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v1.2.1Last reviewed October 2026

UK SECR Reporting

UK SECR methodology — two reporting boundaries under one Act. Quoted companies report worldwide Scope 1 and 2 emissions and global energy; large unquoted companies and LLPs report UK energy and Scope 1 and 2 only. The large test is two of three: 36 million pounds turnover, 18 million pounds balance sheet, 250 employees. Low energy users below 40,000 kWh are exempt.
MasterBrain v2026.284 · updated 6 Nov 2026

Streamlined Energy and Carbon Reporting turns a UK company’s energy bills into a mandatory line in its annual report: total energy use, Scope 1 and Scope 2 emissions, an intensity ratio, and a narrative on what the business did about efficiency.

SECR is not a separate filing you can forget — it lives inside the Directors’ Report, and “we didn’t take any energy-efficiency action” is a sentence you must write down if it is true.

Quick Answer

SECR requires large UK companies and LLPs to report annual energy use (kWh), Scope 1 and Scope 2 emissions (tCO₂e), at least one intensity ratio, and energy-efficiency actions — inside the Directors’ or Energy and Carbon Report, with a prior-year comparison.

UK Reporting · 14 min read

Step-by-step method for meeting Streamlined Energy and Carbon Reporting (SECR) obligations. Covers the large-company qualification test and the low-energy-user exemption, the three reporting tiers (quoted company, large unquoted company, large LLP), the UK-energy-use scope, conversion of energy to emissions using the UK Government GHG Conversion Factors, the mandatory intensity ratio, the energy-efficiency action narrative, and the comply-or-explain rule. Framework: the Companies Act 2006 as amended by SI 2018/1155; emission factors: UK Government GHG Conversion Factors 2026 (DEFRA).

A methodology page is the execution layer — it takes the emissions concepts from the glossary, the qualification and disclosure rules from the regulations, and the conversion factors from the data layer, and tells you exactly how to turn your energy bills into a compliant SECR disclosure. If you already know you qualify, jump to the emissions conversion or the worked examples.

Pre-check — which SECR tier applies to you?

SECR applies to three entity types, each with a slightly different disclosure profile. Identify your tier first — it determines whether you report UK-only or global energy, and whether some items are mandatory or voluntary. Thresholds below are the well-established SECR figures; verify against the current consolidated SI 2018/1155 and DESNZ guidance before relying on a boundary case.

Quoted company
Fullest profile. Already reported global GHG emissions before SECR; now also reports global energy use and an intensity ratio. Reports worldwide, not UK-only.
Large unquoted company
Core SECR tier. Must meet the “large” test. Reports UK energy use, associated Scope 1 + 2 emissions, an intensity ratio, and efficiency actions. This methodology’s main path.
Large LLP
Same as large unquoted, but discloses in a standalone Energy and Carbon Report rather than a Directors’ Report. Same “large” test, same UK-energy scope.
Low energy user (< 40,000 kWh)
Exempt from the detailed disclosure if total UK energy use is at or below 40,000 kWh over the reporting period — but must state that it is a low energy user. The exemption is a statement, not silence.
Not “large” / not in scope
No SECR obligation. A company that fails the “large” test (and is not quoted) is outside SECR — though it may still report voluntarily, and may fall under ESOS for energy auditing.

Two reporting profiles — the quoted/unquoted split changes your scope

The single most consequential SECR decision is which profile you are in, because it changes the geographic boundary of what you report. Quoted companies report worldwide; large unquoted companies and LLPs report UK energy use only. Getting this wrong over- or under-states the entire disclosure.

Quoted company

Global energy + global Scope 1 & 2

Builds on the pre-existing mandatory greenhouse-gas reporting for quoted companies: report worldwide Scope 1 and Scope 2 emissions, global energy use, an intensity ratio, the methodologies used, and energy-efficiency actions. The geographic boundary is the whole group, not just UK operations.

Large unquoted company / LLP

UK energy + UK Scope 1 & 2

Report UK energy use (gas, electricity, and transport fuel), the associated Scope 1 and Scope 2 emissions, at least one intensity ratio, the methodology, and efficiency actions. The scope is UK operations; overseas energy is not required (though it may be reported voluntarily). LLPs use an Energy and Carbon Report.

