
SECR Reporting Requirements 2026: The Complete Guide
A complete guide to SECR reporting requirements for UK businesses in 2026. Covers who must report, what to include, Scope 1/2/3 rules, methodology, deadlines, and how software makes compliance easier.
Streamlined Energy and Carbon Reporting (SECR) is one of the UK's most important mandatory climate disclosure frameworks — and for many businesses, it's their first formal encounter with carbon accounting.
This guide covers everything you need to know: who must report, exactly what to disclose, how to calculate emissions correctly, common pitfalls to avoid, and how carbon accounting software can make the whole process significantly easier. Check out our article here on how to choose the right carbon reporting software for your business. Whether you're preparing your first SECR report or looking to improve the quality of an existing one, this is the most complete resource available.
What is SECR (Streamlined Energy and Carbon Reporting)?
SECR stands for Streamlined Energy and Carbon Reporting. It is a mandatory UK regulatory framework introduced on 1 April 2019 under the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018.
SECR requires eligible UK companies to disclose:
- Their energy consumption (in kWh)
- Their greenhouse gas (GHG) emissions (in tonnes of CO2 equivalent, or tCO2e)
- Energy efficiency measures they have taken or plan to take
- An emissions intensity ratio
This information must be included in the company's annual report — meaning sustainability and financial performance are assessed together, not in isolation.
SECR replaced the Carbon Reduction Commitment (CRC) Energy Efficiency Scheme, which was widely criticised for being overly complex and administratively burdensome. The goal of SECR was to standardise and simplify carbon reporting while broadening the number of companies required to participate.
Why Does the UK Require SECR Reporting?
SECR exists because the UK government has a legally binding commitment to reach net-zero emissions by 2050. Corporate activity is responsible for a substantial share of national emissions, and without mandatory disclosure, it is impossible to track progress or hold businesses accountable.
The key objectives of SECR are:
1. Drive national emissions reductions
By requiring businesses to measure and report energy use and emissions annually, SECR creates a baseline that enables year-on-year progress tracking — both at the company level and nationally.
2. Encourage energy efficiency
The act of measuring energy consumption almost always reveals waste and inefficiency. Many businesses that undertake SECR for the first time identify significant cost-saving opportunities they were previously unaware of.
3. Increase corporate transparency
Investors, lenders, customers, and employees are increasingly scrutinising the environmental performance of businesses they engage with. Public disclosure of SECR data allows stakeholders to assess and compare sustainability credentials.
4. Align with global standards
SECR is designed to align with internationally recognised frameworks such as the GHG Protocol Corporate Standard and increasingly intersects with the EU's Corporate Sustainability Reporting Directive (CSRD), which is extending its reach to some UK subsidiaries of EU companies.
Who Needs to Report Under SECR?
SECR applies to approximately 11,900 businesses in the UK. The framework distinguishes between two types of eligible company, each with slightly different reporting obligations.
Quoted Companies
A quoted company is defined as one listed on:
- The London Stock Exchange (LSE)
- An EEA-regulated market
- The New York Stock Exchange (NYSE) or NASDAQ
Quoted companies must report on their global energy use and carbon emissions — meaning all operations worldwide, not just those in the UK.
Large Unquoted Companies and LLPs
A company or LLP is considered "large" under SECR if it meets at least two of the following three criteria:
| Criterion | Threshold |
| Annual turnover | £36 million or more |
| Balance sheet total | £18 million or more |
| Number of employees | 250 or more |
Unlike quoted companies, large unquoted companies and LLPs are required to report on UK-based activity only — with one important exception: grey fleet emissions (see below).
Who is Exempt from SECR?
Companies that meet the "large" criteria but consumed 40,000 kWh or less of energy in the reporting period are exempt from SECR, provided they state this in their Directors' Report. This exemption is designed to avoid disproportionate administrative burdens on large companies with very low energy use (for example, a large holding company with minimal operational footprint).
What Are the SECR Reporting Requirements?
