Am I in scope of UK SRS?
A practical decision tree walking through the rules in CP26/5, the Companies Act, and the proposed mandatory framework. UK SRS itself is available for voluntary adoption by any UK entity — the question of mandatory application is jurisdiction-specific.
Last verified 27 July 2026 · Subject to FCA Policy Statement on CP26/5, unpublished as of that date
Outcome categories
SECR applies to quoted companies of any size, and to large unquoted UK companies and large LLPs.
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 that satisfies two or more of the following conditions:
- Turnover of not more than £36 million
- Balance sheet total of not more than £18 million
- Not more than 250 employees
Being in scope therefore means exceeding at least two of those three figures.
It is a two-of-three test, not an any-of-three test: exceeding a single threshold does not bring a company into SECR.
SECR requirements apply based on the company's status in the financial year for which the report is being prepared.
Quoted companies: no size test
Quoted companies are in SECR scope regardless of size.
They also report global Scope 1 and Scope 2 emissions and global energy use, where large unquoted companies and LLPs report UK energy use only.
Company types covered
How long UK SRS S2 implementation actually takes
Companies waiting for the FCA Policy Statement to begin preparation are already late. Practitioner consensus puts end-to-end implementation at twelve to eighteen months — driven by Scope 3 data, which can't be compressed.
Last verified 27 July 2026 · Click any workstream for detail
From kickoff to first UK SRS S2 report. Driven by Scope 3 supplier engagement and quantitative scenario modelling — neither compressible.
Of Scope 3 data work — from supplier engagement onset through validation. Of the 15 GHG Protocol categories, Category 1 and Category 11 typically account for >70% of total Scope 3 emissions.
Foundation phase before data work meaningfully begins. Materiality assessment and gap analysis are pre-requisites — running data collection without these creates wasted effort.
UK incorporated companies: Must comply if they meet the large company thresholds.
This includes private and public companies registered with Companies House.
LLPs: Large LLPs must also comply with SECR, with similar thresholds applied to LLP accounts.
Partnerships and sole traders are exempt from SECR requirements.
Groups: Parent companies must include information for the group as a whole where they prepare consolidated accounts.
Individual subsidiaries may also need to comply separately if they meet the thresholds.
The Two-of-Three SECR Size Test
| Test | In-scope figure | Calculation Method | Key Points |
|---|---|---|---|
| Turnover | More than £36 million | Annual revenue from most recent accounts | Must be exceeded together with at least one other test |
| Balance Sheet | More than £18 million | Total assets from most recent balance sheet | Must be exceeded together with at least one other test |
| Employees | More than 250 | Average number of employees during financial year | Must be exceeded together with at least one other test |
Qualification Assessment
SECR qualification is assessed annually based on your company's status in each financial year.
Meeting thresholds in one year creates reporting obligations for that year only.
Exemptions and exclusions
Small and medium-sized companies: Not subject to SECR if they don't meet the large company thresholds.
These companies can choose voluntary reporting if beneficial for stakeholder relations.
Quoted companies: Never exempt on size grounds.
A quoted company is in SECR scope whatever its turnover, balance sheet total or headcount, and reports on a global rather than UK basis.
The 40,000 kWh de minimis: A company or LLP that consumed 40,000 kWh or less of energy in the UK during the reporting period does not have to disclose 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.
Note that the measure is 40,000 kWh of UK consumption — not "under 40 MWh" of global energy use, a formulation that circulates widely and is wrong on both counts.
Dormant companies: No SECR requirements if the company has no significant business activity.
Companies must still file dormancy confirmations with Companies House annually.
The April 2025 Companies Act uplift did not change 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 consequence is counter-intuitive and catches finance teams out.
The SECR thresholds are now lower than the medium-sized accounts thresholds, so a company reclassified from large to medium-sized for accounts purposes can still be in SECR scope.
SECR's future: the 2026 post-implementation review
DESNZ published the statutory post-implementation review of SECR on 26 May 2026.
The formal departmental recommendation is "Amend" — not repeal.
DESNZ post-implementation review, 26 May 2026
"The overarching recommendation is to retain the SECR requirements with amendments… 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.
Claims that UK SRS will replace or phase out SECR are not supported by any government document.
The review also describes enforcement as "light touch", noting that it "works well for quoted companies, where FRC oversight is strongest, but is less effective for the wider private/LLP cohort".
SECR vs Other Energy Reporting Regimes
The UK SRS regulatory timeline
Five-year path from the Technical Advisory Committee's first endorsement recommendation to the proposed comply-or-explain mandate for broader sustainability disclosures. Three regulators, two committees, one set of standards.
Last verified 12 May 2026 · Tap a milestone for sources
SECR vs ESOS comparison:
- SECR: Annual reporting, in scope on a two-of-three test at £36m / £18m / 250 employees
- ESOS: 4-yearly energy audits, in scope at 250+ employees or turnover above £44m and balance sheet total above £38m — a different and higher test
- Proposed alignment of the ESOS thresholds with SECR was postponed to Phase 5 and does not apply to ESOS Phase 4
- Many organisations are subject to both regimes with overlapping data requirements
SECR vs UK SRS comparison:
- SECR: Current requirements since 2019 for energy and carbon disclosure, retained with amendments per the 26 May 2026 DESNZ review
- UK SRS: Proposed for accounting periods beginning on or after 1 January 2027 for in-scope listed companies, subject to the FCA Policy Statement expected in autumn 2026
- The government has committed only to consider how UK SRS energy and emissions data interacts with SECR, with a view to reducing unnecessary duplication
- SECR provides a data foundation that can support future UK SRS compliance
Implementation Considerations for In-Scope Companies
Data collection systems:
Companies subject to SECR need robust energy consumption tracking across all UK operations.
This includes electricity, gas, transport fuels, and any other significant energy sources.
Carbon calculation methodology:
SECR requires greenhouse gas emissions calculations using official government conversion factors, published annually each June by the Department for Energy Security and Net Zero.
The current set is Greenhouse gas reporting: conversion factors 2026, published on 11 June 2026.
Governance and oversight:
Directors must ensure SECR compliance as part of strategic report preparation.
External assurance is encouraged but not mandatory for SECR disclosures.
Enforcement:
There is no SECR-specific regulator and no SECR-specific civil sanction regime.
The disclosures sit in the directors' report filed at Companies House, and 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.
Reporting timeline:
SECR information is included in the directors' report filed with the statutory accounts.
The filing deadline is the ordinary Companies House accounts deadline for the entity, and the late-filing penalties that apply are the standard accounts penalties rather than a SECR sanction.