SECR guidance · GOV.UK
SECR guidance: the 2019 guidelines, read against the law
“SECR guidance” means one specific document: the government’s Environmental Reporting Guidelines on GOV.UK.
It is still the March 2019 edition, and the page was last updated on 29 March 2019.
Most of it still holds; a few passages now mislead, and this page sets out which, then gives the six-step method it describes.
The document
One government document, and two audiences
The guidelines say they are designed “to help companies and limited liability partnerships in complying with the Streamlined Energy and Carbon Reporting (SECR) regulations”.
They also cover voluntary environmental reporting more widely, including greenhouse gas reporting and key performance indicators.
One audience is the finance team assembling the disclosure: the guidance walks through data collection, methodology and the report’s structure.
The other is whoever reads the finished section: an auditor, an investor, a customer checking that the numbers add up.
It interprets SI 2018/1155, the regulations that created SECR; the statutory obligation itself is set out at SECR requirements on our sister reference, and on this site at SECR reporting.
The publication record
| Title | Environmental reporting guidelines: including Streamlined Energy and Carbon Reporting requirements |
| Published by | DESNZ, Defra and the former BEIS |
| First published | 12 June 2013 |
| Last updated | 29 March 2019 |
| Format | PDF, PB13944, 152 pages |
Source: GOV.UK publication page, read 30 September 2026.
Guidance, not law
The guidance explains the duty; the regulations are the duty
The obligations are in Schedule 7 to SI 2008/410 for companies and in regulation 12B of SI 2008/1911 for LLPs.
Where the guidance and the regulations differ, the regulations are the test.
Three common questions are settled by reading the two together.
First, on assurance, the guidance PDF says: “There is no statutory requirement to have your environmental information audited.”
The auditor of the accounts reports under section 496 on whether the directors’ report is consistent with the accounts and prepared in accordance with the law, which is not assurance over the emissions figures.
Second, on Scope 3, it states that it is mandatory for large unquoted companies and LLPs to disclose energy use and emissions from business travel in rental cars or employee-owned vehicles where they are responsible for purchasing the fuel.
The statutory hook is narrower in its words: paragraph 20D(1)(b) says only “the consumption of fuel for the purposes of transport”, so quote the regulation for the duty and the guidance as guidance.
Third, on the intensity ratio, the regulations require “at least one ratio” of annual emissions to “a quantifiable factor associated with the company’s activities”, and the choice is the company’s.
Where it has aged
Four passages that now mislead
Seven years on, the guidance still carries statements that were true, or nearly true, in March 2019 and are not the test today.
| The guidance says | The law says | Why it matters now |
|---|---|---|
| The LLP definition of large is “based on sections 465 and 466 of the Companies Act” | The LLP test is a table of its own in reg 12B (modified s.415A) — £36m / £18m / 250 | Since 6 April 2025 those sections read £54m / £27m, so following the cross-reference gives the wrong answer. |
| The low energy relief is “40MWh or less in the UK, including offshore area”, counting gas, electricity and transport fuel | ¶20D(7)(a): “40,000 kWh of energy or less in the United Kingdom”, with energy meaning all forms | The offshore words come from a different provision, and the energy counted is wider than the energy reported. |
| The CRC Energy Efficiency Scheme, in the present tense, as helping companies meet the new obligations | CRC was revoked from 1 October 2018 by SI 2018/841 | A scheme that closed before SECR began is described as current. |
| Fuel for “personal/hire cars on business use”, including reimbursed mileage | ¶20D(1)(b): “the consumption of fuel for the purposes of transport” | A useful gloss on the grey fleet, but it is guidance wording, not statutory text. |
The figures the guidance prints beside its LLP cross-reference — £36 million, £18 million and 250 — are still the right ones: the defect is the pointer, not the numbers.
The same self-contained test applies to companies under paragraph 20B, and it is set out on SECR thresholds.
Since March 2019
The law around it has not stood still
None of the changes opposite appear in the March 2019 text, because none of them had happened yet.
