SECR reporting · the disclosure
SECR reporting: preparing the disclosure
The SECR reporting requirements are met inside the annual report, not in a separate filing: a company puts its SECR disclosure in the directors’ report under Schedule 7 to SI 2008/410, and an LLP prepares an energy and carbon report.
This page follows one reporting cycle: what data to collect, how to turn it into emissions, what the finished disclosure contains, and where teams most often go wrong.
Where SECR is reported
Part of the annual report, not a separate filing
SECR reporting was created by SI 2018/1155 as extra content for a report companies already produce.
A company’s SECR disclosure is part of its directors’ report, and it is delivered to Companies House with the accounts within the period set by section 442 of the Companies Act 2006.
LLPs have no directors’ report, so regulation 12B requires the members to prepare a separate energy and carbon report, approved by the members and signed by a designated member.
The statutory auditor’s opinion under section 496 covers whether the directors’ report is consistent with the accounts and prepared in accordance with the law; it is not an audit of the SECR figures, and there is no statutory requirement for one.
The Modernising corporate reporting consultation proposes abolishing the directors’ report and letting companies place the SECR disclosure anywhere in the first half of the annual report; that is a proposal, open until 30 November 2026.
| Who | Report vehicle | Provision |
|---|---|---|
| Quoted company | Directors' report | Sch 7 Part 7 |
| Large unquoted company | Directors' report | Sch 7 Part 7A |
| Large LLP | Energy and carbon report | SI 2008/1911 reg 12B |
Step 1 · data
What to collect depends on which Part you report under
Quoted companies report worldwide; large unquoted companies and LLPs report a narrower set of sources and may confine it to the UK.
| Source | Quoted company (Part 7) | Large unquoted company and LLP (Part 7A) |
|---|---|---|
| Fuel burned on site | Combustion of fuel, and the operation of any facility (¶15(2)) | Combustion of gas (¶20D(1)(a)) |
| Transport | Covered only as combustion of fuel for activities the company is responsible for | Consumption of fuel for transport — journeys starting or ending in the UK (¶20D(1)(b), ¶20K) |
| Purchased energy | Electricity, heat, steam or cooling for own use (¶15(3)) | Electricity for own use (¶20D(2)) |
| Energy figure (kWh) | The energy underlying those emissions (¶15(3A)) | Gas, transport fuel and electricity combined (¶20D(3)) |
| Territory | Worldwide, plus the UK and offshore share (¶15(3B)–(3C)) | May exclude energy and emissions outside the UK and offshore area (¶20D(5)) |
In practice the data comes from utility bills and meter readings for gas and electricity, fuel cards and fuel invoices for owned vehicles, and expense and mileage claims for fuel used in employees’ own cars.
The government’s environmental reporting guidelines treat fuel in personal or hire cars on business use, including fuel reimbursed through business mileage claims, as within the unquoted transport limb; that reading is the guidance’s, and the statute says only “the consumption of fuel for the purposes of transport”.
Other fuels a large unquoted company burns, such as heating oil or biomass, are outside the paragraph 20D figures, although they still count towards the 40,000 kWh low-energy test and can be disclosed voluntarily.
Where a bill period does not match the financial year, accrue or apportion the consumption and record how, because the methodology statement must say how the figures were produced.
Where some information is not practical to obtain, paragraph 20D(6) and paragraph 15(4) allow it to be left out, but only if the report states what is not included and why.
Step 2 · calculations
From kWh to tonnes, with the right year’s factors
Most SECR reports calculate emissions with the UK Government conversion factors and state that they follow the GHG Protocol Corporate Standard.
The regulations do not prescribe either; paragraphs 16 and 20F require the report to state the methodology used.
The 2026 set was published by DESNZ on 11 June 2026, and its flat file was corrected on 31 July 2026.
DESNZ’s 2026 methodology paper says the 2026 factors are for use with activity data that falls entirely or mostly within 2026, so the factor year follows the activity year, not the filing year.
Each year’s set stays online — the 2023 conversion factors, for example — so a comparative figure can be checked against the factors it was originally calculated with.
One change needs explaining in 2026 comparatives: DESNZ shortened the data lag behind the UK electricity factor from two years to one, so the move between the 2025 and 2026 electricity factors reflects two years of grid change rather than one.
A company that restates last year’s figure on new factors, or keeps it as reported, should say which it did.
Offsets are never deducted: SECR has no netting provision, so the reported emissions are gross.
The basic calculation
activity (kWh or litres) × factor (kgCO₂e per unit) ÷ 1,000 = tCO₂e
Factors from the DESNZ set for the year the activity falls in. No factor values are reproduced here; take them from the published set.
Step 3 · the intensity ratio
At least one ratio, denominator of your choosing
Paragraphs 17 and 20G require at least one ratio expressing the company’s annual emissions in relation to a quantifiable factor associated with its activities.
