Streamlined Energy and Carbon Reporting (SECR) for academy trusts

Updated 28 September 2022

Applies to England

1. Who is this guidance for?

This guidance is aimed at chief financial officers, accounting officers and trustees in academy trusts.

2. What is the status of this guidance?

The main financial reporting requirements for academy trusts are set out in the Academies Accounts Direction (AAD). This guidance is non-statutory and supplements but does not replace or modify any of those requirements. Accordingly, it should be considered in conjunction with the AAD.

The Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (the 2018 Regulations) implement the government's policy on Streamlined Energy and Carbon Reporting (SECR).

This guidance aims to support academy trusts by providing an overview of the 2018 Regulations to help academy trusts comply with their legal obligations. This guidance is based on HM Government Environmental Reporting Guidelines: including streamlined energy and carbon reporting guidance March 2019 (the Guidelines) and is not intended to cover every scenario that may arise regarding an academy trust's energy consumption and reporting.

If academy trusts have any questions on how to comply with the requirements, they should consult external guidance or professional advisors in the first instance.

3. Why are companies being asked to report on energy use?

The 2018 Regulations are designed to increase awareness of energy costs within organisations, provide them with data to inform adoption of energy efficiency measures and to help them to reduce their impact on climate change. They also seek to provide greater transparency for stakeholders.

4. Who needs to report and where?

ESFA has confirmed with the Department for Business, Energy and Industrial Strategy (BEIS) that academy trusts are within the scope of the legislation.

The 2018 Regulations require large unquoted companies that have consumed (in the UK), more than 40,000 kilowatt-hours (kWh) of energy in the reporting period to include energy and carbon information within their directors' (trustees') report, for any period beginning on or after 1 April 2019.

For academy trusts, disclosures were required for the first time in their 2019/20 accounts. From 2020/21 onwards, the prior year equivalent figures are also required to be disclosed for comparison purposes.

If an academy trust was not in scope in the previous year, there is no requirement to report prior year figures. However, the academy trust may report them voluntarily as comparative figures may aid the reader’s understanding of energy consumption.

Large companies, as defined in sections 465 and 466 of the Companies Act 2006, are companies that meet two or more of the following criteria:

  • turnover (or gross income) of £36 million or more,
  • balance sheet assets of £18 million or more,
  • 250 employees or more.

Note that if academy trusts report at a group level, the thresholds should consider these figures at aggregate level, including subsidiaries.

In assessing whether the 40,000 kWh threshold is met, academy trusts must consider, as a minimum, all the energy from gas, electricity and transport fuel usage in the UK that they are responsible for.

Where a large company does not consume more than 40,000 kWh of energy in a reporting period, it qualifies as a low energy user and is exempt from reporting under these regulations. A statement to this effect should be included in the academy trust's directors' (trustees') report.

The Guidelines acknowledge that in some circumstances, an element of the required energy and carbon information may not be practical to calculate. Where this is the case, this fact should be reported, and the academy trust should explain what is omitted and what steps it is taking to acquire this information in future.

5. Additional voluntary reporting

ESFA encourages large academy trusts to reproduce the energy and carbon disclosures from their accounts in a readily accessible format on their website before 31 March each year.

Where a company is not required to report under the 2018 Regulations, because of its size and/or consumption, BEIS encourages them to do so on a voluntary basis. Academy trusts in this position, which choose to report voluntarily, may do so on their website.

6. What do academy trusts need to disclose?

An academy trust that meets the thresholds at section 4 must publish, as a minimum:

  • its annual UK energy use (in kWh), as a minimum relating to gas, purchased electricity and transport fuel and associated greenhouse gas emissions (in tonnes of carbon dioxide equivalent (CO2e))
  • an emissions intensity ratio chosen by the academy trust. Intensity ratios compare emissions data with an appropriate business metric or financial indicator, such as pupil numbers, to allow comparison over time or with other organisations
  • the methodologies used to calculate the required information
  • a narrative of measures taken to improve energy efficiency in the period of the report. If no measures have been taken, this should be stated
  • the prior year equivalent figures are also required to be disclosed for comparison.

6.1 Subsidiaries

If an academy trust is reporting at group level, it must include energy and carbon disclosures of any subsidiaries included in the consolidation, unless the subsidiary would not itself be obliged to include the information if reporting on its own account.

