SECR Disclosure Examples: What a Compliant Report Looks Like

Key Takeaways:

• The minimum content of a SECR disclosure is fixed by Schedule 7 to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008: emissions in tonnes of CO2e, one aggregate energy figure in kWh, at least one intensity ratio, the methodology, the energy efficiency measures taken, and the previous year's figures.
• SECR's size test is written into paragraph 20B of that Schedule in its own figures of £36 million turnover, £18 million balance sheet total and 250 employees. The April 2025 uplift of the Companies Act limits to £54 million and £27 million left those figures alone, so a company that counts as medium-sized for its accounts can still be inside SECR.
• When the Financial Reporting Council reviewed 27 disclosures from the first mandatory year, every one reported emissions and at least one intensity ratio, but two left out energy use, two reported CO2 rather than CO2e, and only six groups stated clearly which entities sat inside the reporting boundary.
• Fuel the company reimburses through employee business mileage claims counts towards a large unquoted company's UK energy use. Rail, air and taxi travel the company does not operate sits outside the mandatory figure.
• UK grid electricity in the 2026 conversion factors is 0.13096 kgCO2e per kWh, 26% below the 2025 set, which means a reported fall in Scope 2 this year may be mostly the grid rather than the business.
• The directors' report itself is being abolished. SECR outlives it, but the disclosure will move somewhere else in the annual report.

 An SECR disclosure is a short, highly prescribed section of a UK annual report, and most of the arguments about it come down to a handful of lines: which energy counts, which emissions figure goes where, and whether the intensity ratio can be checked against anything else in the accounts.

This article sets out what the regulations actually require, shows a worked disclosure for a large unquoted company using the 2026 conversion factors, and points to real published disclosures that the FRC singled out when it reviewed the first year of mandatory reporting.

It also covers the mistakes that show up in review, the government's own example template and why it is older than it looks, and what the September 2026 reporting consultation would change.

Who Has to Publish One?

Every UK quoted company publishes one, whatever its size, and so does every large unquoted UK company and every large LLP.

The LLP version is a separate document called an energy and carbon report rather than a directors' report, under the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (SI 2018/1155). Only the unquoted population faces a size test.

The size test for the unquoted population is unusual in that the regulation never says a large company must report. Paragraph 20B instead exempts a company that satisfies two or more conditions: turnover of not more than £36 million, a balance sheet total of not more than £18 million, and not more than 250 employees.

Exceed two of the three and the exemption falls away. Parent companies test the group under paragraph 20C, on aggregate figures of £36 million net or £43.2 million gross turnover, and £18 million net or £21.6 million gross balance sheet.

And this is where finance teams have gone wrong since April 2025.

The Companies (Accounts and Reports) (Amendment and Transitional Provision) Regulations 2024 (SI 2024/1303) raised the general company size limits for financial years beginning on or after 6 April 2025. Those regulations did not amend paragraph 20B.

A company with £45 million of turnover and a £22 million balance sheet is therefore medium-sized for its accounts and still obliged to file a SECR disclosure. Worth noting for anyone working from the 2019 government guidance, which describes the SECR threshold as the same as the Companies Act definition in sections 465 and 466. That was true when it was written in March 2019. It is not true now, and the regulation, not the guidance, is what binds.

AIM companies are unquoted for these purposes, so they take the shorter unquoted duty list and the size test with it.

What the Disclosure Has to Contain

Emissions, energy, one intensity ratio, the methodology, the efficiency measures taken and last year's figures. That is the whole list. It is shorter for large unquoted companies and LLPs than for quoted ones, and conflicting advice usually traces back to someone reading across the wrong column.

Two details in the unquoted column catch people out.

1. The first is that paragraph 20D(1) covers the combustion of gas, not the combustion of fuel generally, so an oil-fired boiler or a refrigerant leak falls outside the mandatory minimum even though both are Scope 1 under the GHG Protocol.
2. The second is transport. Chapter 2 of the guidance is explicit that fuel used in personal or hire cars on business, including fuel for which the organisation reimburses employees following business mileage claims, goes into the total. Fuel for train travel, flights and taxis the company does not operate stays out, as does fuel used by a subcontracted haulier.

