SECR Reporting UK Guide (2026): Requirements, Thresholds & Compliance

This article is grounded in the UK Government’s Environmental Reporting Guidelines (March 2019), which introduced the Streamlined Energy and Carbon Reporting (SECR) framework. All technical requirements, thresholds, and definitions are drawn directly from that official guidance. Where relevant, the article incorporates the latest 2025–2026 developments from the Department for Energy Security and Net Zero (DESNZ), including the January 2026 post-implementation evaluation and the introduction of UK Sustainability Reporting Standards.

Understanding SECR in the Fashion & Textile Context

What is SECR and Why It Matters to Your Fashion Business?

The UK’s Streamlined Energy and Carbon Reporting (SECR) framework is one of the most significant pieces of corporate environmental legislation for large businesses operating in the country.

Introduced through the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, and coming into force on 1 April 2019, SECR was designed to widen the scope of mandatory energy and carbon reporting. It builds on earlier requirements that applied only to quoted companies under the Companies Act 2006.

For the fashion, textile, retail, luxury goods, and lifestyle industries, SECR is an invitation, and a legal requirement, to take stock of your organisation’s energy footprint. This includes operations across the value chain, from spinning mills and dyeing vats to retail stores and corporate logistics fleets.

As the official guidance notes, there are direct benefits to measuring and reporting environmental performance:

• Organisations benefit from lower energy and resource costs
• They gain a better understanding of exposure to climate change risks
• They can demonstrate leadership that strengthens green credentials in the marketplace

SECR also responds to a powerful external signal.

• Investors, shareholders, and stakeholders are increasingly requesting stronger environmental disclosures in annual reports.
• Customers, particularly in fashion, textile, retail, luxury goods, and lifestyle, are demanding transparency about how their products are made and at what planetary cost.
• Organisations of all sizes are expected to measure and report on their environmental performance, or risk losing out to competitors who do.

A Brief History: From Mandatory GHG Reporting to SECR

The legislative journey to SECR began with the Companies Act 2006 (Strategic Report and Directors’ Reports) Regulations 2013, which first required quoted companies to disclose greenhouse gas (GHG) emissions in their Directors’ Reports. This Mandatory Greenhouse Gas Reporting (MGHG) regime established the principle that large, listed businesses must be accountable for their carbon output.

However, that requirement left a major gap: the many large unquoted companies and limited liability partnerships that form the backbone of UK manufacturing, retail, and fashion were not covered. 

The 2018 Regulations closed that gap by:

• Extending reporting to large unquoted companies and LLPs
• Requiring quoted companies to disclose global energy use
• Introducing energy efficiency action reporting

SECR effectively replaced the CRC Energy Efficiency Scheme (which closed following the 2018–19 compliance year) and aligned energy reporting with existing business frameworks, making compliance more achievable by allowing companies to build on data they already collect for utility bills, ESOS audits, and Climate Change Agreements.

The Regulatory Architecture: Key Legislation

SECR sits within a broader legal and regulatory framework. The primary instruments are:

• The Companies Act 2006 (Strategic Report and Directors’ Reports) Regulations 2013 — introduced GHG reporting for quoted companies.
• The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 — the core SECR legislation, imposing new obligations from April 2019.
• The Environmental Reporting Guidelines (March 2019, updated) — the official guidance document from BEIS (now DESNZ) that operationalises the legislation and provides detailed methodological guidance.

SECR operates alongside, rather than replacing, other reporting requirements including the Energy Savings Opportunity Scheme (ESOS), Climate Change Agreements (CCA), and the EU Emissions Trading System (ETS) for applicable businesses.

SECR’s Direct Impact on Fashion Brands and Textile Manufacturers

Fashion is one of the world’s most resource-intensive industries. The Ellen MacArthur Foundation has estimated that the fashion industry accounts for around 10% of annual global carbon emissions, more than international flights and maritime shipping combined. For UK fashion businesses, SECR creates a structured mechanism to begin systematically tracking and disclosing this footprint.

The energy landscape in fashion is complex and diverse. Energy is consumed across spinning, weaving, knitting, dyeing, ginning and cutting operations; in high-temperature dyeing and finishing processes; in logistics and distribution centres; in flagship stores and concessions; in head offices and design studios; and in the IT infrastructure underpinning e-commerce. SECR requires businesses to account for the energy flows they control.

