SECR · limited liability partnerships
SECR for LLPs: a separate energy and carbon report
SECR reaches large LLPs through their own instrument, regulation 12B of SI 2008/1911, not through the directors’ report rules that bind companies.
An LLP has no directors’ report, so its members prepare a standalone energy and carbon report, with its own threshold table and its own offences.
It is the SECR population most often mis-cited.
The report
A separate report, not a directors’ report
SECR has three populations: quoted companies, large unquoted companies, and large LLPs.
LLPs are the population everybody mis-cites, because they have no directors’ report to attach SECR content to in the first place.
Regulation 12B, inserted on 1 April 2019 by SI 2018/1155 regulation 10, applies a modified section 415(1) of the Companies Act instead.
It reads: “the members of an LLP must prepare an energy and carbon report for each financial year” — a standalone document, not a section of anything else.
Modified section 419(1) sets who signs it: it must be “approved by the members and signed on behalf of all the members by a designated member.”
Where the LLP heads a group, the report is a consolidated group energy and carbon report covering the undertakings in the consolidation.
A subsidiary LLP included in a parent’s group report need not prepare its own.
| Unquoted company | LLP | |
|---|---|---|
| Where SECR sits | Directors’ report | Energy and carbon report |
| Size test | Sch 7 ¶20B, ¶20C | Modified s.415A(2), (5) |
| Approved and signed | Board; a director or the secretary | The members; a designated member |
| Filing period | Nine months (private) | Nine months |
| Offences | CA 2006 s.419(3)–(4) | Modified ss.415(6)–(7), 419(2)–(3) |
The threshold
The threshold home is not paragraph 20B
The single most common wrong citation in this area is Schedule 7 paragraph 20B, the large unquoted company test.
| Limb | Standalone LLP (modified s.415A(2)) | Group (modified s.415A(5)), net / gross |
|---|---|---|
| Turnover | Not more than £36 million | Not more than £36m net / £43.2m gross |
| Balance sheet total | Not more than £18 million | Not more than £18m net / £21.6m gross |
| Employees | Not more than 250 | Not more than 250 |
Paragraph 20B does not apply to LLPs: modified section 416(2)(b)(iii), inside regulation 12B itself, directs “omit paragraphs 20A(2) and (3), 20B and 20C.”
The Schedule 7 threshold paragraphs are switched off for LLPs by name.
The real test lives inside regulation 12B’s own modified section 415A — subsection (2) for a standalone LLP and subsection (5) for a group.
An LLP qualifies as large by exceeding at least two of the three standalone limbs: identical numbers to the unquoted-company test, under a completely different provision.
Modified section 415A(1) carries the same consecutive-year rule as the company test, so a change of size counts only once it has lasted two financial years.
The headcount is the monthly average of persons employed under contracts of service by the LLP.
For how the same self-contained test works for companies, see who qualifies for SECR.
The trap
GOV.UK’s own guidance gets this wrong, in the present tense
The government’s SECR guidance was published in March 2019 and has not been revised since.
It states that the LLP definition of large is “based on sections 465 and 466 of the Companies Act”, and the same wording appears inside the March 2019 PDF, immediately before the £36 million, £18 million and 250 figures.
That was true by coincidence in March 2019, when section 465 also read £36 million, £18 million and 250.
It has been actively misleading since 6 April 2025, when section 465 was uprated to £54 million turnover and £27 million balance sheet.
Anyone who follows the cross-reference today lands on the wrong figures and concludes SECR moved with it.
It is wrong as law, and always was: the LLP test is regulation 12B’s own table, and nothing in the LLP chain cross-refers to section 465 or 466.
DESNZ’s own post-implementation review lists updating the Environmental Reporting Guidelines among the themes a future consultation may address.
The figures printed next to the error are still the ones to use: £36 million, £18 million and 250.
The defect is the cross-reference, not the numbers beside it.
What an LLP reports
The unquoted-company content, carried across
Once the threshold paragraphs are switched off, modified section 416(2) carries the rest of Schedule 7 Part 7A across to LLPs with modifications.