When to Use This Methodology

✓ Use this methodology when
  • You are a quoted company, large unquoted company, or large LLP determining your SECR obligation
  • You need to convert UK (or global) energy use into Scope 1 and Scope 2 emissions for the annual report
  • You are constructing the mandatory intensity ratio and choosing its denominator
  • You are checking whether the low-energy-user exemption applies — and what you must still state if it does
  • You are aligning SECR with energy-management work or a voluntary GHG Protocol inventory
✗ Do not use this methodology when
  • Your company fails the “large” test and is not quoted — there is no SECR obligation (voluntary reporting aside)
  • You need a full value-chain Scope 3 inventory — SECR mandates Scope 1 and Scope 2, plus (for unquoted companies and LLPs) business travel in rental or employee-owned cars where the company buys the fuel; other Scope 3 is voluntary
  • You are meeting the UK’s separate mandatory climate-related financial disclosure (TCFD-aligned) requirement — that is a distinct regime with different thresholds
  • You are an overseas entity with no UK reporting obligation
SECR figures ARE Scope 1 and Scope 2 — they belong in your inventory

Unlike a CBAM embedded-emissions figure or an EU ETS allowance, SECR emissions are genuine GHG Protocol Scope 1 (direct combustion) and Scope 2 (purchased electricity) emissions. The factors you apply are tagged to those scopes. This means your SECR figure should reconcile with a voluntary corporate inventory rather than sitting in a separate ledger — the same tonnes, reported to a statutory boundary. The only common divergence is geographic scope (SECR UK-only for unquoted entities) and the mandatory-vs-voluntary line around Scope 3.

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Step 1 — Do You Qualify? (The Large-Company Test & the Low-Energy Exemption)

The “large” two-of-three test

A company is “large” for SECR if it meets at least two of three thresholds in the reporting year. The figures below are the well-established SECR thresholds; because they are set in the regulations and are subject to periodic uprating, confirm them against the current consolidated SI 2018/1155 and DESNZ guidance before deciding a marginal case.

Criterion Threshold (meet at least two) Notes
Annual turnover More than £36 million Group figures aggregate where the company is a parent
Balance-sheet total More than £18 million Gross assets before deduction of liabilities
Employees More than 250 Average number over the financial year
Thresholds are statutory and not held in the GreenCalculus data layer — verify them

The £36m / £18m / 250-employee figures and the 40,000 kWh exemption are SECR statutory parameters set by SI 2018/1155 amending the Companies Act 2006. They are not emission factors and are not maintained in the GreenCalculus MasterBrain — they are reproduced here from the regulations and DESNZ guidance. Confirm the operative figures against the current consolidated SI and the latest DESNZ “Environmental reporting guidelines (including SECR)” before deciding a borderline qualification or exemption case. Quoted companies qualify regardless of size.

The 40,000 kWh low-energy-user exemption

A company or LLP that would otherwise be in scope but whose total UK energy use is 40,000 kWh or less over the reporting period is exempt from the detailed SECR disclosures. The exemption is conditional on a positive statement: the report must say the organisation is a low energy user. Staying silent is non-compliance, not exemption.

UK energy use ≤ 40,000 kWh? gas + electricity + transport, UK, over the period
Exempt from detailed disclosure — but must state “low energy user” in the report. Above 40,000 kWh → full disclosure applies. The threshold is on energy use (kWh), not on emissions (tCO₂e). Test it on the kWh total before converting to emissions.

Step 2 — Determine Your Reporting Boundary & What to Disclose

What you must disclose depends on your tier. The matrix below sets the three profiles side by side — the differences are subtle and a frequent source of mis-statement, particularly the geographic boundary and the mandatory/voluntary line on Scope 3.

