First-Time SECR Filer Checklist: Your 30-Day Action Plan

Facing your first Streamlined Energy and Carbon Reporting (SECR) deadline can feel overwhelming. You've discovered your company meets the thresholds, your directors' report is due soon, and you're not sure where to start with carbon reporting.

This comprehensive 30-day action plan breaks down first-time SECR compliance into manageable daily tasks. Whether your financial year-end is approaching rapidly or you're planning ahead, this checklist ensures you gather the right data, apply correct methodologies, and produce a compliant report on time.

Before You Begin: Understanding Your Obligation

First, confirm whether your company actually needs to comply with SECR.

Do You Need to File?

You must prepare a SECR report if you're a:

Quoted Company: Listed on London Stock Exchange Main Market, NYSE, NASDAQ, or equivalent (all quoted companies must report, regardless of size)

OR

Large Unquoted Company or LLP meeting 2 out of 3 criteria for two consecutive financial years:

• More than 250 employees
• Turnover exceeding £36 million
• Balance sheet total exceeding £18 million

Key Point: You must meet the thresholds for two consecutive years before the obligation starts. If your company crossed the thresholds in FY 2023/24 and 2024/25, your first SECR report is due with your FY 2024/25 directors' report.

Still unsure? Use our compliance check tool to instantly verify your obligation.

What's the Deadline?

SECR disclosure must be included in your directors' report (or equivalent for LLPs) filed with Companies House.

Timeline:

• Private companies: Within 9 months of financial year-end
• Public companies: Within 6 months of financial year-end

Example:

Financial year-end: 31 March 2025
Private company filing deadline: 31 December 2025
SECR report must be ready before: Late November 2025
(allowing time for board approval and report finalization)

Critical Warning: This is not a separate reporting obligation with its own deadline. If your directors' report is due, your SECR disclosure must be in it. Missing this means your directors' report is non-compliant.

Week 1: Foundation and Planning (Days 1-7)

Day 1: Assemble Your Team and Assign Responsibilities

SECR compliance requires input from multiple departments.

Core Team Members:

1. Financial Controller / CFO (Lead)

• Overall responsibility for directors' report
• Final approval of SECR disclosure
• Budget approval for any external costs

2. Facilities Manager / Operations Lead

• Access to utility bills and energy consumption data
• Knowledge of all UK sites and facilities
• Vehicle fleet information

3. Finance / Accounts Payable

• Historical utility invoice records
• Supplier payment information
• Cost center allocation data

4. Legal / Company Secretary

• Ensure disclosure meets Companies Act requirements
• Review language and legal compliance
• Coordinate board approval

Optional but Helpful:

5. Sustainability Manager (if you have one)

• Previous environmental reporting experience
• Stakeholder communication
• Energy efficiency initiatives documentation

6. IT/Data Analyst

• Consolidating data from multiple sources
• Spreadsheet setup and calculations
• Data quality assurance

Day 1 Action Items:

• Schedule 30-minute kickoff meeting with core team
• Assign a project lead (typically Financial Controller)
• Set internal deadline (2 weeks before directors' report finalization)
• Create shared folder for SECR documentation

Day 2: Understand the Basic Requirements

Before diving into data collection, ensure everyone understands what SECR requires.

Your SECR Report Must Include:

1. UK Energy Consumption (in kWh)

   • All energy types: electricity, gas, transport fuel, etc.
   • UK operations only (exclude overseas)
   • Full financial year coverage

2. Greenhouse Gas Emissions (in tonnes CO2e)

   • Scope 1: Direct emissions (gas, company vehicles, etc.)
   • Scope 2: Indirect emissions (purchased electricity)
   • Calculated using UK Government conversion factors

3. Intensity Ratio (at least one)

   • Emissions per unit of business activity
   • Examples: tonnes CO2e per £M revenue, per employee, per sq meter

4. Prior Year Comparison

   • Same metrics for previous financial year
   • Explanation of any significant changes

5. Energy Efficiency Actions

   • Description of measures taken during the year
   • Can be brief but must be included

6. Methodology Statement

   • Brief explanation of approach used
   • Reference to standards followed (e.g., GHG Protocol)

Day 2 Action Items:

• Download and review Defra environmental reporting guidance
• Review our complete SECR guide as a team
• Look at a sample SECR report to understand the format
• Note questions for later resolution

Day 3: Define Your Organizational Boundary

Determine exactly which entities and operations to include in your report.

For Single Companies: Include all UK operations owned or controlled by your company.

For Group Companies: Follow your financial reporting boundary:

• If you prepare consolidated accounts including subsidiaries, include their UK energy consumption
• See our detailed guide on SECR for group companies

Key Decisions to Document:

1. Which legal entities are included?

Example - Simple Structure:
- Acme Ltd (parent and only operating company)
- Acme Holdings Ltd (parent, no operations) → no energy to report

Example - Group Structure:
- Acme Group Ltd (parent with consolidated accounts)
  ├── Acme UK Ltd → Include UK operations
  ├── Acme Services Ltd → Include UK operations
  └── Acme France SAS → Exclude (overseas)

2. Which UK sites/facilities operate under these entities?

• Head office
• Regional offices
• Warehouses
• Retail locations
• Manufacturing facilities
• Any other UK premises

3. What about:

• Home workers using company energy allowances? → Generally exclude (minimal and complex to measure)
• Company vehicles? → Include if owned or leased by company
• Employee-owned vehicles with fuel reimbursement? → Generally exclude (business travel is Scope 3, not required for SECR)

Day 3 Action Items:

• List all legal entities in your company/group
• Map which entities have UK operations
• Create master list of all UK facilities/sites
• Document boundary decisions with rationale
• Flag any unclear situations for further research

Day 4: Identify All Energy Consumption Sources

Create a comprehensive inventory of everything that consumes energy in your UK operations.

