Streamlined Energy and Carbon Reporting—SECR—has been a mandatory requirement for large UK companies since April 2019. Yet it remains one of the least understood carbon reporting obligations in the food sector, partly because most guidance has been written for corporate generalists rather than businesses where the majority of emissions sit in purchased ingredients rather than energy systems.
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.
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.
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.
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:
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.
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.
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.
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.
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.
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.
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.
| SECR | CSRD | |
| Jurisdiction | UK | EU (applies to large companies with EU presence or turnover) |
| Scope required | Scope 1 and 2 (Scope 3 voluntary) | Scope 1, 2, and 3 (mandatory) |
| Disclosure format | Directors' Report / Companies House | Management Report / ESRS E1 |
| Verification | Board sign-off; no mandatory third-party audit | Limited assurance required |
| Intensity ratio | Required | Not mandatory but common |
| First applies | FY beginning on or after 1 April 2019 | Wave 1 from FY2024; revised thresholds under EU Omnibus |
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.
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.
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.
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.
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.
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.
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.
Choose a metric appropriate for your business type. Calculate tCO2e per unit of the chosen metric for both the current and prior year.
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.
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.
Q: What does net zero mean in simple terms?
A: Net zero means that the greenhouse gases a business emits are balanced by the greenhouse gases it removes or avoids, so the net effect on the atmosphere is zero. It does not mean producing no emissions at all—it means reducing emissions as far as possible and then neutralizing what remains. The Science Based Targets initiative defines net zero as requiring at least a 90% reduction in absolute emissions before any offsets are used for residual amounts. For food businesses, reaching net zero requires engaging Scope 3 emissions from ingredient sourcing, which typically represent 80–95% of total emissions. See Scope 1, 2, and 3 Emissions for a full breakdown.
Q: What is the difference between net zero and carbon neutral?
A: Carbon neutral typically means a company has offset its current emissions through carbon credits, without necessarily reducing them. Net zero sets a higher bar: it requires at least a 90% reduction in absolute emissions first, with carbon removal used only for the residual fraction that cannot be eliminated. A business can claim carbon neutrality by purchasing offsets; net zero requires demonstrating structural decarbonization over time, with third-party validation. For food businesses, this distinction matters because the majority of emissions sit in agricultural supply chains that must be actively addressed—not offset away.
Q: Why is Scope 3 so important for food businesses pursuing net zero?
A: For most food businesses, Scope 3 emissions—primarily the carbon embedded in purchased ingredients and agricultural production—account for 80–95% of total emissions. That means switching to renewable energy or electrifying kitchen equipment, while valuable, only addresses a small fraction of total climate impact. A credible net zero pathway for a food business is fundamentally a supply chain and procurement strategy: reducing high-impact ingredients, engaging suppliers, and building ingredient-level data that makes progress measurable. Without tackling Scope 3 Category 1, net zero is not achievable regardless of what happens to Scope 1 and 2. For practical guidance, see Sustainability Reporting for Food Businesses.
Q: What is a science-based target and how does it relate to net zero?
A: A science-based target is an emissions reduction target set in line with what climate science says is required to limit global warming to 1.5°C. Science-based targets are validated by the Science Based Targets initiative (SBTi) and provide a credible, independently verified pathway to net zero. For food businesses, SBTi has introduced FLAG (Forest, Land, and Agriculture) guidance that requires separate reduction pathways for land-use and agricultural emissions, which sit in Scope 3 Category 1 for most food operators. A company with an approved SBTi target has, in effect, a structured net zero roadmap.
Q: What is the SBTi FLAG target and why does it apply to food businesses?
A: FLAG stands for Forest, Land, and Agriculture. SBTi's FLAG guidance recognizes that emissions from land use and agricultural production behave differently from fossil fuel emissions—they can be reduced through different interventions and sequestered through land management practices. For food businesses, FLAG emissions sit primarily in Scope 3 Category 1 (purchased ingredients), since agricultural production is the dominant source. SBTi requires food businesses setting science-based targets to set a separate FLAG target alongside their fossil fuel target. This makes ingredient-level emissions data essential; you can't set or track a FLAG target without knowing where your agricultural emissions sit.
Q: How does net zero connect to CSRD reporting?
A: CSRD requires companies in scope to disclose Scope 1, 2, and 3 emissions under ESRS E1 and to describe their transition plans for aligning with a 1.5°C pathway. A company with an SBTi net zero commitment will already have the underlying data, methodology, and reduction targets that CSRD disclosure requires. In practice, the data needed for a credible net zero strategy and the data needed for CSRD compliance are the same: ingredient-level Scope 3 data, structured and auditable, updated annually. For more on how these frameworks overlap, see CSRD for the Food Industry.
Q: How do food businesses start working toward net zero?
A: The starting point is always measurement: building a baseline emissions inventory across all three scopes, with particular depth on Scope 3 Category 1 (purchased ingredients). From there, the process is: set a science-based target, identify the highest-impact reduction opportunities in your supply chain and operations, act on them systematically, and report progress annually. The Carbon Readiness Blueprint is a practical starting resource for food businesses at the beginning of this process. For teams ready to build the underlying data foundation, Klimato Food Emissions automates ingredient-level Scope 3 calculation from procurement data.
Jheri Malm
Growth Marketing Lead, Klimato
UNLOCK MORE INSIGHTS
For food businesses, SECR compliance is straightforward—the harder and more valuable work is building the voluntary Scope 3 layer that makes the disclosure credible. The ingredient-level data that underpins that is the same data that satisfies CSRD and supports SBTi target-setting.
The Carbon Readiness Blueprint covers what that data foundation looks like and how food businesses approach it in practice.