SECR Reporting for Food Businesses: What It Requires and How to Comply

This post covers what SECR requires, who qualifies, what food businesses specifically need to report, and how SECR fits into the broader sustainability reporting landscape alongside CSRD and SBTi.

What Is SECR?

Streamlined Energy and Carbon Reporting is a UK regulatory framework that requires qualifying companies to disclose their energy use, greenhouse gas emissions, and energy efficiency actions as part of their annual Directors' Report. It was introduced under The Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, came into effect on 1 April 2019, and replaced the previous Carbon Reduction Commitment (CRC) Energy Efficiency Scheme.

The scheme extends earlier Mandatory Greenhouse Gas Reporting (MGHG), which applied only to quoted companies. SECR brings large unquoted companies and LLPs into the same reporting framework, significantly expanding the number of UK businesses with formal carbon disclosure obligations.

Who Needs to Report Under SECR?

SECR applies to three categories of UK organisation:

Quoted companies: Any company listed on the London Stock Exchange, a European Economic Area market, the NYSE, or NASDAQ. Quoted companies must report regardless of size.

Large unquoted companies: UK-incorporated companies that meet at least two of the following three criteria in the financial year:

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

Large LLPs: Limited Liability Partnerships meeting the same two-of-three criteria above.

For food businesses, this captures a significant portion of the sector: large contract caterers, hotel groups, food producers, and wholesalers operating at scale in the UK. A multi-site catering company or a national food producer with 250+ employees and £36M+ turnover will almost certainly qualify.

One exemption applies: companies that consume less than 40,000 kWh of energy during the reporting period are exempt from disclosure, even if they meet the size thresholds. For most qualifying food businesses, energy consumption across kitchens, cold storage, and logistics will comfortably exceed this threshold.

What SECR Requires Food Businesses to Report

SECR disclosures must be included in the annual Directors' Report (or an equivalent Energy and Carbon Report for LLPs) and filed with Companies House. The required disclosures cover five areas:

1. UK Energy Use

Total energy consumption in kilowatt-hours (kWh) for the reporting period, including gas, electricity, and transport fuel. For food businesses, this covers:

• Gas consumption across kitchens, catering facilities, and processing sites
• Electricity across all UK operations
• Fuel used in owned or leased vehicle fleets
• Fuel purchased for employee-owned vehicles used for business travel where the company reimburses the cost

Energy from offshore operations should also be included where applicable.

2. Scope 1 and Scope 2 Greenhouse Gas Emissions

Scope 1 covers direct emissions from sources the company owns or controls—gas combustion in kitchens, owned refrigerant systems, owned vehicle fleets. Scope 2 covers indirect emissions from purchased electricity, heat, and cooling.

Both must be reported in tonnes of CO2 equivalent (tCO2e) for the UK, using a methodology consistent with the GHG Protocol Corporate Standard.

3. Scope 3 Emissions (Voluntary but Recommended)

SECR does not mandate Scope 3 disclosure. However, it strongly encourages it, and for food businesses, omitting Scope 3 produces a carbon disclosure that significantly understates actual climate impact.

For most food operators, Scope 3 Category 1 (purchased ingredients and products) represents 80–95% of total emissions. A SECR report that covers only Scope 1 and 2 will capture a small fraction of a food business's true footprint. Investors, corporate clients, and procurement teams increasingly scrutinise whether companies are reporting Scope 3—and the absence of it from a SECR disclosure is becoming more visible. For food businesses, voluntarily including Scope 3 is not just a best-practice gesture; it is what makes the disclosure credible.

4. An Intensity Ratio

An intensity ratio relates emissions to a business metric, enabling year-on-year comparison adjusted for changes in business scale. Common intensity metrics include:

• tCO2e per employee
• tCO2e per £ million turnover
• tCO2e per meal served (particularly relevant for catering and foodservice operators)
• tCO2e per tonne of product (for food producers)

Food businesses should choose a metric that reflects how their emissions scale with business activity. Revenue, meals served or kg of food purchased are typically more meaningful than floor space for a food operator. Note that the intensity ratio requirement applies to all quoted companies; for large unquoted companies and LLPs it is strongly recommended but not strictly mandated.

