New SECR Reporting Guidelines

 

The relevant law is the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, and it will apply to financial years starting on or after 1 April 2019. Companies quoted on a stock exchange already have carbon reporting obligations, but this new legislation extends the requirements for quoted companies and, crucially, imposes new carbon reporting requirements on other types of company: unquoted large companies and LLPs.

Who needs to comply:

  • Organisations that need to participate are:

    1. UK Quoted Company (MGHG)

                     OR

    2. UK listed company with two of the below:

      • Number of employees > 250

      • Turnover > £36m

      • Balance sheet total > £18m

  • SECR affects most organisations currently covered by ESOS legislation. However, most ESOS participants do not currently participate in CRC and so SECR will impose annual energy and carbon reporting on a large number of businesses who until now have only been involved in the four-yearly cycle of ESOS.

  • UK Quoted companies will be required to report Global emissions and Global energy use, where practical.

 

What is SECR?

  • SECR is in effect, an extension of Mandatory Greenhouse Gas (MGHG) reporting. It is an annual reporting requirement for organisations to disclose their energy consumption and carbon emissions relating to their use of electricity, gas and transport.

  • The information above is subject to change since a final SECR Guidance document is expected to be published by the UK government in January 2019.

Quoted companies

If your company is quoted, you already have to disclose:

  • Annual greenhouse gas (GHG) emissions from activities for which your company is responsible.

  • At least one intensity ratio, for example, tonnes of CO2 per kWh for the energy sector, or tonnes of CO2 per square metre for the property sector.

  • The previous year’s figures for comparison purposes (except of course in the first year of reporting).

  • How you gathered data and did your calculations.

Under the new regulations, you will also have to disclose:

  • The total energy consumption that you’ve used as the basis for your calculation of GHG emissions.

  • What proportion of both energy consumption and GHG emissions is linked to the UK rather than abroad.

  • What you’ve done in the past financial year to improve the energy efficiency of the business.

Large unquoted companies and large limited liability partnerships (LLPs)

If your company is already legally required to prepare an annual Directors’ Report and qualifies as “large” under the Companies Act 2006, the forthcoming legislation now requires you to prepare a new kind of document called an Energy and Carbon Report. The same goes for any LLP that counts as large.

Your Energy and Carbon Report should include:

  • UK energy use, including the electricity and gas you’ve purchased in the relevant financial year and energy use from transport. (See our blog post for guidance on how to gather transport energy consumption data for your business.)

  • The GHG emissions arising from your UK energy use.

  • At least one intensity ratio

  • Last year’s figures (except for the first year of reporting).

  • What steps you’ve taken to improve energy efficiency in the relevant year.

  • How you gathered your company’s data and worked out the totals.

Exceptions

Some companies are exempt from the new rules.

If your organisation qualifies as a “low energy user” by consuming 40MWh or less during the relevant financial year, you are not required to provide all this detailed information. But you still need to make it clear to Companies House why you’re exempt, either in your Energy and Carbon Report or your Directors’ Report. 

You may also apply for an exemption on the grounds that your company’s energy and carbon information is commercially sensitive, but this only applies in truly exceptional circumstances.

It is also possible to leave out certain energy and carbon information from your company’s report if it is truly impractical to obtain, but you’ll need to explain what you’re leaving out and why it isn’t possible to include it.

Further advice

The Government’s Environmental Reporting Guidelines contain official guidance on SECR. There is also information on voluntary reporting, for organisations who aren’t yet legally obliged to report their carbon emissions but see it as best practice.

 

Download the government guide

 

 

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