Disclosure item Quoted company Large unquoted company Large LLP
Geographic scope Global UK only UK only
Energy use (kWh) Global, all energy Required UK: gas, electricity, transport Required UK: gas, electricity, transport Required
Scope 1 emissions Global S1 Required UK S1 Required UK S1 Required
Scope 2 emissions Global S2 Required UK S2 Required UK S2 Required
Scope 3 emissions S3 Voluntary (e.g. business travel encouraged) S3 Voluntary S3 Voluntary
Intensity ratio At least one Required At least one Required At least one Required
Energy-efficiency action narrative Required (comply or explain) Required (comply or explain) Required (comply or explain)
Methodology statement Required Required Required
Prior-year comparison Required (after first year) Required (after first year) Required (after first year)
Where it is disclosed Directors’ Report Directors’ Report Energy and Carbon Report
The UK-energy scope for unquoted entities is the trap most often over-reported

Large unquoted companies and LLPs report UK energy use and the emissions arising from it — not global. A common error is to consolidate the whole group’s worldwide energy into the SECR figure, which over-states the disclosure and breaks comparability with peers reporting correctly on a UK basis. If you also run a global voluntary inventory, keep the SECR UK boundary as a clearly labelled subset. Quoted companies are the opposite case: their SECR figure is global.

Step 3 — Gather Energy Use & Convert to Emissions

SECR emissions are activity data (energy use) multiplied by the UK Government GHG Conversion Factors. The mandatory boundary is Scope 1 (direct fuel combustion, including gas and owned-transport fuel) and Scope 2 (purchased electricity). The conversion is mechanical once the energy data is assembled.

Emissions (tCO₂e) = Σ (Energy usei × EFi) ÷ 1,000
Energy usei Activity data for energy stream i (kWh) — e.g. gas kWh, electricity kWh, transport fuel converted to kWh or applied in its own unit
EFi UK Government GHG Conversion Factor for stream i (kgCO₂e per kWh) — gas is a Scope 1 factor, grid electricity a Scope 2 factor
÷ 1,000 kg → tonnes (factors are kgCO₂e; SECR reports tCO₂e)
Energy stream Factor (kgCO₂e/kWh) Scope Basis & status
Natural gas 0.18231 Scope 1 Gross CV (GCV), AR5 GWP-100. Mandatory — UK gas is billed on GCV, the correct SECR convention.
Grid electricity (generation) 0.13096 Scope 2 Location-based, generation-only, AR5 GWP-100. Mandatory — this is the figure for the mandatory Scope 2 line.
Electricity T&D losses 0.01299 Scope 3 Transmission & distribution losses, AR5 GWP-100. Voluntary — a separate Scope 3 line; never folded into the 0.13096.

Factor source: UK Government GHG Conversion Factors 2026 (DEFRA). The underlying conversion methods are documented in the natural gas combustion and Scope 2 electricity methodologies. See the DEFRA factor dataset for the full table.

Do not fold T&D losses into the generation factor

The 0.13096 kgCO₂e/kWh grid factor is generation-only and is the figure for the mandatory Scope 2 disclosure. Transmission and distribution losses (0.01299 kgCO₂e/kWh) are a distinct, voluntary Scope 3 item. Adding them into the 0.13096 to make a single “all-in” electricity factor over-states the mandatory Scope 2 line and mixes a mandatory figure with a voluntary one. Report the Scope 2 figure on 0.13096; if you choose to report T&D, show it as a separate, labelled Scope 3 line. The two must never be blended.

Step 4 — Build the Mandatory Intensity Ratio

SECR requires at least one intensity ratio: emissions normalised by a metric that makes year-on-year and peer comparison meaningful. You choose the denominator, but it must be relevant to your business and applied consistently.

Intensity ratio = Total emissions (tCO₂e) ÷ Activity metric
Total emissions Mandatory Scope 1 + Scope 2 (tCO₂e) for the reporting boundary
Activity metric A relevant denominator — e.g. £m turnover, m² floor area, FTE employees, units of output, tonnes produced. Pick one that reflects the business and hold it constant year to year.

Worked examples

Three calculations on a fictional large unquoted UK company, BRT Manufacturing Ltd. Example 1 builds the mandatory figure; Example 2 shows the voluntary T&D line kept separate; Example 3 is the low-energy-user exemption boundary case. All factors are the UK Government GHG Conversion Factors 2026 (gas 0.18231 GCV / Scope 1; electricity 0.13096 generation / Scope 2; T&D 0.01299 / Scope 3), fixed here as worked-example values; all arithmetic reconciles to the stated inputs.

