
SECR itself does not carry separate penalty provisions. Late filing triggers the standard Companies House late filing penalties under Companies Act 2006 section 453:
Private companies/LLPs:
- Up to 1 month late: £150
- 1-3 months late: £375
- 3-6 months late: £750
- Over 6 months late: £1,500
Public companies:
- Up to 1 month late: £750
- 1-3 months late: £1,500
- 3-6 months late: £3,000
- Over 6 months late: £7,500
What about incomplete or inaccurate SECR reports?
While there are no specific penalties for incomplete SECR reports, directors have a duty to ensure accounts are accurate. Deliberately false or misleading information in directors' reports could result in:
- Director disqualification proceedings
- Investigation by Companies House or the Financial Reporting Council
- Reputational damage if errors are discovered
- Audit qualification if external audit required
Do we need external assurance for SECR?
External assurance is not mandatory under SECR regulations. However, many companies choose independent verification because:
- Quoted companies: Stakeholder expectations for verified data
- Best practice: Enhances credibility of climate reporting
- Preparation: Building capability for UK SRS requirements (which may require assurance)
- Risk management: Reduces likelihood of material errors
When evaluating carbon consultants and assurance providers through tender processes, companies increasingly use RFP software to manage vendor proposals and compliance requirements efficiently.
What happens if we qualify for SECR mid-year?
If a company meets SECR thresholds for the first time during a financial year, SECR reporting applies to that full financial year. Companies cannot pro-rate their first year of compliance.
This means companies approaching the thresholds should monitor their qualification status and prepare for potential SECR compliance before the year-end.
Technical Questions
How do we calculate the intensity ratio?
The intensity ratio expresses emissions per unit of a relevant business metric. Common approaches:
Revenue-based (most common):
Total emissions (tCO₂e) ÷ Revenue (£million) = tCO₂e per £million turnover
Employee-based:
Total emissions (tCO₂e) ÷ Average FTE employees = tCO₂e per employee
Production-based (manufacturing):
Total emissions (tCO₂e) ÷ Units produced = tCO₂e per unit
The ratio should be relevant to the business model and allow meaningful year-on-year comparison.
What emission factors should we use?
The UK Government publishes annual greenhouse gas reporting conversion factors which are updated each year. Most companies use these factors for consistency with other UK reporters.
Key principles:
- Use factors from the relevant reporting year
- Apply UK-specific factors where available
- Include transmission and distribution losses for electricity
- Document which factors are used for audit trail
Can we use renewable energy certificates?
For Scope 2 emissions (electricity), companies can choose between:
- Location-based method: Use grid-average emission factors
- Market-based method: Reflect contractual arrangements including renewable certificates
SECR regulations don't specify which method to use, but the chosen approach should be clearly disclosed and consistently applied year-on-year.
What about energy efficiency actions?
SECR requires narrative description of energy efficiency actions undertaken during the financial year, or a statement that no such action was taken. Examples include:
- LED lighting upgrades
- Building management system improvements
- Equipment replacement with more efficient alternatives
- Behavioural change programs
- Renewable energy installations
The description should be specific and quantify energy savings where possible.
UK SRS Transition Questions
Should quoted companies prepare for UK SRS now?
Yes. Quoted companies likely to be in scope for UK SRS S2 from 2027 should begin transition planning in 2026. UK SRS S2 is significantly more comprehensive than SECR and requires:
- Enhanced governance processes
- Expanded data collection (including Scope 3)
- Risk and opportunity assessment
- Scenario analysis and transition planning
Will SECR data be useful for UK SRS?
SECR provides a foundation for UK SRS compliance but additional requirements include:
- Scope 3 emissions across 15 categories
- Climate-related financial risk assessment
- Transition plan development and disclosure
- Enhanced governance and strategy disclosure
Companies with robust SECR processes will be better positioned for UK SRS implementation.
What about companies not subject to UK SRS?
Large unquoted companies and LLPs (most SECR-scope organisations) are not initially captured by UK SRS proposals. However, they should monitor:
- Customer supply chain requirements
- Investor ESG expectations
- Potential future scope expansion
- Voluntary adoption opportunities
Getting Help
Where can I find official guidance?
The primary official sources are:
- GOV.UK Environmental Reporting Guidelines: Complete implementation guidance
- SECR Regulations (SI 2018/1155): Full legislative requirements
- Companies House guidance: Filing and accounts integration
- UK Government emission factors: Annual calculation factors
What about professional support?
Many companies use external specialists for:
- Initial SECR scope and methodology assessment
- Data collection system design
- Calculation and verification services
- Ongoing compliance management
- UK SRS transition planning
Professional support is particularly valuable for first-time filers or companies with complex operations.