Leveraging SECR for a Sustainable Fashion Future Beyond Compliance

Government guidance emphasises that environmental reporting delivers measurable business benefits. 

A Defra-sponsored study provided robust evidence that environmental management systems generally delivered cost savings and new business sales for the majority of small and medium-sized enterprises studied. 

For larger fashion businesses, the potential is even greater. Energy efficiency improvements translate directly into 

• reduced operating costs
• improved margins
• reduced exposure to volatile energy prices.

Moreover, the guidance notes that many businesses are finding that their environmental risks are material to their operations and supply chains, whether in the form of physical risks from climate change (disruption to cotton harvests, flooding of manufacturing regions) or business risk from volatile commodity prices. SECR is not just about reporting the past but is also a catalyst for managing the future.

Who Needs to Report: Defining Your SECR Obligation in Fashion

Are You Subject to SECR? Three Categories of In-Scope Organisations

SECR affects three categories of organisations:

• Quoted companies — companies whose equity share capital is officially listed on the Main Market of the London Stock Exchange; or officially listed in a European Economic Area state; or admitted to dealing on the New York Stock Exchange or NASDAQ.
• Large unquoted companies — UK-incorporated companies required to prepare a Directors’ Report under Part 15 of the Companies Act 2006, and which are ‘large’ as defined below.
• Large limited liability partnerships (LLPs) — LLPs meeting the same size thresholds as large unquoted companies, required to prepare a new ‘Energy and Carbon Report’.

Important Scope Clarification

Organisations may fall within scope even if they undertake public or not-for-profit activities, provided they are:

• Registered companies
• Companies or LLPs owned by universities
• Companies or LLPs owned by academies
• Companies or LLPs owned by NHS Trusts

However, organisations defined as public bodies are not required to report under SECR at an organisational level, though they may have obligations under the Greening Government Commitments.

What Makes a Company ‘Large’? The Three Thresholds

A company or LLP is ‘large’ if, in a given year, it satisfies two or more of the following conditions:

Criterion	Threshold
Annual Turnover	£36 million or more
Balance Sheet Total	£18 million or more
Number of Employees	250 or more

For charitable companies, ‘turnover’ is taken as a reference to the charitable company’s gross income as defined for its jurisdiction of registration or operation.

Fashion Industry ScenariosExamples of how the thresholds apply in practice:A large apparel manufacturer with 300 employees and £45m turnover → clearly in scopeA fashion retail chain with 500 employees across stores → in scopeA luxury textile producer with a £25m balance sheet → likely in scope

Group Reporting: Fashion Conglomerates and Parent Companies

For fashion groups reporting at the consolidated level, the Directors’ Report must include:

• The parent company’s own energy and carbon information
• The energy and carbon data of subsidiaries included in the consolidation that are quoted companies, unquoted companies or LLPs. 

However, there is flexibility. A group may exclude energy and carbon information relating to a subsidiary if that subsidiary would not itself be required to disclose such information if reporting independently.

Subsidiary Reporting Relief

A subsidiary does not need to include its own SECR disclosure if:

• It is included in a compliant group report
• The report is prepared by its parent company
• The reporting covers the same financial year

This is significant for fashion conglomerates with multiple retail brands, manufacturing subsidiaries, and logistics arms as it allows for a single consolidated disclosure rather than duplicative reporting.

Exemptions: The Low Energy User Threshold

Not all large companies must make detailed energy and carbon disclosures. A ‘low energy user’ exemption applies where an organisation has consumed 40 MWh or less of energy during the relevant reporting period. Such organisations are simply required to state in their report that energy and carbon information is not disclosed for that reason.

For context, 40 MWh represents a very small energy footprint, roughly equivalent to the annual electricity consumption of a small office or boutique store. In practice, very few fashion businesses above the size thresholds will qualify for this exemption.

Quoted Companies: What It Means for Publicly Listed Fashion Brands

Quoted fashion brands, those listed on the London Stock Exchange Main Market, an EEA exchange, the NYSE, or NASDAQ, have faced mandatory GHG reporting obligations since 30 September 2013. 

The 2018 Regulations extended these obligations from April 2019, adding requirements to report total global energy use, information on energy efficiency actions taken, and the methodology used.