The most consequential for a SECR reporter is the April 2025 uplift of the Companies Act size limits, which the regulations did not follow and the guidance’s LLP wording now appears to.
The most recent is the FCA’s PS26/19, finalising CP26/5: listed companies in scope report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
That sits beside SECR rather than replacing it.
How SECR now sits alongside the newer regime is set out at SECR vs UK SRS.
- 1 Apr 2019SECR in force
Three days after the guidance was last updated.
- 6 May 2021The FRC becomes the authorised body
For court applications over defective reports.
- 6 Apr 2022Climate-related financial disclosure
A separate regime, inside the strategic report and the LLP energy and carbon report.
- 6 Apr 2025Companies Act size limits rise
SECR’s £36m / £18m / 250 does not.
- 25 Feb 2026UK SRS S1 and S2 published
Voluntary standards, by the Department for Business and Trade.
- 26 May 2026SECR post-implementation review
Retain with amendments.
- 11 Jun 20262026 conversion factors
With a new electricity methodology.
- 30 Sep 2026FCA PS26/19
UK SRS comply-or-explain for listed companies from 2027.
The method
Six steps, in order
The sequence the guidance describes, written against the current law. Confirm you are in scope before the rest of this matters.
STEP 1
Scope assessment
- Apply the two-of-three test to this year’s and last year’s figures (£36m, £18m, 250).
- Confirm quoted status; an AIM company is unquoted.
- List every group entity and whether a group report will shelter it.
- Document the assessment for the audit trail.
STEP 2
Data collection
- Electricity, gas and transport fuel for unquoted companies and LLPs; all fuel, facilities and purchased heat, steam and cooling for quoted companies.
- Utility bills and meter reads, fuel cards and mileage claims, landlord energy statements.
- Collect monthly, with a named owner for each stream.
STEP 3
Methodology
- Choose the framework — most name the GHG Protocol Corporate Standard.
- Use the DESNZ conversion factors for the year the energy was used.
- Write the methodology down: it is itself a required disclosure.
STEP 4
Calculation and checks
- Energy (kWh) × conversion factor (kgCO₂e/kWh) = emissions; report in tonnes of CO₂e.
- Reconcile energy totals to bills; investigate large year-on-year moves.
- Flag the 2026 electricity-factor methodology change in any comparison.
STEP 5
Intensity ratio
- At least one ratio of emissions to a quantifiable factor of your choice.
- Revenue, floor area, headcount or units of output all satisfy the law.
- Pick one that will still mean something in three years.
STEP 6
Report and file
- Place the section in the directors’ report (for an LLP, the energy and carbon report).
- State any relief relied on, and why.
- File with the accounts by the section 442 deadline.
The size tests themselves sit in Schedule 7 paragraph 20B of SI 2008/410; see SECR thresholds for the test in full.
The filing deadline is fixed by Companies Act 2006 section 442, not by SECR’s own regulations — see SECR deadline for your company type.
A full worked section, with the report structure, is on SECR reporting.
Common failure points are data across multiple sites, methodology drift from year to year, an intensity ratio that stops being meaningful, and forgetting transport fuel for unquoted companies.
Conversion factors
Match the factor year to the year the energy was used
DESNZ publishes the UK Government conversion factors for company reporting once a year, each June.
The 2026 set was published on 11 June 2026, with a correction to the flat file on 31 July 2026.
Its methodology paper says: “The 2026 GHG Conversion Factors are for use with activity data that falls entirely or mostly within 2026.”
So a company reporting its 2026 financial year in spring 2027 uses the 2026 factors — not the set that happened to be latest when its year ended, and not the set current when it files.
A year that straddles two calendar years uses the set for the year in which most of the activity fell.
DESNZ describes the factors as relevant to the Environmental Reporting Guidelines, including SECR, and says other uses are at the user’s own risk.
Whichever set you use, name it in the methodology statement.
DESNZ changed how the electricity factor is calculated in the 2026 set, cutting the data lag from two years to one.
The 2025-to-2026 fall in the factor reflects two years of grid change plus methodology, and there is no 2024 data year.