Energy Source Checklist:

Electricity:

• Main office(s)
• Satellite offices
• Warehouses/distribution centers
• Retail locations
• Manufacturing facilities
• Data centers/server rooms
• External lighting/signage

Natural Gas:

• Office heating
• Warehouse heating
• Manufacturing process heat
• Hot water systems

Other Fuels:

• Heating oil
• LPG (bottled gas)
• Biomass/wood pellets
• Coal (rare but possible)

Transportation:

• Company-owned cars
• Company-owned vans/trucks
• Leased vehicles (under operating or finance lease)
• Pool cars
• Forklift trucks (on-site vehicles)

Refrigerants:

• Air conditioning systems
• Refrigeration units
• Heat pumps

Note: Refrigerant leakage creates direct emissions (Scope 1) even if no fuel is consumed.

Day 4 Action Items:

• Walk through the checklist for each facility
• Speak with facilities managers at each site
• Identify who pays each utility bill
• Note any shared facilities requiring allocation
• Create master spreadsheet with all sources identified

Day 5: Understand Data Collection Requirements

Before requesting data, understand exactly what information you need.

For Each Energy Source You Need:

1. Quantity Consumed

• Electricity: kWh
• Gas: kWh (not cubic meters—bills show both)
• Transport fuel: Liters (petrol, diesel)
• Heating oil: Liters or kWh

2. Time Period

• Must match your financial year exactly
• Example: If FY is April 1, 2024 - March 31, 2025, you need consumption for that exact period

3. Geographic Coverage

• UK only
• If bills cover UK and overseas, you need split data

4. Data Source Documentation

• Utility bill references
• Supplier names
• Account numbers
• Meter point reference (MPR/MPAN for electricity, MPRN for gas)

Common Data Challenges and Solutions:

Challenge 1: Billing periods don't match financial year

Financial year: 1 April 2024 - 31 March 2025
Gas bill: 15 March 2024 - 14 March 2025 (doesn't align)

Solutions:
A) Prorate: Estimate first/last partial periods
B) Request meter readings for exact FY dates
C) Use billing data and note slight mismatch (acceptable if minimal)

Challenge 2: Multiple sites on single bill

Electricity bill covers three office locations
Need to understand consumption by site (if sites are in different entities)

Solutions:
A) Request supplier breakdown by meter point
B) Use sub-meter data if available
C) Allocate proportionally by floor space

Challenge 3: Missing historical bills

Need FY 2023/24 data for comparison but can't locate old bills

Solutions:
A) Request from utility supplier (usually available online for 12-24 months)
B) Check accounts payable records/payment records
C) Last resort: Estimate based on available data and disclose estimation

Day 5 Action Items:

• Confirm exact dates of your financial year
• Identify format needed for each energy type
• Prepare list of suppliers to contact
• Set up data collection spreadsheet template
• Assign team members to collect specific data types

Day 6-7: Begin Data Collection

Start gathering energy consumption data for your reporting year and the prior year.

Data Collection Strategy:

Priority 1: Electricity and Gas (usually 80%+ of emissions)

• Contact main suppliers
• Download bills from online portals
• Request missing bills from accounts payable

Priority 2: Transport Fuels

• Fuel card provider statements
• Expense claim records
• Company credit card statements for fuel purchases

Priority 3: Other Sources

• Heating oil delivery invoices
• Refrigerant top-up/service records
• Any other identified sources

Data Collection Methods by Source:

Supplier Online Portals: Most efficient for electricity and gas

• Log in to supplier website
• Download annual summary or individual bills
• Export to Excel/CSV if available

Accounts Payable: Useful when you don't have direct supplier access

• Request invoices by supplier name and date range
• Provide list of suppliers and account numbers
• Ask for copies or extract data directly

Facilities Managers: Best for multi-site organizations

• Request they gather bills for their locations
• Provide template for consistent data format
• Set clear deadline

Fuel Card Providers: For company vehicles

• Download annual transaction report
• Filter by fuel purchases only
• Sum total liters by fuel type

Day 6-7 Action Items:

• Send data requests to all suppliers
• Download available data from online portals
• Request historic bills from accounts payable
• Contact facilities managers at all sites
• Begin entering collected data into spreadsheet
• Flag any data gaps needing alternative approaches

Week 1 Checkpoint:

By end of Week 1, you should have:

• ✓ Team assembled with clear responsibilities
• ✓ Understanding of SECR requirements
• ✓ Organizational boundary clearly defined
• ✓ Complete inventory of energy sources
• ✓ Data collection in progress

If you're behind schedule, focus on:

1. Getting your boundary definition clear (Days 3-4)
2. Starting electricity and gas data collection (Day 7)
3. Everything else can be caught up in Week 2

Week 2: Data Collection and Validation (Days 8-14)

Day 8-10: Continue Data Collection and Handle Gaps

Focus Areas:

Complete Priority Sources: Ensure you have full FY data for:

• All electricity supplies
• All natural gas supplies
• Major transport fuel consumption

Address Data Gaps:

Gap Type 1: Missing Bills for Specific Periods

If you're missing one or two months of a 12-month period:

Example: Have gas bills for 10 months, missing June and July 2024

Estimation Method:
1. Calculate average of known months: Total ÷ 10 = avg monthly
2. Multiply by 2 for missing months
3. OR: Use same months from prior year if available
4. Document: "June-July 2024 estimated based on prior year consumption"

Gap Type 2: Facility Closed or Opened Mid-Year

Example: Office B opened 1 October 2024 (6 months into FY)

Approach:
- Include actual consumption for period occupied (Oct-Mar)
- Note in methodology: "Office B operational from October 2024"
- For prior year comparison: Note that prior year excludes Office B

Gap Type 3: No Historic Supplier Access

Example: Changed electricity supplier in March 2024, old supplier portal no longer accessible

Solutions:
1. Contact old supplier customer service and request historic bills
2. Check if annual statement was provided at year-end
3. Check accounts payable for payment records showing kWh amounts
4. Last resort: Estimate based on similar period from new supplier

Day 8-10 Action Items:

• Follow up on outstanding data requests
• Compile all collected bills and statements
• Identify remaining gaps
• Develop estimation approach for each gap
• Document all estimations and assumptions
• Aim for 90%+ completeness by Day 10

Day 11: Organize and Validate Your Data

Quality control is critical before calculations.