Example 1 Mandatory Scope 1 + 2 and the intensity ratio S1 S2
Your energy data (UK, reporting year)
BRT Manufacturing Ltd — large unquoted company
Natural gas: 1,200,000 kWh  |  Grid electricity: 800,000 kWh
Turnover: £42m (intensity denominator) UK energy only. Gas EF 0.18231 (GCV, S1); electricity EF 0.13096 (generation, S2). UK Government GHG Conversion Factors 2026 (DEFRA).
Scope 1 — gas
Gas kWh1,200,000
× EF (GCV)× 0.18231
= kgCO₂e218,772
÷ 1,000= 218.77 tCO₂e
218.77 tCO₂e
Scope 1 · gas combustion
Scope 2 — electricity
Electricity kWh800,000
× EF (generation)× 0.13096
= kgCO₂e104,768
÷ 1,000= 104.77 tCO₂e
104.77 tCO₂e
Scope 2 · location-based
Mandatory total = 218.77 + 104.77 = 323.54 tCO₂e. Intensity ratio = 323.54 ÷ 42 = 7.70 tCO₂e per £m turnover. Report the total, the scope split, and the ratio with its denominator stated.
The 2,000,000 kWh total energy use is also a mandatory disclosure in its own right (well above the 40,000 kWh exemption — see Example 3). Report energy use and emissions as separate required lines, not one or the other.
Example 2 Voluntary T&D line — kept separate from the mandatory figure S3 Voluntary
Same electricity data, optional Scope 3 line
BRT Manufacturing Ltd — electricity 800,000 kWh (from Example 1)
T&D loss factor: 0.01299 kgCO₂e/kWh (Scope 3, voluntary) T&D is a distinct row from the 0.13096 generation factor. Shown here as a separate voluntary Scope 3 line — never added into Scope 2.
Mandatory Scope 2 (unchanged)
800,000 × 0.13096= 104,768 kg
Scope 2= 104.77 tCO₂e
104.77 tCO₂e
Scope 2 · the figure that is mandatory
Voluntary Scope 3 — T&D
800,000 × 0.01299= 10,392 kg
Scope 3 (T&D)= 10.39 tCO₂e
10.39 tCO₂e
Scope 3 · separate voluntary line
Mandatory Scope 2 stays 104.77 tCO₂e. The 10.39 tCO₂e of T&D is disclosed (if at all) as a labelled voluntary Scope 3 line. A blended “all-in” factor of 0.13096 + 0.01299 = 0.14395 would mis-report Scope 2 as 115.16 tCO₂e — a 9.9% overstatement of the mandatory figure.
This is the single most common SECR electricity error. The generation factor and the T&D factor answer different questions and live in different scopes — keep them on separate lines.
Example 3 Low-energy-user exemption — the boundary case Exemption
A small-footprint in-scope entity
SVC Advisory LLP — meets the “large” test on turnover & balance sheet, minimal energy
UK gas: 12,000 kWh  |  UK electricity: 22,000 kWh  |  Transport: 4,000 kWh
Total UK energy: 38,000 kWh Test the 40,000 kWh threshold on energy use (kWh), before converting to emissions.
Exemption test
Gas12,000 kWh
+ Electricity+ 22,000 kWh
+ Transport+ 4,000 kWh
= Total38,000 kWh
vs 40,000 kWhbelow → exempt
Exempt
≤ 40,000 kWh · must still state it
If it had been 42,000 kWh
Total42,000 kWh
vs 40,000 kWhabove → full disclosure
Obligationfull SECR report
Full report
2,000 kWh over the line
At 38,000 kWh SVC Advisory LLP is exempt from detailed disclosure but must still state in its report that it is a low energy user. At 42,000 kWh it would owe the full disclosure — the exemption is a hard kWh line, not a sliding scale.
Reminder: the exemption threshold is tested on energy use in kWh, not on converted emissions. Convert to tCO₂e only after confirming you are above the line and therefore in scope.

Step 5 — Report, Narrate Efficiency Actions & the Comply-or-Explain Rule

SECR disclosures are not a standalone document — they sit inside the statutory annual report and carry a mandatory narrative on energy efficiency. The cycle below is the standard order of assembly.