In practice that means the same content an unquoted company reports.
Emissions from the combustion of gas and the consumption of fuel for transport, and from purchased electricity.
An aggregate kWh figure, a description of the principal energy efficiency measures taken, at least one emissions intensity ratio, the methodology, and comparative-year figures from the second year.
An LLP may exclude energy and emissions outside the UK, which is an option rather than a rule.
Scope 3 is limited the same way it is for unquoted companies: only fuel consumed for the purposes of transport, and nothing wider.
There is no requirement anywhere in the LLP chain for a target, a transition plan or third-party assurance.
The 40,000 kWh low energy relief carries across in its unquoted-company form: 40,000 kWh or less “in the United Kingdom” during the period, with the report stating that reason — see paragraph 20D(7)(a).
It is relief from disclosure, conditional on saying so, not exemption from SECR.
The line-by-line content is on SECR requirements.
Filing
Nine months, with the accounts
Regulation 17 of SI 2008/1911 applies a modified section 442: “The period is nine months after the end of the relevant accounting reference period.”
Where an LLP’s first accounting reference period runs over twelve months, the deadline is whichever expires last of nine months from the first anniversary of incorporation and three months after the period ends.
The Secretary of State may extend the period by notice, but never to more than twelve months after the period ends.
Regulation 19 requires a large LLP’s designated members to deliver a copy of the energy and carbon report to the registrar alongside the accounts and the auditor’s report.
A deadline on a weekend does not move, and the full arithmetic is on SECR deadlines.
Worked dates
| Year end | Energy and carbon report due |
|---|---|
| 31 December 2025 | 30 September 2026 |
| 31 March 2026 | 31 December 2026 |
| 30 April 2026 | 31 January 2027 |
Nine months after the accounting reference date; a month-end date runs to the month end.
Penalties
LLP-specific offences, not the company ones relabelled
Regulation 12B does not simply extend the company offences to LLP members: it writes SECR-specific analogues.
Failing to prepare the report at all: modified section 415(6)–(7) makes this an offence by every person who was a member immediately before the end of the filing period and failed to take all reasonable steps to secure compliance.
Approving a non-compliant report: under modified section 419(2)–(3), every member who knew it did not comply, or was reckless as to whether it complied, and failed to take reasonable steps, commits an offence.
The defective-accounts machinery, including court-ordered revision, is applied to LLPs by regulations 23 and 24 of SI 2008/1911.
Since 6 May 2021 the body authorised to apply to court is the FRC, under SI 2021/465.
The DESNZ evaluation estimated suspected non-compliance at 14–23%, concentrated among private companies and LLPs.
For the company-side offences, the FRC’s actual record, and why “SECR has no penalty” needs a caveat for LLPs specifically, see SECR enforcement and penalties.
A neighbouring regime
Climate disclosure shares the vehicle — don’t let it bleed in
Inside the same regulation 12B, modified section 416A — inserted on 6 April 2022 by SI 2022/46 — places climate-related financial disclosures for the largest LLPs inside the energy and carbon report.
That applies to LLPs with more than 500 employees and more than £500 million turnover.
For companies, the equivalent climate-related disclosure sits in the strategic report, under a separate instrument.
It is a different regime with a different population, made years after SECR itself, that happens to share the LLP’s report vehicle.
It does not mean SECR requires a target or a transition plan for any LLP below that much higher bar, and it does not mean SECR’s own rules changed in 2022.
Nor do the FCA’s UK SRS rules reach an LLP’s SECR duty: PS26/19 applies to listed companies in certain listing categories, finalising CP26/5.
For how SI 2008/1911 regulation 12B fits into SECR’s wider legislative structure, see the enabling legislation behind SECR on our sister reference, uksrs.org.uk.
The complete SECR guide covers all three populations together.
Frequently asked
Questions people ask
Does SECR apply to LLPs?