Data Validation Checklist:

1. Completeness:

• All identified sources have data (actual or estimated)
• Both reporting year and prior year covered
• Dates align with financial year

2. Accuracy:

• Units correct (kWh for electricity/gas, liters for fuel)
• No obvious errors (e.g., 10x expected consumption)
• Decimals in correct place

3. Consistency:

• All sites using same units
• Same accounting basis year-on-year
• Boundaries consistent with prior year

Common Data Issues to Check:

Issue 1: Cubic Meters vs. kWh for Gas

Gas bills show both cubic meters (m³) and kWh. You need kWh.

Correct: 52,450 kWh
Incorrect: 4,812 m³ (this is volume, not energy)

If you only have m³, convert using calorific value:
kWh = m³ × calorific value × volume correction
(Details on bill or use 10.5-11.0 kWh/m³ as approximation)

Issue 2: Imperial vs. Metric for Fuel

Ensure consistent units:

Petrol/diesel: Use liters (some older pumps show gallons)
1 UK gallon = 4.546 liters
Heating oil: Usually liters in UK

Issue 3: Gross vs. Net Electricity

Some bills show:

• Gross consumption (total used)
• Net consumption (after on-site generation)

For SECR: Use gross consumption (total used including any self-generated)

Day 11 Action Items:

• Review all collected data for completeness
• Check units are correct and consistent
• Verify figures seem reasonable (compare to prior year)
• Flag any anomalies for investigation
• Create "clean" dataset ready for calculations

Day 12: Download Current Emission Factors

SECR requires using UK Government GHG Conversion Factors for the reporting year.

Key Points:

1. Use Correct Year's Factors

• Factors are updated annually (usually published June)
• Use factors for the year your reporting period falls in
• If your FY is April 2024-March 2025, use 2024 factors (published June 2024)

2. Download the Full Dataset Visit: https://www.gov.uk/government/collections/government-conversion-factors-for-company-reporting

Download: Excel file with all conversion factors

3. Identify Factors You Need

Common Factors:

Electricity:

UK electricity - Location-based:
2024: 0.21233 kg CO2e per kWh (example—check current factors)
2023: 0.21869 kg CO2e per kWh

Note: Factors for England, Scotland, Wales, N Ireland if needed

Natural Gas:

Natural gas (100% mineral blend):
2024: 0.18316 kg CO2e per kWh

Transport:

Petrol (average car):
2024: 2.31020 kg CO2e per liter

Diesel (average car):
2024: 2.58561 kg CO2e per liter

Other Fuels: Check dataset for heating oil, LPG, coal, etc.

Day 12 Action Items:

• Download current and prior year conversion factor spreadsheets
• Identify exact factors needed for your energy types
• Record factors in your calculation spreadsheet
• Note source: "UK Government GHG Conversion Factors 2024"
• Save copies of factor spreadsheets for audit trail

Day 13: Calculate Emissions

Now apply emission factors to your energy data to calculate CO2e emissions.

Calculation Formula:

Energy Consumption (kWh or liters) × Emission Factor (kg CO2e per unit) = Emissions (kg CO2e)

Convert to tonnes: ÷ 1,000

Step-by-Step Example:

FACILITY: Head Office, London
FINANCIAL YEAR: 1 April 2024 - 31 March 2025

SCOPE 2 - PURCHASED ELECTRICITY:
Annual consumption: 245,600 kWh
Emission factor (2024): 0.21233 kg CO2e/kWh
Calculation: 245,600 × 0.21233 = 52,148 kg CO2e
In tonnes: 52,148 ÷ 1,000 = 52.1 tonnes CO2e

SCOPE 1 - NATURAL GAS:
Annual consumption: 128,400 kWh
Emission factor (2024): 0.18316 kg CO2e/kWh
Calculation: 128,400 × 0.18316 = 23,518 kg CO2e
In tonnes: 23,518 ÷ 1,000 = 23.5 tonnes CO2e

SCOPE 1 - COMPANY VEHICLES (Diesel):
Annual consumption: 8,450 liters
Emission factor (2024): 2.58561 kg CO2e/liter
Calculation: 8,450 × 2.58561 = 21,848 kg CO2e
In tonnes: 21,848 ÷ 1,000 = 21.8 tonnes CO2e

TOTAL EMISSIONS:
Scope 1: 23.5 + 21.8 = 45.3 tonnes CO2e
Scope 2: 52.1 tonnes CO2e
Total: 97.4 tonnes CO2e

Spreadsheet Setup:

Create columns for:

1. Energy source/facility
2. Consumption quantity
3. Unit (kWh, liters)
4. Emission factor
5. Factor source/year
6. Calculated emissions (kg CO2e)
7. Calculated emissions (tonnes CO2e)
8. Scope classification (1 or 2)

Day 13 Action Items:

• Build calculation spreadsheet with clear formulas
• Calculate emissions for each energy source
• Sum by Scope (Scope 1 total, Scope 2 total)
• Calculate total GHG emissions
• Repeat for prior year using prior year's factors
• Double-check all calculations

Day 14: Calculate Intensity Ratio

SECR requires at least one intensity metric showing emissions relative to a business activity measure.

