SECR compliance: a specialist guide to the requirements

Three groups. Every quoted company, at any size. Unquoted companies — including AIM companies — that exceed at least two of three limits: turnover of £36 million, a balance sheet total of £18 million and 250 employees. And LLPs that exceed the same limits. An unquoted company is exempt where it satisfies two or more of the “not more than” conditions in Schedule 7, paragraph 20B of SI 2008/410.

No. The Companies Act size thresholds rose on 6 April 2025, but SECR’s test is written into its own table in paragraph 20B and never cross-refers to them. The amending instrument, SI 2024/1303, left Part 7A untouched. Since then a company can be medium-sized for its accounts and still in scope for SECR on the same figures.

For an unquoted company: UK energy use in kWh, the emissions from gas, purchased electricity and transport fuel, at least one intensity ratio, the methodology, a narrative of the principal energy efficiency measures taken, and the previous year’s figures. A quoted company reports its global emissions from fuel combustion, facilities and purchased electricity, heat, steam or cooling, the energy in kWh, and the proportion relating to the UK and offshore area.

In the directors’ report, for companies — or in a separate energy and carbon report, for LLPs, which have no directors’ report. The government’s Modernising corporate reporting consultation of September 2026 proposes to remove the directors’ report, which would move SECR disclosures elsewhere in the annual report; that is a proposal, and the duty itself would not change.

Yes, but it is relief from disclosure, not from SECR. An unquoted company or LLP that consumed 40,000 kWh of energy or less in the United Kingdom in the period may omit the energy and emissions disclosures, provided the report states that the information is not disclosed for that reason. A quoted company has the same relief without the UK qualifier.

SECR sits in the annual report, so it follows the accounts filing deadline in section 442 of the Companies Act 2006: nine months after the end of the accounting reference period for a private company and six months for a public company. Companies House is clear that a deadline falling on a weekend or bank holiday does not move.

No. Nothing in Schedule 7 requires assurance or verification of SECR figures, and the government’s guidance says there is no statutory requirement to have environmental information audited. The statutory auditor reports only on whether the directors’ report is consistent with the accounts and prepared in accordance with the law.

SECR has no penalty of its own. A director who approves a directors’ report knowing it does not comply, or reckless as to whether it complies, commits an offence under section 419 of the Companies Act 2006, and the FRC can apply to court for a defective report to be revised. Late filing of the accounts attracts Companies House’s civil penalties.

No. A quoted company under section 385 of the Companies Act 2006 is one whose equity is on the Official List, officially listed in an EEA State, or admitted to dealing on the New York Stock Exchange or Nasdaq. AIM is none of these, so an AIM company is unquoted and in scope only if it exceeds at least two of the size limits.