This is a tick list for an accountant preparing the SECR section of a client's annual report. It follows the order of the 2018 regulations (SI 2018/1155). For the background, see our SECR guide; for offering the work as a service, see carbon reporting for accountants.
1. Is the client in scope?
- Quoted company? Always in scope, whatever its size.
- Unquoted company or LLP: does it meet two or more of more than 250 employees (the monthly average of people on contracts of service), more than £36 million turnover, or a balance sheet total over £18 million?
- Use the SECR figures, not the new Companies Act ones. The size thresholds that rose for financial years starting on or after 6 April 2025 don't apply to SECR. A client that dropped to "medium" for accounts may still be large for SECR.
- Check the two-year rule. As with the accounts size tests, the exemption only changes once the client has been on the other side of the line for two years in a row.
- Group parent? Test the group on aggregate figures: £36 million net (£43.2 million gross) turnover and £18 million net (£21.6 million gross) balance sheet, with 250 employees.
- Subsidiary? No separate disclosure is needed if it is covered by a parent's group report that meets the SECR rules for a year ending at the same time or earlier.
- Low energy user? At 40,000 kWh or less in the UK, the report states that it is not disclosing the figures for that reason.
Not sure? The free SECR checker runs the tests in under a minute.
2. Collect the data for the financial year
- Electricity bills for every UK site, in kWh, covering all twelve months (including any electricity used to charge company vehicles).
- Gas bills in kWh. Check whether the bill shows gross or net calorific value; the government factors are given for both.
- Fuel cards and receipts for company vehicles, in litres.
- Business mileage in employees' own cars or hire cars where the company pays for the fuel.
- Turnover (or another measure) for the intensity ratio, from the same accounts.
- Last year's SECR figures, if this isn't the first year.
- A note of any energy efficiency work in the year: new lighting, heating controls, electric vehicles, solar panels.
Missing a month? Estimate it from the others and say so in the methodology. Where some information is not practical to get, the regulations ask the report to say what is missing and why.
3. What the disclosure must contain
| Tick | Item | Unquoted company or LLP | Quoted company |
|---|---|---|---|
| ☐ | Energy use | UK total in kWh: gas, transport fuel and purchased electricity | Global total in kWh, and the share used in the UK and offshore area |
| ☐ | Emissions | Tonnes CO2e from gas and transport fuel (Scope 1) and from purchased electricity (Scope 2), in the UK | Global Scope 1 and Scope 2 in tonnes CO2e, and the UK share |
| ☐ | Intensity ratio | At least one, such as tCO2e per £1 million turnover | At least one |
| ☐ | Methodology | The methods used to calculate the figures | The same |
| ☐ | Energy efficiency action | The principal measures taken in the year, if any | The same |
| ☐ | Previous year | Last year's figures alongside, from the second year of reporting | The same |
| ☐ | Reporting period | Stated, if it differs from the financial year | The same |
An unquoted company may leave out energy and emissions outside the UK. A quoted company reports globally. Our post on the carbon intensity ratio covers choosing one that stays comparable year to year.
4. Check the numbers before the directors sign
- The conversion factors are the UK government's for the right year (the set for the year the reporting period mostly falls in), and the methodology says which.
- Electricity is shown on the location-based method (the UK grid average), with any market-based figure alongside and clearly labelled. A green tariff doesn't change the location-based figure; see green tariffs and Scope 2.
- Every site and vehicle in the fixed asset register or the lease list has energy data, or an explanation.
- The intensity ratio uses the same turnover as the accounts. If it has moved a lot, check whether a cleaner grid explains it (the 2026 electricity factor is much lower than 2025's), and say so.
- The comparison with last year uses last year's published figures, or explains any restatement.
- The energy efficiency narrative describes what was actually done in the year, not plans.
The free report check recalculates electricity and gas from the kWh you enter and flags anything SECR asks for that is missing.
5. Where it goes
- Companies: in the directors' report, approved by the board and filed at Companies House with the accounts.
- LLPs: in a separate energy and carbon report, approved by the members and signed by a designated member. See SECR for LLPs.
- Groups: a group report covers the subsidiaries in the consolidation, unless they are left out under the regulations.
What may change
The government's Modernising Corporate Reporting consultation, open until 30 November 2026, proposes abolishing the directors' report and letting companies place the SECR disclosure anywhere in the first half of the annual report. DESNZ also intends to consult on SECR and ESOS later in 2026. None of this changes the rules for current reporting years. Our post on SECR reform follows it.
How Carbon Recycling helps
Add the client's bills, fuel cards and mileage, and Carbon Recycling produces the SECR table, the intensity ratio, last year's comparison and a methodology statement, ready to put in the directors' report or the LLP's energy and carbon report. Every figure shows the government factor and its ID. For practices with several clients, our page on which plan and add-ons you need works out the cost, and the free trial lets you see a client's report before you pay (printing, saving and downloading need a paid plan).