Several competitor guides state the opposite on mileage claims. Check the guidance before you follow them.

A Worked SECR Disclosure

The figures below are illustrative. They are built from the 2026 UK Government conversion factors for a fictional manufacturer with a 31 December 2026 year end, and are shown to demonstrate the arithmetic rather than to be copied.

Energy and carbon report for the year ended 31 December 2026

Methodology: emissions have been calculated from supplier meter data and fuel card records using the 2026 UK Government greenhouse gas conversion factors published by DESNZ, applied in line with the GHG Protocol Corporate Standard on an operational control boundary. Purchased electricity is reported on a location-based basis at 0.13096 kgCO2e per kWh. Gas is converted on a gross calorific value basis. The intensity ratio is total reported emissions per £ million of turnover as stated in the financial statements.

Now the part that matters more than the table. Reported emissions fell by 83.7 tCO2e, which reads as an 11% reduction. Convert last year's 1,180,000 kWh of electricity at this year's factor and it would have produced 154.5 tCO2e rather than the 208.9 tCO2e published. So 54.4 tonnes of the 83.7 tonne fall, close to two thirds of it, comes from the change in the grid factor rather than from anything the company did.

Electricity volumes fell by 5%. Reported electricity emissions fell by 30%.

A disclosure that reports the fall without explaining it is compliant and misleading at the same time. The FRC's expectation is that preparers distinguish between reductions driven by efficiency measures and reductions driven by something else.

Which Factor Set Applies to Your Year End?

The set that matches the year most of your activity data falls in, which DESNZ states as data falling entirely or mostly within 2026 for the 2026 factors. A December year end sits cleanly inside one set. A 31 March 2026 year end does not, and most preparers in that position use the 2025 set because nine of the twelve months fall in 2025.

DESNZ published the 2026 factors on 11 June 2026, with the flat file reissued on 31 July 2026 to correct values that had been shown as zero for some hybrid, CNG and LPG car well-to-tank figures and for hotel stays in certain countries. The full set published in June was not revised.

Grid decarbonisation between 2023 and 2024 accounts for most of that fall, around 16 percentage points of it. A further 3 points come from an extra year of data and the remaining 6 or 7 points from methodology changes, including a correction to a double-counting issue affecting autogenerators, all set out in the department's major changes report.

The lag between the data year and the publication year has been cut from two years to one, which means the 2024 data year is skipped entirely: the 2025 publication used 2023 data and the 2026 publication uses 2025 data.

If you restate prior years on the new basis, say so in the methodology. If you do not, the comparison in your table is not like for like.

Real Disclosures Worth Reading

The FRC's thematic review of SECR, published on 22 September 2021, remains the only regulator-level examination of how companies actually wrote these disclosures. It covered 27 entities: ten FTSE 350 companies, ten AIM companies, five large private companies and two LLPs. The report reproduces extracts and names the reporters, which makes it the most useful single source of worked examples in print.

• Persimmon Plc, Annual Report 2020, page 68. Shows a scope-by-scope table alongside a plain statement that the group operates only in England, Wales and Scotland, so UK and offshore emissions are the whole picture. It also explains a mid-period change in how Scope 1 business travel was estimated, moving from fuel card and expense analysis to an extrapolated sample.
• Ernst & Young LLP, members' annual report to 3 July 2020, page 5. An LLP energy and carbon report that quantifies the efficiency work: LED replacement, DALI lighting controls, a new building management system and fan coil unit upgrades at its London Bridge office, expected to save roughly 1.6 million kWh a year for a capital cost of around £6 million.
• GlobalData Plc, Annual Report and Accounts 2020, page 36. An AIM company applying the unquoted rules, stating that the figures cover UK operations under operational control and that non-UK subsidiaries which would not qualify in their own right are excluded.
• Smart Metering Systems plc, Annual report and accounts 2020, page 47. Goes beyond the minimum with Scope 3, sub-categories of emissions, and both location-based and market-based electricity.
• SEGRO plc, Annual Report and Accounts 2020, page 86. Sets out which emissions categories sit inside its net zero commitment, including the categories determined not to be relevant.