1
Disclose energy use and emissionsUK (or global, if quoted) energy use in kWh, Scope 1 and Scope 2 emissions in tCO₂e, in the Directors’ Report (companies) or Energy and Carbon Report (LLPs).
2
State at least one intensity ratioEmissions ÷ a relevant denominator, with the denominator named and applied consistently year on year.
3
Narrate energy-efficiency actionsDescribe the energy-efficiency action taken in the reporting year. If none was taken, you must say so — this is the comply-or-explain element.
4
State the methodologyName the calculation methodology and the emission factor source (the UK Government GHG Conversion Factors), so the figures are reproducible.
5
Show the prior-year comparisonAfter the first reporting year, present the prior year’s figures alongside the current year for comparability.
“Comply or explain” means the absence of action is itself a required disclosure

The energy-efficiency narrative is mandatory in substance: if the organisation took energy-efficiency action during the year, describe it; if it took none, the report must state that no measures were taken. There is no option to simply omit the section. A blank where the narrative should be is non-compliance, not a neutral choice — and an explicit “no action taken this year” is a legitimate, if uncomfortable, disclosure.

An interactive UK SECR calculator — energy-to-emissions conversion, intensity ratio, and the low-energy-user exemption test — is on the GreenCalculus roadmap. Until it ships, the worked examples above show the conversion by hand.

SECR vs ESOS, TCFD/IFRS-S2 & a Voluntary Inventory

SECR is one of several overlapping UK obligations. Knowing where its boundary sits relative to the others prevents both duplicated effort and gaps.

Regime What it requires How it relates to SECR
SECR Annual energy use + Scope 1 & 2 emissions + intensity ratio + efficiency narrative, in the annual report The reporting obligation itself — recurring, in the financial statements
ESOS Periodic energy audit of significant energy consumption for large undertakings Energy auditing, not annual reporting — feeds the efficiency actions SECR then narrates; pairs with ISO 50001
UK climate-related financial disclosure TCFD-aligned governance, strategy, risk, metrics for the largest entities A separate, broader regime with different thresholds; SECR emissions data can feed its metrics pillar
Voluntary GHG inventory Full GHG Protocol Scope 1/2/3 inventory SECR Scope 1 + 2 are a statutory subset of the same tonnes — reconcile, don’t double-count

The clean mental model: ESOS audits the energy, SECR reports it annually with the resulting emissions, and the UK climate-related financial disclosure regime wraps the largest entities in a broader risk-and-strategy narrative. Because SECR Scope 1 and Scope 2 are genuine GHG Protocol scopes, they slot directly into a voluntary inventory as the UK statutory subset — the same emissions, reported to a narrower boundary.

What a Calculator Handles vs What You Decide

A calculator automates the conversion and the ratio. The judgements that set scope, denominator, and exemption status are yours.

⚙ A calculator handles automatically
  • Energy-to-emissions conversion: kWh × the UK Government GHG Conversion Factor ÷ 1,000
  • Scope 1 (gas, transport) and Scope 2 (electricity) split, kept separate from voluntary T&D
  • The 40,000 kWh low-energy-user exemption test on the kWh total
  • Intensity ratio against your chosen denominator
  • Prior-year comparison once last year’s figures are entered
  • Total energy-use figure as its own required line
✎ You must decide before using a calculator
  • Tier: quoted (global) or large unquoted / LLP (UK only)?
  • Boundary: which operations and which energy streams are in scope?
  • Denominator: which intensity-ratio metric reflects the business?
  • Exemption: is total UK energy at or below 40,000 kWh — and have you written the required statement?
  • Voluntary Scope 3: do you report T&D / business travel, and as a clearly separate line?
  • Factor vintage: which year’s UK Government GHG Conversion Factors match your reporting period?

