Does my business need to report under SECR?

Start with the organisation, not the energy bill

Streamlined Energy and Carbon Reporting (SECR) is an annual reporting requirement for certain UK companies and limited liability partnerships (LLPs). A high energy bill alone does not put a small business in scope, and using little energy does not always mean you can say nothing in the annual report.

Work through four questions: what legal entity is reporting, does the relevant size route apply, is it covered by a qualifying group report, and does the low-energy exemption apply? Your accountant or company-secretarial adviser should confirm the final position.

1. Confirm the legal entity

• UK-incorporated quoted company: there is a separate, broader route covering global energy and emissions. Do not use the unquoted-company size test to rule it out. “Quoted” has a specific legal definition; confirm the relevant listing with your adviser.
• UK unquoted company or UK LLP: check the SECR size rules and any applicable group arrangements.
• Another organisation type: check the legal form and any sector-specific rules. A charity can be a company; a trading name is not enough to identify the reporting duty.

Carbon Verify’s SECR workspace supports the unquoted-company and LLP workflow. It does not prepare the full quoted-company global disclosure.

2. Check the SECR size rules—not just the accounts label

The SECR size assessment uses turnover, balance-sheet total and average employee numbers. The monetary reference thresholds are £36 million turnover and £18 million balance-sheet total, alongside 250 employees. The relevant two-of-three test, first-year rules and size history must be considered.

The April 2025 increases in general company-accounts thresholds do not automatically increase these SECR thresholds. A business described as medium-sized in its accounts can still need a SECR assessment. HM Treasury explicitly notes that SECR no longer aligns with the general definition of “large”. Check the current government explanation.

Use the annual-accounts figures and average employee count, not today’s headcount or a forecast. Where a figure is exactly on a threshold, the company is new, or its size has changed, ask your adviser to apply the statutory rules rather than rounding the numbers. Group calculations also need the correct net or gross basis.

3. Confirm whether a parent report covers you

Being owned by another business is not, by itself, an exemption. Ask the parent’s reporting team which entities its report includes, whether it satisfies the relevant UK requirements and whether the reporting periods and exemption conditions match.

Keep that confirmation with the reporting file. If your business prepares a group report, agree the consolidation boundary and group size test with the accounts team before adding subsidiary figures. Do not add an entity’s records twice.

4. Check the 40,000 kWh low-energy route

For an otherwise in-scope unquoted company or LLP, relevant UK energy consumption of 40,000 kWh or less during the reporting period can qualify for the low-energy exemption. It reduces the detailed disclosure requirement; the relevant report must still say that energy and carbon information is not disclosed for that reason.

Assess gas, purchased electricity and qualifying transport energy—not just the office electricity meter. Include the required group boundary where reporting as a group. Quoted companies have different geographic coverage and should use their own guidance.

What happens after the check?

• Full reporting route: collect energy and emissions data, the relevant comparison figures, an intensity ratio, the methodology and energy-efficiency measures. Companies generally disclose in the Directors’ Report; LLPs prepare an Energy and Carbon Report.
• Low-energy route: retain the calculation supporting eligibility and arrange the required statement.
• Qualifying parent coverage: retain confirmation of the coverage and conditions.
• Outside mandatory SECR: you may still choose to measure your footprint or need to answer a customer’s request. That is a different question from a statutory SECR duty.

A procurement Carbon Reduction Plan is not a substitute for SECR, and SECR does not automatically satisfy a tender’s Carbon Reduction Plan requirements. The underlying records can overlap, but the reporting purposes and coverage differ.