Your Tenants' Energy Just Became Your Reporting Liability. Here's What SECR 2025 Means for Your Data.

The UK government has quietly tightened the screws on Streamlined Energy and Carbon Reporting (SECR). From 2025, large organisations must report scope 3 emissions — the indirect emissions from their supply chain, tenant activities, and capital goods. For building operators, this means the energy your tenants use, the waste they generate, and the embodied carbon in your next chiller replacement all become reportable numbers.

If your current data setup can't track these, you have a compliance problem that starts before the regulation lands.

What SECR scope 3 actually asks of building operators

SECR has existed since 2019 for quoted companies, large private companies, and LLPs. Until now, it covered scope 1 (direct emissions from gas, fuel, fleet) and scope 2 (purchased electricity). Scope 3 was voluntary.

That changes with the government's response to its 2023 consultation on SECR expansion. The new rules require reporting on:

• Category 1 — Purchased goods and services: The embodied carbon in everything you buy, from HVAC components to cleaning chemicals.
• Category 3 — Fuel and energy-related activities: Well-to-tank emissions for the energy you purchase.
• Category 5 — Waste generated in operations: Tenant and common-area waste streams.
• Category 6 — Business travel: Staff travel in non-company vehicles.
• Category 13 — Downstream leased assets: The energy use of your tenants, if you're the landlord.

For a hotel operator in Manchester or a commercial landlord in Canary Wharf, category 13 is the one that keeps chief engineers awake. You now need to report energy data from spaces you don't directly control — and you need it annually, auditable, and in tonnes of CO₂ equivalent.

Why most building data systems can't handle this

Here's the practical problem. Most BMS and energy management platforms were designed for scope 1 and 2. They track the gas boiler, the chiller plant, the main electricity meter. They do not track what happens inside a tenant's demised area, or what the waste contractor collects, or the carbon factor of the replacement AHU you installed last quarter.

A 180-room hotel in Birmingham we spoke with recently had 14 separate energy sub-meters for its F&B outlets, spa, and back-of-house. Only three were connected to the BMS. The rest were read manually, quarterly, by a maintenance supervisor who also handles pool chemistry and guest complaints. That data never made it into an annual report.

Under expanded SECR, that hotel's operator would need to estimate or measure those 11 unmetered zones. The Carbon Trust's guidance allows estimation for scope 3, but the methodology must be documented and consistent. A quarterly clipboard reading from a busy engineer is not a defensible methodology.

The data you need to start collecting now

If you manage a portfolio that falls under SECR — typically 250+ employees or £36m+ turnover — here is what you need to have in place before the 2025 reporting year:

Tenant energy data

For multi-let commercial buildings, you need either sub-metered tenant consumption or a robust allocation method. The EPC deadline changes for 2028-2030 already push landlords toward better data. SECR scope 3 makes it mandatory.

Waste data by stream

General waste, recycling, food waste, hazardous waste. You need tonnages and the waste contractor's emissions factors. If your contract only gives you a monthly lift count and an estimated bin weight, that won't pass audit.

Capital goods carbon

Every chiller, boiler, AHU, and roof replacement carries embodied carbon. The UK Green Building Council's Life Cycle Assessment guidance is the emerging standard. Start asking suppliers for Environmental Product Declarations (EPDs) on every major purchase.

Tenant and visitor travel

For hotels, this is significant. Guest travel to and from the property is scope 3 category 6. You need an estimate based on occupancy data, typical transport modes, and distances. The zero-carbon ready mandate from 2025 will compound this, as embodied carbon in retrofits also becomes reportable.

What this costs if you wait

The penalty for non-compliance with SECR is not a fine — yet. Companies that fail to report, or report inaccurately, face reputational risk, investor pressure, and potential qualification in their audit opinion. For listed companies, that matters.

But the real cost is operational. If you wait until the 2025 reporting deadline to gather scope 3 data, you will be doing it manually, under time pressure, with incomplete records. The cost of a one-off data collection exercise for a 50-building portfolio runs to £80,000–£150,000 in consultant fees alone, based on recent tender data from the Better Buildings Partnership.

Compare that to the cost of integrating sub-meters, waste management APIs, and procurement carbon factors into your existing BMS or energy platform. That integration typically costs £5,000–£15,000 per building, depending on complexity. And it gives you data you can use year after year — for SECR, for EPC compliance, for tenant billing, and for the operational savings that come from knowing where energy actually goes.

Where to start

Begin with a data gap analysis. Map every energy and carbon data point you currently collect against the SECR scope 3 categories that apply to your portfolio. The mandatory efficiency audits in Abu Dhabi follow a similar logic — you cannot manage what you do not measure.

Then prioritise the categories that represent the largest emissions and the weakest data. For most commercial landlords, that is category 13 (downstream leased assets) and category 1 (purchased goods). For hotels, add category 6 (business travel and guest transport).

Finally, look at your platform. If your BMS or energy management system cannot ingest sub-meter data, waste records, and EPDs into a single reporting view, you will be stitching spreadsheets together every March. That is where a platform like Herman comes in — it was built to handle exactly this kind of multi-source, multi-scope data, and to answer questions about it in plain English.

SECR scope 3 is not a distant regulatory change. It is the next reporting year. The buildings that have their data ready will file their reports, move on, and focus on the work that actually cuts carbon and cost. The ones that don't will be paying consultants to reconstruct last year's waste tonnages from bin-lift invoices.

— The HermanWa Team