SECR Fines and Penalties: What Happens If You Don’t Report Your Emissions

SECR Is Not Optional for Qualifying Companies

The Streamlined Energy and Carbon Reporting (SECR) framework has been mandatory since April 2019 for UK companies that meet certain size thresholds. If your business qualifies, you are legally required to include energy and carbon information in your annual directors’ report. And unlike many environmental regulations, SECR has teeth.

SECR applies to all UK incorporated companies that meet at least two of these three criteria:

• Annual turnover of £36 million or more
• Balance sheet total of £18 million or more
• 250 or more employees

Quoted companies (those listed on the London Stock Exchange, AIM, or an EU-regulated market) have additional obligations regardless of size.

The Penalties Are Real

Non-compliance with SECR reporting requirements is a breach of the Companies Act 2006. The consequences include:

• Criminal offence — directors who approve a report that does not include the required SECR disclosures commit a criminal offence under section 415 of the Companies Act. This applies to every director who approved the report
• Fines — the penalty for failing to include required information in the directors’ report is an unlimited fine. There is no cap. Companies House can refer cases to the Crown Prosecution Service
• Personal liability — directors can be held personally liable. “The company didn’t tell me” is not a defence if you signed off the annual report
• Filing rejection — Companies House is increasingly scrutinising annual reports for SECR compliance. Incomplete reports may be queried or rejected

The Reputational Cost

Beyond the legal penalties, failing to report carries significant reputational risk. Annual reports are public documents. Investors, clients, and competitors can see whether you have complied. In an era where ESG performance is scrutinised by institutional investors, failing to meet a basic reporting requirement sends a damaging signal.

Several activist investor groups now systematically check SECR compliance across publicly listed companies. Non-compliant companies are named in reports that receive media coverage. For smaller companies, the risk is less public but no less real — corporate clients increasingly check suppliers’ compliance as part of due diligence.

What SECR Requires You to Report

The required disclosures depend on your company type:

For large unquoted companies (meeting the size thresholds above):

• UK energy consumption (electricity, gas, transport fuel)
• Associated greenhouse gas emissions (at minimum, Scope 1 and 2)
• At least one emissions intensity ratio (e.g., tCO2e per employee or per £m revenue)
• A narrative description of energy efficiency actions taken
• Prior year comparatives (from the second reporting year onwards)

For quoted companies, the requirements are more extensive and include Scope 3 emissions and global (not just UK) data.

The Overlap with PPN 006

If you already need a carbon reduction plan for PPN 006, you are likely already collecting the data needed for SECR. But the two requirements are distinct. A CRP is a forward-looking strategy document. SECR is a backward-looking reporting obligation in your annual accounts.

The smart approach is to do both at the same time. When you calculate your footprint for your CRP, the same data feeds into your SECR disclosure. A Carbonhogs plan gives you the numbers you need for both — calculated using DEFRA 2024 factors, broken down by scope, with intensity ratios included.

Don’t Wait for an Enforcement Notice

Companies House enforcement of SECR has increased significantly since 2023. The days of filing without the required disclosures and hoping nobody notices are over. If your business meets the SECR thresholds, getting your energy and carbon data in order is not just good practice — it is a legal obligation with real consequences.