Error Traps — With Calculable Consequences

Error What happens Consequence How to avoid
Folding T&D into the Scope 2 generation factor Using 0.13096 + 0.01299 = 0.14395 as one “all-in” electricity factor for the mandatory line. Scope 2 overstated ~9.9%
On 800,000 kWh: 115.16 tCO₂e reported vs the correct mandatory 104.77 — and a voluntary Scope 3 figure mixed into a mandatory one.		 Mandatory Scope 2 uses 0.13096 (generation only). Report T&D (0.01299) as a separate voluntary Scope 3 line, if at all.
Reporting global energy as a large unquoted company Consolidating the whole group’s worldwide energy into a UK-scope SECR disclosure. Disclosure overstated + non-comparable
Unquoted entities report UK energy only; a global figure breaks peer comparability and mis-states the boundary.		 Unquoted companies / LLPs report UK energy. Only quoted companies report global. Confirm your tier first.
Testing the 40,000 kWh exemption on emissions, not energy Converting to tCO₂e first, then comparing to 40,000 — the threshold is on kWh. Wrong exemption call
A 38,000 kWh user is exempt; converting first and comparing tonnes to 40,000 is a category error that can wrongly claim or deny exemption.		 Sum energy use in kWh and compare to 40,000 kWh before any conversion to emissions.
Omitting the energy-efficiency narrative when no action was taken Leaving the efficiency section blank because there is “nothing to report”. Non-compliant report
Comply-or-explain: an explicit “no measures taken” is required; silence is not permitted.		 Always include the narrative. If no action was taken, state that explicitly.
Using AR6 or non-GCV gas factors Applying an AR6-basis or net-CV gas factor instead of the DEFRA GCV, AR5 figure. Small but systematic mis-statement
UK gas is billed on GCV; the SECR convention is the DEFRA GCV factor (0.18231, AR5). Mixing bases breaks consistency.		 Use the UK Government GHG Conversion Factors on the GCV, AR5 basis. Do not mix GWP bases within one report.
Changing the intensity-ratio denominator year to year Reporting per-£m one year and per-FTE the next, defeating comparability. Trend becomes unreadable
The whole point of the ratio is year-on-year comparison; switching denominators erases it.		 Choose a relevant denominator and hold it constant; add a second ratio rather than replacing the first.
Treating SECR emissions as separate from the GHG inventory Maintaining a SECR figure and a voluntary inventory figure that do not reconcile. Two conflicting numbers
SECR Scope 1 + 2 are genuine GHG Protocol scopes — they should reconcile with the inventory’s UK subset.		 Reconcile SECR Scope 1 + 2 to the UK portion of the voluntary inventory; differences should be only boundary, not method.

Methodology Metadata — For the Directors’ / Energy and Carbon Report

Copy into your SECR methodology statement. The emission factors are DEFRA-sourced; the statutory parameters are set by the regulations and should be verified against the current consolidated text before each reporting cycle.

Methodology GreenCalculus UK SECR Reporting Calculation Methodology v1.1 (June 2026). greencalculus.com/methodology/uk-secr-methodology/
Governing regulation The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (SI 2018/1155), amending the Companies Act 2006.
Operative guidance HM Government / DESNZ “Environmental reporting guidelines: including Streamlined Energy and Carbon Reporting guidance”. Verify the current edition for thresholds and disclosure detail.
Emission factors UK Government GHG Conversion Factors 2026 (DEFRA). Natural gas 0.18231 kgCO₂e/kWh (GCV, Scope 1); grid electricity 0.13096 kgCO₂e/kWh (location-based generation, Scope 2); T&D losses 0.01299 kgCO₂e/kWh (Scope 3, voluntary). GWP basis AR5 GWP-100 (DEFRA convention).
Accounting basis Scope definitions per the GHG Protocol Corporate Standard. SECR Scope 1 and Scope 2 are genuine GHG Protocol scopes and reconcile with the UK subset of a voluntary inventory.
Mandatory boundary Scope 1 + Scope 2 (UK for unquoted companies / LLPs; global for quoted companies), plus, for unquoted companies and LLPs, business travel in rental or employee-owned cars where the company buys the fuel (Scope 3). Other Scope 3, including electricity T&D losses, is voluntary.
Intensity ratio At least one ratio of total emissions to a relevant activity metric (e.g. tCO₂e per £m turnover), applied consistently year on year with a stated denominator.
UK SECR Reporting — GreenCalculus.com
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Does this regime apply to you? Scoping is a separate question from reporting, and the six regimes use six different size tests. For the thresholds side by side — revenue, public float, turnover, balance sheet and headcount — with first reporting years and assurance phase-ins, see Regulatory Thresholds.

Factor reference: the thresholds that decide who reports — across CSRD, SECR, CBAM and the SEC rules — are published version-stamped with their sources as regulatory reporting thresholds.

