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UK business carbon, energy and waste compliance (SECR, ESOS, EPR)

UK government guidance on corporate environmental compliance: Streamlined Energy and Carbon Reporting (SECR) and GHG reporting, ESOS phase 4 qualification and audits, packaging Extended Producer Responsibility (EPR) and the waste duty of care code of practice. For sustainability, finance and operations teams. Curated by Kopik from public sources: GOV.UK, DESNZ, Defra, Environment Agency (OGL v3).

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This assistant answers questions on UK corporate environmental compliance: Streamlined Energy and Carbon Reporting (SECR), the Energy Savings Opportunity Scheme (ESOS), extended producer responsibility (EPR) for packaging and the waste duty of care. It is meant for sustainability, finance and operations teams, and every answer comes from official GOV.UK guidance published by DESNZ, Defra and the Environment Agency.

Who falls within the scope of SECR

SECR affects three kinds of organisation: quoted companies, large unquoted companies (including charitable companies) and large limited liability partnerships (LLPs). An unquoted company or LLP counts as large in a year in which it meets two or more of these conditions: turnover of £36 million or more, a balance sheet total of £18 million or more, and 250 or more employees.

The guidance points out that organisations doing public or not for profit work can still be in scope, for example registered companies or LLPs owned by universities, academies or NHS Trusts.

The requirements from the 2018 Regulations apply to reports for financial years starting on or after 1 April 2019. Quoted companies have had to make carbon disclosures in their Directors' Reports since 30 September 2013.

What an SECR disclosure contains

Quoted companies report their annual global greenhouse gas emissions from activities they are responsible for, such as burning fuel and operating facilities, plus emissions from electricity, heat, steam or cooling bought for their own use (Scope 1 and Scope 2). They also report the underlying global energy use and state what proportion of energy and emissions relates to the UK, including the offshore area.

Large unquoted companies and LLPs report UK energy use, covering at least purchased electricity, gas and transport fuel, together with the associated emissions.

Both groups must give at least one intensity ratio, the previous year's figures (except in the first year), the energy efficiency action taken during the financial year and the methodology used. Large LLPs put this information in an 'Energy and Carbon Report', approved by the members and signed on behalf of the LLP by a designated member.

Low energy users and the 'comply or explain' options

An organisation that consumed 40MWh or less during the reporting period is a low energy user. It does not have to make the detailed disclosures, but it must state in its report that the information is not disclosed for that reason. For unquoted companies and LLPs, energy from gas, electricity and transport fuel counts towards the threshold; quoted companies must consider all their energy use.

Information can also be left out when directors or members consider that disclosing it would be seriously prejudicial to the organisation. The guidance expects this to be very rare, for example during a restructuring or acquisition, and says the Financial Reporting Council may question it.

Where some data is not practical to obtain, the report must state what is omitted and why. The guidance recommends setting out the level of materiality and the steps being taken to acquire the information.

How the four regimes fit together

SECR is a disclosure duty in annual reports. ESOS is a mandatory energy assessment every four years for large undertakings. EPR for packaging places reporting, recycling and fee obligations on businesses that supply or import packaging. The waste duty of care applies to anyone handling controlled waste in England or Wales.

The SECR guidance notes that taking part in other schemes, such as ESOS or Climate Change Agreements, will further help companies meet their reporting obligations.

Questions fréquentes

What intensity ratio should we use for SECR?

You are free to choose your own ratio, but it should suit your business activity, be calculated on a consistent basis each year, have its method disclosed and be meaningful to stakeholders. Examples in the guidance include tonnes of CO2e per square metre for the property sector, per million tonnes of production for manufacturing, and per £m of sales revenue or per full time equivalent for any sector.

Does a subsidiary have to report separately if its parent publishes a group report?

A subsidiary can be exempt when it is included in its parent's group report, that report covers the energy and carbon information of the parent and its subsidiaries, and it is prepared for a financial year ending at the same time as or before the subsidiary's own. The exemption does not apply if the group report relies on the seriously prejudicial option.

What counts as a quoted company for SECR?

A UK incorporated company whose equity share capital is officially listed on the main market of the London Stock Exchange or in a European Economic Area State, or admitted to dealing on the New York Stock Exchange or NASDAQ. Quoted companies of any size that must prepare a Directors' Report are covered.

What must a group report include?

When reporting at group level, you take into account your own information and that of any subsidiaries included in the consolidation that are quoted companies, unquoted companies or LLPs. The same rule applies to LLPs preparing a group Energy and Carbon Report.

Do offshore businesses report differently under SECR?

Yes. If your activities consist wholly or mainly of offshore activities as defined in the 2018 Regulations, you must disclose your emissions and energy use for both the UK and the offshore area.

What do the Environmental Reporting Guidelines recommend beyond the legal minimum?

They describe five steps: set your organisational boundaries, choose the data period, identify your key environmental impacts, measure, then report. They recommend reporting at least three KPIs linked to those impacts and considering actions such as setting a base year, setting a target and obtaining assurance.

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claude mcp add --transport http kopik-uk-business-carbon-energy-waste-compliance "https://kopik.io/api/mcp?base=uk-business-carbon-energy-waste-compliance" --header "Authorization: Bearer kpk_…"
Configuration JSON (mcpServers)
{
  "mcpServers": {
    "kopik-uk-business-carbon-energy-waste-compliance": {
      "url": "https://kopik.io/api/mcp?base=uk-business-carbon-energy-waste-compliance",
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        "Authorization": "Bearer kpk_…"
      }
    }
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}

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