UK SECR Guide (2026) for Apparel and Footwear

Status:  ✅ Approved law

If your brand has a large company registered in the UK, it most likely already reports carbon emissions every year. That obligation comes from SECR – Streamlined Energy and Carbon Reporting.

SECR reporting requirements (Scope 1 and 2 emissions) are light compared to frameworks like CSRD. Yet, on average, SECR takes about 94 hours of staff time and costs about £7,100 a year. It is also often a brand's first public carbon disclosure, and the baseline everything else builds on.

That baseline matters increasingly in 2026. The UK Sustainability Reporting Standards (UK SRS), which include Scope 3 alongside Scope 1 and 2, become mandatory for listed companies from 2027. The UK is moving towards full GHG reporting.

Let’s break down what SECR compliance means for apparel and footwear companies today, with real examples from brands' own filings!

What Is SECR?

SECR (Streamlined Energy and Carbon Reporting) is a UK regulation that requires large companies to publish their energy use and carbon emissions every year in their annual report. It has applied to every financial year starting on or after 1 April 2019.

For most fashion brands, SECR covers the energy used by stores, offices, warehouses, and company vehicles. It does not cover products, materials, or manufacturing. Those sit in Scope 3, which is currently voluntary under SECR.

Read our carbon accounting guide for apparel and footwear.

Source: Corporate Value Chain (Scope 3) Accounting and Reporting Standard, page 5.

Key SECR Terms

• Quoted company: a UK company whose shares trade on the London Stock Exchange main market, an EEA regulated market, NYSE or Nasdaq.

• Unquoted company: any other company, including private companies and those on AIM (the London Stock Exchange’s market for smaller companies).

• LLP (limited liability partnership): a partnership whose members have limited liability, common for law and accounting firms but rare in fashion.

• Annual report: the yearly financial report every UK company must file. SECR figures go in its Directors’ Report section.

• Companies House: the UK government office that keeps company records. Filed annual reports are public there.

Which Apparel and Footwear Brands Must Comply With SECR?

Three types of UK-registered entities must report:

1. Quoted companies: UK companies whose shares are listed on the London Stock Exchange main market, an EEA regulated market, NYSE or Nasdaq. They must report regardless of their size.

Examples: Next, JD Sports Fashion.

2. Large unquoted companies: Companies that meet at least 2 of these 3 requirements:

• turnover of £36m or more
• balance sheet total of £18m or more
• 250 or more employees

Examples: White Stuff Limited, Seasalt Limited

3. Large limited liability partnerships (LLPs): Partnerships that meet the same 2 of 3 requirements. Few apparel or footwear brands are set up as LLPs.

Do Non-UK Brands Have to Comply?

SECR does not apply to companies registered outside the UK, including foreign parent companies. But a UK-registered subsidiary must report if it meets the thresholds.

So a US, French, German, or Spanish brand with a large UK subsidiary is in scope. Examples from fashion brands that already reported:

• H&M (Sweden): H&M Hennes & Mauritz UK Limited
• Zara / Inditex (Spain): ITX UK Limited
• Levi's (US): Levi Strauss (U.K.) Limited
• Puma (Germany): PUMA United Kingdom Ltd
• Lacoste (France): Lacoste UK Limited

What Are the SECR Exemptions?

• Low energy use: Brands using 40 MWh or less in the year don’t need to report their energy use or emissions, but must state in their report that they qualify for this exemption. In practice, this is very unlikely for fashion brands with stores, offices or warehouses.

• Group report: A large subsidiary does not need its own SECR report if its UK parent company's group report covers it.

Example: Clarks reports through its parent, C&J Clark (No 1) Limited. Kurt Geiger and Fat Face also report through their parent companies.

SECR Reporting Requirements: 6 Things to Disclose

In-scope brands have 6 SECR reporting requirements:

1. Energy Use (kWh)

Energy use covers only the energy a brand uses itself: fuel burned in its own sites and vehicles (Scope 1) and the electricity it buys (Scope 2). Energy used in the supply chain, such as in fabric mills or factories (Scope 3), is not included.

Does it differ by company type? Yes.

• Quoted companies report total energy use worldwide, with the UK share shown separately.
• Large unquoted companies and LLPs report UK energy only, from gas, electricity and transport fuel.

2. Greenhouse Gas Emissions (tCO₂e)

Does it differ by company type? Yes.

• Quoted companies report Scope 1 and 2 emissions worldwide, with the UK share shown separately. This covers all fuel they burn, and the electricity, heat, steam and cooling they buy.
• Large unquoted companies and LLPs report UK emissions from gas, electricity and transport fuel. This includes fuel for business trips in employees’ own or hired cars. Bought heat, steam and cooling are optional.

3. At Least 1 Intensity Ratio

Does it differ by company type? No.

Every brand must show at least one intensity ratio – emissions compared to a business measure. This allows readers to compare years even when the business grows or shrinks. The brand picks the measure.