SECR reporting requirements differ between quoted and unquoted companies. The table below sets out the key disclosure obligations for each.
Reporting Requirements by Company Type
| Disclosure Element | Quoted Companies | Large Unquoted Companies & LLPs |
| Scope 1 emissions (global) | Required | Not Required |
| Scope 1 emissions (UK only) | Required | Required |
| Scope 2 emissions (global) | Required | Not Required |
| Scope 2 emissions (UK only) | Required | Required |
| Grey fleet emissions (Scope 3) | Required | Required |
| Other Scope 3 emissions | Encouraged | Encouraged |
| Total energy consumption (kWh) | Required | Required |
| Emissions intensity ratio | Required | Required |
| Energy efficiency measures | Required | Required |
| Prior year comparatives | Required | Required |
| Methodology disclosure | Required | Required |
What Are Scope 1, 2 and 3 Emissions?
The Scope framework is defined by the GHG Protocol Corporate Standard — the globally accepted gold standard for corporate carbon accounting. Check out our full guide here on how to measure your company's carbon footprint.
Scope 1 — Direct emissions
Emissions from sources that your company directly owns or controls. Examples include:
- Natural gas combustion in office boilers or industrial processes
- Fuel combustion in company-owned or leased vehicles
- Fugitive emissions (e.g. refrigerants from air conditioning systems)
Scope 2 — Indirect energy emissions
Emissions from the generation of purchased electricity, heat, steam or cooling consumed by your organisation. For SECR purposes, the location-based method is the most common, using grid average emission factors published by DEFRA. However, companies with renewable energy tariffs or PPAs may also use the market-based method.
Scope 3 — All other indirect emissions
A broad category covering emissions across your entire value chain, including:
Supply chain (purchased goods and services)
Employee commuting
Business travel (flights, hotels, public transport)
Waste disposal
Upstream and downstream logistics
Scope 3 is not mandatory under SECR — with one critical exception.
Which Scope 3 Emissions Are Mandatory Under SECR?
Grey fleet emissions are the one mandatory Scope 3 category for large unquoted companies and LLPs. Grey fleet refers to business travel in employee-owned or rental vehicles where the company reimburses fuel costs — for example, when employees submit mileage claims for using their own car for work trips.
Grey fleet does not include:
- Employee commuting to a regular workplace
- Business travel by public transport or flights
- Company-owned vehicles (these are Scope 1)
Beyond grey fleet, SECR strongly encourages voluntary Scope 3 disclosure. Companies with net-zero commitments or those subject to investor or customer pressure on sustainability will typically go further than the minimum.
What Methodology Should I Use for SECR?
SECR does not mandate a single methodology, but the two most widely used and accepted approaches are:
1. GHG Protocol Corporate Standard
The global gold standard for corporate carbon accounting, developed by the World Resources Institute (WRI) and the World Business Council for Sustainable Development (WBCSD). It defines the Scope framework, provides guidance on organisational and operational boundaries, and outlines calculation methodologies.
2. DEFRA Greenhouse Gas Reporting Conversion Factors
Published annually by the UK Department for Environment, Food & Rural Affairs (DEFRA), these conversion factors are used to translate raw energy and activity data into CO2 equivalent figures. They are updated each year to reflect changes in the UK's electricity grid carbon intensity and other factors.
For SECR compliance, you should use DEFRA's most recent conversion factors for the reporting year in question — not a previous year's figures.
Can I Use Estimates in My SECR Report?
Wherever possible, you should use primary data — actual meter readings, energy bills, and fuel receipts — for your SECR report. However, the regulation recognises that primary data is not always available, and it permits the use of estimates in specific circumstances.
When Are Estimates Acceptable?
Estimates are acceptable when primary data genuinely cannot be obtained. Common situations include:
- You occupy a shared office or co-working space and your landlord cannot provide sub-meter data
- You switched energy provider mid-year and have a gap in your records
- You disposed of fleet vehicles and don't have complete mileage records for the disposal period
What Estimation Methods Are Allowed?
