SECR Reporting Guide 2026

SECR Report Structure

SECR reporting is not a separate filing — it forms part of the directors' report within your annual accounts submitted to Companies House under Companies Act 2006 section 442.

Where SECR Appears

• Directors' report section — specific subsection for energy and carbon information
• Integrated with annual accounts — not a standalone document
• Public disclosure — available on Companies House public record
• Audit scope — subject to statutory audit where applicable

Step-by-Step Reporting Process

Phase 1: Data Collection (3-4 months before filing)

Energy Consumption Data

Collect total UK energy consumption in kilowatt hours (kWh):

Electricity:

• Grid electricity — utility bills and meter readings
• Renewable sources — solar panels, wind generation
• Self-generation — CHP, backup generators

Gas:

• Natural gas — utility bills for heating and processes
• LPG and other gases — bottled gas and alternative fuels

Transport Fuels:

• Company vehicles — petrol, diesel fuel purchases
• Aviation fuel — business travel in company aircraft
• Marine fuel — company boats and vessels

Other Fuels:

• Heating oil — oil-fired heating systems
• Biomass — wood pellets, biogas
• District heating — purchased heating from networks

Data Quality Requirements

• Actual measurements preferred — meter readings and bills
• Reasonable estimation acceptable — for immaterial amounts
• Consistent methodology — same approach year-on-year
• Audit trail maintained — documentation of data sources

Phase 2: Emissions Calculations (2-3 months before filing)

Calculation Methodology

Most companies use the GHG Protocol Corporate Standard with UK Government conversion factors:

Scope 1 Emissions (Direct):

Energy consumption (kWh) × Emission factor (kgCO₂e/kWh) ÷ 1000 = Emissions (tCO₂e)

Scope 2 Emissions (Indirect):

Purchased electricity (kWh) × Grid emission factor × ÷ 1000 = Emissions (tCO₂e)

Emission Factors

Use UK Government (DEFRA) conversion factors updated annually:

Intensity Ratio Calculation

Calculate an intensity ratio expressing emissions per business metric:

Revenue-based (most common):

Total emissions (tCO₂e) ÷ Annual turnover (£millions) = Intensity ratio (tCO₂e/£M)

Alternative metrics:

• Per employee: Total emissions ÷ FTE employees
• Per unit: Total emissions ÷ production units
• Per area: Total emissions ÷ floor area (m²)

Phase 3: Report Preparation (1-2 months before filing)

Required Disclosure Structure

1. Energy Consumption

During the year ended [date], the Company consumed [X] kWh of energy within the UK, comprising [breakdown by fuel type].

2. Greenhouse Gas Emissions

The Company's UK greenhouse gas emissions for the year were [X] tCO₂e, comprising [X] tCO₂e Scope 1 emissions and [X] tCO₂e Scope 2 emissions.

3. Intensity Ratio

The Company's intensity ratio is [X] tCO₂e per £million of turnover ([prior year]: [X] tCO₂e/£M).

4. Methodology

Emissions have been calculated using the GHG Protocol Corporate Standard with UK Government conversion factors published by DEFRA.

5. Energy Efficiency Measures

During the year, the Company [description of measures taken OR "undertook no energy efficiency measures"].

6. Comparative Information

[Prior year figures for all metrics with context for significant changes]

Narrative Quality

• Concise but complete — cover all required elements
• Factual tone — avoid promotional language
• Specific measures — concrete efficiency actions taken
• Context for changes — explain significant year-on-year variations

Phase 4: Integration and Filing (Month of deadline)

Directors' Report Integration

• Dedicated subsection — clearly titled "Streamlined Energy and Carbon Reporting"
• Consistent formatting — matches annual report style
• Cross-references — link to related business strategy sections
• Page allocation — typically 1-2 pages depending on complexity

Quality Assurance Process

1. Internal review — finance and sustainability teams
2. Management approval — senior management sign-off
3. Board approval — formal board resolution
4. External review — auditor consideration if in audit scope
5. Final integration — incorporation into final accounts

