SECR Requirements 2026

Quick SECR Eligibility Check

Your company must comply with SECR if it meets any of these criteria under the SECR regulations:

1. Quoted Companies (All Sizes)

All UK-incorporated quoted companies must comply with SECR, regardless of size.

A quoted company means equity shares officially listed on:

• the official list, under Part 6 of the Financial Services and Markets Act 2000 (the London Stock Exchange Main Market)
• an official listing in an EEA State
• the New York Stock Exchange, or Nasdaq

AIM is not on that list. Securities admitted to AIM are not admitted to the official list, so an AIM company is unquoted for SECR and reaches scope only through the Schedule 7 paragraph 20B size test below.

2. Large Unquoted Companies

UK companies that exceed at least 2 of 3 size tests. SECR’s test is self-contained in Schedule 7 and was not affected by the Companies Act size limits uprated on 6 April 2025:

• More than 250 employees (average over the year)
• More than £36 million annual turnover
• More than £18 million balance sheet total

3. Large LLPs

Limited Liability Partnerships meeting the same size tests as unquoted companies.

What You Need to Report Under SECR

SECR requires disclosure of seven core elements within the directors' report, as specified by Schedule 7 to SI 2008/410:

Energy Consumption Data

UK Energy Use (kWh)

Total energy consumption from all UK operations including:

• Electricity consumption — grid electricity and renewable sources
• Gas consumption — natural gas and other heating gases
• Transport fuel — petrol, diesel, aviation fuel for company vehicles
• Other heating fuels — oil, biomass, district heating

Methodology

• Consumption measurement — actual meter readings where available
• Estimation methods — acceptable for immaterial amounts
• Data quality — reasonable accuracy standard applies
• Boundary definition — operational control approach typically used

GHG Emissions Data

UK Emissions (tCO₂e)

Greenhouse gas emissions from UK operations calculated using UK Government (DESNZ) conversion factors, published as a new set every June:

• Scope 1: Direct emissions from owned or controlled sources
• Combustion in owned boilers, vehicles, industrial processes
• Process emissions and refrigerant losses
• Company-owned transport and machinery

• Scope 2: Indirect emissions from purchased energy
• Purchased electricity consumption
• Purchased steam, heating, and cooling
• Use location-based or market-based approach

• Scope 3: Other indirect emissions — there is no statutory Scope 3 limb for quoted companies at all
• Mandatory for large unquoted companies and LLPs: fuel used for transport — aircraft, road-going vehicle, train or vessel journeys starting or ending in the UK (SI 2008/410 Sch 7 para 20D(1)(b))
• All other Scope 3 categories (employee commuting, wider supply-chain emissions, etc.) remain voluntary for every population

Emission Intensity Ratio

Express annual emissions as a ratio against a relevant business metric:

• Revenue basis — tCO₂e per £million turnover (most common)
• Production basis — tCO₂e per unit of product
• Area basis — tCO₂e per square meter of floor space
• Employee basis — tCO₂e per full-time equivalent employee

Narrative Requirements

Energy Efficiency Measures

Description of measures taken to improve energy efficiency during the financial year, including:

• Technology upgrades — more efficient equipment, LED lighting, smart systems
• Process improvements — operational changes reducing energy use
• Behavioural changes — staff training, awareness campaigns
• Building improvements — insulation, heating system upgrades

If no measures were taken, state explicitly: "No energy efficiency measures were undertaken during the year."

Methodology Description

Describe the methodology used for energy and emissions calculations:

• Calculation standards — typically GHG Protocol Corporate Standard
• Emission factors — UK Government (DESNZ) conversion factors
• Data collection approach — measurement vs estimation
• Boundary setting — operational control approach

Prior Year Comparatives

Previous year data for all quantitative metrics to enable trend analysis:

• Energy consumption — comparative kWh figures
• GHG emissions — comparative tCO₂e figures
• Intensity ratios — year-on-year performance
• Context for changes — explanations for significant variations

Additional Reporting Requirements

Director Approval

The SECR report must be:

• Approved by the board — formal board resolution
• Signed by a director — typically the CEO or CFO
• Included in directors' report — integrated with annual reporting
• Subject to audit — external verification where required

Compliance Integration

SECR reporting integrates with existing compliance obligations:

• Annual accounts filing — submitted as part of Companies House filing
• Audit requirements — subject to statutory audit where applicable
• Public disclosure — available on public record
• Corporate governance — part of ESG reporting framework

Exemptions and Special Cases

Who is Exempt?

• Companies below size thresholds — don't meet 2 of 3 tests
• Dormant companies — no business activity during the year
• First year operations — may have limited data availability
• Specific exemptions — certain financial services entities

Special Considerations

• Group companies — each entity applies thresholds independently
• Subsidiary reporting — parent and subsidiary may both be in scope
• Acquisition integration — newly acquired entities have transition periods
• Short financial periods — pro-rate thresholds for periods under 12 months

Low Energy Users

Companies with very low energy consumption may:

• Use simplified approaches — reasonable estimation methods
• 40,000 kWh or less — relief from disclosure (not exemption from SECR) where the report states that reason; UK-only for large unquoted companies and LLPs, no UK qualifier for quoted companies (SI 2008/410 Sch 7 para 15(5)(a), para 20D(7)(a))
• State low consumption — silent omission does not satisfy the relief; the report must say why the information is withheld
• Maintain proportionality — effort proportionate to emissions

SECR vs Future Requirements

UK SRS Interaction

With UK SRS published 25 February 2026:

For Quoted Companies

• SECR continues — all existing requirements remain
• UK SRS S2 has no effective date in the published Standards — 2027/2029 is only the FCA's own proposed timing, not yet decided
• Dual compliance — may need both frameworks

For Large Unquoted Companies

• SECR remains primary — no immediate change
• UK SRS voluntary — available for competitive advantage
• Supply chain pressure — customers may require enhanced disclosure

Building SECR Systems for the Future

• Data system flexibility — design for potential expansion
• Scope 3 consideration — voluntary disclosure now, potentially mandatory later
• Governance integration — climate oversight and board engagement
• Stakeholder communication — prepare for increased ESG scrutiny

Getting Started with SECR Requirements

1. Threshold assessment — determine if SECR applies using size tests
2. Boundary definition — identify which operations and entities are included
3. Data collection setup — establish energy consumption monitoring
4. Calculation methodology — choose appropriate standards and factors
5. Internal processes — board approval and sign-off procedures
6. Annual planning — integrate with financial year-end and accounts preparation

The key to SECR compliance is systematic preparation and consistent application of methodology year-on-year.

Early planning ensures comprehensive data collection and timely reporting within Companies House deadlines, and the same data underpins the broader UK sustainability reporting standards guidance a company will meet next.