Quoted companies must report on a global basis, not just UK operations, which is particularly significant for international fashion brands with manufacturing operations across Asia, sourcing hubs in the Middle East, and retail presence across Europe and North America. The quoted companies are required to state what proportion of their energy consumption and emissions relates to UK (including offshore) activities.

What to Report: The SECR Data Deep Dive for Fashion & Textiles

Different Requirements for Quoted vs. Unquoted Fashion Businesses

SECR reporting requirements differ based on company type. The table below summarises the key distinctions:

Reporting Element	Quoted Companies	Large Unquoted & LLPs
GHG Emissions	Global Scope 1 & 2 (mandatory)	UK-associated emissions (mandatory)
Energy Use	Underlying global energy use (kWh)	UK energy: gas, electricity, transport (kWh)
Intensity Ratio	At least one (mandatory)	At least one (mandatory)
Prior Year Figures	Required (from second year)	Required (from second year)
Energy Efficiency Actions	Narrative description required	Narrative description required
Methodology	Must be disclosed	Must be disclosed
Scope 3	Voluntary but recommended	Voluntary but recommended

Energy Consumption: From Mill to Mannequin

For large unquoted fashion companies and LLPs, the mandatory energy reporting scope covers three categories of UK energy use:

Electricity

This refers to the annual quantity of energy consumed in the UK from purchased electricity.

For fashion companies, this includes electricity used in:

• Manufacturing facilities
• Distribution and logistics centres
• Retail stores
• Corporate offices
• Data centres supporting e-commerce
• Electricity used for transport, such as charging electric company vehicles.

Gas

The annual quantity of energy consumed from activities involving the combustion of gas The guidance defines ‘gas’ as any combustible substance gaseous at 15°C and 101.325 kPa that consists wholly or mainly of methane, ethane, propane, butane, hydrogen, carbon monoxide, or combinations thereof.

In fashion operations, gas is commonly used for:

• Steam generation for dyeing and finishing
• Heating manufacturing facilities
• Space heating retail stores and offices

Transport

The annual quantity of energy consumed from activities involving the consumption of fuel for transport, including:

• Fuel used in company cars for business travel
• Fuel used in fleet vehicles
• Fuel in personal or hire cars reimbursed through mileage claims
• Fuel used in company-operated aircraft or private jets
• Fuel used in on-site vehicles such as forklifts

Critically, transport energy where the organisation procures a transportation service (rather than directly purchasing the fuel) is not mandatory; for example, freight costs paid to a third-party logistics provider are not included in mandatory transport energy. However, organisations are encouraged to report these separately as part of Scope 3 voluntary disclosures.

Calculating Carbon Emissions: Scope 1, 2, and the Textile Challenge

Scope 1 — Direct Emissions

Scope 1 covers emissions from activities for which the organisation is directly responsible and that they own. In a fashion and textile context, this includes:

• Stationary combustion — boilers, furnaces, burners, and other stationary equipment burning fuels in manufacturing, dyeing, and finishing plants.
• Mobile combustion — combustion of fuel in company vehicles, trucks, forklifts, and any mobile plant or equipment owned and operated by the business.
• Process emissions — where applicable, for example from chemical treatments in textile processing.
• Fugitive emissions — refrigerant leaks from air conditioning and cooling systems in offices, stores, and cold-chain logistics.

Scope 2 — Indirect Energy Emissions

Scope 2 covers indirect GHG emissions from the generation of purchased electricity, heat, steam, or cooling consumed by the company for its own use. For fashion businesses, this is typically the largest component of their reported carbon footprint at the operational level, reflecting the intensive electricity consumption of manufacturing processes, retail stores, and logistics infrastructure.

A separate figure must be given for emissions from the purchase of electricity, heat, steam, or cooling. Organisations should use the UK Government’s published conversion factors for company reporting to translate energy use into CO2 equivalent (CO2e) tonnes.

The Intensity Ratio — Fashion’s Comparability Tool

All organisations in scope must report at least one intensity ratio. This expresses the organisation’s annual GHG emissions relative to a quantifiable business metric, enabling comparison of energy efficiency performance over time and across similar businesses. The most appropriate metric will depend on business activity.

Formula:

Intensity Ratio = Total Emissions (tCO2e)/Normalisation Factor

Recommended Factors for Fashion:

1. Retailers: Tonnes of CO2e per square metre of floor space (Sales floor + Warehouse).
2. Manufacturers: Tonnes of CO2e per tonne of textile produced.
3. Fashion businesses with significant headcount: Tonnes of CO2e per employee.
4. Brands: Tonnes of CO2e per £ million turnover or per garment sold.