Choosing Your Intensity Metric:

Option 1: Revenue-Based (Most Common)

• Tonnes CO2e per £million turnover
• Pros: Easy to calculate; data already in financial statements
• Best for: Most companies, especially services

Option 2: Employee-Based

• Tonnes CO2e per full-time equivalent (FTE)
• Pros: Suitable for people-centric businesses
• Best for: Professional services, offices

Option 3: Floor Space

• Tonnes CO2e per square meter
• Pros: Useful when activity scales with property
• Best for: Retail, property companies, office-based businesses

Option 4: Production-Based

• Tonnes CO2e per unit produced/sold
• Pros: Directly relates to output
• Best for: Manufacturing, distribution

Calculation Examples:

EXAMPLE 1: Revenue-Based

Total emissions: 97.4 tonnes CO2e
Annual turnover: £42.3 million

Intensity ratio: 97.4 ÷ 42.3 = 2.30 tonnes CO2e per £M turnover

EXAMPLE 2: Employee-Based

Total emissions: 97.4 tonnes CO2e
Average FTE employees: 285

Intensity ratio: 97.4 ÷ 285 = 0.34 tonnes CO2e per FTE

EXAMPLE 3: Floor Space

Total emissions: 97.4 tonnes CO2e
Total floor space: 8,450 square meters

Intensity ratio: 97.4 ÷ 8,450 = 0.012 tonnes CO2e per sq meter
(or 12 kg CO2e per sq meter)

Day 14 Action Items:

• Choose intensity metric most relevant to your business
• Gather denominator data (revenue, employees, floor space, etc.)
• Calculate intensity ratio for reporting year
• Calculate intensity ratio for prior year (same metric)
• Calculate percentage change year-on-year
• Document why you chose this metric

Week 2 Checkpoint:

By end of Week 2, you should have:

• ✓ Complete energy consumption data (or documented estimates)
• ✓ All emissions calculated using UK Government factors
• ✓ Intensity ratio calculated
• ✓ Prior year figures for comparison

If you're behind:

• Focus on getting electricity and gas calculations complete (usually 80%+ of total)
• Estimate any remaining minor sources
• Intensity ratio can be finalized in Week 3

Week 3: Reporting and Documentation (Days 15-21)

Day 15-16: Document Energy Efficiency Actions

SECR requires describing energy efficiency actions taken during the reporting year.

What Qualifies as an "Energy Efficiency Action"?

Any measure taken to reduce energy consumption or improve energy efficiency:

Physical Improvements:

• LED lighting installations
• Building insulation upgrades
• Heating system replacements or upgrades
• Window replacements (double/triple glazing)
• Installation of renewable energy (solar panels, heat pumps)
• Vehicle fleet upgrades (more efficient vehicles, EVs)

Operational Changes:

• Smart building management systems
• Heating/cooling temperature policies
• Equipment switch-off policies
• Flexible working/reduced office use

Behavioral Initiatives:

• Staff energy awareness campaigns
• Energy monitoring and reporting
• Travel reduction policies
• Supplier engagement on energy efficiency

What If You Took No Actions?

You must still include a statement. Options:

Option 1: Honest disclosure

"During the reporting year, no specific energy efficiency actions were undertaken. The company plans to review energy reduction opportunities in FY 2025/26."

Option 2: Acknowledge ongoing practices

"The company maintains existing energy management practices including standard office temperature controls and equipment maintenance schedules. No new initiatives were introduced during the reporting year."

Option 3: Highlight future plans

"While no new initiatives were implemented this year, the company is evaluating LED lighting upgrades and smart heating controls for implementation in the next financial year."

Best Practice Approach:

Even small actions are worth noting:

Example 1 - Office-Based Company:

"During FY 2024/25, the company undertook the following energy efficiency measures:

- Installed LED lighting in 40% of head office areas, reducing lighting energy consumption by an estimated 15% in affected areas
- Implemented remote work policy allowing 2 days per week working from home, reducing office energy use and commute-related emissions
- Upgraded to energy-efficient IT equipment during routine replacement cycle
- Continued monitoring of energy consumption through monthly utility bill reviews

The company will evaluate further efficiency improvements including completing LED installation across remaining areas and investigating smart building controls."

Example 2 - Manufacturing Company:

"The company implemented several energy efficiency measures during the year:

- Completed compressed air system leak survey and repairs, reducing compressor runtime
- Optimized production scheduling to reduce equipment idle time
- Installed variable speed drives on three main production line motors
- Upgraded warehouse heating system from oil to natural gas, improving efficiency and reducing emissions intensity

These measures contributed to a 7% reduction in energy consumption per unit produced."

Day 15-16 Action Items:

• Review capital expenditure records for energy-related investments
• Speak with facilities team about operational changes
• Check if any efficiency projects were completed
• Draft energy efficiency actions section (3-5 bullet points minimum)
• Quantify impacts where possible (e.g., "estimated 10% reduction")
• Note future plans to demonstrate ongoing commitment

Day 17: Draft Methodology Statement

SECR requires explaining the methodological approach used.

What to Include:

1. Reporting Standard State which framework you followed:

"The company has reported emissions in accordance with the Streamlined Energy and Carbon Reporting (SECR) requirements. Emission calculations follow the GHG Protocol Corporate Accounting and Reporting Standard."

2. Organizational Boundary Explain what's included:

Single company:

"The report covers all UK operations of [Company Name] Ltd under financial control."

Group company:

"The report covers [Parent Company] and all UK operations of its fully consolidated subsidiaries, consistent with the financial reporting boundary used in our consolidated accounts."

3. Operational Boundary Specify emission scopes:

"The report includes Scope 1 emissions (direct emissions from company-owned sources including natural gas consumption and company vehicles) and Scope 2 emissions (indirect emissions from purchased electricity) from UK operations."

4. Emission Factors Reference the source:

"Emissions have been calculated using UK Government GHG Conversion Factors for Company Reporting 2024, published by DEFRA."

5. Data Quality Note any estimation:

If minimal estimation:

"Emissions calculations are based on actual meter readings and invoices from utility suppliers."

If some estimation required:

"Emissions calculations are based primarily on actual consumption data from supplier invoices. Where data was unavailable, consumption has been estimated using [describe method, e.g., 'prior year monthly averages' or 'comparable facility data'], affecting approximately [X%] of total consumption."

Complete Methodology Example:

METHODOLOGY

This report has been prepared in accordance with the Companies Act 2006 (Strategic Report and Directors' Report) Regulations 2013 and the Streamlined Energy and Carbon Reporting (SECR) requirements, as amended by The Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018.

Organizational Boundary: The report covers all UK operations of Acme Limited under financial control, including our London head office, Birmingham warehouse, and company vehicle fleet.