6.2 Basis of occupancy

For academy trusts where there is a landlord/tenant arrangement in place (e.g. through a PFI agreement), the party responsible for the consumption of energy should take responsibility for reporting of it, despite not being directly responsible for its purchase.

7. Elements of the disclosure in detail

7.1 UK energy use

  • Electricity consumption – includes the purchase of electricity by academy trusts for their own use, including for the purposes of transport.

  • Gas combustion – includes gas consumed for stationary or mobile activities for which the academy trust is responsible.

  • Transport – includes energy consumption from transport where the academy trust is responsible for purchasing the fuel e.g. fuel used in company/fleet cars for business use, fuel used in personal/hire cars for business use (including where the academy trust reimburses staff for business mileage claims) and fuel used in academy trust controlled minibuses.

    This excludes where a transportation service is procured that includes an indirect payment for the fuel consumption e.g. train/plane/taxi/coach travel or similar where the academy trust does not operate the transport. However, an academy trust may elect to report them separately (including as part of Scope 3 emissions – see below).

  • Collecting energy use data - It is not expected that academy trusts will need to engage specialist consultants to support the reporting requirements; the example below shows how an academy trust could calculate the figures themselves.

    Academy trusts must use verifiable data where reasonably practicable and should consider obtaining meter data or using invoices or annual statements from suppliers. Where verifiable data is not available academy trusts may estimate data by using data from another comparable time period to fill the gap, calculating figures using pro-rata extrapolation or benchmarking to proxy the energy consumption of one site to a similar site.

7.2 Greenhouse gas (GHG) emissions

The trustees' report must state the annual gross quantity of emissions in tonnes of carbon dioxide equivalent resulting from the total UK energy use from electricity, gas and transport, as defined above. Government emission conversion factors for greenhouse gas company reporting should be used to help measure energy consumption in common units.

7.3 Emissions intensity ratio

The report must state at least one metric which expresses the academy trust's annual emissions in relation to a quantifiable factor. For consistency across the sector, academy trusts are encouraged to use tonnes of CO2e per pupil, with pupil numbers based on the Autumn Census data. The same ratio should be used each year for comparability.

7.4 Methodology

Academy trusts are required to disclose the methodology used to calculate the required information and it is important that robust and accepted methods are used.

There are several widely recognised independent standards available (as set out in the Guidelines) and the standard used in the worked example set out below is the GHG Reporting Protocol - Corporate Standard. Emissions are defined under three different scopes by the GHG Protocol.

8. Definition of emission scopes and their minimum reporting requirements under GHG Protocol

Scope Report
Scope 1 - direct GHG emissions

Includes emissions from activities owned or controlled by the academy trust that release omissions into the atmosphere. Examples include emissions from combustion in owned or controlled boilers, vehicles.
Report as a minimum:

• emissions from combustion of gas and fuel for transport purposes.
Scope 2 – energy indirect emissions

Includes emissions from own consumption of purchased electricity, heat, steam and cooling. These are a consequence of the academy trust's activities but are from sources not owned/controlled.
Report as a minimum:

• emissions from purchased electricity.
Scope 3 – other indirect emissions

Emissions that are as a consequence of the academy trust's actions, but the source is not owned or controlled, and which are not classed as scope 2 emissions.

For example business travel in private cars.
Report as a minimum:

• emissions from business travel in rental or employee-owned vehicles where the academy trust is responsible for purchasing the fuel.

8.1 Energy efficiency action

The report must include a narrative description of the principal measures taken to increase energy efficiency in the relevant year. It is recommended that the actions reported are those which have had a direct impact on energy efficiency and, where possible, the resulting energy saving from actions reported are also stated. If no measures have been taken, then this fact should be reported.

9. Other sources of information

The Charities Commission has published an information sheet on the Energy and Carbon Report Regulations 2018, as applied to Charitable Companies.

Academy trusts may also find information contained in recent Condition Improvement Fund (CIF) bids, the DfE Energy Providers Framework and in Display Energy Certificates helpful. ESFA has published Good Estate Management Tools which includes tips to reduce energy consumption.

