Carbon reporting for charities and housing associations

Large charitable companies must report energy and carbon under SECR in their trustees' report, and from periods starting on or after 1 January 2026 the Charities SORP requires charities with income over £15 million to summarise how they manage environmental matters. Many housing associations report through the voluntary Sustainability Reporting Standard for Social Housing instead, which asks for Scope 1, 2 and 3 emissions and emissions per home.

Updated 19 October 2026 by the Carbon Recycling team. Figures use the official UK government conversion factors and are checked against the current gov.uk guidance.

Charities: what applies to you

Rule	Who it catches	What it asks for
SECR	Charitable companies meeting two of 250 employees, £36 million gross income and an £18 million balance sheet, using over 40,000 kWh a year	UK energy use, the resulting emissions, an intensity ratio, the method and efficiency actions, in the combined directors' and trustees' report
Charities SORP 2026, tier 3	Charities with gross income over £15 million, for periods starting on or after 1 January 2026	A summary of how the charity is responding to and managing environmental, governance and social matters
Charities SORP 2026, tiers 1 and 2	Charities with gross income up to £15 million	Nothing compulsory. Trustees may choose to report on the same matters
PPN 006 and NHS rules	Charities bidding for large public contracts	A Carbon Reduction Plan above £5 million a year, and a net zero commitment for smaller NHS contracts

For SECR, the government's guidance says a charitable company's "turnover" means its gross income. Charities that aren't companies, such as charitable incorporated organisations and trusts, aren't covered by SECR at all. The SORP's tier 3 requirement doesn't prescribe a method, but it gives as an example the key performance indicators used to manage climate-related risks and opportunities, with a description of how they are calculated. A measured footprint is the obvious KPI.

Housing associations: the Sustainability Reporting Standard

SECR only applies to companies and LLPs, so a housing association set up as a registered society or a charitable trust isn't caught by it. Many housing associations report instead through the Sustainability Reporting Standard for Social Housing (SRS). It's voluntary and has 44 criteria; Sustainability for Housing says more than 160 organisations have signed up as adopters or endorsers, 38 of them lenders or investors. The climate criteria in version 2.1 ask for:

the spread of EPC ratings for existing homes and for homes completed in the last year;
whether you have a net zero target and strategy, and progress and retrofit work in the last 12 months;
Scope 1, Scope 2 and Scope 3 emissions, and total emissions per home, or when you expect to be able to report them;
whether you've assessed flood, water stress and overheating risks to your homes.

Whose emissions are they?

For a landlord, the boundary question decides everything. Gas for communal boilers, electricity for stairwell lighting and lifts, your offices and your repairs vans are yours: Scope 1 and 2. Energy that tenants buy for their own homes is normally your Scope 3, category 13 (downstream leased assets), and with hundreds or thousands of homes it can be far larger than your own Scope 1 and 2. Our property and real estate page explains landlord and tenant boundaries in more detail.

A worked example: emissions per home

A housing association with 1,500 homes adds up a year of its own energy and fuel, using the 2026 government factors:

Source	Quantity	Scope	tCO2e
Communal heating boilers (gas)	450,000 kWh	1	82.04
Maintenance vans (diesel)	12,000 litres	1	31.00
Communal lighting, lifts and offices (electricity)	220,000 kWh	2	28.81
Scope 1 and 2			141.85

That's about 95 kg CO2e per home for the landlord's own Scope 1 and 2. The SRS asks for total emissions per home, so say which scopes your per-home figure includes, and use the same definition every year. Our post on choosing an intensity ratio covers this. If you add tenants' energy as Scope 3, the per-home figure changes completely, so keep the two clearly separate.

Where to start

List every meter and fuel account you pay for, by site or scheme.
Gather a year of bills, fuel cards and refrigerant service records.
Pick a reporting year that matches your accounts, and stick to it.
Decide how you'll estimate Scope 3, starting with the biggest category, and write the method down.

Schools and academy trusts have their own rules, covered in carbon reporting for schools.

How Carbon Recycling helps

Add each office, shop or scheme as a site and import bills and fuel from a spreadsheet, and Carbon Recycling produces the SECR disclosure for a charitable company's trustees' report, with an intensity ratio per £m of income, per employee or per square metre, and a PPN 006 Carbon Reduction Plan from the same figures. Site reports show each scheme's footprint on its own. Check whether SECR applies with the free SECR checker. For a housing association, the communal heating in this example is the biggest line: every 10% cut in its gas use avoids about 8.20 tonnes of CO2e a year.

Frequently asked questions

Do charities have to report their carbon emissions?

Only some. A charitable company must include SECR energy and carbon figures in its combined directors' and trustees' report if it meets two of 250 employees, £36 million gross income or an £18 million balance sheet, and uses more than 40,000 kWh a year. Charities that aren't companies, such as CIOs and trusts, aren't covered by SECR.

What does the Charities SORP 2026 say about climate?

For reporting periods starting on or after 1 January 2026, charities with gross income above £15 million (tier 3) must summarise in the trustees' report how they are responding to and managing environmental, governance and social matters. Smaller charities may choose to. It gives climate-related KPIs as an example, but doesn't set a carbon reporting method.

Do housing associations have to report under SECR?

Only if the housing association is a company, or an LLP, that meets the large company tests. SECR is part of company law, so a housing association set up as a registered society or a charitable trust isn't covered, though the government encourages organisations outside SECR to report voluntarily.

What is the Sustainability Reporting Standard for Social Housing?

A voluntary framework of 44 criteria run by Sustainability for Housing, used by housing providers to report to lenders and investors. Its climate criteria ask for EPC ratings of existing and new homes, a net zero target and progress, Scope 1, 2 and 3 emissions and total emissions per home.

Are tenants' home energy emissions the housing association's?

Usually not in Scope 1 or 2. Energy that tenants buy and use in their own homes is normally Scope 3 category 13, downstream leased assets, for the landlord. Communal heating, lighting and lifts that the landlord pays for are its own Scope 1 and 2.

Plastic Packaging Tax: what it is and how it links to carbon
The 2026 rate, who registers, the April 2027 changes and where plastic packaging sits in your Scope 3 footprint.
Packaging EPR: what small producers have to report
Who counts as a small producer under packaging EPR, what to report by 1 April, the fees, and how the data links to your carbon footprint.
ISO 14064-1 explained: do you need it?
The ISO greenhouse gas inventory standard in plain English: its six categories, how it compares with the GHG Protocol, and when you need it.

All posts on this topic →

Get your figures and reports done in an afternoon

Add a year of bills and Carbon Recycling produces your footprint, PPN 006 Carbon Reduction Plan and SECR report, with every figure traced to its government factor. Prices are on the pricing page, from £59 a month + VAT.

Start free trial See prices

14 days free. No card needed.