Emission Scopes: We report Scope 1 emissions (direct emissions from natural gas consumption and company-owned vehicles) and Scope 2 emissions (indirect emissions from purchased electricity consumed at our UK facilities).

Methodology: Emissions have been calculated using the GHG Protocol Corporate Standard methodology. Energy consumption data has been obtained from utility supplier bills and fuel purchase records covering our financial year from 1 April 2024 to 31 March 2025. Greenhouse gas emissions have been calculated by applying UK Government GHG Conversion Factors for Company Reporting 2024 to our consumption data.

Data Quality: Calculations are based on actual meter readings and supplier invoices for all electricity and gas consumption. Company vehicle emissions are based on fuel card transaction records for the reporting period. No significant estimations were required.

Day 17 Action Items:

• Draft methodology statement covering all required elements
• Ensure consistency with actual approach used
• Note any limitations or assumptions
• Keep it concise (typically 1-2 paragraphs sufficient)
• Have technical team member review for accuracy

Day 18: Compile Complete SECR Disclosure

Bring together all elements into the final disclosure for your directors' report.

SECR Disclosure Structure:

STREAMLINED ENERGY AND CARBON REPORTING

UK Energy Consumption and Greenhouse Gas Emissions

[Opening paragraph setting context]

We report the following energy consumption and emissions for our UK operations:

[TABLE FORMAT:]

                                    FY 2024/25    FY 2023/24    Change
Energy Consumption (kWh)            XXX,XXX       XXX,XXX       +/-X%
Scope 1 Emissions (tonnes CO2e)     XX.X          XX.X          +/-X%
Scope 2 Emissions (tonnes CO2e)     XX.X          XX.X          +/-X%
Total Emissions (tonnes CO2e)       XX.X          XX.X          +/-X%

Intensity Ratio:
[Metric description]                X.XX          X.XX          +/-X%

Energy Efficiency Actions

[Bullet points of actions taken]

Methodology

[Methodology statement from Day 17]

Complete Example:

STREAMLINED ENERGY AND CARBON REPORTING

As a large unquoted company, Acme Limited is required to report on energy consumption and greenhouse gas emissions under the Streamlined Energy and Carbon Reporting framework.

UK Energy Consumption and Greenhouse Gas Emissions

We report the following energy consumption and emissions for our UK operations for the financial year ended 31 March 2025:

                                        2024/25     2023/24     Change
UK Energy Consumption (kWh)             1,247,850   1,308,420   -4.6%
Scope 1 Emissions (tonnes CO2e)         45.3        48.1        -5.8%
Scope 2 Emissions (tonnes CO2e)         52.1        57.3        -9.1%
Total GHG Emissions (tonnes CO2e)       97.4        105.4       -7.6%

Intensity Ratio:
tCO2e per £million turnover             2.30        2.61        -11.9%

The decrease in absolute emissions of 7.6% and improvement in emissions intensity reflects both reduced energy consumption following efficiency improvements and favorable changes in the UK electricity grid emission factor.

Energy Efficiency Actions

During the year, the company implemented several energy efficiency measures:

• Completed installation of LED lighting across 40% of head office space, reducing lighting energy consumption by an estimated 15% in upgraded areas
• Introduced flexible working policy allowing remote work two days per week, reducing overall office energy consumption
• Upgraded 30% of company vehicle fleet to more fuel-efficient models during scheduled replacement cycle
• Implemented automated heating controls in Birmingham warehouse, optimizing operational hours
• Continued monthly monitoring of energy consumption to identify further efficiency opportunities

These measures contributed to the year-on-year reduction in energy consumption and emissions.

Methodology

This report has been prepared in accordance with the SECR requirements under The Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. The report covers all UK operations of Acme Limited under financial control. We report Scope 1 emissions (direct emissions from natural gas consumption and company-owned vehicles) and Scope 2 emissions (indirect emissions from purchased electricity).

Emissions have been calculated using the GHG Protocol Corporate Standard methodology. Energy consumption data has been obtained from utility supplier bills and fuel purchase records for the financial year 1 April 2024 to 31 March 2025. Greenhouse gas emissions have been calculated by applying UK Government GHG Conversion Factors for Company Reporting 2024 to our consumption data.

Day 18 Action Items:

• Compile all elements into single disclosure document
• Format professionally for directors' report
• Include data table with clear formatting
• Proofread for errors
• Check all numbers match your calculations
• Save as draft for review

Day 19: Internal Review and Quality Assurance

Before presenting to directors, conduct thorough internal review.

Quality Assurance Checklist:

Calculation Accuracy:

• All arithmetic checked (ideally by second person)
• Formulas in spreadsheet verified
• Units consistent throughout
• Prior year figures match last year's report (if applicable)
• Percentage changes calculated correctly

Data Completeness:

• All identified energy sources included
• Full financial year covered
• Both current and prior year present
• No obvious missing sources

Regulatory Compliance:

• UK Government conversion factors used (correct year)
• Scope 1 and Scope 2 clearly separated
• At least one intensity metric included
• Energy efficiency actions described
• Methodology statement included
• Year-on-year comparison provided

Disclosure Quality:

• Clear, professional language
• No ambiguous statements
• Consistent terminology throughout
• Appropriate level of detail
• Formatting suitable for directors' report

Supporting Documentation:

• Calculation spreadsheet complete and documented
• Source data referenced (bill numbers, dates)
• Emission factors documented with source
• Assumptions and estimates clearly noted
• Audit trail for all figures

Common Errors to Check:

Error 1: Wrong conversion factor year Ensure you're using factors for the correct year, not latest/outdated

Error 2: Mixing units All electricity/gas in kWh; all fuel in liters (not mixed with gallons, m³, etc.)