Companies House Filing

• Standard process — filed with annual accounts
• No separate submission — integrated document only
• Public accessibility — available on Companies House website
• Deadline compliance — must meet standard accounts filing deadline

Common Reporting Challenges

Data Collection Issues

Multi-Site Operations

• Centralized billing — some utilities bill multiple sites together
• Decentralized data — different sites use different systems
• Tenant/landlord splits — shared utilities in rented properties
• Solution: Establish site-level data collection processes early

Billing Period Alignment

• Utility cycles — bills may not align with financial year
• Meter reading timing — estimated vs actual reads at year-end
• Accruals required — for unbilled consumption
• Solution: Use consistent estimation methodology for partial periods

Transport Fuel Complexity

• Fuel cards — multiple suppliers and card systems
• Personal vehicles — business mileage in personal cars
• Overseas travel — flights and international transport
• Solution: Focus on material sources, use reasonable proxies

Calculation Difficulties

Emission Factor Updates

• Annual changes — government factors updated yearly
• Methodology changes — occasional calculation approach updates
• Consistency maintenance — balancing updates with comparability
• Solution: Document methodology decisions and apply consistently

Intensity Ratio Selection

• Business relevance — choosing meaningful business metric
• Year-on-year consistency — maintaining comparable ratios
• External benchmarking — industry comparison challenges
• Solution: Choose ratio reflecting core business activity

Scope 3 Considerations

• Voluntary disclosure — not required but increasingly expected
• Data availability — often limited supplier information
• Materiality assessment — determining significant categories
• Solution: Start with business travel and employee commuting if disclosing

Integration Challenges

Board Approval Timing

• Board calendar — limited board meeting dates
• Review time — adequate time for board consideration
• Amendment cycles — changes after board review
• Solution: Plan board approval well before filing deadline

Audit Coordination

• Auditor involvement — understanding SECR requirements
• Evidence requirements — documentation of calculations
• Materiality assessment — auditor view on SECR significance
• Solution: Early engagement with auditors on SECR approach

Best Practice Report Examples

Energy Efficiency Measures Section

Good Example:

"During the year, the Company implemented LED lighting across 75% of office space, upgraded the HVAC system at the main facility with variable speed drives, and introduced hybrid working policies reducing office energy consumption by an estimated 15%. Training was provided to 150 staff on energy efficiency practices."

Poor Example:

"The Company continued its commitment to sustainability and environmental responsibility through various energy efficiency initiatives."

Methodology Section

Good Example:

"Energy consumption data is collected from utility bills and meter readings. GHG emissions are calculated using the GHG Protocol Corporate Standard with current-year UK Government conversion factors published by DESNZ (annually updated each June). Scope 1 emissions include natural gas consumption and company vehicle fuel. Scope 2 emissions include purchased electricity using the location-based method."

Poor Example:

"Emissions calculated using industry standard methodology."

SECR Reporting and UK SRS

Current Requirements (2026)

• SECR mandatory — continue existing reporting obligations
• UK SRS voluntary — optional enhanced disclosure
• Separate frameworks — different requirements and standards

Future Considerations (2027 onwards)

For quoted companies potentially subject to UK SRS S2:

• Dual compliance — SECR continues alongside UK SRS
• Data harmonization — align SECR and UK SRS data collection
• Narrative coordination — consistent climate story across reports
• Process integration — efficient preparation workflows

Preparation Recommendations

1. Build flexible systems — design for potential UK SRS expansion
2. Consider Scope 3 — voluntary disclosure in SECR prepares for UK SRS
3. Strengthen governance — board oversight of climate matters
4. Enhance documentation — robust evidence and methodology records

Successful SECR reporting requires systematic data collection, consistent methodology application, and integration with annual reporting processes. Early planning and board engagement ensure compliant, high-quality disclosure that meets stakeholder expectations and prepares for future requirements.