A practical guide to SECR for UK businesses

The core thesis

For most mid‑sized UK businesses the biggest obstacle to a compliant SECR submission is not the regulation itself but the lack of a disciplined data‑collection process. By treating SECR as a routine part of energy management rather than a one‑off exercise, you can meet the legal requirement, demonstrate genuine carbon reduction, and create a foundation for future efficiency projects.

Who needs to report

SECR applies to any UK organisation that meets either of two thresholds in the accounting period:

• Annual turnover of £85 million or more, or
• Total annual purchased electricity of 100 MWh (or gas consumption of 25 MWh). Mid‑size firms typically fall into the turnover bracket, but a manufacturing plant with high electricity use may be captured by the energy‑use test alone. The reporting entity is the same legal entity that files the company accounts – usually the parent company.

Preparing the evidence trail

A robust evidence trail is the single most important defence against a potential audit by the Environment Agency or HMRC. The trail must show how you derived the figures you report and that they are consistent with the GHG Protocol Scope 1 and Scope 2 methodology.

Data sources

1. Utility bills – Collect all electricity and gas invoices for the reporting year. Ensure they are itemised to the correct cost centre.
2. Meter readings – Where bills are estimated, supplement with actual half‑hourly (HH) data from the supplier or from your own sub‑metering system.
3. Fuel invoices – Include diesel, LPG, or other liquid fuels used in generators or fleet vehicles.
4. On‑site generation records – Export data from solar PV, wind or CHP installations, typically available via the installer’s portal.
5. Energy‑efficiency projects – Keep commissioning reports for voltage optimisation, LED retrofits, or demand‑response schemes.

Calculations

Scope	What to include	Typical conversion factor
1	Direct emissions from owned or controlled sources (fuel‑combustion, on‑site generation)	CO₂e = Fuel × EF (kg CO₂e/kWh) – use UK Government conversion tables
2	Indirect emissions from purchased electricity and heat	CO₂e = kWh × Grid emission factor (currently 0.233 kg CO₂e/kWh for electricity)

All calculations should be performed in a spreadsheet that logs the source of each figure (e.g., "Invoice #1234 – Jan 2025"). This audit‑ready approach mirrors the GHG Protocol’s requirement for transparent, traceable data.

Aligning with the GHG Protocol

The GHG Protocol defines Scope 1 as direct emissions and Scope 2 as indirect emissions from purchased energy. SECR asks for the same two scopes, but presents them as:

• Total energy consumption (kWh) – broken down by fuel type.
• Associated emissions (tCO₂e) – again split into Scope 1 and Scope 2. Map each line item from your evidence trail to the appropriate scope. For example, diesel used in a company van is Scope 1, while the electricity that powers your office lighting is Scope 2. Using the same conversion factors as the GHG Protocol ensures consistency and reduces the risk of audit findings.

Common audit findings and how to avoid them

Finding	Why it occurs	Prevention
Missing half‑hourly data for electricity	Reliance on estimated bills	Request HH data from the supplier or install a simple sub‑meter.
Inconsistent fuel conversion factors	Manual entry errors	Use a master table of UK Government factors and lock cells in the spreadsheet.
Scope 1 and Scope 2 double‑counting	Including on‑site generation in both scopes	Report on‑site generation only in Scope 1 (as a negative emission) and exclude it from Scope 2 electricity totals.
No evidence of energy‑efficiency measures	Projects not documented	Keep commissioning certificates and, where possible, before‑and‑after meter data.

Addressing these points during data collection eliminates most of the issues that trigger a post‑submission audit.

Submitting your SECR report

1. Complete the SECR template – Available on the Companies House website. Fill in the energy‑consumption and emissions tables.
2. Attach the evidence – While the template does not require you to upload supporting documents, retain them for at least six years and be ready to provide them on request.
3. Sign off – The senior director (often the Finance Director) must sign the report, confirming accuracy.
4. File with annual accounts – SECR is filed as an annex to the company’s statutory accounts, usually by the same deadline (typically 9 months after year‑end).

Using TUS services to streamline the process

TUS offers a suite of tools that can reduce the manual effort described above:

• Yolk portal – A free, cloud‑based dashboard that aggregates utility bills, HH data and on‑site generation records. Current users achieve an average 27 % saving when switching suppliers through the portal, providing a ready‑made evidence base for SECR.
• Flex management – With 150 + GWh under active demand‑response management, TUS can supply half‑hourly consumption profiles that meet audit standards without additional metering.
• Voltage optimisation – Projects deliver 5‑15 % energy savings with a typical 2‑3 year payback. The commissioning reports generated by TUS are accepted as audit‑ready evidence of efficiency measures.
• Supplier panel – Our 30 + supplier panel enables rapid contract benchmarking, helping you demonstrate that you have taken “reasonable steps” to reduce costs – a factor considered by Ofgem when reviewing SECR compliance. By integrating these services, you can close the evidence loop in weeks rather than months, and you gain a baseline for future carbon‑reduction initiatives.

Bottom line

SECR is a statutory requirement, not a one‑off compliance exercise. Treat it as the first step in a continuous energy‑management cycle: collect reliable data, align it with the GHG Protocol, and retain a clear audit trail. Leveraging TUS’s free Yolk portal and proven flex‑management data can cut the administrative burden and improve the credibility of your submission. With a disciplined approach, your SECR report becomes a trusted foundation for cost savings, carbon reduction and strategic decision‑making.