Error 3: Scope misclassification Natural gas is Scope 1 (not Scope 2); electricity is Scope 2 (not Scope 1)

Error 4: Double counting If you report group figures, ensure subsidiaries don't also report same emissions separately

Error 5: Intensity calculation error Check formula: total emissions ÷ business metric (not the reverse)

Day 19 Action Items:

• Complete full quality assurance checklist
• Have colleague review calculations independently
• Verify all figures trace back to source data
• Correct any identified errors
• Update draft disclosure if changes needed
• Prepare list of any residual uncertainties to flag

Day 20: Prepare Board Pack and Supporting Materials

Directors must approve the SECR disclosure as part of the directors' report.

Materials to Prepare:

1. Executive Summary (1 page)

Brief overview for board review:

• Summary of SECR obligation and deadline
• Key figures (total emissions, intensity, year-on-year change)
• Notable items or decisions needed
• Confirmation of compliance

2. Draft SECR Disclosure

The actual text to be included in directors' report (from Day 18)

3. Supporting Calculation Summary

Simplified breakdown showing:

• Energy sources and consumption
• Emission calculations by scope
• Intensity ratio calculation
• Comparison with prior year

4. Methodology and Assumptions Document

Details of approach taken:

• Boundary definition and rationale
• Data sources and quality
• Any estimations and justification
• Emission factors used

5. Recommendations

Any items needing board input:

• Approval of proposed disclosure
• Choice of intensity metric (if multiple options considered)
• Future energy efficiency commitments
• Budget for next year's reporting

Example Executive Summary:

BOARD MEMORANDUM: SECR COMPLIANCE FY 2024/25

PURPOSE
To seek board approval for the company's Streamlined Energy and Carbon Reporting (SECR) disclosure to be included in the Directors' Report for FY 2024/25.

BACKGROUND
As a large unquoted company, Acme Ltd is required under The Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 to disclose energy consumption and greenhouse gas emissions in our Directors' Report.

KEY FIGURES
                                2024/25     2023/24     Change
Total Energy (kWh)              1,247,850   1,308,420   -4.6%
Total Emissions (tCO2e)         97.4        105.4       -7.6%
Intensity (tCO2e per £M)        2.30        2.61        -11.9%

HIGHLIGHTS
• Emissions reduced 7.6% year-on-year driven by energy efficiency measures and reduced electricity emission factors
• Emissions intensity improved 11.9%, demonstrating efficiency gains exceeded business growth
• LED lighting and flexible working policies contributed to reductions

COMPLIANCE
The disclosure has been prepared in accordance with SECR requirements using UK Government GHG Conversion Factors 2024 and follows GHG Protocol methodology. All calculations have been reviewed and verified.

RECOMMENDATION
The board is asked to:
1. Approve the attached SECR disclosure for inclusion in the Directors' Report
2. Note the company's improved environmental performance
3. Support continued energy efficiency investments

Supporting documents attached:
- Draft SECR disclosure text
- Detailed calculation summary
- Methodology and assumptions note

Day 20 Action Items:

• Prepare executive summary for board
• Compile complete board pack
• Arrange board meeting or circulation
• Brief CEO/CFO in advance if needed
• Prepare to answer board questions
• Set realistic timeline for approval

Day 21: Board Approval

Present SECR disclosure to board for approval.

Board Meeting Approach:

Advance Circulation:

• Send board pack 3-5 days before meeting
• Allow directors time to review and raise questions

At Meeting:

• Brief presentation (5-10 minutes) covering:
  • SECR obligation recap
  • Key figures and trends
  • Compliance approach
  • Request for approval

Typical Board Questions:

Q: "How do our emissions compare to similar companies?" A: [If you've researched benchmarks, provide context. Otherwise:] "As this is our first report, we will establish benchmarks against industry peers in future years to contextualize our performance."

Q: "What will it cost to reduce emissions further?" A: "We are evaluating options for further reductions. The measures implemented this year [LED lighting, etc.] had costs of approximately £X with payback period of Y years through energy savings."

Q: "Do we need to report this publicly beyond Companies House?" A: "The disclosure will be publicly available via our Directors' Report filed with Companies House. Some companies also voluntarily publish on their website. We recommend [your recommendation]."

Q: "What happens if we don't comply?" A: "Non-compliance means our Directors' Report would be deficient under Companies Act requirements, potentially leading to civil penalties. As a large company, we have a legal obligation to include this disclosure."

Q: "Could we improve our intensity ratio by changing the metric?" A: "We selected [chosen metric] because [rationale]. While alternative metrics are permissible, consistency year-on-year is important for meaningful comparison. We recommend maintaining this metric going forward."

Approval Outcomes:

Approved as Presented:

• No changes needed
• Proceed to finalize directors' report

Approved with Minor Changes:

• Note changes requested
• Revise disclosure accordingly
• Circulate updated version for confirmation

Deferred:

• Address board concerns
• Revise and re-present
• Ensure sufficient time remains before filing deadline

Day 21 Action Items:

• Present to board (or circulate for written approval)
• Address any questions raised
• Obtain formal board approval
• Document approval in board minutes
• Note any requested changes
• Update disclosure if changes required

Week 3 Checkpoint:

By end of Week 3, you should have:

• ✓ Energy efficiency actions documented
• ✓ Methodology statement drafted
• ✓ Complete SECR disclosure compiled
• ✓ Internal quality assurance completed
• ✓ Board materials prepared
• ✓ Board approval obtained

If you're behind:

• Focus on getting board approval (this is critical path)
• Disclosure text can be refined after approval if needed
• Ensure adequate time for Week 4 finalization

Week 4: Finalization and Filing (Days 22-30)

Day 22-24: Finalize Directors' Report

Integrate your approved SECR disclosure into the complete directors' report.

Integration Points:

1. Determine Placement

SECR disclosure typically appears in directors' report as:

• Dedicated section: "Streamlined Energy and Carbon Reporting"
• Within: "Environmental and Social Matters" section
• After: Business review and principal activities
• Before: Directors' responsibilities statement

2. Formatting

Ensure consistent:

• Font and styling with rest of report
• Table formatting
• Heading hierarchy
• Page layout

3. Cross-References

Consider linking to:

• Related sections (e.g., principal risks if climate mentioned)
• Financial performance (especially if discussing intensity ratios)
• Corporate governance statement

4. Additional Voluntary Disclosures (Optional)

Some companies enhance SECR with:

• Commentary on climate risks and opportunities
• Longer-term emission reduction targets
• Broader sustainability initiatives
• Scope 3 emissions (if calculated voluntarily)
• CDP or other voluntary framework reporting

Only include voluntary additions if your company is committed to enhanced disclosure.

