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SECR specialists · buyer’s guide

Choosing a SECR compliance specialist

A SECR compliance specialist prepares the energy and carbon disclosure the SECR regulations require in a company’s directors’ report.

Unlike ESOS, SECR has no approved register and no credential — so choosing a specialist means testing their method, and this page shows how.

Checked against 14 sources fromlegislation.gov.ukDepartment for Energy Security and Net ZeroFinancial Reporting CouncilSee the sources

The role

What a SECR specialist actually does

“SECR compliance specialist” describes a service, not a status.

The disclosure itself is the directors’ duty, set out in Part 7 of Schedule 7 for quoted companies, Part 7A for large unquoted companies and regulation 12B of SI 2008/1911 for LLPs.

A specialist’s value is knowing which of those applies and what each one asks for, because they differ.

A quoted company reports global emissions from fuel, facilities and purchased electricity, heat, steam or cooling, with the UK and offshore share; an unquoted company reports gas, electricity and transport fuel, and may confine itself to the UK.

What the requirements are, in full, is on our SECR compliance guide.

The specialist’s job, in order

  1. 01
    Place you in the right population

    Quoted, unquoted or LLP — three instruments, three tests.

  2. 02
    Fix the boundary

    Entities, sites and whether non-UK energy may be excluded.

  3. 03
    Build the figures

    kWh, emissions, the intensity ratio.

  4. 04
    Write the method and narrative

    How the figures were made; what was done to save energy.

  5. 05
    Hand to the board

    Directors approve the directors’ report; LLP members the energy and carbon report.

The credential question

There is no SECR credential — so test the method

No paragraph in Part 7 or Part 7A mentions assurance, verification or audit of the SECR figures.

The government’s SECR guidance says so directly: there is no statutory requirement to have environmental information audited.

UKAS, appointed under regulation 3 of the Accreditation Regulations 2009, accredits certification, testing, inspection and verification bodies; consultancy is not an activity it accredits.

The statutory auditor’s report under section 496 covers whether the directors’ report is consistent with the accounts and lawfully prepared — not the accuracy of the emissions.

A company that wants its figures assured can commission it voluntarily; ISSA (UK) 5000, issued by the FRC for voluntary use, applies to engagements on periods beginning on or after 15 December 2026.

DESNZ’s 2026 review of SECR put the consequence plainly: limited verification undermines confidence in data quality.

SI 2014/1643 reg 12 · UK ETS verification rules · SI 2008/410 Sch 7.
RegimeCredential the law requires
ESOSA lead assessor on one of seven approved registers
UK ETSA verifier accredited by UKAS to ISO 14065
SECRNone — no verification, no register

The checklist

Ten questions for SECR specialists

Put the same ten questions to every shortlisted specialist, and ask for the answers in writing.

01

Which SECR population are we — quoted, large unquoted or LLP — and which paragraph puts us there?

02

If we are a parent, will you run the paragraph 20C group test on net or gross figures, and why?

03

Will you rely on the permission to exclude energy used outside the UK and offshore area, where we have it?

04

Which year’s government conversion factors will you use, and how will you document the choice?

05

How will you estimate missing meter or fuel data, and how will the methodology statement describe it?

06

Which intensity ratio do you recommend, and will it stay comparable next year?

07

If we used 40,000 kWh or less, how will the report state that the disclosures are omitted for that reason?

08

How will the same energy data serve ESOS Phase 4 and any UK SRS reporting?

09

Do you earn anything from the energy-efficiency measures that will appear in our narrative?

10

What does your written quote include — data collection, drafting, board review, next year’s comparatives?

No UK regulator publishes a fee scale for SECR work, so compare written quotes against the same boundary and deliverables.

What a full engagement involves, step by step, is on the SECR consultancy page.

Red flags

Five statements that mark a weak specialist

Each of these is common in SECR marketing, and each is wrong in a way the instruments show.

If a specialist says…The instrument says
“SECR thresholds rose to £54m and £27m in April 2025.”Those are the Companies Act figures in section 466. SECR’s paragraph 20B keeps its own £36m / £18m / 250 table, untouched by the uplift.
“Companies under 40 MWh are exempt from SECR.”The relief is “40,000 kWh of energy or less”, it relieves disclosure rather than SECR itself, and it applies only if the report states the reason.
“SECR requires your Scope 3 emissions.”Quoted companies have no Scope 3 limb; unquoted companies and LLPs report only the consumption of fuel for transport.
“A certified SECR provider.”SECR has no certification, register or accreditation, and UKAS does not accredit consultants.
“SECR carries a fine under section 463.”Section 463 is a safe harbour for directors; the offence is in section 419, and SECR creates no penalty of its own.

A sixth, specific to listed groups: an AIM company is not quoted under section 385, so it is in scope only if it exceeds the size limits.

