SECR reporting explained — who has to do it and what to include
Streamlined Energy and Carbon Reporting: qualifying thresholds, what to report, common mistakes, and how to align it with your energy procurement strategy.
Who has to report under SECR
SECR (Streamlined Energy and Carbon Reporting) applies to UK large companies, LLPs and quoted companies. The threshold is any two of: >250 employees, >£36m turnover, >£18m balance sheet total. Groups are assessed at parent level. Charities and public bodies have separate reporting frameworks (ESOS, public sector carbon reporting) but many of the same underlying principles apply.
What has to be reported
Total UK energy use (kWh) across gas, electricity and transport fuels; associated greenhouse gas emissions in tCO2e; at least one intensity ratio (e.g. tCO2e per £m turnover or per FTE); a narrative on energy-efficiency actions taken in the year; and the methodology used. Global energy use is required for quoted companies; unquoted large companies report UK-only.
Scopes 1, 2 and 3 in plain English
Scope 1: direct emissions from combustion you control — gas boilers, on-site generation, company vehicles. Scope 2: emissions from purchased electricity, heat or steam. SECR requires Scope 1 and 2 as a minimum; Scope 3 (upstream/downstream value chain) is voluntary under SECR but increasingly expected by customers and investors.
Market-based vs. location-based Scope 2
Location-based Scope 2 uses the grid average emissions factor for the country of consumption. Market-based Scope 2 reflects the specific electricity you actually procure — a REGO-backed 100% renewable contract has zero market-based Scope 2 emissions, even though the physical grid mix is unchanged. SECR encourages reporting both. This is where energy procurement decisions directly move the number in the annual report.
Common mistakes
Using estimated bill data instead of half-hourly reads for HH sites; forgetting company-vehicle fuel; double-counting REGOs and PPAs; and quietly changing the intensity ratio year on year to flatter the trend. Auditors are getting better at catching all four.
Aligning procurement with SECR
The three procurement decisions that move SECR numbers most: switching to a REGO-backed contract (immediate market-based Scope 2 impact); signing a corporate PPA (long-term additionality and hedging); and any on-site generation like rooftop solar (Scope 2 reduction plus real cost savings). Build the SECR conversation into your renewal cycle, not as a separate workstream.
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