Agree these three things before asking for bills
This checklist is for the UK unquoted-company and LLP reporting route. Quoted companies need a broader global disclosure. If the reporting position is not settled, start with does my business need to report under SECR?
- The organisation: the legal entity, sites and any subsidiaries included in the report.
- The dates: normally the financial year in the annual accounts. For a year ending 31 December 2025, start by collecting records for 1 January–31 December 2025, not the latest 12 bills regardless of date.
- The reviewer: who will resolve boundary questions and approve the final disclosure.
Create one evidence folder with subfolders for energy, transport, calculations and approvals. Keep original bills separate from your working totals. A simple register of source, period, quantity, unit and evidence reference makes the work easier to check.
The collection checklist: what to ask for and who to ask
| Collect | Start with | Check before using |
|---|---|---|
| Electricity consumption in kWh | Finance, facilities, supplier portal or landlord | All relevant meters and dates; actual versus estimated readings; credits and corrected bills |
| Gas consumption in kWh | Gas bills and meter records | Use the billed kWh or document conversion from volume; do not treat cubic metres as kWh |
| Qualifying transport fuel | Fleet manager, fuel cards and fuel invoices | Litres by fuel type, the relevant vehicles and period, and any non-business use |
| Business mileage in employees’ cars | Payroll, expense claims and travel logs | Reimbursed business journeys, distance units, vehicle/fuel information and the estimation method |
| Other potentially relevant energy | Facilities and operations | Flag unusual fuels, on-site generation, purchased heat or offshore activity for boundary review; keep voluntary additions distinct |
| Previous disclosure and calculations | Accounts team and last annual report | The reported period, method, boundary and any restated figures |
| Intensity denominator | Finance, HR or production records | A documented metric covering the same reporting period and boundary |
| Efficiency measures taken | Facilities, fleet and operational managers | What actually happened during the year, when it happened and supporting records |
Ask for consumption, not just pounds spent. A bill of £2,000 is not a measure of energy use. Use a documented estimation approach only where necessary and make the uncertainty visible.
Be precise about business travel
For unquoted companies and LLPs, the mandatory transport boundary is not every journey appearing in the expenses system. Gather fuel for transport the organisation operates, including relevant owned, leased or hired vehicles, and reimbursed business mileage in employees’ own cars.
Ordinary employee commuting and third-party flights, rail and taxi journeys are not generally part of this route’s minimum mandatory transport disclosure. They can be useful voluntary footprint information, but keep them separate and confirm unusual arrangements with your reviewer. The government guidance includes a transport decision table.
Avoid double counting: do not calculate the same company-car journey once from its fuel-card litres and again from mileage. Electricity used to charge an electric vehicle must also not be added twice if it is already included in a site’s electricity total.
When a bill is missing or a landlord pays it
Ask the supplier for a duplicate or the landlord for metered consumption and the basis of any allocation. Utilities bundled into rent are a reason to investigate, not a reason to enter zero.
If a reasonable estimate is needed, record the source, calculation, dates and reviewer. If required information is genuinely impractical to obtain, the reporting rules require the omission and reason to be explained; this is not a blanket exemption for inconvenient records.
The information around the totals matters too
Your working file should support energy in kWh, related emissions in tonnes of CO2 equivalent (tCO2e), at least one intensity ratio, the calculation method and the energy-efficiency steps taken during the year. Keep required and voluntary figures clearly identified.
An intensity ratio relates emissions to business activity. For example, a fictional 120 tCO2e divided by 200 average employees gives 0.60 tCO2e per employee. This explains the maths, not a recommended benchmark. Choose a denominator that suits the business and use it consistently.
Comparison energy, emissions and intensity figures are generally required after the first mandatory reporting year. “My first time preparing the report” is not the same as “the company’s first mandatory reporting year”—ask for the prior report before leaving a comparison blank.
For efficiency measures, describe work actually undertaken, such as changing heating controls or driver training. Separate future intentions from completed work and do not claim a measured saving without evidence.
A useful handover to your accountant or reviewer
- The entity, sites, period and reporting-route decision.
- A list of source records and the quantities used, with units.
- The factor source, edition and calculation method appropriate to the period.
- A separate list of estimates, omissions and outstanding questions.
- Current and applicable prior-year totals and the intensity calculation.
- Draft wording, evidence of efficiency measures and an approval record.
Carbon Verify SECR helps assemble the supported records, calculations and draft Word and Excel outputs. It works independently of the CRP tool. The business and its reviewer remain responsible for the boundary, accuracy and final disclosure. Keep your evidence files and portable workspace backup somewhere secure; browser storage is not a managed backup.
Official sources
- Government environmental reporting guidance, Chapter 2: SECR — reporting scope, energy and transport, exemptions and required disclosures.
- HM Treasury sustainability reporting guidance 2025–26 — the SECR section and note on the separate size thresholds.
- The Companies (Directors’ Report) and LLPs (Energy and Carbon Report) Regulations 2018 — the underlying reporting legislation.
- UK Government greenhouse gas conversion factors — choose and document the relevant edition.
General guidance checked on 18 September 2026. Rules and circumstances can change. These guides do not certify compliance or replace professional review. Government information is reused under the Open Government Licence v3.0; examples and collection suggestions are Carbon Verify’s own.
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