5. Energy Efficiency Actions

A narrative description of the energy efficiency measures taken during the reporting period. This can include operational changes (LED lighting, equipment upgrades, refrigeration efficiency), renewable energy procurement, fleet electrification, and any broader energy management programmes. There is no minimum threshold for what constitutes a reportable action, but the narrative should be substantive rather than boilerplate.

Comparatives

SECR requires current-year figures to be presented alongside the prior year's equivalent, enabling trend tracking. For a company's first SECR report, prior-year comparatives are not required.

SECR vs. CSRD: How They Relate

For large UK food businesses with EU operations or clients, SECR and CSRD may both apply—or one may apply now while the other applies in the near future. The two frameworks have different scopes, different disclosure formats, and different audiences, but draw on the same underlying data.

For food businesses that need to comply with both, building a single underlying data infrastructure—covering Scope 1, 2, and 3 with consistent methodology—is significantly more efficient than running parallel reporting processes. The GHG Protocol Corporate Standard underpins both frameworks, so ingredient-level Scope 3 data collected for CSRD purposes can be incorporated into SECR reporting with minimal additional work.

For a full breakdown of CSRD requirements for food businesses, see CSRD for the Food Industry.

The Specific Challenge of SECR for Food Businesses

Most SECR guidance assumes a business where Scope 1 and 2—energy and direct operations—are the dominant emissions sources. For food businesses, this assumption doesn't hold.

The energy-centric framing of SECR (electricity, gas, transport fuel) maps cleanly onto manufacturing, property, or logistics companies. For food operators, it captures the smaller portion of climate impact. A large caterer or food producer complying with the letter of SECR—Scope 1 and 2 only—will produce a disclosure that excludes the 80–95% of emissions embedded in its supply chain.

This creates a reputational and commercial risk. As corporate clients, investors, and procurement frameworks become more sophisticated about emissions reporting, a SECR disclosure without voluntary Scope 3 data signals either a lack of awareness or a deliberate decision not to measure the most material part of the footprint.

The practical solution is to build Scope 3 data alongside SECR compliance rather than treating them as separate work streams. The ingredient-level procurement data required for credible Scope 3 Category 1 calculation is data food businesses already work with operationally. Connecting it to a carbon calculation methodology produces SECR-ready Scope 3 figures, CSRD-aligned disclosure data, and the foundation for SBTi target-setting—all from the same underlying data layer.

How to Prepare Your First SECR Report: A Practical Checklist

Step 1: Confirm Whether You Qualify

Check against the two-of-three criteria: 250+ employees, £36M+ turnover, £18M+ balance sheet. If your company is part of a group, thresholds are assessed at subsidiary level as well as group level.

Step 2: Establish Your Reporting Boundaries

Define which UK operations are in scope. The standard approach is operational control—all sites and activities the company operationally controls, including leased premises where the company controls energy use.

Step 3: Collect Scope 1 and 2 Data

Gather gas bills, electricity bills, and fuel records for all UK operations for the full financial year. For vehicle fleets, collect fuel purchase records. Ensure prior-year comparatives are available for your second and subsequent reports.

Step 4: Calculate Emissions Using GHG Protocol Methodology

Apply UK government conversion factors (published annually by DESNZ) to convert energy use to tCO2e. Use location-based or market-based methodology for Scope 2 electricity—SECR accepts both; document which you've used.

Step 5: Decide on Scope 3 Inclusion

For food businesses, the strong recommendation is to include at minimum Scope 3 Category 1 (purchased ingredients). The data collection and calculation methodology for this is more involved than Scope 1 and 2, but it is what makes the disclosure meaningful.

Step 6: Select and Calculate Your Intensity Ratio

Choose a metric appropriate for your business type. Calculate tCO2e per unit of the chosen metric for both the current and prior year.

Step 7: Document Energy Efficiency Actions

Prepare a narrative covering the energy efficiency measures taken during the year. Be specific—name the initiatives, the sites they applied to, and where possible the energy or emissions savings delivered.

Step 8: Include in the Directors' Report

SECR disclosures must appear in the Directors' Report as filed with Companies House. The disclosure must be signed off by the board. For LLPs, an equivalent Energy and Carbon Report is lodged separately.

