What Is SECR?

SECR is replacement legislation to a number of existing and some soon to expire programmes covering energy and carbon reporting and taxation. SECR came into force on 1 April 2019.

Why Do We Need SECR?

The Company's Act 2006 described a regime where all large businesses (and we read that as all private businesses apart from SMEs) report carbon emissions in the annual reports and accounts. Until 2019, this had only been enacted only for FTSE Main Market Companies. 

With pressures on the UK to meet its climate change targets, the government launched SECR so all large UK companies to report their carbon emissions and energy usage on an annual basis.

But you might ask why should we not just rely on Energy Savings Opportunity Scheme (ESOS)?

ESOS stems from EU legislation and is somewhat separate from SECR. Additionally, ESOS only applies to large entities (under the EU definition) and - most importantly - only requires reporting once every 4 years and proven reductions are not obligated. Therefore, ESOS alone cannot be relied upon to generate the scale of carbon savings year on year that we need to mitigate climate change.

SECR aims to harmonise reporting, removing the multiple carbon reports with different reporting dates and will be streamlined to be consistent with financial reporting years. It will also make it easier to monitor and achieve reductions in carbon and cost each year. 

Who Needs to Report 

SECR is now in force & covers financial reporting years starting on or after 1 April 2019.  It replaces Mandatory Greenhouse Gas Reporting (MGHG). First reports will be published in 2020 – i.e. for financial years starting on or after 1st April 2019.

The qualifying conditions are met by a company or LLP in a year satisfying two or more of the following criteria: 

• Turnover £36 million or more
• Balance sheet TOTAL of £18 million or more
• Number of employees 250 or more

If you qualify, you will need to report UK energy use and associated greenhouse gas emissions relating to gas, electricity and transport, as well as an intensity ratio, information relating to energy efficiency action, within your annual reports. This is only mandatory to include subsidiaries if they qualify for SECR themselves (note - this different to ESOS where all members of a group structure apply if at least one qualifies).

If you meet the qualification conditions but consume less than 40MWh, then there is no requirement for detailed disclosure. All companies that meet the qualification criteria must comply or explain rationale (as in MGHG).

How is SECR Enforced and What Are The Penalties 

SECR will be enforced by The Conduct Committee of the Financial Reporting Council - penalties for non-compliance have yet to be published, though if these are anything like those of ESOS or the CRC they will be substantial (fines of £40,000 plus have been issued).

What Must be Included Within a SECR Report

This will depend on whether you are a Quoted or Unquoted company. Quoted Companies will report the information currently disclosed under the Mandatory Greenhouse Gas Regulations, and must also report what proportion of their energy consumption and their emissions relate to the UK and its offshore area, as well as information relating to energy efficiency measures undertaken in the financial reporting year.

Unquoted Companies need to make the following publicly available, with suitable intensity metrics:

• Emissions related to UK energy usage

• Energy efficiency actions taken by the company over the previous year

Scope 3 emissions are voluntary Disclosure

SECR Reports for FTSE Main Market companies (i.e. those previously in MGHG reporting):

Your reporting must include Global GHG Protocol Scope 1 and Scope 2 emissions and your previous year’s figures (except in the first year).

Your methodology must include: 

• At least one intensity ratio
• Global energy use kWh (including previous year’s figure from year two) 
• Information about energy efficiency action taken, leading on from recent ESOS assessments
• State what proportion of your energy consumption and emissions are related to emissions in the UK and offshore area

SECR Reporting for Other Large Entities - including AIM, Privately Owned Businesses and LLPs (new to Carbon Reporting )

Similar to the FTSE companies, you will have to report energy use (to include as a minimum electricity, gas, company owned transport and grey fleet), with associated Scope 1 and Scope 2 greenhouse gas emissions, though this will just need to be for your UK operations, excluding any other global sites. 

You will also have to include at least one intensity ratio as well as information about energy efficiency action taken in the organisation’s financial year and previous year’s figures for energy use and GHG emissions (from second year onward).

What It Means - Annual Carbon Footprint Appraisals

If your business meets the qualification criteria, you will need to assess and report your carbon footprint on an annual basis. If you have been assessing your carbon footprint on a voluntary basis and/or completing  ESOS assessments, you will find the SECR process to be quite familiar, as it uses a similar dataset.

Regular assessment and management of company carbon footprints frequently helps to reduce energy use and brings operational cost savings to a business.