Organisations are encouraged to work with their sector associations to consider whether it is appropriate to adopt a consistent metric across the fashion and textile industry.

Mandatory: Energy Efficiency Actions

Every in-scope business must include a narrative description of the principal measures taken to increase energy efficiency during the relevant financial year. The guidance notes that if no measures have been taken, this must also be stated. So, there is no scope to simply omit this section.

In a fashion and textile context, energy efficiency actions might include:

• Installation of LED lighting in manufacturing facilities, warehouses, and retail stores.
• Replacement of energy-intensive dyeing or finishing machinery with more efficient models.
• Installation of variable speed drives on motors in textile manufacturing processes.
• Implementation of smart energy monitoring and building management systems.
• Transitioning fleet vehicles from fossil fuels to electric vehicles.
• Waste heat recovery from industrial processes (e.g., recapturing heat from dyeing baths).
• Insulation improvements to manufacturing buildings and distribution centres.
• Behavioural change programmes encouraging energy-conscious practices among staff.

Where possible, the resulting energy saving from reported actions should also be quantified. This transforms the narrative from a list of activities into a demonstration of genuine efficiency progress.

The Voluntary, But Crucial, Scope 3 Emissions Reporting for Fashion

Scope 3 covers all other indirect emissions that occur in a company’s value chain, upstream and downstream, which are not included in Scope 2. For the fashion industry, Scope 3 is not a marginal consideration and typically accounts for the vast majority of a brand’s total carbon footprint.

Organisations are not required to report on other emissions associated with inputs into their company (such as supply chain emissions) or emissions linked with outputs (such as those from products when used by customers). However, they are strongly encouraged to report these separately to give a wider picture to investors and shareholders, particularly where they represent material risks, opportunities, or financial impacts.

A 2023 call for evidence by the Department for Energy Security and Net Zero (DESNZ) on Scope 3 reporting noted that Scope 3 emissions can account for 80–95% of the total value chain carbon footprint of an organisation. For fashion businesses, this is acutely relevant.

The ‘Hidden’ Emissions in Fashion’s Scope 3

The upstream Scope 3 emissions in fashion include:

• Raw material sourcing — cotton farming (with its associated land use, irrigation, and pesticide application), polyester production from petrochemicals, wool from sheep farming, and the processing of all natural and synthetic fibres into usable yarn.
• Supplier manufacturing — the energy used at third-party factories to spin, weave, knit, cut, sew, and finish garments and textile products. For most fashion brands, this is the single largest component of Scope 3.
• Transportation of raw materials and goods — the shipping of raw materials to mills, of fabric to cut-and-make factories, and of finished goods to distribution centres and stores.
• Packaging materials — the production of tags, bags, boxes, and other packaging.

The downstream Scope 3 emissions include:

• Use phase — the energy consumed by consumers washing, drying, and ironing garments throughout the product’s useful life.
• End of life — emissions from landfill disposal or incineration of garments.
• Transportation and distribution — freight emissions from logistics providers not covered under Scope 1.

Challenges of Scope 3 for Fashion

Indirect environmental impact of the supply chain may be greater than the organisation’s own direct impact. The guidance provides a framework for engaging with suppliers:

• Identify companies from which goods and services are purchased and categorise expenditure into sector groupings.
• Assess the typical environmental impacts and risks for each sector.
• Determine where to focus efforts, prioritising suppliers based on both spend and relative environmental impact.
• Engage directly with suppliers and encourage them to report on their key environmental impacts.
• Influence purchasing decisions with the information gathered, making clear that environmental performance is a factor in buying decisions.

Why Scope 3 Reporting Is Strategically Important for Fashion: While Scope 3 is currently voluntary under SECR, the regulatory trajectory is clear. The 2023 DESNZ call for evidence explicitly explored the practicalities of mandatory Scope 3 reporting. Fashion brands that invest now in supplier engagement, Life Cycle Assessment (LCA) tools, and industry benchmark data will be far better positioned when mandatory Scope 3 reporting arrives and will be far more credible to the investors, retailers, and consumers who already demand it.

Where and How to Report SECR in the Fashion Industry

The Directors’ Report: Your SECR Disclosure Hub

The primary location for SECR disclosures is the Directors’ Report, which forms part of a company’s annual accounts filed with Companies House. 

