SECR Reporting Requirements in 2026: Who Must Report, and Why the New Size Limits Don’t Change It
In brief
- Streamlined Energy and Carbon Reporting (SECR) requires quoted UK companies and large unquoted companies and LLPs to report energy use and greenhouse gas emissions in their annual report.
- An unquoted company or LLP is in scope if it meets at least two of three tests: turnover of £36 million or more, a balance sheet of £18 million or more, and 250 or more employees.
- The April 2025 rise in Companies Act size limits (to £54 million turnover and £27 million balance sheet) did not change the SECR thresholds. Some companies are now “medium” for accounts but still must report under SECR.
- Companies that used 40 MWh or less in the year do not have to disclose the detailed figures, but must still state that they are below the threshold.
SECR has applied since April 2019, so most guides to it are old, and several now give the wrong thresholds. The common mistake is to assume that the new, higher company size limits from April 2025 also moved SECR. They did not. This guide explains who must report, what goes in the report, and how to prepare it.
Who must report under SECR?
| Type of organisation | In scope? |
|---|---|
| Quoted companies (UK-incorporated, listed in the UK, EEA, New York or Nasdaq) | Yes, whatever their size; they report global emissions |
| Unquoted companies | Yes, if two or more of: turnover ≥ £36m, balance sheet ≥ £18m, employees ≥ 250 |
| LLPs | Yes, on the same two-of-three test |
| Companies below the tests, or using 40 MWh or less | No detailed disclosure needed |
For financial years beginning on or after 6 April 2025, the Companies Act size limits for a medium company rose to £54 million turnover and £27 million balance sheet. ICAEW’s guidance points out that the SECR scoping thresholds were not amended. A company with £40 million turnover, a £20 million balance sheet and 180 staff may now prepare medium-sized accounts, but it still meets two SECR tests and must still report.
What must the SECR report include?
| Item | What it means |
|---|---|
| UK energy use | Electricity, gas and transport fuel, in kWh, at minimum |
| Associated emissions | Greenhouse gas emissions from that energy use, in tonnes CO₂e |
| An intensity ratio | At least one, for example t CO₂e per £ million turnover or per employee |
| Previous year | The same figures for the prior year (from your second year of reporting) |
| Methodology | The standard and factors used, for example the GHG Protocol and the UK Government conversion factors |
| Energy efficiency action | What you did in the year to improve energy efficiency |
Quoted companies report a little more: global Scope 1 and 2 emissions, as they have since 2013, plus the energy use and efficiency narrative. In practice, the SECR figures are the Scope 1 and 2 part of a normal carbon footprint, with transport fuel included. Scope 3 is voluntary under SECR, except for business travel in rental cars or employee-owned vehicles where the company buys the fuel, which counts towards the transport figure.
How to prepare it
Use the same 12 months as your financial statements. Collect electricity and gas in kWh from bills, and fuel in litres from fuel cards and mileage claims. Convert with the UK Government factors for the matching year: the 2026 set lowers the electricity factor sharply, so a fall between years may be a factor change rather than a real reduction (see the factor trap). Then write a short methodology note and a paragraph on efficiency measures. The report goes in the directors’ report (or the strategic report for quoted companies) and is filed at Companies House with the accounts.
SECR is a Scope 1 and 2 footprint with a few extra lines. If you already measure your footprint for a customer or a tender, most of the work is done.
The same numbers feed a Carbon Reduction Plan for public tenders, so it pays to measure once. If you want the SECR section prepared and checked, our GHG accounting service covers it.
Frequently asked questions
What are the SECR thresholds in 2026?
Unquoted companies and LLPs are in scope if they meet two or more of: turnover of £36 million or more, a balance sheet of £18 million or more, and 250 or more employees. All quoted companies are in scope.
Did the April 2025 company size changes affect SECR?
No. The Companies Act size limits rose for financial years beginning on or after 6 April 2025, but the SECR scoping thresholds were not amended.
Is Scope 3 required under SECR?
No, Scope 3 is voluntary, although transport fuel the company pays for, including in rental and employee cars on business, is part of the required energy and emissions figures.
What if we use very little energy?
If you used 40 MWh or less in the period, you do not have to give the detailed figures, but you should state that you are below the threshold.
Does SECR need to be audited?
There is no requirement for independent assurance, but the auditor checks that the directors’ report is consistent with the accounts, so the figures should be documented.
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