Following up on my earlier post, I attended a webinar where Gary Shanahan, Head of Business and Industrial Energy Efficiency, Tax and Reporting at BEIS, clarified some key points:
- Timing: Organisations will report in their Annual Report and Accounts covering their first reporting period after 31st March 2019. Thus an organisation with the typical April-March financial year will report in their Annual report ending 31st March 2020 on energy and emissions from 1st April 2019 to 31st March 2020. These organisations have just six months to prepare their data collection processes. An organisation with a calendar year reporting cycle, January-December, would report on energy and emissions in the Annual Report and Accounts covering the period 1 Jan 2020- 31 Dec 2020, sometime in 2021.
- Scope: Unlike the CRC, subsidiaries only have to report their energy and emissions (either alone or as part of a group) if they themselves would qualify (the criteria being any 2 of the following: at least 250 employees, net annual turnover greater than £36m and net annual balance sheet total greater than £18m). In terms of Group reporting, it is not clear whether organisations with multiple overseas parents can nominate one single organisation to report on their behalf or whether there has to be a direct parent-subsidiary connection (I suspect the latter given the wording of the draft legislation).
The consultation website does not mention it, but there is draft legislation covering SECR, which I was able to track down. The legislation itself is somewhat “legalese” and has duplicate sections covering LLPs (Limited Liability Partnerships) , listed and unlisted companies, but the Explanatory Notes on page 19 do provide some clarification.
Finally, Gary Shanahan advised that it was the intention of BEIS to publish detailed guidance on the regulations by “the end of January 2019”, and I will update folks as soon as I see this is available.