The official guidance specifies that companies in scope must include their energy and carbon information as part of their annual filing obligations under the Companies Act.

Flexibility in Disclosure Location

There is, however, an important degree of flexibility. Where energy usage and carbon emissions are of strategic importance, the relevant information may be included in the Strategic Report instead of the Directors’ Report.

This is appropriate where the information is necessary for understanding:

• the development of the company
• the position of the company
• the performance of the company
• the impact of the company’s activities

If information is moved to the Strategic Report, a statement explaining this decision must still be included in the Directors’ Report.

Reporting Period and Deadlines

SECR applies to reports for financial years starting on or after 1 April 2019. The reporting period should be for 12 months and should ideally correspond with the financial year, to allow for easier comparison of environmental and financial performance.

Financial Year Start Date	First Mandatory SECR Report Covers	Filed With Companies House
1 April (e.g., April–March)	1 April 2019 to 31 March 2020	From 2020 onwards
1 January (e.g., Jan–Dec)	1 January 2020 to 31 December 2020	From 2020 onwards

From the second mandatory reporting year onwards, organisations must also include previous year’s figures for energy use, GHG emissions, and intensity ratios. The guidance encourages organisations to disclose up to five years of performance data where possible, to demonstrate longer-term trajectories.

Setting Your Organisational Boundary

Before collecting data, every fashion business must define which parts of its organisation are within the reporting boundary. Here are three principal boundary approaches:

• Financial control boundary — the organisation reports on all sources of environmental impact over which it has financial control, i.e. the ability to direct financial and operating policies with a view to gaining economic benefits.
• Operational control boundary — the organisation reports on all sources of environmental impact over which it or a subsidiary has the full authority to introduce and implement operating policies.
• Equity share boundary — the organisation accounts for GHG emissions from operations according to its share of equity.

For fashion businesses with complex ownership structures, joint ventures with overseas manufacturers, franchise operations, concessions within department stores, the choice of boundary has material implications for reported figures. The guidance recommends aligning the reporting boundary with the consolidated financial statement, and where differences exist, clearly reconciling entities included or excluded.

Data Collection: From Invoices to Smart Meters

When calculating total energy consumption, the guidance requires organisations to use verifiable data where reasonably practicable. Acceptable data sources include:

• Meter data obtained from the supplier, Data Collector, Data Aggregator, or energy systems provider — described as the preferred method.
• Energy invoices from suppliers.
• Annual statements from suppliers (combining multiple supplies or meters for the same site as appropriate).

Where verifiable data is not available, the guidance permits estimation through direct comparison (using comparable historical data), pro-rata extrapolation, or benchmarking. Any estimates must be clearly disclosed alongside the methodology used.

Methodology Disclosure: What Standards to Use

There is no single prescribed methodology under the legislation, but organisations must disclose the methodology used to calculate required information. It recommends widely recognised independent standards, including:

• GHG Reporting Protocol — Corporate Standard (the most widely used).
• ISO 14064-1:2018 (International Standard for GHG quantification and reporting).
• Climate Disclosure Standards Board (CDSB) framework.

Businesses may use data compiled for other regulatory purposes, ESOS audits, Climate Change Agreements, the EU ETS, to help fulfil their SECR obligations, provided they state this as part of their methodology disclosure and ensure the data covers all required elements.

Enforcement and Penalties

Enforcement of SECR is overseen by the Conduct Committee of the Financial Reporting Council (FRC), which has powers to inquire into cases of apparent non-compliance and, in the most serious cases, to apply to court for a declaration that accounts do not comply with statutory requirements.

Practical Enforcement

In most cases, enforcement operates through agreement and correction rather than litigation.

However:

• Companies House may reject accounts that do not meet Companies Act requirements.
• Late filings trigger civil penalties.

Under Section 453 of the Companies Act 2006, late filing penalties range from:

• £150
• up to £7,500, depending on company type and delay.

The FRC Conduct Committee may also impose:

• civil penalties of up to £50,000
• public censures

Public censures can create significant reputational damage, particularly for consumer-facing fashion brands.

A Note on External Verification

There is no statutory requirement for SECR disclosures to undergo independent assurance.

However, the guidance recommends independent verification as best practice.

