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Year of commencement –

As part of the UK government’s approach to meeting its reduced carbon emission target, large organisations are required to gather and report their annual carbon emissions. ESFA have confirmed that  Multi-Academy Trusts  are within the scope of the  legislation, and the government have published guidelines SECR for Academy trusts which is summarised below.

The 2018 regulations require that any unquoted company that consumes more than 40,000 kilo-watt hours (kWh) of energy in the reporting period, to include their energy and carbon consumption in the directors (trustees) report for any period beginning on or after the 1st April 2019.

For Academy Trusts, the first period began in the accounting year 2019/20. With the exception of the first year, the previous year’s figures must be disclosed  as a comparison.

Which academies fall under the definition of large organisation?

Large companies as defined in Sections 465 and 466 of the Companies Act required any two of the following criteria being met to qualify;

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

Thus if a Multi-Academy Trust reports at a group level, the aggregated figure for all participating schools and subsidiaries must be included in the scope of the assessment.

What is included in the energy consumption?

In assessing whether the 40,000 kWh figure has been reached, they must include all the energy from Gas, Electricity and Transport fuel they have consumed in the UK.

If a qualifying trust, does not consume 40,000 kWh threshold, it will be deemed a low energy user and therefore does not need to report. A note – this affect shall be included in the Directors (Trustees) Annual Report. It will be a measure of good practice if energy consumption is reported voluntarily, notwithstanding that the mandatory thresholds have not been attained in the qualifying period.

What do academies include in the SECR?

An academy trust that meets the thresholds 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
  • narrative of measures taken to improve energy efficiency in the period of the report. If no measures have been taken, this should be stated
  • in future years, the prior year equivalent figures are also required to be disclosed for comparison, but this is not mandatory in the first year

Reporting is the responsibility of the Consumer, thus if a Landlord /Tennant Agreement exists, for example under a PFI Agreement, the Academy will undertake the SECR as the consumer, if not directly responsible for the purchase.


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)
    • 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.  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.
  • 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.

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.


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) .

Call to action, lowering the carbon footprint

The Climate Crisis is now at the top of the Agenda for Governments and Businesses as they seek to find a sustainable route and avoid a calamitous legacy for our children. Maybe your leadership team are the forefront of taking action to reduce carbon and energy consumption. Maybe stakeholders, pupils , PTA and the wider community that you serve are making explicit demands for change.

There are now many examples, where action has been taken that not only reduces consumption, but provides a sustainable solution and support your long term business plans.

Auditel have a highly experienced and qualified team to help you plan and implement your Net Zero journey.

We are delighted to offer a consultative workshop for you and your leadership team to help you understand your options. We will do this at any time to suit you, it will provided remotely and without charge!

For more information and to request the Net Zero report, please contact Nick Rumble by email: