A summary of the FRC review findings on SECR - Inteb

A summary of the FRC review findings on SECR


In September 2021, The Financial Reporting Council (FRC) published its review of emissions, energy consumption and related matters under the new Streamlined Energy and Carbon Reporting (SECR) rules, which came into effect in the UK in April 2019.

Which companies took part in the review?

The FRC’s review sampled a selection of 27 companies, including Limited Liability Partnerships (LLPs), from a cross-section of industries that had complied with SECR requirements. However, heavy bias was placed on those who expected to generate significantly high emissions.

The 27 unnamed businesses included:

  • 10 FTSE 350 companies
  • 10 AIM-quoted companies
  • 5 large private companies
  • 2 LLP’s

What were the reports key observations?

While the 21-page report is thorough, there were three main takeaways:

One. The sample companies complied with the minimum statutory disclosure requirements

Every company revealed their emissions and energy use – but several had errors or omissions.

Two. Changes are needed to make disclosures understandable and relevant for users

The FRC admitted they’d made mistakes in this first year of reporting, including not requesting sufficient information about how emissions and energy were calculated.

It was also unclear whether the ratios were the most appropriate for the entities’ operations. And it wasn’t possible to recalculate emissions ratios by reference to other disclosures in the report, including emissions per £m revenue.

And disclosures about energy efficiency measures weren’t straightforward.

Three. The FRC saw examples of emerging good practice

Several reports included encouraging information relating to SECR guidelines, including Scope 3 emissions, information about switching and using renewable energy.

Many reports included emission reduction targets or an intention to set targets. While the best practice examples explained ‘net-zero’ or other emission-reduction commitments and strategies, including:

  • Specific details
  • Pathways
  • Interim targets

They also reported encouraging progress on climate-related matters in the context of a developing regulatory environment.


Put simply, what all of the above means is that while the sample companies largely complied with the minimum disclosure requirements for energy consumption and emissions, more needs to be done by the FRC to make the report understandable and relevant for the sample group.

In particular:

  • How information is calculated needs to be much clearer
  • Which operations and emissions are included in the reported numbers
  • The level of third-party assurance obtained over the information

And they also need to consider how to integrate other narrative reporting on climate change, especially for emission-reduction targets.

What this means for your business

Every business is honour-bound to reduce its carbon footprint. But to do that effectively, you need to calculate your emissions.

That’s where we can help.

At Inteb, our experts help you set targets and put a framework in place to meet your net-zero targets. And for added peace of mind, we’re accredited to FutureNetZero standard, which means we give practical and accurate advice to companies serious about reaching net-zero.

We do the work. You reap the benefits.

Start reducing your carbon emissions today

Let’s get the conversation started – call us now on 0151 601 3476