The following estimation approaches are recognised as acceptable:
| Method | Description |
| Direct comparison | Use data from a comparable prior period in place of missing data |
| Pro-rata extrapolation | Scale up partial-period data to cover the full year (e.g. use 9 months of data to estimate 12 months) |
| Benchmarking | Use the measured consumption of one similar asset to estimate consumption for another (e.g. one retail outlet to another) |
| Average-data estimates | Use published averages — e.g. kWh per m² of floor space, or litres of fuel per £ spent on fuel |
All estimation methods used must be disclosed in the report, along with the reason primary data was unavailable.
Can I Exclude Anything from My SECR Report?
SECR includes a "comply or explain" provision. This allows companies to exclude specific activities from their report if collecting the relevant data would be:
Impractical — for example, where the administrative cost of collecting data is disproportionate to its materiality
Seriously prejudicial to the company's interests — a high bar that applies in limited circumstances
If an exclusion is made, the report must clearly explain:
- What has been excluded
- Why it has been excluded
- What steps (if any) were taken to obtain the data
This is not a licence to avoid reporting inconvenient data — it is a narrow carve-out for genuinely impractical situations.
What Is an Intensity Ratio and How Do I Choose One?
An intensity ratio puts your absolute emissions figure into business context. It is calculated by dividing total emissions (in tCO2e) by a relevant business metric. This allows stakeholders to assess whether your emissions are rising or falling relative to the scale of your business activity.
SECR requires all companies to report at least one intensity ratio. Common options include:
| Intensity Metric | Formula | Best suited for |
| Per £ million revenue | tCO2e ÷ £m turnover | Most sectors |
| Per employee (FTE) | tCO2e ÷ number of employees | Professional services |
| Per m² of floor space | tCO2e ÷ m² | Retail, hospitality, property |
| Per tonne of product | tCO2e ÷ units produced | Manufacturing |
| Per delivery | tCO2e ÷ number of deliveries | Logistics |
| Per passenger mile | tCO2e ÷ passenger miles | Transport |
Choosing a sector-specific ratio — rather than defaulting to revenue — generally provides more meaningful data for stakeholders and allows better peer-to-peer benchmarking.
Does My SECR Report Need to Be Independently Assured?
No — independent assurance is not a legal requirement under SECR. However, it is strongly recommended by government guidance, particularly for companies that:
- Have a dedicated net-zero commitment
- Are subject to investor or lender scrutiny on ESG matters
- Intend to use their SECR data in wider sustainability disclosures (e.g. CDP, CSRD, TCFD)
- Want to reduce the risk of reputational damage from errors
Assurance is typically provided by an accredited third-party auditor against standards such as ISO 14064-3 or the ISAE 3410 standard for greenhouse gas assurance engagements.
How is SECR Different from ESOS?
SECR and the Energy Savings Opportunity Scheme (ESOS) both apply to large UK businesses, but they serve different purposes.
| SECR | ESOS | |
| Purpose | Annual reporting of energy and carbon | Identifying energy efficiency opportunities |
| Frequency | Annual (in line with financial reporting) | Every 4 years |
| Output | Public disclosure in annual report | Internal audit report; notification to Environment Agency |
| Public disclosure | Yes | No |
| Scope | Energy use, emissions, intensity ratio, efficiency measures | Energy consumption in buildings, processes and transport |
| Lead assessor required | No | Yes — ESOS Lead Assessor |
Many businesses subject to both SECR and ESOS find it efficient to align their data collection and boundary-setting processes, since they draw on similar underlying energy data.
Step-by-Step: How to Produce Your SECR Report
Here is a practical seven-step process for preparing a compliant and high-quality SECR report.
Step 1: Define Your Organisational Boundary
Before collecting any data, you need to determine which entities and activities fall within scope.
The most common approach is the operational control method — under which you include emissions from all operations over which you have the authority to introduce and implement operating policies. In simple terms: if you manage it, you report it.
For quoted companies, this boundary extends globally. For large unquoted companies and LLPs, it covers UK operations plus grey fleet emissions.