Fashion examples:

• Zara UK: tCO₂e per £m of turnover
• H&M UK: tCO₂e per square meter of retail space
• Puma UK: tCO₂e per square meter of floor space
• Boden: tCO₂e per employee
• Clarks: tCO₂e per £1,000 of turnover, and per 1,000 units sold

4. Methodology

Does it differ by company type? No.

Every brand must state how it calculated its figures. The law does not prescribe a method. The government recommends a recognized standard such as the GHG Protocol Corporate Standard or ISO 14064-1. Most brands also use the UK Government's annual GHG conversion factors, which turn energy use (kWh) into emissions (tCO₂e).

Fashion examples:

• Levi's UK follows the GHG Protocol and reports emissions two ways: location-based and market-based. The market-based figure reflects its renewable electricity contracts.
• Seasalt follows the GHG Protocol and the government guidance, using an operational control boundary.

5. Energy Efficiency Actions

Does it differ by company type? No.

Every brand must describe, in words, the main actions it took to cut energy use that year. If it took none, it must say so.

Fashion examples:

• H&M UK fitted full LED lighting in 23 stores, upgraded track lighting in 17 stores and improved energy management systems in 13 stores.
• Lacoste UK sets timers to switch off window-display lighting and turns off IT equipment overnight.

6. Previous Year's Figures

Does it differ by company type? No.

Every brand must show last year's figures next to this year's, except in its first reporting year.

(Overview of the SECR requirements)

How and Where Do Fashion Brands Report SECR?

SECR figures go in the brand's annual report, the yearly financial report every UK company must publish. The annual report is filed at Companies House, the UK government office that keeps company records. Once filed, it is public, so anyone can look up a brand's SECR figures online.

NOTE: A separate GHG or sustainability report does not replace this. Brands can reuse the same data, but the figures must appear in the annual report.

SECR Examples From Fashion Brands

These apparel and footwear brands publish a full SECR section in their latest annual report:

What Happens If a Brand Doesn't Comply?

SECR is part of UK company law. Directors who fail to include compliant SECR figures in the annual report can face a fine, with no fixed upper limit set in law. The Financial Reporting Council (FRC) can also ask a court to order a corrected report.

Separately, late annual reports trigger automatic late filing penalties: £150 to £1,500 for private companies and £750 to £7,500 for PLCs, doubled if accounts are late 2 years in a row.

Is UK SRS Replacing SECR?

The UK Sustainability Reporting Standards (UK SRS S1 and S2) are the UK version of the international ISSB standards. Published in February 2026, they will become mandatory for listed companies from 2027, on a “comply or explain” basis: brands either report the required information or publicly explain why they haven’t.

UK SRS does not replace SECR. The two rules apply side by side.

UK SRS goes much further than SECR. Brands report on climate risks, strategy, targets and Scope 1, 2 and 3 emissions, measured with the GHG Protocol. Scope 3 applies from the second reporting year.

For fashion brands, this will mean covering materials, manufacturing and transport, which is where most of the footprint sits.

Explore our textile regulations navigator by region.

Learnings for Fashion Brands From the 2026 SECR Review

In May 2026, the Department for Energy Security and Net Zero (DESNZ) published its post-implementation review of SECR, based on an independent evaluation. Here is what matters for fashion brands:

• SECR costs more than expected. Compliance takes about 94 hours of staff time and £7,100 a year on average, including outside help. Companies with 1,000+ employees spend about £12,200. 65% of ongoing costs go to consultants and auditors.

• Avoid a UK-only baseline you will have to redo. The review warns SECR's narrow scope can create "incomplete or UK-only baselines". When brands later add Scope 3 or other countries, emissions can appear to jump. Measure the full footprint from the start and report the SECR subset from it.

• Numbers differ across reports. Different rules can produce "multiple reported numbers for the same year". Use one dataset for SECR, CSRD, SB 253 and UK SRS.

• Go beyond the minimum. Investors want targets and transition plans. Companies with forward-looking commitments were more likely to report actual reductions.

How Carbonfact Can Help

SECR is the narrowest of the carbon reports a fashion brand produces. The risk is building it in isolation, then rebuilding the same numbers for CSRD, SB 253 and UK SRS.

Carbonfact is sustainability reporting software for apparel and footwear brands. We help brands measure emissions once and reuse them for various regulations:

• One dataset for every report. Scope 1, 2, and 3 sit in the same GHG Protocol-aligned inventory, so your SECR figures are consistent with your CSRD, SB 253, and UK SRS disclosures.

• Audit-ready methodology. Carbonfact's calculation engine is reviewed annually by PwC, so you can state your methodology with confidence.

• Automated reporting. Generate the SECR report using the data already in your account to populate energy consumption in kWh, emissions intensity ratio, carbon emissions, and the rest of the requirements.