The honest answer to "who has to report under SECR?" is: probably fewer companies than you fear and more than you think. It depends on whether you are quoted, how big you are on the day your financial year ends, and whether a parent already reports for you.
The three groups in scope
- Quoted companies. Companies whose equity is listed on the main market, in the EEA or on a US exchange. These have reported emissions since 2013. SECR added energy use and an intensity ratio.
- Large unquoted companies. Companies that are not quoted and not medium-sized or smaller.
- Large LLPs. Limited liability partnerships under the same size test, reporting in an energy and carbon report.
Everything below is about the second and third group, because that is where the size test matters.
The size test
For unquoted companies, SECR applies where the company is not within the medium-sized limits. The text of Schedule 7 to the 2008 Regulations (as revised on legislation.gov.uk) sets those limits as:
| Test | Upper limit for a medium-sized company |
|---|---|
| Turnover | £36 million |
| Balance sheet total | £18 million |
| Average number of employees | 250 |
A company is outside "medium" when it exceeds two or more of the three. So a business with turnover of £50 million, a balance sheet of £20 million and 120 staff is large for SECR. A business with turnover of £50 million, a balance sheet of £10 million and 120 staff is not, because it breaks only one limit.
Three practical points:
- Two out of three, not all three, and not the biggest figure on its own. Many owner-managed businesses with a large turnover and few staff stay outside because of this.
- Employees is an average across the year, counted by the company's own method. Part-timers and agency workers are treated according to the Companies Act rules, so ask your accountant how your figure was derived for the accounts.
- Turnover is adjusted if the financial year is not twelve months.
A caution about the higher limits
You may have seen that the Companies Act size thresholds went up for financial years beginning on or after 6 April 2025 (the 2024 uplift, for example turnover of £54 million and £27 million balance sheet for the medium test). That uplift amended the Companies Act sections for small and micro companies and set transitional wording for others. The SECR schedule, as published on legislation.gov.uk when we checked it in October 2026, still carries the £36 million, £18 million and 250 figures. Thresholds are sensitive to amendment, so confirm with your accountant before relying on any number, including ours.
Groups
For a group, the test is applied on an aggregate basis across the parent and subsidiaries, with a net or gross alternative for turnover and balance sheet total:
- Turnover: £36 million net or £43.2 million gross
- Balance sheet total: £18 million net or £21.6 million gross
- Employees: 250
A parent that is in scope reports for the group, including subsidiaries within the consolidation, subject to the exclusions in the schedule.
Subsidiaries may be exempt where they are included in a parent's report that already meets the SECR requirements for a financial year that ends at the same time as, or before, the subsidiary's. The conditions are precise, so read them against your own structure rather than assuming.
The low energy exemption
A large unquoted company or LLP that consumed 40,000 kWh of energy or less in the UK during the period does not have to provide the SECR information. It must still say, in the report, that the information is not disclosed for that reason.
40,000 kWh sounds small and is. A single office running on gas heating can exceed it. A construction contractor running generators and a van fleet will clear it easily. Count fuel as well as electricity and gas, and count transport fuel too.
There is also a narrow exemption where disclosure would, in the directors' opinion, be seriously prejudicial to the company's interests. The report must say so. It is not a way round routine commercial sensitivity.
Cases that catch people out
- A holding company with few staff. The group test counts the whole group, not the parent's payroll.
- A growing business. You are tested for each financial year. Crossing two limits in a year puts you in scope for that year, subject to how the Companies Act treats the change between years.
- A charity with a trading arm. The trading company is tested as a company in its own right.
- An overseas parent. UK companies and LLPs are tested on their own and group figures. Check whether a UK parent's group report covers you.
- A subcontractor to a big contractor. Your client's SECR duty does not make you report. It does make you answer their data requests, which is a different pressure. See Scope 1, 2 and 3 for contractors.
If you are out of scope
Many companies below the line report anyway. Reasons that come up:
- A tender asks for a Carbon Reduction Plan under PPN 006, which uses the same data.
- A customer asks for annual emissions in a supplier questionnaire.
- A lender or insurer asks for a carbon figure.
- Directors want the figure before it becomes compulsory.
You do not need the full SECR format to do this. Start with the same energy and emissions inventory and add the intensity ratio and methodology note. Our SECR guide for contractors has the disclosure checklist, and what is SECR explains the framework.
What to do now
- Check your last set of accounts against the three size limits and whether you broke two of them.
- Check whether your parent already reports on your behalf under SECR.
- Total your UK energy use in kWh. If it is above 40,000, you cannot rely on the low-energy exemption.
- Agree who owns the data: finance, operations or facilities.
- Build the disclosure from records you can evidence.
MetricOra keeps the energy and emissions behind a SECR report in one place, so the disclosure traces back to meter reads, fuel records and invoices. See the product's reporting. It does not decide scope for you. That is a matter for the finance director and the company's advisers.
Frequently asked questions
Who has to report? Quoted companies, large unquoted companies and large LLPs.
What makes a company large? Exceeding two or more of £36 million turnover, £18 million balance sheet total and 250 employees, as the schedule currently reads.
Is there an exemption? Yes, for 40,000 kWh or less of UK energy in the period, and for a narrow prejudice case. Both must be stated in the report.
Do subsidiaries report? Not if a qualifying parent report covers them. Check the conditions.
Do small companies report? Not under the mandatory rules.
Sources
- The Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008, Schedule 7, Parts 7 and 7A, legislation.gov.uk
- SI 2018/1155, Energy and Carbon Report Regulations, legislation.gov.uk
- Environmental reporting guidelines, including SECR, GOV.UK
- The Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018