SECR Reporting: Meeting Streamlined Energy and Carbon Reporting Requirements Without the Guesswork

What SECR actually involves

Streamlined Energy and Carbon Reporting (SECR) is a UK mandatory reporting framework requiring large companies and LLPs to disclose their UK energy use, greenhouse gas emissions, and energy efficiency measures in their annual directors' report. SECR applies to quoted companies (all energy and GHG data globally) and unquoted large companies and LLPs (UK energy and GHG data). The disclosure must include Scope 1 and Scope 2 emissions, total UK energy consumption in kWh, an intensity ratio, a description of energy efficiency measures taken during the year, and a comparison with the previous year. SECR is governed by the Companies Act 2006 as amended and is enforced by Companies House.

Why it's harder in practice than it looks

Boundary definitions catch companies out

SECR requires quoted companies to report global emissions and unquoted companies to report UK energy use. Defining what counts as UK versus global for companies with complex international operations, subsidiaries, joint ventures, or leased assets requires careful analysis of the regulatory guidance and GHG Protocol boundary setting principles.

Intensity ratio selection is not prescribed and creates comparability challenges

SECR requires an intensity metric but does not specify which denominator to use, options include revenue, headcount, floor area, or units of output. Companies that change their intensity metric between years or use a metric that is not meaningful for their business face questions from investors and regulators about the consistency and relevance of the disclosure.

Energy efficiency measure descriptions are frequently inadequate

SECR requires a description of the principal energy efficiency measures taken during the year. Many companies meet this requirement with vague, generic statements, LED lighting upgrades, behavioural change programmes, without quantifying the impact. Regulators and investors are increasingly expecting quantified savings rather than activity descriptions.

SECR data quality may not meet CSRD assurance standards

SECR has no mandatory assurance requirement. Companies that have produced SECR disclosures without independent verification may find their data does not meet the internal control and documentation standards required for CSRD assurance. Closing this gap requires investment in data infrastructure that goes beyond SECR's minimum requirements.

What good looks like

A high-quality SECR disclosure is grounded in a complete energy data collection process covering all sources within the reporting boundary, uses the GHG Protocol methodology for emissions calculations with documented emission factors, reports both location-based and market-based Scope 2 figures, uses an intensity metric that is meaningful for the business and consistent year-on-year, and describes energy efficiency measures with quantified savings where possible. For companies also subject to CSRD, SECR data forms part of the verified emissions inventory and should meet assurance-ready quality standards.

When to bring in external support

SECR boundary definition, data collection methodology, emissions calculation, and integration with wider carbon accounting programmes benefit from specialist support. Leafr's network includes SECR and energy reporting specialists who support companies in producing compliant, investor-grade annual disclosures that form a sound foundation for broader sustainability reporting.

Frequently asked questions

Who must comply with SECR?

SECR applies to: quoted companies (all sizes, listed on any UK or overseas market); unquoted large companies meeting at least two of three criteria (more than 250 employees, turnover over £36m, balance sheet over £18m); and large LLPs meeting equivalent size criteria. Companies that consumed less than 40MWh of energy in the reporting year are exempt from the energy and emissions disclosure requirements but must still state this in their directors' report.

What emissions must be included in a SECR disclosure?

Quoted companies must disclose global Scope 1 (direct combustion and process emissions) and Scope 2 (purchased electricity and heat) emissions, plus total global energy consumption. Unquoted large companies disclose UK Scope 1 and 2 emissions and UK energy consumption. All companies must provide a year-on-year comparison and an intensity ratio. Scope 3 emissions are not required under SECR but may be included voluntarily.

What emission factors should be used for SECR?

SECR requires use of appropriate emission conversion factors. For UK companies, the standard source is the UK government's Greenhouse Gas Reporting: Conversion Factors, published annually by DEFRA and BEIS. These factors must be the version current for the reporting year, using outdated factors without explanation is a compliance issue. For international operations of quoted companies, internationally recognised factors from sources such as the IEA are appropriate.

Is SECR data independently verified?

SECR does not require independent verification, but the disclosure appears in the annual directors' report alongside financial statements that are audited. Auditors of the accounts are expected to consider whether the SECR disclosures are consistent with their knowledge of the business. For companies subject to CSRD, the SECR data forms part of the sustainability disclosure that requires third-party assurance, so verification of SECR data is effectively mandated for in-scope companies through the CSRD assurance requirement.

How does SECR relate to other energy and carbon reporting requirements?

SECR replaced the mandatory greenhouse gas reporting requirements for quoted companies under the Companies Act (which had been mandatory since 2013) and the Carbon Reduction Commitment Energy Efficiency Scheme (CRC). It sits alongside ESOS (Energy Savings Opportunity Scheme), which requires energy audits but not public disclosure. For CSRD-in-scope companies, SECR data feeds into ESRS E1 climate disclosures. For companies in the UK ETS, separate allowance surrender obligations apply independently of SECR reporting.

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