Turnover, headcount, output and floor area are all in use, and the regulations prefer none of them.
It is an emissions ratio; SECR has no statutory energy-intensity ratio.
Choosing the denominator, with worked examples by sector, is covered on the SECR intensity ratio.
Step 4 · the disclosure
An illustrative structure for the SECR section
There is no official template; the regulations fix the content, not the layout.
The structure below is our illustration of a large unquoted company’s section, built from the Part 7A paragraphs. Square brackets are placeholders, not figures.
Energy consumption
In the year ended [date] the company consumed [X] kWh of energy in the United Kingdom, comprising [X] kWh of gas, [X] kWh of purchased electricity and [X] kWh of transport fuel.
Greenhouse gas emissions
Emissions from gas combustion and transport fuel were [X] tCO₂e; emissions from purchased electricity were [X] tCO₂e; total [X] tCO₂e.
Intensity ratio
Total emissions were [X] tCO₂e per £ million of turnover (prior year: [X]).
Methodology
Figures were calculated using the GHG Protocol Corporate Standard and the UK Government conversion factors for [year], from utility invoices, meter readings and fuel card data; [describe any estimates].
Energy efficiency measures
During the year the company [describe the principal measures taken].
Prior year
Each figure above is shown with the previous year's figure, except in the first year of reporting.
A quoted company adds its worldwide figures and, under paragraph 15(3B) and (3C), the proportion relating to the UK and offshore area.
Paragraph 20D(4) requires a description only if measures were taken, but a short statement that none were is clearer for a reader than silence.
Stronger and weaker wording
Illustrative, not taken from any real report: a stronger efficiency paragraph names what was done and where — “replaced the lighting at the main warehouse with LED fittings and fitted variable-speed drives to the site’s ventilation fans”.
A weaker one says nothing a reader can check — “the company continued its commitment to sustainability through various initiatives”.
The same test applies to the methodology: name the standard, the factor year and the data sources, rather than “industry standard methodology”.
Step 5 · approval and filing
Approve it with the report, file it with the accounts
The SECR section is approved and signed as part of the directors’ report, so board review of the figures belongs in the accounts timetable, not after it.
A director who approves a directors’ report knowing it does not comply, or reckless as to whether it complies, commits an offence under section 419(3)–(4) of the Companies Act 2006; the detail is on SECR enforcement and penalties.
Companies House does not extend a filing deadline that falls on a Sunday or bank holiday, and the dates for each year end are set out on SECR deadlines.
One cycle, in order
- Year endClose the data
Final reads, accruals, fuel and mileage data.
- ThenCalculate and draft
Factors for the activity year; ratio; comparatives; methodology.
- Before sign-offBoard review
The SECR section is approved with the directors' report.
- 9 / 6 monthsFile
With the accounts, within the s.442 period.
Where SECR reporting goes wrong
Seven problems that recur
Multi-site estates
Different sites on different billing systems, landlord-supplied utilities and shared meters. Set up site-level collection early and record how shared supplies were apportioned.
Billing periods
Invoices rarely match the financial year. Accrue for unbilled consumption and use the same approach each year, stated in the methodology.
Transport fuel
Fuel cards, several suppliers and mileage claims. For large unquoted companies and LLPs the transport limb is mandatory, so it cannot be left for later.
Factor years
Using the set current at filing rather than the set for the activity year. The factor year follows the data.
Comparatives
Changing the ratio, the boundary or the factors without saying so. The prior-year figure is on the face of the report, so any change shows.
Reliefs used silently
Omitting figures without the statement the relief requires. Every relief in Schedule 7 depends on saying why information is missing.
Group reports
Reporting for the parent alone. A group directors' report covers the undertakings in the consolidation under ¶15A or ¶20E.
DESNZ’s 2026 post-implementation review found comparability between companies hampered by heterogeneous intensity metrics and inconsistent placement and formatting.
A multi-site estate is also the point at which a spreadsheet stops paying its way; for how to judge a platform against the artefacts Schedule 7 actually requires, rather than a vendor’s compliance claim, see SECR reporting software.
The government’s own March 2019 guidance remains the most detailed worked material, though some of its wording diverges from the regulations, as SECR guidance explains.
SECR reporting and UK SRS
SECR continues alongside UK SRS
SECR reporting remains a legal duty for every company and LLP in scope.
The FCA’s PS26/19, published on 30 September 2026, finalises CP26/5 and requires 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, with first reports in 2028.
That is a listing-rule obligation on top of SECR, not a replacement for it.
DESNZ has said it will consider how energy and emissions data reported under UK SRS interacts with SECR, with a view to reducing unnecessary duplication where possible; nothing has been decided.
A listed company therefore collects one set of energy data and reports it twice, on two different bases — the detail is on SECR vs UK SRS.
The same records underpin the wider UK sustainability reporting standards a company may adopt voluntarily.
To talk a first SECR report through, you can book a free 15-minute call.
