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 LLPs have no directors' report to attach SECR content to in the first place.
SI 2008/1911 reg 12B, inserted 1 April 2019 by SI 2018/1155 reg 10, instead applies a modified version of Companies Act s.415(1): “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 s.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.”
The Threshold Home Is Not Paragraph 20B
The single most common wrong citation in this area is Schedule 7 ¶20B — the large-unquoted-company test.
It does not apply to LLPs. Modified s.416(2)(b)(iii), inside reg 12B itself, expressly 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 reg 12B's own modified sections instead — modified s.415A(2) for a standalone LLP, modified s.415A(5) for a group.
| Test | Standalone LLP | Group (net / gross) |
|---|---|---|
| Turnover | more than £36 million | £36m net / £43.2m gross |
| Balance sheet total | more than £18 million | £18m net / £21.6m gross |
| Employees | more than 250 | 250 |
An LLP qualifies as large by exceeding at least two of the three standalone limbs — the identical numerical thresholds to the unquoted-company test, under a completely different provision.
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.
Live guidance, dead cross-reference
The GOV.UK guidance page states the LLP threshold is “based on sections 465 and 466 of the Companies Act.” The same wording appears inside the March 2019 PDF itself, immediately before the £36m / £18m / 250 figures.
That was true by coincidence in March 2019, when s.465 also read £36m / £18m / 250. It has been actively misleading since 6 April 2025, when s.465 was uprated to £54m turnover / £27m 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 reg 12B's own hardcoded table, not a live pointer into the Companies Act; nothing in the LLP chain cross-refers to s.465 or s.466 at all.
The figures printed next to the error are still the ones to use — £36m / £18m / 250. The defect is the cross-reference, not the numbers beside it.
This is the same self-contained-threshold point that applies to unquoted companies — see our page on who qualifies for SECR for how the April 2025 Companies Act uprating left the company-side test untouched too.
What an LLP Actually Reports
Once the threshold paragraphs are switched off, modified s.416(2) carries the rest of Schedule 7 Part 7A across to LLPs “with modifications” — the substantive disclosure duties, not just the exemption mechanics.
In practice that means the same content an unquoted company reports: gas combustion and transport fuel consumption, purchased electricity, an aggregate kWh figure, a narrative on energy-efficiency measures, at least one emissions intensity ratio, and comparative-year figures.
Scope 3 is limited the same way it is for unquoted companies — only fuel consumed for the purposes of transport. No other Scope 3 category is required, and 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: consumption of 40,000 kWh or less in the United Kingdom during the period, with the report stating that reason for the omission. It is relief from disclosure, conditional on saying so — not exemption from SECR.
LLP-Specific Penalties, Not the Company Ones Relabelled
Reg 12B does not simply extend the company offences to LLP members — it writes SECR-specific analogues.
- Failing to prepare the report at all: modified s.415(6)–(7) makes this an offence committed 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: modified s.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.
For the company-side offences, the FRC's actual enforcement record, and why "SECR has no penalty" needs a caveat for LLPs specifically, see our full breakdown of SECR enforcement and penalties.
A Different Regime Shares the Same Report Vehicle — Don't Let It Bleed In
Inside the same reg 12B, modified s.416A (inserted 6 April 2022 by SI 2022/46 reg 4) places climate-related financial disclosures for the largest LLPs — more than 500 employees and more than £500 million turnover — inside the energy and carbon report.
For companies, the equivalent climate-related disclosure sits in the strategic report instead, under the separate SI 2022/31.
That is a different regime with a different population, made four 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. SECR's last and only amendment was made in 2018, for financial years beginning on or after 1 April 2019.
For how SI 2008/1911 reg 12B fits into SECR's wider legislative structure, see the enabling legislation behind SECR on uksrs.org.uk.