Frequently Asked Questions

SECR applies to three groups: quoted companies, large unquoted companies, and large LLPs. A company is “large” if it meets at least two of three thresholds — more than £36 million turnover, more than £18 million balance-sheet total, and more than 250 employees — in the reporting year. Quoted companies are in scope regardless of size. A would-be-in-scope organisation whose total UK energy use is 40,000 kWh or less qualifies for the low-energy-user exemption but must still state that it is a low energy user. These statutory thresholds are set by SI 2018/1155 and should be verified against the current consolidated regulations and DESNZ guidance for a borderline case.

At minimum: total energy use in kWh, Scope 1 and Scope 2 greenhouse-gas emissions in tCO₂e, at least one intensity ratio, a narrative on energy-efficiency action taken in the year (or an explicit statement that none was taken), and a statement of the methodology used. After the first reporting year, a prior-year comparison is also required. Quoted companies report this on a global basis; large unquoted companies and LLPs report UK energy use and the associated emissions only. Companies disclose in the Directors’ Report; LLPs use a standalone Energy and Carbon Report.

Multiply each energy stream’s activity data by the matching UK Government GHG Conversion Factor, then divide by 1,000 to convert kgCO₂e to tonnes. Natural gas uses a Scope 1 factor on the gross calorific value (GCV) basis — 0.18231 kgCO₂e/kWh in the 2026 factors, the correct convention because UK gas is billed on GCV. Grid electricity uses a Scope 2 location-based factor of 0.13096 kgCO₂e/kWh (generation only). The factors are published by DEFRA on the AR5 GWP-100 basis; use a consistent factor vintage matching your reporting period and do not mix GWP bases within one report.

No. The mandatory Scope 2 figure uses the generation-only grid factor (0.13096 kgCO₂e/kWh in the 2026 factors). Transmission and distribution losses are a separate emission factor (0.01299 kgCO₂e/kWh) classified as Scope 3, and reporting them is voluntary under SECR. Folding T&D into the generation factor to make a single “all-in” electricity figure over-states the mandatory Scope 2 line — on 800,000 kWh it would report 115.16 tCO₂e instead of the correct 104.77, a 9.9% overstatement — and mixes a voluntary figure into a mandatory one. If you choose to disclose T&D, show it as a clearly labelled, separate voluntary Scope 3 line.

SECR requires at least one intensity ratio — total emissions (tCO₂e) divided by a metric that makes the figure comparable over time and against peers. You choose the denominator, but it must be relevant to the business: common choices are tCO₂e per £m turnover, per square metre of floor area, per full-time employee, or per unit of output. The key discipline is consistency: pick a denominator that reflects how the business scales and hold it constant year to year, because the ratio exists to show a trend. If you want to add a second ratio you may, but do not replace the first one mid-series — switching denominators erases the comparability the ratio is meant to provide.

They are the same kind of number, calculated to a narrower statutory boundary. SECR Scope 1 and Scope 2 emissions are genuine GHG Protocol scopes — direct combustion and purchased electricity — so they should reconcile with the corresponding part of a voluntary corporate inventory rather than form a separate, conflicting figure. For a large unquoted company the main difference is geographic: SECR covers UK energy only, so it is the UK subset of a global inventory. SECR mandates Scope 1 and Scope 2 and, for unquoted companies and LLPs, one slice of Scope 3 (business travel in rental or employee-owned cars where the company buys the fuel); other Scope 3, including electricity T&D, is voluntary, whereas a full inventory would quantify Scope 3 as well. Differences between the two should be boundary differences, never method differences.

They are distinct UK obligations that interlock. ESOS is a periodic energy audit of large undertakings’ significant energy consumption — it identifies efficiency opportunities but is not an annual reporting requirement; it pairs naturally with ISO 50001 energy management, and its findings feed the energy-efficiency actions that SECR then narrates each year. The UK’s mandatory climate-related financial disclosure regime (TCFD-aligned) is broader and applies to the largest entities, covering governance, strategy, risk management, and metrics — SECR’s emissions data can feed its metrics pillar. SECR itself is the recurring annual energy-and-emissions report in the financial statements. Many large groups are subject to all three.

Tools that apply this methodology

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