If you're researching SECR for your multi-academy trust, you might be figuring out if you need to report now, getting ready for your next disclosure, or expecting to report in the near future.
In any case, it is important to understand the requirements.
Streamlined Energy and Carbon Reporting (SECR) might seem simple at first. You calculate your energy use and emissions, apply an intensity ratio, and add the results to your annual report. However, the calculation is often the easiest step.
Many multi-academy trusts deal with a mix of schools, suppliers, billing systems, and varying data quality. One school might have detailed electricity data, while another only has estimated bills every quarter. Another might be under a Private Finance Initiative (PFI) contract, where utility information is managed by an outside provider. When a new academy joins, its past data might be incomplete, inconsistent, or missing.
For a multi-academy trust, SECR means knowing what to report, creating a clear and reliable picture of energy use across all schools, and keeping this information consistent each year.
This guide explains SECR in straightforward terms. It covers who needs to report, what information to include, common challenges, and how to handle the process.
Is your academy trust in scope for SECR?
Under the current Academies Accounts Direction, an academy trust falls within SECR scope if it meets two or more of the following conditions:
- Turnover = More than £36 million
- Balance sheet total = More than £18 million
- Number of employees = More than 250
The trust must also consume more than 40,000 kWh of energy in the UK during the reporting period (more on that below).
The qualification period lasts two years. Your trust must meet two of the conditions for two years in a row to come under SECR, and fail to meet them for two years in a row to leave. Growing trusts should check their status well before the reporting deadline, not just when preparing annual accounts.
What is the low-energy user exemption?
If a trust meets the size conditions but consumes no more than 40,000 kWh during the reporting period, it qualifies as a low-energy user and is exempt from providing the full SECR disclosure. The trust still needs to measure or gather enough of its energy data to establish its position, and include a statement confirming exemption in its Trustees' Report.
Still, for most multi-academy trusts with several school buildings, using less than 40,000 kWh is rare.
Can trusts report voluntarily?
Yes. The DfE suggests that academy trusts not required to report under SECR can share their energy and carbon information on its website. This helps a growing trust set a baseline and get used to reporting before it becomes required.
Further reading: How to set your carbon baseline
Do the thresholds apply to each academy separately?
No. SECR covers the academy trust as a whole, not each school on its own. You need to look at the trust's total turnover, balance sheet value, and employee numbers for the whole organisation. If the trust prepares group accounts, you may also need to include relevant subsidiaries.
What must your trust disclose?
An in-scope trust must report on the following:
- Annual UK energy consumption in kWh
As a minimum, this covers gas, purchased electricity and relevant transport fuel. - Associated greenhouse gas emissions (tCO2e)
Reported in tonnes of carbon dioxide equivalent. - An emissions intensity ratio
This expresses emissions relative to the size of the trust (for example, tonnes of CO2e per pupil or per square metre of floor space). - The calculation methodology
A clear explanation of how you calculated the figures. - Energy-efficiency actions taken during the year
Or, if no actions were taken.
You also need to show the previous year's figures alongside the current year, unless the trust wasn't in scope then.
The disclosure should be included in the Trustees' Report, which is part of your annual report and accounts. The DfE also suggests that larger academy trusts publish this information on their website by 31 March, but this is optional.
What should the energy-efficiency narrative cover?
The energy-efficiency narrative should summarise the main energy-efficiency measures completed during the reporting year (for example, LED lighting upgrades, boiler replacements, solar panel installation) alongside estimated energy savings (where possible). If the MAT took no measures during the year, you should say so.
Note, this section should only include actions that have already been completed, not planned projects.
How Scopes 1, 2 and 3 apply to academy trusts
SECR disclosures are generally organised using the Greenhouse Gas Protocol's three emissions scopes.
Scope 1: direct emissions
These are emissions from sources owned or controlled by the trust, such as gas used in school boilers, heating oil or LPG, and fuel used in trust-run minibuses or other controlled vehicles.
Scope 2: purchased energy
These are the emissions associated with electricity purchased and used across academies, central offices and other trust-operated sites.
Scope 3: other indirect emissions
SECR does not require MATs to calculate their full Scope 3 footprint. However, one narrow category is mandatory: business travel in rental or employee-owned vehicles where the trust is responsible for buying or reimbursing the fuel.
Other Scope 3 emissions (such as purchased goods, waste, staff and pupil commuting, capital projects, trains, flights, taxis and contracted coaches) can be reported voluntarily as part of a wider carbon footprint or Climate Action Plan.
Which energy sources and emissions should MATs include?
In practice, most MATs will need to include:
- Gas used in school boilers
- Electricity used across academies and central offices
- Heating oil or LPG, where relevant
- Fuel used in trust-run minibuses
- Fuel used in other trust-owned or controlled vehicles
- Business mileage in employees' own vehicles where the trust reimburses the mileage or fuel
- Fuel purchased for rental vehicles used on trust business
When it comes to transport, the easiest way to decide what belongs in the mandatory disclosure is to ask whether the trust is buying the fuel or buying a transport service. A trust-operated minibus is included because the trust is responsible for the vehicle and fuel, whereas a coach hired for a school trip is not part of the mandatory figures because the trust is buying a transport service rather than purchasing the fuel directly. The same generally applies to trains, flights and taxis.
