Two UK carbon reporting duties keep getting mixed up, usually in the same email from a buyer or an accountant. One is SECR. The other is PPN 006. They share data and they share vocabulary. They do not share a trigger, and getting that wrong costs people either wasted effort or a failed bid.
The one-line difference
SECR applies because of what your company is: large, by the Companies Act tests, or quoted.
PPN 006 applies because of what you are bidding for: an in-scope central government contract worth £5 million a year or more, excluding VAT.
A 40-person business can need a Carbon Reduction Plan and never touch SECR. A large company can report under SECR for years and never bid for a central government contract.
Side by side
| SECR | PPN 006 | |
|---|---|---|
| What it is | A disclosure in the annual report | A Carbon Reduction Plan given to a buyer |
| Source | Schedule 7 of SI 2008/410 and SI 2018/1155 | Cabinet Office procurement policy note |
| Triggered by | Company size or being quoted | Bidding for an in-scope contract |
| Size test | Large: two of more than 250 employees, £36m turnover, £18m balance sheet, over two years | None. Contract value of £5m a year or more |
| Where it sits | Directors' report, filed with the accounts | Published on your own website |
| Core content | UK energy in kWh, Scope 1 and 2 emissions, an intensity ratio, prior year, methodology, efficiency actions | Net zero by 2050 commitment, Scope 1 and 2, defined Scope 3 categories, environmental measures, sign-off |
| Scope 3 | Transport fuel the company pays for, including grey fleet | A defined subset |
| Net zero commitment | Not required | Required |
| Who reads it | Shareholders, Companies House, auditors | Central government buyers |
| Consequence of missing it | Non-compliance with company law | Excluded at selection stage |
What they have in common
Both are built on the same raw material. You need fuel, electricity and mileage data for your own operations, converted into tonnes of CO2e using the same government conversion factors. Both ask for a Scope 1 and Scope 2 figure. Both expect you to say how you calculated it.
That overlap is the practical point. You do not need two inventories. You need one that can be cut two ways.
Where they differ in ways that bite
The boundary. SECR covers the company that files the report, with UK energy and the emissions that follow from it. The Carbon Reduction Plan covers the bidding entity. If the bidding entity is a subsidiary and your emissions are recorded centrally, the plan still has to reflect the bidder, or meet the conditions for relying on a parent's plan.
The Scope 3 list. A SECR report does not ask for most of Scope 3. A Carbon Reduction Plan does ask for a defined set, including business travel, employee commuting, waste, and upstream and downstream transport. If you only built a SECR dataset, you will have gaps. Commuting and waste are the usual ones.
The commitment. SECR is disclosure only. You report, you explain, you do not have to promise anything. The plan needs a signed declaration committing to net zero by 2050 at the latest.
The freshness. A SECR report is an annual document tied to your financial year. A Carbon Reduction Plan has to be signed off within 12 months of the procurement and updated at least annually. Buyers check the date.
Scoring. Government buyers check that a plan meets the requirements. They do not score one against another. Meeting the requirements is a pass.
Which one do I need?
Ask two questions in order.
- Am I large, or quoted? If you meet two of the three Companies Act tests on turnover, balance sheet and employees, or you are quoted, SECR applies and you report it with your accounts. Check the exemption for companies using 40,000 kWh or less of UK energy.
- Am I bidding for a central government contract of £5 million a year or more? If yes, you need a plan, whatever the answer to question one.
You can answer yes to both. Many contractors do.
How to run one dataset for both
- Keep one activity ledger of fuel, electricity, mileage, waste and travel, with the dates and sources.
- Apply one set of conversion factors for the reporting year, and record which.
- Produce the SECR cut: UK energy kWh, Scope 1 and 2, an intensity ratio, efficiency actions.
- Produce the plan cut: the same Scope 1 and 2, plus the required Scope 3 categories, the net zero declaration and the environmental measures.
- Reconcile the two. If the Scope 1 and 2 figures differ, you should be able to say why, because the boundary differs.
A mismatch you can explain is fine. A mismatch you cannot explain looks careless in a bid.
Where MetricOra fits
MetricOra holds one ledger for a company's fuel, energy and travel, with the factor library and methodology recorded against every figure. From it you can produce a SECR-ready report and a PPN 006 Carbon Reduction Plan without re-keying data, and the totals match because they come from the same snapshot. Methodology is on the methodology page.
Frequently asked questions
Is PPN 006 the same as SECR? No. One is company law, the other is a bid requirement.
If I report under SECR, do I still need a plan? Yes, if you bid for an in-scope contract.
Can a small business need a plan? Yes. The trigger is the contract.
Which needs Scope 3? The plan, for a defined subset. SECR only for transport fuel the company pays for.
Where is each published? SECR in the directors' report; the plan on your website.
Related reading
- What is SECR?
- Who has to report under SECR?
- What is PPN 006?
- PPN 006 Carbon Reduction Plan: what bidders need
Sources
- The Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008, Schedule 7, legislation.gov.uk
- SI 2018/1155, Energy and Carbon Report Regulations, legislation.gov.uk
- PPN 06/21: Frequently asked questions, GOV.UK (scope, sign-off, bidding entity and Scope 3 categories; PPN 006 replaced this note, so check the current PPN 006 text for any change)
- Procurement Policy Note 006, GOV.UK