SECR and business travel: what large unquoted companies must report

Streamlined Energy and Carbon Reporting (SECR) puts energy use and emissions into the directors’ report of large companies. For business travel it draws a line most people would not guess. Flights, trains and taxis are optional, because the company does not buy the fuel. The fuel in an employee’s own car on a business journey is mandatory, because the company reimburses it through the mileage claim. This page quotes the regulations and the government guidance on who is in scope — including a size test that did not move when company size thresholds rose in 2025 — and sets out what a travel and expenses system needs to capture.

Who has to report

SECR for unquoted companies is in Part 7A of Schedule 7 to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008. Paragraph 20A: unless exempt, “this Part of this Schedule applies to the directors’ report for a financial year if the company is an unquoted company.” Quoted companies report under the separate Part 7 of the same Schedule, which this page does not cover.

The exemption is in paragraph 20B. A company that is not a parent is exempt where it meets two or more of these conditions:

The thresholds that did not move

When SECR was introduced the two tests matched. The 2019 guidance says: “The definition of “large” is the same as applies in the existing framework for annual accounts and reports, based on sections 465 and 466 of the Companies Act 2006.” It then lists “Turnover £36 million or more”. Since then, the medium-sized limits in s.465 have been raised — legislation.gov.uk records “Words in s. 465(3) table substituted (6.4.2025) by The Companies (Accounts and Reports) (Amendment and Transitional Provision) Regulations 2024 (S.I. 2024/1303) , regs. 1(2) , 10(1)(b)” — and the section now reads “Turnover Not more than £54 million” and “Balance sheet total Not more than £27 million”. Paragraph 20B was not amended with it; it states its own figures, “Turnover not more than £36 million” and “Balance sheet total not more than £18 million”.

The practical result: a company with, say, £45 million turnover and £20 million of assets is now medium-sized for its accounts, but still above the SECR exemption and still has to report. The guidance sentence linking the two definitions has not been updated, so anyone working from it alone would reach the wrong answer. Group parents have a parallel test in paragraph 20C, also with its own figures.

What the directors’ report must contain

• Emissions from gas and transport fuel: “The directors’ report must state the annual quantity of emissions in tonnes of carbon dioxide equivalent resulting from activities for which the company is responsible involving— a the combustion of gas; or b the consumption of fuel for the purposes of transport.”
• Emissions from purchased electricity: “The report must state the annual quantity of emissions in tonnes of carbon dioxide equivalent resulting from the purchase of electricity by the company for its own use, including for the purposes of transport.”
• Total energy in kWh from the same sources.
• Efficiency measures: where any were taken, “a description of the principal measures taken for that purpose”.
• Methodology: “The directors’ report must state the methodologies used to calculate the information disclosed”.
• An intensity ratio: “The directors’ report must state at least one ratio which expresses the company’s annual emissions in relation to a quantifiable factor associated with the company’s activities.”

Two limits apply. Figures “may exclude emissions and energy consumed outside of the United Kingdom.” And the requirements apply only so far as practical; where not, “the report must state what information is not included and why.” A company that “the company consumed 40,000 kWh of energy or less in the United Kingdom during the period in respect of which the directors’ report is prepared, and the report states that the information is not disclosed for that reason” need not disclose.

Which business travel is mandatory

The key words in paragraph 20D are “activities for which the company is responsible”. The guidance turns that into a test about who buys the fuel:

The guidance lists, among activities to include, “Fuel used in company cars on business use.” and “Fuel used in personal/hire cars on business use (including fuel for which the organisation reimburses its employees following claims for business mileage).” Among those not required: “Fuel associated with train travel of your employees where you do not operate the train.”, “Fuel associated with flights your employees take where you do not operate the aircraft.” and “Fuel associated with taxi journeys your employees take where you do not operate the taxi firm.” Its summary table is explicit about the grey fleet line: “Mandatory for large unquoted companies and LLPs to disclose energy use and related emissions from business travel in rental cars or employee-owned vehicles where they are responsible for purchasing the fuel.”

What that means for expenses data

For business travel, the lines SECR reaches are reimbursed mileage and fuel for hire cars, and they are recorded in the expenses system rather than the booking system. To turn it into kWh and CO2e the company needs the miles, and ideally the fuel type and size of each car; a claim recorded only as pounds at 55p a mile can be converted back to miles, but not to fuel type. The government guidance says: “Use the Government conversion factors for company reporting to help you measure energy consumption in common units.” The 2026 car, rail, flight and hotel factors are on business travel emissions factors. The health and safety side of the same journeys is on grey fleet.

Flights, rail and hotels: optional but encouraged

“Other Scope 3 emissions voluntary, but strongly encouraged where this is a material source of emissions.” Whether flights are material is a judgement for each company; the mandatory figures alone do not show it. If they are reported, state the factor year and whether the air figures include indirect effects, and keep them separate from the mandatory totals.

A checklist for the travel and expenses side

• Confirm the company is above the paragraph 20B test, not the s.465 test.
• Capture miles, fuel type and engine size or car size on mileage claims.
• Record fuel paid for hire cars separately from the hire charge.
• Separate electricity used to charge company cars, which is mandatory, from other electricity.
• Decide whether to report flights, rail and hotels voluntarily; if so, ask the travel supplier for distance by haul and class.
• Write down the methodology and factor year, which the report must state.

Government bids add a separate requirement that does include air and rail: the Scope 3 business travel category in a Carbon Reduction Plan. This page quotes the regulations and guidance as read on 2026-10-03; it is not accounting or legal advice.

Common questions