Day 22-24 Action Items:

• Insert approved SECR disclosure into directors' report
• Ensure formatting consistency
• Number pages correctly
• Check table of contents includes SECR section
• Verify cross-references work
• Final proofread of entire report

Day 25: Archive Supporting Documentation

Maintain comprehensive records to support your SECR disclosure.

What to Archive:

1. Source Data Files

• All utility bills (PDF copies)
• Fuel purchase records
• Supplier statements
• Meter readings
• Any other consumption evidence

2. Calculation Workbooks

• Master calculation spreadsheet
• All formulas preserved
• Clear documentation of approach
• Version control (final version clearly marked)

3. Emission Factors

• Downloaded UK Government conversion factor spreadsheets
• Specific factors used highlighted
• Version/year clearly noted

4. Methodology Documentation

• Organizational boundary definition
• Data collection protocols
• Estimation methodologies
• Quality assurance checks completed

5. Approval Records

• Board minutes showing approval
• Executive summary presented
• Any board questions and responses

6. Correspondence

• Data requests sent
• Supplier responses
• Internal communications

Storage Requirements:

Retention Period: Minimum 6 years (in line with Companies Act requirements)

Access Control: Secure storage with appropriate access restrictions

Organization: Clearly labeled by financial year

Format: Both digital and (where appropriate) hard copy

Recommended Folder Structure:

SECR FY 2024-25/
├── 01_Source_Data/
│   ├── Electricity_Bills/
│   ├── Gas_Bills/
│   ├── Fuel_Records/
│   └── Other_Energy_Sources/
├── 02_Calculations/
│   ├── Master_Calculation_Spreadsheet_FINAL.xlsx
│   ├── Prior_Year_Comparison.xlsx
│   └── Intensity_Ratio_Calculation.xlsx
├── 03_Emission_Factors/
│   ├── UK_Govt_Factors_2024.xlsx
│   └── UK_Govt_Factors_2023.xlsx
├── 04_Methodology/
│   ├── Boundary_Definition.pdf
│   ├── Data_Collection_Protocol.pdf
│   └── QA_Checklist_Completed.pdf
├── 05_Approval/
│   ├── Board_Pack.pdf
│   ├── Board_Minutes_Extract.pdf
│   └── Approved_Disclosure.docx
└── 06_Final_Report/
    └── Directors_Report_FY2024-25_FINAL.pdf

Day 25 Action Items:

• Create organized filing structure
• Collect all supporting documents
• Ensure all files clearly labeled
• Save final versions of all calculations
• Archive in secure, accessible location
• Document archive location for next year's team

Day 26-27: Internal Communication

Inform relevant stakeholders about your SECR report.

Internal Audiences:

1. Senior Leadership

• Share final report
• Highlight key metrics and trends
• Discuss future improvement opportunities

2. Facilities/Operations Teams

• Acknowledge their contribution
• Share results showing impact of efficiency measures
• Discuss priorities for next year

3. Finance Team

• Provide copies of supporting documentation
• Brief on filing timeline
• Note any follow-up items

4. Broader Staff (Optional)

• Consider internal announcement
• Explain company's environmental performance
• Encourage continued energy consciousness

Sample Internal Communication:

SUBJECT: Acme Ltd's FY 2024/25 Environmental Performance

I'm pleased to share that we have completed our Streamlined Energy and Carbon Reporting (SECR) disclosure for FY 2024/25.

Key Highlights:
• Total emissions decreased 7.6% year-on-year
• Emissions intensity improved 11.9%
• Energy efficiency measures delivered measurable results

This positive performance reflects the collective efforts of our facilities teams and all staff who contributed to energy-saving initiatives throughout the year.

Our SECR report will be included in our Directors' Report filed with Companies House and publicly available.

Thank you to everyone who contributed to this improved environmental performance. We'll continue to identify and implement further efficiency measures in the coming year.

[Name]
Chief Financial Officer

Day 26-27 Action Items:

• Draft internal communications
• Share with senior leadership
• Inform operations/facilities teams
• Consider broader staff communication
• Address any questions raised

Day 28: External Communication (If Applicable)

Decide whether to communicate SECR performance beyond statutory filing.

Optional External Communication Channels:

1. Company Website

• Publish SECR section of directors' report
• Create dedicated sustainability/environment page
• Include PDF of full directors' report

2. Press Release (if newsworthy)

• Significant emissions reduction
• Major efficiency investment
• Industry-leading performance

3. Stakeholder Letters

• Key customers asking about environmental performance
• Investors interested in ESG factors
• Industry associations

4. Social Media

• LinkedIn post highlighting performance
• Keep factual and professional
• Link to full disclosure

When to Communicate Externally:

Consider external communication if:

• Strong performance improvement to showcase
• Customers/suppliers requesting environmental data
• Recruitment/employer branding opportunity
• Building corporate reputation on sustainability

Skip external communication if:

• This is standard compliance only
• No particular stakeholder interest
• Company prefers low profile
• Limited resources for managing inquiries

Day 28 Action Items:

• Decide if external communication appropriate
• Draft any planned communications
• Obtain necessary approvals
• Coordinate with marketing/communications team
• Schedule publication (typically after Companies House filing)

Day 29: Final Pre-Filing Checks

Before submitting your directors' report to Companies House, conduct final verification.

