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SECR and ESG reporting: how solar evidence actually fits in

What SECR requires and how to evidence on-site solar in your report. Solar can cut your reported emissions, yet it is never the whole net-zero story.

Corporate campus with a solar canopy over parking and planted green areas
Published by Solar StrategiesUpdated

Solar shows up in your SECR report in three places: the electricity you buy goes down, the electricity you generate on site is stated, and any power you export is shown separately. To report it safely you need metered data, not a brochure estimate. Plan that evidence before the panels go live, because the first report is not the time to find the meter readings are missing.

This article covers what SECR asks for, how to evidence solar, and how to avoid over-claiming. It is general guidance. Your auditor or accountant should confirm how it applies to your company.

What SECR requires

Streamlined Energy and Carbon Reporting (SECR) comes from the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. It applies to quoted companies and to large unquoted companies and LLPs, for financial years starting on or after 1 April 2019.

The government’s Environmental Reporting Guidelines say “large” means meeting two or more of these tests: turnover of £36 million or more, a balance sheet total of £18 million or more, or 250 or more employees. Company size limits in the Companies Act were raised for later years by SI 2024/1303, so ask your accountant which test applies to you now.

In scope, you report each year:

  • UK energy use, covering at least gas, electricity and transport fuel.
  • The related greenhouse gas emissions, at least those equal to Scope 1 and Scope 2.
  • At least one intensity ratio, such as emissions per unit of revenue or floor area.
  • What you did to improve energy efficiency in the year.

Low energy users are different. If you used 40 MWh or less, you do not make the detailed disclosures, but the guidance says you must state that you are not disclosing for that reason.

How solar changes the numbers

The guidance asks reporters to state the electricity they purchased, and, separately, the electricity generated from owned or controlled sources, saying whether it is on site or off site. It also asks for the amount of your own renewable power exported to the grid, and whether that export is backed by Renewable Energy Guarantees of Origin (REGOs).

Solar therefore lowers the electricity you buy. It does not make the electricity you still buy cleaner. For that grid power, the guidance asks you to use the grid average emission factor. It also says you may show a market-based figure alongside it, for example where you hold REGOs or a power purchase agreement, and it encourages reporting both.

An illustrative example

This example uses made-up numbers to show the layout. It is not a real site.

Line in the reportIllustrative figure
Total electricity used on site1,000 MWh
Generated by on-site solar120 MWh
Of which used on site100 MWh
Of which exported20 MWh
Bought from the grid900 MWh

Emissions from the 900 MWh bought would use the grid average factor from the current government conversion factors. The 100 MWh used on site does not appear as grid emissions. The 20 MWh exported is reported on its own line and states whether REGOs back it.

The evidence chain

A figure that comes from an installer’s yield estimate will not survive a hard question. Build the chain from real records:

EvidenceWhat it showsWhere it comes from
Commissioning recordsThe system, its address and its rated capacityYour installer at handover
Half-hourly generation dataActual output over timeInverter monitoring or meter
Import and export readingsWhat you bought and what you sent outYour supplier meters
REGO records, if you claim themCertificates issued per MWh of eligible outputOfgem’s REGO scheme

Ofgem says one REGO is issued per MWh of eligible renewable output. Whether you can use REGOs for power you consume yourself is a question for Ofgem’s guidance and your adviser, because the scheme page we checked does not cover it.

Keep on-site generation separate from anything you buy, such as a green tariff. On-site output is a physical fact you can meter. A purchased certificate is a contract. Mixing the two is a classic way to lose an auditor’s trust.

The mistake that gets picked apart

Solar is visible, popular and produces a pleasing number, so it tends to be over-claimed. Two errors recur:

  • Presenting solar as “our net-zero plan” with no evidence of efficiency, controls or purchasing changes beside it.
  • Treating generation as if it cut total emissions by the same amount, when most sites still buy a large share of their power from the grid.

SECR expects a short account of efficiency actions in the year. Boards and investors expect the same: each measure stated on its own, with its own contribution. If your report rests on one solar figure, expect the question “what else have you done?”. Our piece on what net zero actually requires of a UK business sets out the wider set of measures.

How this connects to UK SRS and other frameworks

The Department for Business and Trade published the final UK Sustainability Reporting Standards, S1 and S2, in February 2026, based on the ISSB’s global standards. ICAEW’s page on the UK standards tracks them. They are not yet a general legal requirement.

The FCA has consulted on requiring listed companies to report under UK SRS S2, proposing a start for accounting periods beginning on or after 1 January 2027. That is a proposal, and the final rules were due in autumn 2026, so check the current position. Government has also said it will review how UK SRS and SECR fit together, so SECR still applies in the meantime.

Lenders, investors and large customers often ask for the same energy data in their own formats. The practical lesson is to build the evidence chain once, to the highest standard anyone will ask for.

Putting it into practice

Before the system goes live, agree who owns the data, which meters feed the report and how you will store half-hourly records. Link this to the investment case, using the same figures your finance team used. Our guides on the full expensing mistake and corporation tax and solar cash flow cover the money side.

Our net-zero strategy service places on-site generation alongside efficiency, storage and purchasing, and produces the carbon and cost evidence in a form your finance and sustainability teams can defend.

SECR evidence starts with good data, because a report is only as strong as its meters. Our net zero strategy work sets out how solar fits your targets, while energy and ROI modelling records the expected generation. A feasibility study sizes the array, and portfolio optimisation ranks sites across a group. For the wider picture, read what net zero actually requires.

Further reading

Related insights

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