Voluntary assurance can strengthen confidence in:

• the accuracy of energy data
• the completeness of emissions reporting
• the consistency of efficiency action disclosures

SECR vs. CSRD: Understanding the Broader Sustainability Landscape

Key Differences Between SECR and CSRD

As fashion businesses navigate a rapidly evolving sustainability reporting landscape, it is important to understand where SECR fits relative to the EU’s Corporate Sustainability Reporting Directive (CSRD). Though both frameworks require sustainability disclosures, they differ substantially in scope, geography, and ambition:

Dimension	SECR	CSRD
Jurisdiction	UK only	EU member states (+ EEA / UK subsidiaries of EU groups)
Scope of Topics	Energy use and carbon emissions	Full ESG: environment, social, governance
GHG Scope	Scope 1 & 2 mandatory; Scope 3 voluntary	Scope 1, 2 & 3 mandatory (with materiality)
Reporting Standard	No single standard prescribed	European Sustainability Reporting Standards (ESRS)
Assurance	No mandatory external assurance	Mandatory limited (later reasonable) assurance
Effective Date	April 2019	Phased: large companies from FY 2024
Location in Report	Directors’ Report or Strategic Report	Separate sustainability statement in management report

UK Sustainability Reporting Standards: The 2025–2026 Horizon

In 2025–2026, the UK introduced its own UK Sustainability Reporting Standards (UK SRS), developed as an endorsement of the IFRS Sustainability Disclosure Standards (IFRS S1 and S2) from the International Sustainability Standards Board (ISSB). The UK SRS are expected to be available for voluntary use from early 2026, with the government and FCA subsequently considering whether to mandate their adoption for certain entities.

Alignment with SECR

The UK Government has confirmed that DESNZ will examine how UK SRS disclosures interact with SECR reporting requirements.

The objective is to reduce duplication in energy and emissions reporting.

For fashion companies, this is an important signal that future reporting systems may converge.

Strategic Advantage: SECR as the Foundation: Fashion brands that treat SECR as the foundation of a broader sustainability reporting infrastructure will be positioned to adapt most efficiently as regulatory requirements expand. Every investment made in energy data systems, supply chain transparency, and carbon accounting methodology has compounding returns as the reporting landscape evolves.

Real-World Impact and Future Trends in SECR for Fashion

What the January 2026 Government Evaluation Found

In January 2026, the Department for Energy Security and Net Zero (DESNZ) published its post-implementation evaluation of the SECR regulations. This was a landmark assessment commissioned to gather evidence on how SECR has operated in practice and whether it has achieved its intended goals.

The evaluation found compelling evidence that SECR has driven genuine energy efficiency improvements.

Estimated energy savings among companies in scope were:

• 4.5% in 2020
• 6.2% in 2021
• 4.9% in subsequent years

These reductions were statistically significant and were attributed to the introduction of mandatory reporting.

The Evolving Regulatory Landscape: What’s Next for SECR?

The Scope 3 Question

Perhaps the most significant open question for fashion businesses is the future of mandatory Scope 3 reporting. The 2023 DESNZ call for evidence gathered stakeholder views on the costs, benefits, and practicalities of mandatory Scope 3 disclosures, and the evidence base is being actively developed. Given that Scope 3 emissions represent 80–95% of fashion’s total carbon footprint, any future mandatory Scope 3 requirement would fundamentally transform the reporting landscape for the industry.

Fashion businesses that invest now in supplier engagement programmes, Life Cycle Assessment tools, and industry-standard Scope 3 measurement methodologies, including GHG Protocol’s Corporate Value Chain (Scope 3) Standard, will be far better positioned to comply with any future mandatory requirement.

Integration with UK SRS

As noted above, DESNZ has committed to exploring how UK SRS reporting on energy and emissions data can align with existing SECR requirements, reducing duplication. For fashion brands subject to both frameworks, this is welcome news. However, UK SRS covers a broader range of climate-related disclosures, including governance, strategy, risk management, and metrics and targets aligned with TCFD, that go well beyond SECR’s energy and carbon reporting scope.