A Scope 2 fall between FY2025 and FY2026 must say so, or it credits the company with a methodology change.
Methodology standards
The GHG Protocol, ISO, and what is changing
The regulations do not name a methodology; most SECR reports name the GHG Protocol Corporate Standard and apply the DESNZ factors within it.
The GHG Protocol and ISO are consolidating their corporate standards into one: their standard development plan estimates a public consultation in Q2 2027 and a published revised standard in Q4 2028.
Nothing in that programme is in force, and the existing Corporate Standard remains the text reports cite.
ISO 14064-1:2018, ISO’s organisation-level standard for quantifying and reporting greenhouse gases, is marked by ISO as to be revised and falls within the same consolidation.
Either can support a SECR methodology statement, as long as the statement says which was used and how.
State whether electricity emissions are location-based or market-based, and keep the choice consistent from year to year.
By organisation type
The same method, three starting points
Quoted companies
Worldwide, with the UK share
Report energy and emissions worldwide, and state what proportion relates to the UK and offshore area.
Listed companies in scope of PS26/19 also report against UK SRS on a comply-or-explain basis from 2027, so build one data set for both.
Large unquoted companies
UK energy, plus transport fuel
Report UK energy from gas, transport fuel and electricity; energy used outside the UK may be left out.
Decide early who owns the data and who owns the numbers.
LLPs
A separate report
The same content as an unquoted company, in an energy and carbon report signed by a designated member.
The threshold is in regulation 12B, not paragraph 20B.
For a quoted company, the general requirements standard UK SRS S1 and its climate companion S2 were published by the Department for Business and Trade on 25 February 2026, and UK SRS S2 asks for considerably more than SECR.
For an unquoted company, deciding who owns the data matters: a mid-sized company can use a part-time fractional sustainability lead rather than a full-time hire.
Putting finance in charge of the numbers helps too — a smaller company can hire a fractional CFO to own the first SECR report.
Keep marketing claims in line with the reported figures — see sustainability in go-to-market.
LLPs have their own page: SECR for LLPs.
What may change
The government’s own reviewers noticed
The 2026 post-implementation review, published by DESNZ on 26 May 2026, does not just note the guidance is old.
It recommends retaining SECR with amendments, to be explored through a planned consultation, and lists five themes that, in its own words, “do not represent final decisions”.
Updated guidance on eligibility thresholds, site inclusion and group versus entity reporting is the first of them — three of the questions this site exists to answer in the meantime.
The review also names comparability as hampered by heterogeneous intensity metrics and inconsistent placement and formatting.
The modernising corporate reporting consultation says DESNZ intends to consult on SECR and ESOS later in 2026.
Until then, the March 2019 guidance is the current edition.
The complete picture — thresholds, disclosures, deadlines, and how SECR sits alongside UK SRS — is in the complete SECR guide.
Guidance on eligibility, site and group boundaries.
A standardised disclosure template.
Aligning SECR definitions and metrics with ISSB, CSRD and TCFD.
Light-touch forward-looking elements.
Digital access options.
Frequently asked
Questions people ask
What is the official SECR guidance?
The government’s Environmental Reporting Guidelines, including Streamlined Energy and Carbon Reporting requirements, published on GOV.UK by DESNZ, Defra and the former BEIS. The current edition is March 2019, and the GOV.UK page was last updated on 29 March 2019. It is a 152-page PDF designed to help companies and LLPs comply with the SECR regulations.
Is the SECR guidance legally binding?
No. The duty is in the regulations: Schedule 7 to SI 2008/410 for companies and regulation 12B of SI 2008/1911 for LLPs. The guidance interprets them, and where the two differ the statutory text is the test.
Is the SECR guidance out of date?
In places. It has not been revised since March 2019. It describes the LLP threshold as based on sections 465 and 466 of the Companies Act, which has misled since those limits rose in April 2025; it still mentions the CRC Energy Efficiency Scheme, revoked in 2018; and it states the low energy relief as 40MWh including the offshore area, where the regulations say 40,000 kWh in the United Kingdom.