FAQ About SECR

Q: What is SECR reporting?
A: SECR—Streamlined Energy and Carbon Reporting—is the UK's mandatory framework requiring large companies and LLPs to disclose their energy use, greenhouse gas emissions, and energy efficiency actions within their annual Directors' Report. It came into force on 1 April 2019 under the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. For food businesses, SECR is the primary UK-level carbon disclosure obligation, sitting alongside EU-level CSRD requirements for companies with EU operations or clients. See CSRD for the Food Industry for how the two frameworks interact.

Q: Is SECR reporting mandatory?
A: Yes. SECR is a legal requirement under the Companies Act for all qualifying quoted companies and large unquoted companies and LLPs. Failure to include required disclosures in the Directors' Report filed with Companies House is a breach of the Companies Act. The Scope 1 and 2 energy and emissions disclosures are mandatory; Scope 3 is encouraged but voluntary. For food businesses, voluntary inclusion of Scope 3 Category 1 (purchased ingredients) is strongly recommended, as it represents 80–95% of total emissions and is increasingly expected by corporate clients and investors. See Sustainability Reporting for Food Businesses for the broader reporting context.

Q: Who has to report under SECR?
A: Three categories of UK organisation must report: all quoted companies (regardless of size), large unquoted companies meeting at least two of three criteria (250+ employees, £36M+ annual turnover, or £18M+ balance sheet total), and large LLPs meeting the same two-of-three test. For the food sector, this captures most large contract caterers, hotel groups, national food producers, and major wholesalers. Companies that consumed less than 40,000 kWh of energy during the reporting period are exempt even if they meet the size thresholds, though this exemption is unlikely to apply to most qualifying food businesses.

Q: Do charities have to report under SECR?
A: No. SECR applies to companies incorporated under the Companies Act and qualifying LLPs. Most charities, which are typically incorporated as charitable companies limited by guarantee or as charitable incorporated organisations, are not subject to SECR. However, a charity that is also a large unquoted company and meets the size thresholds may qualify—the determining factor is legal structure and size, not charitable status. Charities subject to other reporting frameworks such as the Charities SORP should check their specific obligations separately.

Q: Do public sector organisations have to report under SECR?
A: No. SECR does not apply to public sector bodies such as NHS trusts, local authorities, government departments, or publicly funded institutions. Public sector organisations in the UK have separate energy and carbon reporting obligations under the Greening Government Commitments and other frameworks. However, public sector bodies that operate through company structures and meet the size thresholds may need to take specific advice on their SECR position.

Q: What is the SECR reporting deadline?
A: SECR disclosures must be included in the Directors' Report as filed with Companies House. The deadline follows standard Companies Act filing timelines: nine months after the accounting reference date for private companies, and six months for public companies. For a private company with a 31 December year-end, SECR disclosures are due by 30 September of the following year. There is no separate SECR submission—the disclosure is embedded in the annual accounts filing.

Q: How does SECR relate to CSRD for food businesses?
A: SECR and CSRD are complementary rather than duplicative. SECR applies in the UK and requires Scope 1 and 2 disclosure (with Scope 3 voluntary). CSRD applies in the EU and requires Scope 1, 2, and 3 disclosure for large companies meeting EU thresholds. For food businesses operating across both jurisdictions, the same underlying data infrastructure can serve both frameworks—GHG Protocol-aligned Scope 1, 2, and 3 data collected for CSRD purposes maps directly into SECR disclosures. For food businesses, building a single ingredient-level Scope 3 data layer is the most efficient path to satisfying both. See CSRD for the Food Industry for a full comparison.

Q: How does SECR interact with the UK Sustainability Reporting Standards introduced in 2026?
A: The UK Sustainability Reporting Standards (UK SRS), published in February 2026, align closely with the ISSB's IFRS S1 and S2 frameworks. The UK government has committed to reviewing how UK SRS disclosures interact with existing SECR requirements, with the goal of reducing unnecessary duplication. As of June 2026, SECR remains the active mandatory framework—UK SRS adoption is currently voluntary. Food businesses should monitor this interaction, as the UK SRS may eventually introduce climate-related financial disclosure requirements that sit alongside or partially overlap with SECR energy reporting.