Yes, to large LLPs. An LLP is in scope if it exceeds at least two of turnover of £36 million, a balance sheet total of £18 million and 250 employees, under SI 2008/1911 regulation 12B. Its members then prepare an energy and carbon report for each financial year.
What is an LLP energy and carbon report?
It is the LLP’s SECR report. An LLP has no directors’ report, so regulation 12B applies a modified section 415 requiring the members to prepare a separate energy and carbon report, approved by the members and signed on behalf of all of them by a designated member.
Is the LLP SECR threshold in Schedule 7 paragraph 20B?
No. Regulation 12B expressly omits paragraphs 20A(2) and (3), 20B and 20C for LLPs. The LLP test is its own table in modified section 415A: the same £36 million, £18 million and 250 figures, two or more to be met for the exemption.
Did the LLP SECR threshold change in April 2025?
No. The LLP table is written into regulation 12B and does not cross-refer to the Companies Act, so the April 2025 rise in the Companies Act size limits did not reach it. The government’s 2019 guidance says the LLP definition of large is based on sections 465 and 466 of the Companies Act, which is misleading today; the figures printed beside that statement are the right ones.
When must an LLP file its energy and carbon report?
With its accounts, within nine months after the end of the accounting reference period, under the modified section 442 applied by regulation 17 of SI 2008/1911. Regulation 19 requires a large LLP’s designated members to deliver a copy of the energy and carbon report to the registrar with the accounts.
What must an LLP report under SECR?
The same content as an unquoted company: emissions from the combustion of gas and from fuel used for transport, emissions from purchased electricity, an aggregate kWh figure, a description of principal energy efficiency measures taken, at least one emissions intensity ratio, the methodology and prior-year comparatives. It may exclude energy used outside the UK.
What are the penalties for an LLP that does not comply?
Regulation 12B creates LLP-specific offences: failing to prepare the energy and carbon report is an offence by every member who failed to take all reasonable steps to secure compliance, and approving a non-compliant report is an offence by every member who knew or was reckless and failed to take reasonable steps. Late filing of the accounts carries the ordinary late filing penalty.
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.
- legislation.gov.ukSI 2008/1911, regulation 12B — energy and carbon report
Modified ss.415, 415A, 416, 416A and 419: the duty, the size tables, the omission of ¶20B and the offences.
- legislation.gov.ukSI 2008/1911, regulation 17 — duty to file accounts and reports
Modified s.442: nine months after the end of the accounting reference period.
- legislation.gov.ukSI 2008/1911, regulation 19 — filing obligations of large LLPs
A copy of the energy and carbon report goes to the registrar.
- legislation.gov.ukSI 2008/1911 — the LLP accounts regulations
Regs 23 and 24 apply the defective-accounts provisions to LLPs.
- legislation.gov.ukSI 2018/1155 — the regulations that created SECR
Reg 10 inserted Part 5A / reg 12B from 1 April 2019.
- legislation.gov.ukSI 2008/410, Schedule 7, Part 7A — the disclosures regulation 12B applies
- legislation.gov.ukSI 2008/410, Schedule 7, paragraph 20D — disclosures and reliefs
The 40,000 kWh “in the United Kingdom” relief.
- legislation.gov.ukCompanies Act 2006, section 465
The cross-reference the 2019 guidance makes, and why it now misleads.
- legislation.gov.ukSI 2022/46 — climate-related financial disclosure for LLPs
Inserted s.416A into the energy and carbon report from 6 April 2022.
- legislation.gov.ukSI 2021/465 — the FRC authorised for defective-report applications
In force 6 May 2021; substitutes the FRC for the Conduct Committee in the LLP regulations.
- GOV.UKEnvironmental Reporting Guidelines, including SECR guidance (March 2019)
The “based on sections 465 and 466” wording.
- DESNZSECR regulations: evaluation (29 January 2026)
Non-compliance concentrated among private companies and LLPs.
- DESNZ2026 Post-Implementation Review of the SECR Regulations 2018
- Financial Conduct AuthorityPS26/19 — UK SRS for listed companies