Document your boundary clearly, including any exclusions and the rationale for them.
Step 2: Collect Your Energy Data
Gather energy consumption data for the full reporting period (typically 12 months aligned with your financial year). The main data sources are:
- Gas and electricity bills — your most important source; request half-hourly data if available
- Fuel receipts and fleet management records — for company vehicles
- Employee expense claims — for grey fleet mileage data
- Meter readings — particularly useful for gaps in billing data
All energy data should be recorded in kWh. If you have fuel data in litres, you will need to convert using DEFRA's conversion factors.
Step 3: Calculate Your Emissions
Convert your energy data into CO2 equivalent (CO2e) figures using DEFRA's annual greenhouse gas reporting conversion factors.
The basic calculation is:
Emissions (tCO2e) = Activity Data × Emission Factor
For example:
Gas consumption: kWh of gas × DEFRA gas emission factor
Electricity: kWh of electricity × DEFRA grid electricity emission factor (for location-based method)
Diesel vehicles: litres of diesel × DEFRA diesel emission factor
Report Scope 1 and Scope 2 separately, and grey fleet as a Scope 3 sub-category.
Step 4: Convert Transport Data to Energy (If Needed)
For vehicle data, companies often hold mileage records rather than fuel consumption data in kWh. DEFRA publishes conversion factors that allow you to convert:
- Miles driven → fuel consumed (litres) → kWh
- Litres of fuel → kWh
This step ensures your total energy consumption figure (in kWh) is comprehensive and accurately reflects transport activity.
Step 5: Calculate Your Intensity Ratio
Select a normalisation metric that is appropriate to your business (see the intensity ratio table above). Divide your total tCO2e by that metric.
Provide a prior-year comparative where possible — this is required if you have previously reported under SECR.
Step 6: Document Your Energy Efficiency Measures
SECR requires you to disclose the energy efficiency measures you have taken during the reporting period, and any planned actions. These should be specific and credible. Examples include:
- LED lighting upgrades across office or manufacturing sites
- EV fleet transition and installation of charge points
- Building energy management systems (BEMS)
- Installation of solar PV panels
- Staff behaviour change programmes
- Procurement of renewable electricity via Power Purchase Agreement (PPA)
There is no minimum threshold for what counts as an efficiency measure — but vague or boilerplate language will attract scrutiny from auditors and stakeholders alike.
Step 7: Compile and Submit in Your Annual Report
Integrate your SECR data into your Directors' Report (for quoted companies) or your Directors' Report / Energy and Carbon Report (for unquoted companies and LLPs). Ensure the following are clearly presented:
Total energy consumption (kWh) broken down by source
- Scope 1 and Scope 2 emissions in tCO2e
- Grey fleet (Scope 3) emissions in tCO2e
- Prior year comparatives
- Intensity ratio(s)
- Methodology and conversion factors used
- Any exclusions and explanations
- Energy efficiency measures taken and planned
SECR and CSRD: What's the Connection?
An increasing number of businesses operating in the UK are also being pulled into the scope of the EU's Corporate Sustainability Reporting Directive (CSRD), which came into force in 2024 and is being phased in progressively. CSRD applies to:
- Large EU companies (already phasing in)
- Listed SMEs on EU-regulated markets (phasing in from 2026)
- Non-EU parent companies with significant EU revenue (€150m+) and at least one large EU subsidiary — phasing in from 2028
For UK businesses with EU subsidiaries or significant EU customers, CSRD reporting obligations may overlap significantly with SECR. The good news is that both frameworks draw on the GHG Protocol and similar emissions data — which means a well-structured SECR process provides a strong foundation for CSRD compliance.
If you're facing both obligations, building your carbon accounting infrastructure now — rather than managing each framework in isolation — will save significant time and cost.
Common SECR Mistakes to Avoid
Based on how businesses commonly approach SECR for the first time, these are the most frequent errors:
1. Using the wrong year's DEFRA conversion factors
Always confirm which version of DEFRA's factors applies to your reporting period. Using outdated factors will produce inaccurate emissions figures.