The government’s own 2019 guidance still describes the LLP test as based on sections 465 and 466, which is how the £54m / £27m error spreads; the figures printed beside that sentence are the right ones.

Your options

Specialist, in-house or software

OptionSuitsWatch for
SECR specialistNew to scope; parent group test; quoted global reporting; boundary changesMethod, not marketing: the ten questions above
In-houseStable boundary, good meter and fuel data, a prior year to copyMethodology statement and comparatives — often the weak points
SoftwareMany sites and fuels; repeatable calculationA “SECR-compliant” label means nothing; the duty is the directors’

Many organisations combine them: software for the calculation, a specialist for the first year or for the judgement calls.

If ESOS also applies, one data set can serve both — see ESOS consultants — and the wider inventory is the subject of emissions compliance consultants.

Carbon Legal is an independent guide and prepares no SECR reports; it can introduce you to independent specialists, and you can book a free 15-minute call.

Frequently asked

SECR specialists — frequently asked

What is a SECR compliance specialist?

Someone who prepares, or helps a company prepare, the Streamlined Energy and Carbon Reporting disclosure in its directors’ report — or an LLP’s energy and carbon report. It is a market description, not a regulated role: SECR has no approved register and no accreditation.

Is there a SECR certification or accreditation?

No. SECR requires no verification or assurance, no register of SECR practitioners exists, and UKAS accredits certification and verification bodies, not consultants. A provider describing itself as “SECR certified” or a “UKAS-accredited SECR consultant” is describing something that does not exist.

Do SECR specialists need to be independent?

No legal independence test applies to SECR, unlike ESOS, where the lead assessor’s independence decides how many responsible officers sign. It is still sensible to ask whether a SECR specialist earns anything from the energy-efficiency measures it describes in your narrative.

What questions should I ask a SECR specialist?

Which of the three SECR populations you fall into and why; how the boundary will be set; which conversion factors will be used; how missing data will be estimated and documented; which intensity ratio they recommend; how the same data will serve ESOS or UK SRS; and what the written quote includes.

Can our auditor act as our SECR specialist?

Your statutory auditor already reports under section 496 of the Companies Act 2006 on whether the directors’ report is consistent with the accounts and prepared in accordance with the law. That is not assurance over the emissions figures. Whether the same firm may also prepare the disclosure is a question for its own independence rules.

When is a SECR specialist worth it?

When a company is newly in scope, when a parent company must apply the group test, when a quoted company must report global emissions with the UK and offshore proportion, when an acquisition changes the boundary, or when the in-house team lacks the time to collect a full year of energy data.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.

  1. legislation.gov.uk
    Companies (Directors’ Report) and LLP (Energy and Carbon Report) Regulations 2018 (SI 2018/1155)

    Created SECR.

  2. legislation.gov.uk
    SI 2008/410, Schedule 7, Part 7 — quoted companies

    No size test; global figures; ¶15(5)(a) relief.

  3. legislation.gov.uk
    SI 2008/410, Schedule 7, Part 7A — large unquoted companies

    ¶20D(1)(b) transport fuel; ¶20D(7)(a) UK-qualified relief.

  4. legislation.gov.uk
    SI 2008/410, Schedule 7, paragraph 20B — the SECR exemption test

    Two or more of the “not more than” conditions.

  5. legislation.gov.uk
    SI 2008/1911, regulation 12B — the LLP energy and carbon report

    The LLP test lives here, not in paragraph 20B.

  6. legislation.gov.uk
    Companies Act 2006, section 385 — quoted companies

    AIM is not on the list.

  7. legislation.gov.uk
    Companies Act 2006, section 466 — the medium-sized group test

    £54m / £27m since 6 April 2025 — a Companies Act test, not SECR’s.

  8. legislation.gov.uk
    Companies Act 2006, section 419 — approval of the directors’ report

    The offence behind a non-compliant report.

  9. legislation.gov.uk
    Companies Act 2006, section 463 — liability for statements in reports

    A safe harbour, not a penalty.

  10. legislation.gov.uk
    Companies Act 2006, section 496 — auditor’s report on the directors’ report

    Consistency and legality, not assurance.

  11. legislation.gov.uk
    Accreditation Regulations 2009 (SI 2009/3155), regulation 3

    UKAS’s appointment as the national accreditation body.

  12. Department for Energy Security and Net Zero
    Environmental reporting guidelines, including SECR guidance

    “There is no statutory requirement to have your environmental information audited.”

  13. Financial Reporting Council
    ISSA (UK) 5000 — General Requirements for Sustainability Assurance Engagements (PDF)

    Issued 12 November 2025 for voluntary use; effective for periods beginning on or after 15 December 2026.

  14. Department for Energy Security and Net Zero
    2026 Post-Implementation Review of the SECR Regulations 2018

    “Limited verification undermines confidence in data quality.”

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