These are from the first mandatory reporting year, so the figures are old. The structures are not.

But for current disclosures, go to the filing history on the Companies House register. Every in-scope company files its accounts there, the SECR section sits in the directors' report, and the search is free.

Common Issues Reviewers Find

Most of what the FRC found wrong was arithmetic or labelling rather than judgement, which makes the list worth running against a draft before it goes to the board.

Two entities gave no energy use figure at all. Two disclosed a single combined Scope 1 and 2 total instead of separate subtotals, which the regulations require as two distinct figures. Two quoted companies omitted the UK and offshore proportion. Two reported CO2 rather than CO2e, which excludes the other five greenhouse gases named in section 92 of the Climate Change Act 2008.

Methodology was thinner. Of 27 entities, 25 described a method, but one gave none and another pointed only at its website, which the FRC said does not meet the requirement. Sixteen explained how the reporting boundary was set, eleven of them using operational control. Only six made clear which entities were inside it, and the FRC found no reconciliation to the financial statement boundary of the kind the guidance recommends.

Intensity ratios were universally present and frequently uncheckable. All 27 gave at least one, usually tonnes of CO2e per £m of revenue, used by 18 of them. But the FRC could only recalculate the ratio from the annual report in 15 cases, and in several others arrived at a materially different number, often because the denominator was a pre-consolidation or segment figure. If a reader cannot rebuild your ratio from your own accounts, the disclosure needs a reconciliation.

Assurance was the other weak point. Ten entities said they had obtained third-party assurance and only seven explained what level. Describing figures as audited or verified without saying what was covered implies more than was given.

None of the 27 used the low energy user exemption or the seriously prejudicial exemption. Both exist, both require a statement in the report saying the information is withheld and why, and the guidance expects the prejudicial route to be rare enough that the FRC may ask about it.

The Government's Own Template

Annex H of the Environmental Reporting Guidelines carries a full example reporting format: company information, reporting period, reasons for the change in emissions, quantification methodology, the organisational boundary, Scope 1, 2 and 3 tables with columns for exclusions and for the percentage of activity data that was estimated, a geographical breakdown, base year and recalculation policy, targets, the intensity measurement with an explanation of why that metric was chosen, assurance, and a note on exported renewable electricity.

The exclusions column is the part worth stealing. Rather than silently dropping a source, the template names it and sizes it, as in fugitive emissions from office air conditioning excluded on cost grounds and estimated at under 0.5% of Scope 1.

There is one caveat. The March 2019 edition of the guidelines updated the introduction and chapters 1 and 2 only. Annex H still runs on a 2013 to 2014 reporting period, references the 2013 conversion factors and is built around the old quoted-company framework. It is a sound structural model and a poor source of current figures. Annex F, which lists intensity ratios by sector, has aged better: tonnes of CO2e per square metre for retail and property, per tonne of production for manufacturing, per megawatt hour for electricity utilities, per gigabyte transmitted for telecoms.

Where Does an SECR Report Belong and What Happens If It Is Missing?

For companies, the disclosure belongs in the directors' report. It can be promoted into the strategic report where energy and emissions are of strategic importance, but the directors' report must then say so, under paragraph 1A of Schedule 7.

LLPs produce a separate energy and carbon report, approved by the members, signed by a designated member, and identifying each member during the year.

Charitable companies report in the combined directors' and trustees' annual report, and read the turnover threshold as gross income.

Enforcement runs through three routes. The FRC's Conduct Committee monitors compliance and can apply to the court under section 456 of the Companies Act 2006 for an order requiring directors to prepare revised accounts.