Actionable Steps for Fashion Businesses to Enhance Their SECR Strategy

Based on the official guidance and current best practice, fashion businesses should consider the following priority actions:

Immediate Compliance Actions

• Confirm whether your organisation meets the SECR thresholds (quoted status, or two of the three ‘large’ criteria).
• Identify your reporting boundary, financial control, operational control, or equity share, and document the rationale.
• Establish data collection processes for electricity, gas, and transport fuel across all UK operations.
• Use the UK Government’s current conversion factors to translate energy use into CO2e figures.
• Select an appropriate intensity ratio for your business activity and commit to calculating it consistently.
• Document all energy efficiency actions taken during the financial year, with quantified savings where possible.
• Disclose the methodology used (e.g., GHG Protocol Corporate Standard).

Building Towards Best Practice

• Begin supplier engagement to collect Scope 3 data, starting with your highest-impact suppliers.
• Invest in carbon accounting software capable of handling multi-tier supply chain data.
• Consider voluntary independent assurance of your SECR disclosures to enhance credibility.
• Set science-based emissions reduction targets aligned with the Paris Agreement’s 1.5°C pathway.
• Report in line with TCFD recommendations on climate-related financial risks and opportunities.
• Use SECR data as the foundation for CSRD and UK SRS readiness assessments.

Strategic Leadership Actions

• Publish a standalone sustainability report that contextualises SECR disclosures within a broader net-zero strategy.
• Engage your board and senior leadership in setting ambitious, measurable sustainability targets.
• Collaborate with industry associations and peer fashion brands on sector-specific intensity metrics and Scope 3 methodologies.
• Communicate your SECR progress to consumers, investors, and supply chain partners to build trust and competitive advantage.

Glossary of Key SECR and Sustainability Terms

Term	Definition
SECR	Streamlined Energy and Carbon Reporting — the UK mandatory reporting framework for large companies’ energy use and carbon emissions, introduced April 2019.
Scope 1	Direct GHG emissions from sources owned or controlled by the organisation, including combustion of fuel and operation of facilities.
Scope 2	Indirect GHG emissions from the generation of purchased electricity, heat, steam, or cooling consumed by the organisation.
Scope 3	All other indirect GHG emissions that occur in the organisation’s value chain, upstream and downstream.
CO2e	Carbon dioxide equivalent — a standard unit for measuring the climate impact of different greenhouse gases, expressed as an equivalent amount of CO2.
Intensity Ratio	A metric expressing GHG emissions relative to a business activity indicator (e.g., turnover, employees, floor space), enabling comparison over time.
Directors’ Report	A statutory document required of UK companies under the Companies Act, in which SECR disclosures must be included.
LLP	Limited Liability Partnership — a business structure subject to SECR reporting requirements if it meets the ‘large’ thresholds.
ESOS	Energy Savings Opportunity Scheme — a separate mandatory energy audit requirement for large UK organisations, conducted every four years.
TCFD	Task Force on Climate-related Financial Disclosures — a global framework for reporting climate-related financial risks and opportunities.
CSRD	Corporate Sustainability Reporting Directive — the EU’s broad mandatory sustainability reporting framework, covering environmental, social, and governance topics.
UK SRS	UK Sustainability Reporting Standards — the UK’s national endorsement of IFRS S1 and S2, expected for voluntary use from early 2026.
GHG Protocol	The most widely used international accounting standard for measuring and managing GHG emissions (Corporate Standard).
DESNZ	Department for Energy Security and Net Zero — the UK government department responsible for SECR policy (successor to BEIS).
FRC	Financial Reporting Council — the UK body responsible for enforcing compliance with SECR reporting requirements in company accounts.
LCA	Life Cycle Assessment — a methodology for evaluating the total environmental impact of a product across its entire value chain.
Low Energy User	An organisation consuming 40 MWh or less during the reporting period, exempt from detailed SECR energy and carbon disclosures.

Sources and Further Reading

Primary source: UK Government Environmental Reporting Guidelines: Including streamlined energy and carbon reporting guidance (March 2019, Updated Introduction and Chapters 1 and 2). Published by the Department for Business, Energy and Industrial Strategy (BEIS), now the Department for Energy Security and Net Zero (DESNZ).

Additional sources: DESNZ SECR Regulations Evaluation (January 2026); UK Government Response to Consultation on UK Sustainability Reporting Standards (February 2026); DESNZ Call for Evidence on Scope 3 Emissions Reporting (October 2023). For the latest SECR guidance, visit: www.gov.uk

This article is for informational purposes only and does not constitute legal or professional advice. Businesses should refer directly to the official SECR regulations or seek independent legal advice to confirm compliance.