Pre-Filing Checklist:

SECR Content:

• UK energy consumption (kWh) disclosed
• Scope 1 emissions (tonnes CO2e) disclosed
• Scope 2 emissions (tonnes CO2e) disclosed
• Total emissions calculated correctly
• At least one intensity metric included
• Prior year comparatives provided
• Energy efficiency actions described
• Methodology statement included

Data Accuracy:

• All figures match approved disclosure
• Calculations verified
• Units clearly stated
• No transcription errors from approval to final report

Formatting:

• SECR section clearly headed
• Tables formatted consistently
• Numbers aligned and easy to read
• Font/styling consistent with report

Legal Requirements:

• Disclosure in directors' report (correct location)
• Board approval obtained and minuted
• Report signed by director
• All Companies Act requirements met

Filing Package:

• Complete annual accounts prepared
• Directors' report finalized (including SECR)
• All signatures obtained
• Filing deadline verified
• Companies House login credentials ready

Day 29 Action Items:

• Complete final pre-filing checklist
• Resolve any identified issues
• Obtain final director signature(s)
• Prepare filing package
• Confirm filing deadline
• Brief person responsible for Companies House submission

Day 30: File with Companies House

Submit your annual accounts and directors' report (including SECR disclosure) to Companies House.

Filing Methods:

1. Software Filing

• Using Companies House-compatible accounting software
• Most common method
• Immediate confirmation

2. WebFiling Service

• Free online service from Companies House
• Requires authentication code
• Suitable for smaller companies

3. Third-Party Agent

• Accountant or company secretary service
• Often included in annual compliance package
• Handles filing on your behalf

Post-Filing Steps:

1. Confirmation

• Check for Companies House acceptance email
• Verify documents appear on public record
• Note actual filing date

2. Certificate

• Download/save confirmation
• File with supporting documentation

3. Update Records

• Note successful filing in company records
• Mark SECR compliance complete for FY 2024/25
• Archive all final documents

4. Next Year Planning

• Schedule next year's SECR reporting timeline
• Note lessons learned
• Identify data collection improvements
• Consider efficiency improvements based on performance

Day 30 Action Items:

• Submit accounts and directors' report to Companies House
• Verify successful filing
• Save confirmation documentation
• Update internal compliance register
• Brief team on lessons learned
• Schedule planning for next year's report

Week 4 Checkpoint:

By end of Week 4, you should have:

• ✓ Final directors' report with SECR disclosure complete
• ✓ All supporting documentation archived
• ✓ Internal and external communications completed
• ✓ Report filed with Companies House
• ✓ Confirmation of successful filing received

Beyond Day 30: Continuous Improvement

Your first SECR report is complete, but environmental reporting is an ongoing commitment.

Lessons Learned Review

Within 2 weeks of filing, conduct a team debrief:

What Went Well:

• Which data sources were easily accessible?
• Which calculations were straightforward?
• What processes worked efficiently?

What Was Challenging:

• Where did data gaps occur?
• Which stakeholders were hard to engage?
• What took longer than expected?

Improvements for Next Year:

• Better data collection protocols
• Earlier start date
• Improved tools or systems
• Additional resources needed

Setting Up for Next Year

Immediate Actions (Within 1 Month):

• Document data sources for next year
• Establish quarterly energy data collection
• Set up automated supplier data downloads
• Create calendar reminders for next year's deadline

Ongoing Actions:

• Monitor energy consumption quarterly
• Track energy efficiency measures implemented
• Maintain invoice filing system
• Keep emission factor updates bookmarked

Strategic Actions:

• Evaluate energy reduction opportunities
• Consider carbon reduction targets
• Assess if automated reporting tools justified
• Review if additional voluntary disclosures appropriate

Consider Automation for Future Years

Now that you've completed your first report manually, you understand the full process. Many companies find significant efficiency gains by automating:

Comply Carbon's Platform Automates:

• Multi-source data collection via simple upload
• Automatic emission calculations using latest factors
• Intensity ratio calculation
• Year-on-year comparison
• Board-ready report generation
• Complete audit trail

Time Saving: 10 minutes vs. 30+ days

Cost Saving: £1,999 vs. £15k-25k consultant fees

Accuracy: Built-in UK Government factors, automated calculations eliminate manual errors

Consider whether automation makes sense for your organization based on:

• Time spent on first report
• Complexity of your energy sources
• Number of sites/entities
• Value of staff time redirected to strategic work

Conclusion: You've Completed Your First SECR Report

Congratulations on completing your first SECR compliance filing. You've successfully:

✓ Defined your reporting boundary and identified all emission sources ✓ Collected comprehensive energy data across your UK operations ✓ Calculated accurate emissions using UK Government methodology ✓ Produced a compliant disclosure meeting all statutory requirements ✓ Obtained board approval and filed with Companies House ✓ Established a foundation for ongoing environmental reporting

Key Takeaways

Start Early: 30 days is achievable but tight. Next year, start 60 days before filing deadline for less pressure.

Documentation Matters: Comprehensive supporting records protect against queries and ease next year's process.

Consistency Is Critical: Maintain the same boundary and methodology year-on-year for meaningful comparison.

Energy Efficiency Pays: Many measures reduce both emissions and energy costs, delivering financial and environmental benefits.

It Gets Easier: First year is hardest due to establishing processes. Subsequent years follow the established framework.

Resources for Ongoing Compliance

Official Guidance:

• Defra Environmental Reporting Guidelines
• UK Government GHG Conversion Factors (updated annually)
• Companies House Filing Guidance

Comply Carbon Resources:

• Full SECR Guide - comprehensive regulatory overview
• Sample Report - see complete examples
• Compliance Check - verify your obligations
• Automated Platform - streamline future reporting

Final Checklist for First-Time Filers

Before closing this project, verify:

• Directors' report filed with Companies House including SECR disclosure
• All supporting documentation archived for 6+ years
• Board approval documented in minutes
• Team debriefed on lessons learned
• Next year's reporting timeline scheduled
• Ongoing energy monitoring process established
• Stakeholders informed of results
• Improvements identified for next year

You've successfully navigated one of the more technical compliance requirements UK businesses face. The framework you've established this year will serve as the foundation for streamlined, efficient reporting in all future years.

Well done on achieving SECR compliance.

This 30-day action plan reflects SECR requirements as of January 2026. Always verify current requirements through official government guidance and consider professional advice for complex situations.