2. Forgetting grey fleet
Grey fleet is mandatory for unquoted companies but is frequently missed — particularly in professional services firms where employees regularly travel by car.
3. Treating energy and emissions as interchangeable
Your SECR report must include both your energy consumption (in kWh) and your emissions (in tCO2e). These are different figures calculated from the same underlying data.
4. Not providing prior-year comparatives
If you have previously reported under SECR, you are required to provide comparative data from the prior year. This is a common omission.
5. Vague intensity metrics
Choosing a generic intensity metric (like revenue) without explaining why it is appropriate, or failing to use it consistently year on year, undermines the value of the ratio.
6. Boilerplate efficiency measures
Listing generic statements like "we are committed to reducing our energy use" does not satisfy the requirement for specific efficiency measures. Be concrete.
Frequently Asked Questions About SECR
Q: What is the SECR reporting deadline?
SECR data must be included in the company's annual report and filed with Companies House within the statutory filing deadline — typically nine months after the financial year end for private companies, and six months for public companies.
Q: Is SECR mandatory in Ireland?
No — SECR is a UK-specific regulation under UK company law. Irish-incorporated companies are not required to comply with SECR. However, Irish subsidiaries of UK-listed quoted companies may be pulled into scope if their parent is a quoted company required to report globally. Irish businesses may instead be subject to the EU's CSRD framework.
Q: Do I need specialist software for SECR reporting?
You can prepare an SECR report manually using spreadsheets, but this approach is error-prone and time-consuming — especially as your operations grow or as you move toward voluntary Scope 3 disclosure. Carbon accounting software automates data collection, applies the correct DEFRA conversion factors, generates audit-ready outputs, and enables you to track intensity ratios over time.
Q: What happens if I don't comply with SECR?
Failure to comply with SECR is treated as a breach of the Companies Act 2006. Companies House can reject annual reports that do not include required SECR disclosures. Directors can face personal liability for persistent non-compliance. While enforcement to date has been relatively light, scrutiny is increasing as SECR data is used by investors, lenders and rating agencies.
Q: Can a small business voluntarily report under SECR?
Yes. Any business can voluntarily align with SECR's methodology and structure, even if not legally required to. Many SMEs do this to demonstrate sustainability credentials to customers, prepare for future mandatory reporting, or build the internal capacity needed before they cross the size threshold.
Q: How does SECR relate to CDP reporting?
CDP (formerly the Carbon Disclosure Project) is a voluntary disclosure platform widely used by listed companies and those responding to investor or customer pressure. CDP disclosure is more comprehensive than SECR but draws on the same underlying data. A robust SECR process significantly reduces the effort required to complete a CDP submission.
How Carbon Accounting Software Helps with SECR
Managing SECR manually — through spreadsheets, email chains, and manual conversions — is risky and time-consuming. Carbon accounting software streamlines every step of the process:
Automated data collection: Connect directly to energy data sources, expense systems, and fleet management tools to eliminate manual data entry
Always up-to-date conversion factors: DEFRA factors are updated automatically each year, removing the risk of using outdated figures
Scope 1, 2, and 3 tracking: Track all categories in a single platform, with clear separation by scope and source
Intensity ratio calculations: Automatically calculate and track your chosen intensity metrics over multiple years
Audit-ready outputs: Generate SECR-compliant reports formatted for inclusion in your Directors' Report, with full methodology disclosure
CSRD alignment: If you face dual reporting obligations, a good platform will support both frameworks from the same underlying dataset
Emerald Power is built specifically for businesses in Ireland and the UK navigating mandatory and voluntary carbon reporting. Our platform combines flexible, customisable reporting with dedicated expert support — so your team isn't left to figure out GHG Protocol nuances alone.
[See how Emerald Power supports SECR compliance]
This guide is accurate as of June 2026. Regulatory requirements may be updated; always refer to the latest DEFRA guidance and Companies House requirements for your specific reporting period.