SECR thresholds: the April 2025 decoupling explained
Streamlined Energy and Carbon Reporting has its own size test, and it did not move when the Companies Act size thresholds did. Since April 2025 the two tests give different answers for some companies, and the companies caught in the gap are exactly the ones most likely to conclude, wrongly, that they no longer need to report.
Published 18 September 2026.
The SECR test
Quoted companies are always in scope. An unquoted company or LLP is in scope when it meets at least two of the three tests in the 2018 Regulations: more than 250 employees, turnover over £36m, or a balance sheet total over £18m. A company that used 40,000 kWh or less in the period states that it is a low energy user instead of reporting in full.
What changed in April 2025 — and what did not
For financial years beginning on or after 6 April 2025, the Companies Act thresholds for a medium-sized company rose to £54m turnover and £27m balance sheet. The SECR Regulations carry their own figures and were not amended, so the two tests parted company. A business with 240 employees, £48m turnover and a £21m balance sheet is now medium-sized for its accounts — and still large for SECR, because it passes two of the three 2018 tests.
The trap is reading the new accounts thresholds, concluding the company has dropped out of scope, and stopping the energy and carbon disclosure. The duty check below tests both regimes from the same figures and flags this decoupled case explicitly.
The two-year rule
Size status changes only after two consecutive financial years on the same side of the tests, except in a company's first financial year. So a company that crosses the thresholds this year for the first time is usually in scope from next year. (Group qualification rules are not modelled in our check; confirm group cases with your auditor.)
What SECR actually requires
The disclosure is a page of the annual report: UK energy use in kWh (gas, electricity and transport fuel, including business mileage in employee-owned cars where the company pays for the fuel), the Scope 1 and 2 emissions, at least one intensity ratio used consistently, the prior-year comparison, the energy-efficiency action taken, and the methodology. It is approved by the directors with the annual report — due nine months after the period end for private companies and LLPs, six for public companies. No assurance, verification or professional qualification is required by law.
Check your position in two minutes. Enter the figures from your latest accounts and see the SECR verdict alongside every other UK carbon reporting duty, each naming the rule it came from.
Sources
- Companies (Directors' Report) and LLP (Energy and Carbon Report) Regulations 2018
- Environmental reporting guidelines including SECR guidance (gov.uk)
General information, not legal, accounting or assurance advice. Verdicts on this site come from a versioned rule set; the current version and its verification date are shown with every result. Privacy · Terms