Companies House may refuse accounts that fall short of the Act's requirements. Late filing carries a civil penalty under section 453, with separate action against directors under section 451.

And the statutory auditor, under ISA (UK) 720, has to state whether the information in the directors' report is consistent with the financial statements and prepared in accordance with legal requirements. The auditor does not audit the emissions numbers themselves. They do check the disclosure is there and internally consistent.

What Changes Next?

One change is settled, one is out for consultation and one is still to come.

• Settled: the directors' report is going. The government confirmed in its October 2025 Regulation Action Plan update that the requirement to produce one will be removed, with some provisions deleted and others relocated, and statutory instruments to follow.
• Proposed: the Modernising Corporate Reporting consultation, published by the Department for Business, Innovation, Science and Trade on 7 September 2026 and closing at 11:59pm on 30 November 2026, would not prescribe where SECR disclosures sit once the directors' report disappears, leaving companies free to place them in the first half of the annual report. No substantive change to the content is proposed in that document.
• Expected: DESNZ completed a post-implementation review of SECR in May 2026 which recommended retaining the regime with targeted amendments, and intends to consult separately on SECR and the Energy Savings Opportunity Scheme. Separately, the UK Sustainability Reporting Standards were endorsed in February 2026 and are available for voluntary use. None of this removes a filing obligation for the current year.

More Information

• Environmental reporting guidelines: including Streamlined Energy and Carbon Reporting requirements, DESNZ, Defra and BEIS, March 2019. Chapter 2 covers the duty lists, Annex F the intensity ratios and Annex H the example format.
• Greenhouse gas reporting: conversion factors 2026, DESNZ, published 11 June 2026 and updated 31 July 2026.
• Schedule 7 to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008, legislation.gov.uk. Part 7 for quoted companies, Part 7A for large unquoted companies.
• Streamlined Energy and Carbon Reporting thematic review, Financial Reporting Council, 22 September 2021.
• Gaia's SECR reporting software builds the statutory content, energy totals, intensity ratios and comparison years from measured data, and Gaia Carbon Accounting keeps the evidence behind each figure for the audit. For the underlying concepts, see what carbon accounting is.

FAQs

What does an SECR disclosure have to include?

Emissions in tonnes of CO2e, one aggregate energy consumption figure in kWh, at least one intensity ratio, a statement of the methodology used, a description of the principal energy efficiency measures taken in the year, and the previous year's figures for all of these except in the first reporting year. Quoted companies also state the proportion relating to the UK and offshore area.

Where can I find real published SECR disclosures?

In the directors' report section of filed annual accounts, which are free to search on the Companies House register. The FRC's 2021 thematic review reproduces extracts from named companies including Persimmon, SEGRO, Smart Metering Systems, GlobalData and Ernst & Young LLP, with page references to the original reports.

Does SECR require Scope 3 emissions?

No. The mandatory minimum for large unquoted companies covers gas combustion, transport fuel and purchased electricity in the UK, which maps roughly to Scope 1 and Scope 2. Business mileage reimbursed to employees is inside that minimum despite being Scope 3 under the GHG Protocol. Wider Scope 3 reporting is encouraged by the guidance but voluntary.

Is an SECR disclosure audited?

Not directly. Under ISA (UK) 720, the statutory auditor states whether the directors' report is consistent with the financial statements and prepared in accordance with legal requirements, which is a different exercise from verifying emissions calculations. Voluntary independent assurance is encouraged by the government guidance, and if obtained, the disclosure should say what level of assurance was given and what it covered.

Did the 2025 company size changes take us out of SECR?

Probably not. The SECR thresholds sit in paragraph 20B of Schedule 7 in their own figures of £36 million, £18 million and 250 employees, and the April 2025 uplift of the Companies Act limits to £54 million and £27 million did not amend them. A company reclassified as medium-sized for accounts purposes can still be in scope. Check against the regulation, and take advice on your own position.