10. How might academy trusts go about calculating their energy, greenhouse gas emissions and intensity ratio?

The following is a worked example and method of how an academy trust might undertake the calculations to support minimum disclosure.

The academy trust has 3 academies, all with their own boilers which are gas fuelled and electricity is purchased. The academy trust owns 2 diesel-powered mini-buses and has approximately 20 members of staff who claim business mileage. For both the mini-buses and business travel, the trust has recorded the number of miles travelled during the year.

This methodology follows the GHG Reporting Protocol and uses the 2022 Government emission conversion factors for greenhouse gas company reporting.

The conversion factors are updated annually and are generally released each year in June. Trusts should use the 2022 conversion factors for the 2021/22 financial year as these cover the greatest proportion of the year.

10.1 Table 2: illustrative example of how an academy trust might calculate figures for 2021/22

Energy Source Consumption Scope Emissions calculation
Gas – total kWh (kilowatt-hours) used for the year taken from gas bills for each academy within the trust 171,584 kWh (gross CV (calorific value)) Scope 1 171,584 kWh * 0.18254 (2022 fuels, natural gas conversion factor gross CV to kg CO2e)

= 31,321 kgCO2e

= 31.32 tCO2e
Electricity – total kWh used for the year, taken from the electricity bills for each academy within the trust 56,169 kWh Scope 2 56,169 kWh * 0.19338 (2022 UK electricity conversion factor to kgCO2e)

= 10,862 kgCO2e

= 10.86 tCO2e

Mini-bus 1 – 7,633 miles in the year

Mini-bus 2 - 7,800 miles in the year
15,433 miles * 1.12567 (2022 SECR kWh pass & delivery vehicles, vans class 2, diesel)

= 17,372 kWh
Scope 1 15,433 miles * 0.28186 (2022 delivery vehicles - vans class 2, diesel)

= 4,350 kgCO2e

= 4.35 tCO2e
Transport – total mileage for petrol reimbursed from staff claims = 1,332 miles 1,332 miles * 1.14779 (2022 SECR kWh pass & delivery vehicles, average car conversion factor to kWh, petrol)

=1,528 kWh
Scope 3 1,332 * 0.27436 (2022 business travel and average car conversion factor to kgCO2e, perol)

= 366 kgCO2e

= 0.36 tCO2e
Total 246,653 kWh   46.89 tCO2e
Intensity ratio Emissions data (tCO2e) compared with an appropriate business activity (pupil numbers as per Autumn census)   46.89 tCO2e/1,620 pupils

= 0.03 tCO2e per pupil

**To note: where an academy trust has data in litres of fuel consumed, the ‘fuels’ conversion factors should be applied, which provide more accurate emissions results. Fuel consumption data in litres can be converted to kWh using the ‘fuel properties’ tab. This is the preferred and more accurate data to use.

11. Disclosure of minimum information to be reported in the Trustee’s Report based on the above example

The previous year’s data must also be reported for comparison purposes.

UK Greenhouse gas emissions and energy use data for the period 1 September 2021 to 31 August 2022 Current reporting year 2021/22 Comparison reporting year 2020/21 (figures are for illustrative purposes)
Energy consumption used to calculate emissions (kWh) 246,653 255,530
Energy consumption break down (kWh) (optional):

• gas
• electricity
• transport fuel
Scope 1 emissions in metric tonnes CO2e

Gas consumption
Owned transport – mini-buses
Total Scope 1


Scope 2 emissions in metric tonnes CO2e

Purchased electricity


Scope 3 emissions in metric tonnes CO2e

Business travel in employee owned vehicles


Total gross emissions in metric tonnes CO2e 46.89 59.35
Intensity ratio Tonnes CO2e per pupil 0.03 0.04

Quantification and reporting methodology

We have followed the 2019 HM Government Environmental Reporting Guidelines. We have also used the GHG Reporting Protocol – Corporate Standard and have used the 2022 UK Government's Conversion Factors for Company Reporting.

Intensity measurement

The chosen intensity measurement ratio is total gross emissions in metric tonnes CO2e per pupil, the recommended ratio for the sector.

Measures taken to improve energy efficiency

We have continued to install smart meters across all sites and increased video conferencing technology for staff meetings, to reduce the need for travel between sites.