SECR Eligibility UK 2026: Does Your Company Need to Report?

Written by Calvin Lo, Founder of Aphelios Software | August 2026 | 6 min read

Every year, thousands of UK companies ask the same question: "does SECR apply to us?" The Streamlined Energy and Carbon Reporting regime has been in force since April 2019, but eligibility confusion is still the single most common reason companies start their carbon reporting late.

The good news is that the SECR eligibility test is a clear, three-part check under the Companies Act 2006. Once you know your headcount, turnover and balance sheet total, you can work out where you stand in under a minute. This guide walks through the test, the group rules, the exceptions and what to do if SECR does not apply to you but you want to report anyway.

Who Is in Scope for SECR?

SECR applies to two broad categories of company:

• Quoted companies - SECR applies regardless of company size. Quoted companies must report their UK energy use and associated greenhouse gas emissions every year, even if they are small.
• Large unquoted companies and groups - UK companies (or groups) that meet the Companies Act 2006 s.465 "large company" test, described below.

The SECR Large-Company Test

A company is "large" if it meets two or more of the following three thresholds in its most recent financial year:

Groups are assessed on the aggregate figures across the group, so a collection of individually small companies can still be in scope. Parent companies of in-scope groups are responsible for the group disclosure.

The 1-Minute SECR Eligibility Check

Because the test is purely arithmetic, it can be automated. Aphelios Software includes a built-in SECR eligibility screener that applies the s.465 test to your employee count, turnover and balance sheet total, flags quoted companies as in scope regardless of size, and saves the assessment so it is on record for the next financial year.

If you are borderline, the screener tells you exactly which criteria you pass and which you miss - so you can plan ahead if you expect to cross a threshold.

What SECR In-Scope Companies Must Report

For the year’s disclosure, in-scope companies must report:

• UK energy use in kWh for Scope 1 (gas, fuel) and Scope 2 (purchased electricity)
• Associated greenhouse gas emissions in tonnes of CO2e, using the official UK Government (DESNZ) conversion factors
• An intensity ratio, such as tonnes CO2e per £1 million of turnover
• Previous-year comparatives (from the second reporting year onwards)
• An energy-efficiency actions narrative in the Directors’ Report

Our guides cover Scope 1, 2 and 3 emissions, the official DESNZ conversion factors, the 40 MWh low-energy exemption and the intensity ratio and efficiency narrative in more detail.

What if SECR Does Not Apply to You?

Two common situations arise:

• Voluntary reporting - suppliers and lenders increasingly ask for carbon data through supply-chain questionnaires and ESG requests. Tracking voluntarily now means you can answer in days, not weeks.
• Growth planning - if you are close to the thresholds, building the data habits before you cross them makes your first in-scope year dramatically easier.

Aphelios supports both cases: the emissions module works identically whether you are in scope or reporting voluntarily, so you can record activities, import official factors and build a compliant report without any special setup.

SECR Eligibility FAQ

The SECR eligibility check is a planning aide, not legal advice. Thresholds and the final SECR position should be confirmed with your accountant before filing.