Why SECR becomes complicated across multiple schools
The final disclosure might only be a page or two in your annual report, but reaching that stage can be challenging.
In many trusts, SECR is handled by someone in finance, estates, or operations who already has a busy job and may not have a background in carbon accounting. Getting help from a consultant can be useful, but it is not always affordable, especially when much of the work is about collecting invoices, fixing spreadsheets, and filling in missing data.
The challenge is finding a reliable way to collect, check, store and calculate information across every school in the trust.
Working out what belongs in the report
Before collecting data, you need to be clear about which sites, organisations and activities fall within the reporting boundary.
This becomes more complicated where a trust has separate central offices, subsidiaries, shared community facilities, PFI arrangements or schools joining and leaving during the year.
Under some PFI and landlord-and-tenant arrangements, the trust may still need to report the energy it uses even where another organisation holds the account or pays the supplier. Shared meters create a similar issue: if one supply serves both the school and another organisation, the trust may need to estimate its share and record they reached that estimate.
Bringing data together across the trust
Most MATs become stuck trying to create one reliable dataset from information held across different schools, suppliers and systems. Missing invoices, estimated readings, duplicate accounts, incomplete data from new academies and inconsistent mileage claims are all common.
Without a central process, spreadsheets are sent back and forth, different versions appear, and supporting evidence stays in individual inboxes. A final total is not enough. The trust needs to know where each figure came from, if it was estimated, and what evidence supports it. Keeping all data, evidence, assumptions, and calculations in one place makes SECR easier to manage and gives auditors or consultants a clearer trail to follow.
Keeping the figures consistent from year to year
SECR requires comparative figures, so the process needs to be repeatable rather than rebuilt from scratch each year.
Results can change if schools join or leave, pupil numbers change, data improves, conversion factors are updated, or energy-efficiency projects are finished. Increased emissions does not always mean performance is worse, and fewer emissions does not always mean the trust used less energy.
What matters most is being able to explain what changed and why. This is much easier when the trust uses a consistent reporting structure, keeps its methodology in one place and can trace each figure back to the underlying data.
How to manage SECR across your trust
A workable SECR process usually has five stages:
- Confirm whether the trust is in scope
Check the financial thresholds and energy use across the group. - Define the reporting boundary
Identify which schools, sites, subsidiaries and transport activities need to be included. - Collect and check the data
Bring together invoices, meter readings, mileage records and other relevant information from across the trust, then check for gaps, duplicates and inconsistencies. - Calculate emissions and prepare the disclosure
Apply the relevant conversion factors, calculate the intensity ratio and produce the figures required for the Trustees' Report. - Document the methodology and retain the evidence
Your methodology should explain the reporting period, organisational boundary, data sources, conversion factors, treatment of missing or shared data, intensity ratio, assumptions, exclusions and any changes from the previous year. DfE model accounts recommend total gross emissions in tonnes of CO2e per pupil as the standard intensity ratio.
Your methodology does not need to be complicated. It just needs to show how the figures were calculated and where the data came from. The harder part is making sure every school uses the same approach, and that all data, evidence, and assumptions are kept together instead of being spread across different files and inboxes.
Can you complete SECR without a consultant?
Yes. You don't need to hire a specialist consultant to complete your SECR disclosure. Many trusts can handle the process internally with the right staff, structure and tools.
Carbon management software for trusts can help you collect the required data, calculate emissions, track your intensity ratio and keep all the supporting evidence in one place. This gives finance, estates or sustainability teams a practical way to complete SECR without relying on disconnected spreadsheets or needing specialist carbon accounting knowledge.
Some trusts may still want additional support, particularly if they are reporting for the first time, have complex PFI or shared-meter arrangements, are dealing with missing data or want help moving from compliance into a wider carbon reduction strategy.
Something to think about: When opting to use a consultant, consider who owns the process long term. Many MATs work with a consultant through an independent carbon measurement platform for schools, allowing them to gradually bring more of the work in-house when they no longer need the same level of support.
Closing thoughts (and how TrackZero ties in)
SECR is much more difficult if the work starts at the end of the year, when invoices are missing, supplier accounts have changed, and staff are asked to gather a year's worth of information quickly.
A better way is to collect and check data all year, keep the reporting boundary current, and store the evidence for each figure as you go. This makes the final disclosure easier to prepare and helps the trust see where energy is used and where it can be reduced. The same data can also support other work, like school Climate Action Plans, energy-efficiency projects, and long-term carbon reduction goals.
TrackZero gives MATs one place to manage this process for every school. Energy and transport data, emissions calculations, intensity ratios, evidence, and yearly figures are all kept together instead of being spread across spreadsheets, inboxes, and different file versions. You can manage reporting yourself, work with a consultant on the platform, or use extra TrackZero support when needed, without losing control of your data or having to rebuild the process each year.
Are you ready to make SECR reporting easier for your trust? Book a TrackZero demo.
