SECR Reporting Care Home Groups 2026 — BEIS Methodology

Streamlined Energy and Carbon Reporting (SECR) compliance is now mandatory for most major UK care home groups. The thresholds — 250+ employees, OR turnover >£36m, OR balance sheet >£18m (two of three for unquoted companies) — catch HC-One, Barchester, Bupa, Care UK, Avery, Anchor, MHA, and most regional groups operating 15+ homes.

For these groups, solar generation reduces Scope 2 (purchased electricity) and gets reported in the annual Directors’ Report. This piece sets out the methodology we recommend, the conversion factors that apply in 2026, and the group-level reporting playbook we deliver as standard at install handover.

What SECR actually requires

The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 require eligible UK companies and LLPs to disclose in their annual Directors’ Report:

• Total UK energy use in kWh (Scope 1 + Scope 2 minimum; Scope 3 optional)
• Total UK greenhouse gas emissions in tCO₂e
• A methodology statement covering the approach used and conversion factors applied
• At least one intensity ratio (typically tCO₂e per £m revenue, or per resident-bed for care)
• A narrative on energy efficiency actions taken in the reporting period
• A year-on-year comparison after the first reporting period

The framework is principles-based — there’s no single mandated format — but BEIS/DESNZ guidance and ICAEW best-practice frameworks set out the conventions.

Where solar shows up in the disclosure

Solar PV generation reduces purchased electricity, which is the Scope 2 category. The reporting treatment is straightforward in principle but has three methodology choices to make:

Choice 1 — Location-based vs market-based reporting. Location-based uses the average grid emissions intensity for the country (UK 2024: 0.18661 kgCO₂e/kWh, with the 2026 BEIS update typically published mid-year). Market-based uses contractual instruments (renewable energy certificates, green tariffs) where they exist. For solar self-consumption, both approaches converge — the energy doesn’t come from the grid in either accounting model.

Choice 2 — How to treat exported electricity. Exported solar electricity displaces grid generation elsewhere — strictly, this is a Scope 3 avoidance, not a Scope 2 reduction. Most groups report self-consumed solar as a Scope 2 reduction and disclose exported solar separately as a memo item.

Choice 3 — Sub-meter vs estimated allocation. Where individual sites within a group have separate energy meters, site-level reporting is straightforward. Where landlord-paid and tenant-paid metering is mixed (common in extra care and sheltered), the boundary needs an explicit methodology note.

The 2026 BEIS conversion factors

The BEIS Greenhouse Gas conversion factors for company reporting are updated annually, typically in June. Key factors relevant for care home SECR in 2026 (using the 2024 published factors until 2026 update):

• Electricity (UK grid average): 0.18661 kgCO₂e/kWh (location-based)
• Natural gas: 0.18293 kgCO₂e/kWh (delivered)
• Heating oil: 2.7559 kgCO₂e/litre
• LPG: 1.5570 kgCO₂e/litre
• Diesel (fleet): 2.6906 kgCO₂e/litre
• Petrol (fleet): 2.3192 kgCO₂e/litre

For a typical 50-bed nursing home using 75,000 kWh of grid electricity and 350,000 kWh of gas, baseline Scope 1 + 2 = 78 tCO₂e/year. A 50 kWp solar install displacing 28,000 kWh of grid electricity reduces Scope 2 by 5.2 tCO₂e/year (6.7% group reduction on that site).

How we deliver SECR documentation

As part of standard install handover, we provide:

• Generation log auto-extracted from monitoring platform — kWh by month and by year
• Scope 2 reduction calculation in tCO₂e using current BEIS factors
• Methodology note suitable for inclusion in the Directors’ Report
• Year-on-year comparison once second year of data is available
• Source data extract for auditor review — typically delivered within 5 working days of group request

For groups with multiple sites, we deliver group-aggregated data plus per-site detail. The aggregation accounts for site commissioning dates (a site commissioned mid-year contributes pro-rata to the year’s reduction).

Common reporting mistakes

We see four recurring issues when groups self-report:

1. Double-counting exported electricity. Exported solar can’t be claimed as both a Scope 2 reduction and a Scope 3 avoidance. Choose one (typically Scope 2 for self-consumption + Scope 3 memo for export) and document the methodology.

2. Failing to update conversion factors annually. BEIS factors change year-on-year. Using 2022 factors in a 2026 report misstates the reduction by 5–8% typically.

3. Site boundary ambiguity in mixed-tenure schemes. Extra care and sheltered schemes with mixed landlord and tenant metering need an explicit boundary. The cleanest approach is to report only landlord-supplied electricity in the SECR boundary and disclose the tenant portion as out-of-scope.

4. Skipping the energy efficiency narrative. SECR requires a narrative description of energy efficiency actions taken in the reporting period. “Installed solar PV at 6 sites” is a reportable action; “no actions” is non-compliant.

The TCFD overlay

For groups with institutional investors (private equity, infrastructure funds, pension fund LPs), TCFD-aligned disclosure is increasingly required alongside SECR. TCFD covers governance, strategy, risk management, and metrics — with quantitative metrics overlapping SECR substantially.

Solar contributes to TCFD scenario analysis under the “transition risk” axis: a portfolio with substantial Scope 2 reduction is more resilient to carbon-pricing and energy-cost-inflation scenarios. We provide the data needed for scenario analysis input — typically asked for by the group’s investor relations team during half-year or annual reporting cycles.

For more on the broader ESG reporting picture, see ESG, CQC and SECR Reporting for Care Home Solar or our grants and funding guide which covers the financial implications of each route.