Does the SECR guidance require assurance?
No. The guidance says there is no statutory requirement to have environmental information audited, and nothing in Schedule 7 Part 7 or 7A mentions assurance, verification or audit. The auditor’s duty under section 496 of the Companies Act is to say whether the directors’ report is consistent with the accounts and prepared in accordance with the law, which is not assurance over the emissions data.
Which conversion factors does the SECR guidance use?
The UK Government greenhouse gas conversion factors, published by DESNZ each June. DESNZ says the 2026 factors are for activity data falling entirely or mostly within 2026, so the factor year should match the year the energy was used, not the year the report is filed.
Does SECR guidance require Scope 3 emissions?
Only narrowly. For large unquoted companies and LLPs the regulations capture fuel consumed for transport, and the guidance treats business travel in rental cars or employee-owned vehicles, where the company buys the fuel, as mandatory. Other Scope 3 is voluntary. Quoted companies have no transport-fuel limb.
Which intensity ratio does the SECR guidance recommend?
The regulations require at least one ratio expressing annual emissions against a quantifiable factor associated with the company’s activities, and leave the choice to the company. Revenue, floor area, headcount and units of output all satisfy it; what matters is that it will still mean something in the comparative years.
Will the SECR guidance be updated?
Possibly. DESNZ’s post-implementation review of 26 May 2026 recommends retaining SECR with amendments and lists updated guidance on eligibility, site and group boundaries among themes for a planned consultation, which it says are not final decisions. A DESNZ consultation on SECR and ESOS is promised later in 2026.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- GOV.UKEnvironmental reporting guidelines: including Streamlined Energy and Carbon Reporting requirements
Published 12 June 2013, last updated 29 March 2019; PB13944, 152 pages.
- GOV.UKEnvironmental Reporting Guidelines (March 2019) — PDF
The business-travel Scope 3 table; “no statutory requirement to have your environmental information audited”.
- legislation.gov.ukSI 2018/1155 — the regulations the guidance explains
- legislation.gov.ukSI 2008/410, Schedule 7 — Parts 7 and 7A
The duties; ¶17 and ¶20G the intensity ratio.
- legislation.gov.ukSI 2008/410, Schedule 7, paragraph 20B — the size exemption
- legislation.gov.ukSI 2008/410, Schedule 7, paragraph 20D — disclosures and reliefs
“the consumption of fuel for the purposes of transport”; the 40,000 kWh relief.
- legislation.gov.ukSI 2008/1911, regulation 12B — the LLP test and report
- legislation.gov.ukSI 2018/841 — CRC Energy Efficiency Scheme (Revocation and Savings) Order 2018
CRC revoked from 1 October 2018.
- legislation.gov.ukCompanies Act 2006, section 496 — auditor’s report on the directors’ report
- legislation.gov.ukCompanies Act 2006, section 442 — period allowed for filing accounts
- DESNZGovernment conversion factors for company reporting — collection
- DESNZGreenhouse gas reporting: conversion factors 2026
Published 11 June 2026; flat file corrected 31 July 2026.
- DESNZ2026 GHG conversion factors — methodology paper
¶1.10 the activity-year rule; ¶1.13 the electricity methodology change.
- GHG ProtocolCorporate Accounting and Reporting Standard
- GHG ProtocolConsolidated Corporate Standard — Standard Development Plan v2.0 (29 July 2026)
Consultation estimated Q2 2027; revised standard estimated Q4 2028.
- ISOISO 14064-1:2018 — organisation-level GHG quantification and reporting
Stage 90.92, to be revised.
- DESNZ2026 Post-Implementation Review of the SECR Regulations 2018
Retain with amendments; five themes for consultation, not decided.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation (7 September 2026)
¶150: DESNZ intends to consult on SECR and ESOS later in 2026.
- Financial Conduct AuthorityPS26/19 — UK SRS for listed companies, comply-or-explain from 2027
- Department for Business and TradeUK SRS S1 and UK SRS S2 (25 February 2026)