SECR Mandatory Thresholds

The size test is drafted as an exemption, not an inclusion test.
Paragraph 20B(2) of Schedule 7 to SI 2008/410 exempts a company satisfying two or more of: turnover not more than £36 million; balance sheet total not more than £18 million; not more than 250 employees.

SECR is therefore mandatory for an unquoted company or LLP that exceeds at least 2 of these 3 figures:

Quick SECR Compliance Check

Answer these questions about your company:

1. Are you a quoted company? If yes, SECR applies regardless of size and the remaining questions are irrelevant.
2. Annual turnover: Is it more than £36 million?
3. Number of employees: Do you employ more than 250 people?
4. Balance sheet total: Is it more than £18 million?

If you answered "yes" to 2 or more of questions 2–4, SECR reporting is mandatory.

The April 2025 threshold uplift did not apply to SECR

SI 2024/1303 raised the general Companies Act 2006 size thresholds by roughly 50% for financial years beginning on or after 6 April 2025.
The SECR thresholds in Part 7A of Schedule 7 to SI 2008/410 were not amended.

The SECR thresholds are now lower than the medium-sized accounts thresholds.
A company reclassified from large to medium-sized for accounts purposes can therefore still be in SECR scope.

Who Must Report Under SECR

Companies Subject to SECR

SECR applies to:

• Large UK companies (meeting 2/3 thresholds)
  
• Large LLPs (Limited Liability Partnerships)
  
• UK subsidiaries of overseas companies (if large)

Companies Exempt from SECR

SECR does not apply to:

• Unquoted companies and LLPs exceeding fewer than 2 of the 3 figures
• Dormant companies
• Partnerships and sole traders, which are outside the regulations entirely

The 40,000 kWh de minimis. An in-scope company or LLP that consumed 40,000 kWh or less of energy in the UK during the reporting period may withhold the quantitative information.
The relief is not automatic: paragraph 20D(7)(a) requires the report to state that the information is not disclosed for that reason.
It is measured on UK consumption, and it is 40,000 kWh or less — not "under 40 MWh".

What SECR Requires

If SECR is mandatory for your company, you must report:

1. Energy consumption (kWh) for the reporting period
2. Carbon emissions (tonnes CO2e) from energy use
3. Energy efficiency measures taken during the year
4. Methodology used for calculations

SECR vs UK SRS Requirements

UK SRS is not replacing SECR.
The DESNZ statutory post-implementation review of 26 May 2026 recommends "Amend" — retaining SECR with amendments — and says that "removing SECR would risk reversing gains in transparency and board level accountability".
Refinements will be explored through a planned 2026 consultation on streamlining energy and emissions reporting, which had not launched as of 27 July 2026.

Who enforces SECR

There is no SECR-specific regulator and no SECR-specific civil sanction regime.
Enforcement rides on Companies Act 2006 machinery: the FRC's Conduct Committee, an authorised body under section 457 of the Companies Act 2006, monitors compliance through Corporate Reporting Review and can apply to court for revised accounts.
DESNZ describes the regime as "light touch", effective for quoted companies where FRC oversight is strongest and "less effective for the wider private/LLP cohort".

Next Steps for SECR Compliance

If SECR is mandatory for your company:

1. Identify data sources for energy consumption across your operations
   
2. Set up tracking systems for electricity, gas, and transport fuel use
   
3. Calculate carbon emissions using the current DESNZ conversion factors — the 2026 set was published on 11 June 2026
   
4. Prepare your report within 6 months of financial year-end

For implementation guidance, see our SECR deadline and SECR and UK SRS.