Frequently asked
SECR reporting — frequently asked
Is SECR reporting a separate filing?
No. For a company the SECR disclosure is part of the directors' report, which is filed at Companies House with the annual accounts. For an LLP it is a separate energy and carbon report, but it is still prepared and delivered with the accounts rather than filed through a SECR portal. There is no SECR form and no SECR register.
Where does SECR go in the annual report?
In the directors' report, today. The Modernising corporate reporting consultation of 7 September 2026 proposes abolishing the directors' report and letting companies place the SECR disclosure anywhere in the first half of the annual report. That is a proposal; until legislation is made, the directors' report is where it belongs.
What goes in a SECR report?
Annual greenhouse gas emissions from the activities Schedule 7 lists, the underlying energy use in kWh, at least one intensity ratio, a statement of the methodology used, a description of the principal energy efficiency measures taken in the year, and the previous year's figures from the second year of reporting. A quoted company also states what proportion of its emissions and energy relates to the UK and offshore area.
Which conversion factors should I use for SECR?
The UK Government (DESNZ) conversion factors for the year your activity data falls in. DESNZ says the 2026 set is for activity data falling entirely or mostly within 2026, so a financial year that ends in 2026 is calculated with the 2026 set, published on 11 June 2026, not with whichever set is current when the report is filed.
Does the SECR report need to be audited?
No. There is no statutory requirement to audit or assure SECR data. The statutory auditor states under Companies Act 2006 section 496 whether the directors' report is consistent with the accounts and prepared in accordance with the law, which is not an audit of the energy or emissions figures. Independent verification is voluntary.
When are SECR reports due?
With the accounts. Under Companies Act 2006 section 442 a private company has nine months from the end of its accounting reference period and a public company six months. Companies House does not move a deadline that falls on a weekend or bank holiday.
Can a company leave figures out of its SECR report?
Only through a relief, and only by saying so. Information that is not practical to obtain can be omitted if the report states what is missing and why; a company that consumed 40,000 kWh or less (in the UK, for unquoted companies and LLPs) can omit the figures if the report says that is the reason; and directors can withhold information whose disclosure would be seriously prejudicial, again stating the reason.
Is there a template for a SECR report?
Not an official one. The regulations set the content, not a format, and DESNZ's 2026 post-implementation review lists a standardised disclosure template only as an area a future consultation may explore. The structure on this page is an illustration built from the Schedule 7 paragraphs.
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 2018/1155 — the SECR regulations
Created the duties; in force for financial years beginning on or after 1 April 2019.
- legislation.gov.ukSI 2008/410, Schedule 7 — matters to be dealt with in the directors' report
Where the SECR disclosure lives for companies.
- legislation.gov.ukSI 2008/410, Schedule 7 Part 7 — quoted companies
¶¶15–19A: global emissions and energy, UK proportions, methodology, ratio, comparatives.
- legislation.gov.ukSI 2008/410, Schedule 7 Part 7A — large unquoted companies
¶¶20D–20J: gas, transport fuel and electricity; UK-only option; reliefs.
- legislation.gov.ukSI 2008/1911, regulation 12B — the LLP energy and carbon report
The separate report LLPs prepare instead of a directors' report.
- legislation.gov.ukCompanies Act 2006, section 442 — period for filing accounts
Nine months private, six months public.
- legislation.gov.ukCompanies Act 2006, section 496 — auditor's report on the directors' report
Consistency with the accounts and legal compliance; not assurance over emissions.
- GOV.UKEnvironmental reporting guidelines, including SECR requirements
The government guidance, last updated 29 March 2019.
- GOV.UKEnvironmental reporting guidelines — the March 2019 PDF
The scope table on transport fuel and the statement that audit is not required.
- Department for Energy Security and Net ZeroGreenhouse gas reporting: conversion factors 2026
Published 11 June 2026; flat file corrected 31 July 2026.
- Department for Energy Security and Net Zero2026 GHG conversion factors methodology paper
¶1.10: the 2026 factors are for activity data falling mostly within 2026.
- Department for Energy Security and Net ZeroGreenhouse gas reporting: conversion factors 2023
An earlier annual set, for checking comparatives calculated in that year.
- GHG ProtocolCorporate Accounting and Reporting Standard
The methodology most SECR reports state they follow.
- Companies HouseLate filing penalties
A deadline on a Sunday or bank holiday still stands.
- Department for Energy Security and Net Zero2026 Post-Implementation Review of the SECR Regulations 2018
Comparability hampered by heterogeneous metrics; a template is a candidate change, not a decision.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation (7 September 2026)
¶149: the proposed move of SECR out of the directors' report.
- Financial Conduct AuthorityPS26/19 — UK SRS for listed companies, comply or explain
Published 30 September 2026; periods beginning on or after 1 January 2027.
- Financial Conduct AuthorityCP26/5 — the consultation behind PS26/19
Published 30 January 2026.
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