With the UK’s Streamlined Energy and Carbon Reporting (SECR) framework and the newer Sustainability Disclosure Requirements (SDR) placing increasing demands on transparency, the need for clarity, capability, and consistency in emissions reporting has never been greater.

Yet, many fleet managers do not understand the difference between Scope 1, 2, and 3 emissions, and if you rely on spreadsheets or paper-based processes to record fleet data, you could struggle to meet your requirements. This knowledge gap risks regulatory non-compliance, makes winning new work and retaining existing clients more difficult, and represents missed opportunities for operational efficiency and reputational leadership. Understanding the three scopes of emissions is vital for effective reporting.

Emissions scopes explained

The key reporting frameworks

SECR is a mandatory framework for large companies based on financial and employee thresholds, while SDR is a more expansive framework that gradually broadens the scope of mandatory climate and sustainability disclosures based on a company's size and market listing.

Streamlined Energy and Carbon Reporting (SECR)

Who must report:

All public companies and any private companies or Limited Liability Partnerships (LLPs) that meet at least two of the three criteria in a given financial year.
Thresholds:

• Annual turnover of more than £36 million.
• Balance sheet total of more than £18 million.
• Number of employees exceeding 250.

Sustainability Disclosure Requirements (SDR)

Thresholds and scope:

The newer SDR has broader reporting scope and is tiered, impacting a wider range of companies than SECR. While SDR doesn’t set a single threshold for Scope 1 and 2, it builds upon existing requirements like SECR but also introduces new obligations for broader climate-related financial disclosures.
Market Eligibility:

The specific thresholds and detailed reporting requirements under the SDR are tied to a company's market eligibility.

• Large-cap listed companies: Will have more extensive disclosure requirements from the outset.
• Mid-cap companies: Will have phased-in requirements.
• Large private companies: Will have requirements in line with the UK Financial Conduct Authority (FCA) rules.

Focus:

In addition to the energy reporting covered by SECR, the SDR requires reporting on the broader climate-related risks and opportunities impacting a company's financial performance.

Why does emissions reporting matter?

Fleet managers in large companies with legal reporting obligations

Under SECR and SDR, large companies are legally required to report Scope 1 and 2 emissions – and increasingly expected to disclose Scope 3. Fleet operations are often a major contributor to Scope 1 emissions, making accurate and auditable reporting essential.
Key priorities:

• Ensure full visibility of owned and leased fleet emissions.
• Integrate telematics and fuel data into central reporting systems.
• Align fleet strategy with corporate net zero targets.
• Avoid reputational and financial risk from non-compliance.

Compliance officers responsible for supply chain emissions

Scope 3 emissions, particularly those from transport and logistics, are increasingly scrutinised in ESG reporting and sustainability audits. Compliance officers must gather credible data from suppliers and ensure it meets regulatory and investor expectations.

Key priorities:

• Identify and engage high-impact suppliers (e.g. logistics, vehicle providers).
• Standardise emissions data collection across the supply chain.
• Ensure traceability and consistency in Scope 3 reporting.
• Support procurement teams with emissions-based decision-making.

Smaller companies within larger supply chains

Even if not directly regulated, smaller fleet operators supplying larger organisations are increasingly required to disclose emissions data. This is often a prerequisite for contract renewal, tender eligibility, or ESG alignment.

Key priorities:

• Understand Scope 1–3 emissions and how they apply to your operations.
• Prepare to respond to customer requests for emissions data.
• Build credibility and competitive advantage through proactive reporting.
• Avoid being excluded from future procurement processes.

Smaller companies not yet affected by regulations

Regulatory scope is expanding. As thresholds lower and voluntary reporting becomes the norm, smaller companies will increasingly be expected to understand and manage their emissions, especially if they seek investment or public sector contracts.

Key priorities:

• Future-proof your business by building emissions literacy now.
• Identify low-cost ways to track and reduce fleet emissions.
• Position your company as a responsible and forward-thinking supplier.
• Avoid being caught off-guard by regulatory changes.

The consequences of not meeting SECR and SDR

From a fleet management standpoint, failing to meet the SECR and emerging SDR frameworks can have consequences that go far beyond regulatory compliance. These frameworks are increasingly intertwined with corporate reputation, operational efficiency, and strategic positioning. Here's a breakdown of the key risks and impacts:

Regulatory and legal consequences

SECR (Mandatory for qualifying companies)

• Rejected annual accounts: Companies House may reject filings if SECR disclosures are missing or inadequate.
• Financial penalties: The Financial Reporting Council’s Conduct Committee can impose fines for non-compliance. Accounts that were rejected and subsequently amended may then incur late filing penalties.
• Audit and scrutiny: Inaccurate or incomplete reporting may trigger deeper audits or reputational scrutiny.

SDR (Emerging but expected to be mandatory for many)

• Future enforcement: SDR is being built on ISSB (International Sustainability Standards Board) and TCFD (Task Force on Climate-related Financial Disclosures) principles, with mandatory climate-related disclosures expected for large and listed entities.
• Cross-regulatory exposure: Non-compliance could affect ESG ratings, investor confidence, and access to capital.

Strategic and operational risks

Reputational damage

• Stakeholders increasingly expect transparency on sustainability.
• Failure to report undermines credibility with clients, partners, and employees – especially in sectors like transport and logistics where emissions are significant.

Missed efficiency gains

• SECR and SDR frameworks encourage data-driven energy management.
• Without compliance, fleets may miss opportunities to reduce fuel costs, optimise routes, or transition to lower-emission vehicles.

Competitive disadvantage

• Many tenders and partnerships now require ESG disclosures.
• Non-compliant fleets may be excluded from procurement processes or lose out to more transparent competitors.

Emissions blind spots

A recent study on fleet emissions reporting by business mobility specialists Alphabet found that:

38% of fleet managers still rely on basic spreadsheets or paper logs.
26% don’t understand Scope 1, 2, and 3 distinctions – a critical gap for strategic planning.
23% are unaware of financial penalties for failing to report.

This suggests that many fleets are not just non-compliant – they’re unaware of the risks they’re carrying.

Strategic implications for fleet managers

For fleet managers shaping policy and engagement across the UK fleet sector, non-compliance is a strategic vulnerability that could affect:

• Board-level governance.
• Investor and stakeholder trust.
• Long-term decarbonisation planning.
• Alignment with Vision Zero and broader ESG goals.

TCFD: Task Force on Climate-related Financial Disclosures

TCFD was created by the Financial Stability Board to help organisations disclose climate-related financial risks in a consistent, comparable way. It’s already mandatory for large UK companies and underpins much of the SDR framework.

TCFD’s four pillars for emissions reporting:

1. Governance: Disclose the organisation’s governance around climate-related risks and opportunities.
2. Strategy: Disclose the actual and potential impacts of climate-related risks and opportunities on the organisation’s business, strategy, and financial planning.
3. Risk management: Disclose how the organisation identifies, assesses, and manages climate-related risks.
4. Metrics and targets: Disclose the metrics and targets used to assess and manage relevant climate-related risks and opportunities.

TCFD’s seven disclosure principles:

1. Relevant.
2. Specific and complete.
3. Clear, balanced, and understandable.
4. Consistent over time.
5. Comparable across sectors.
6. Reliable and verifiable.
7. Timely.

These principles guide how emissions data should be presented – especially for fleets where operational complexity can obscure clarity.

ISSB: International Sustainability Standards Board

ISSB is part of the IFRS Foundation and is developing global baseline standards for sustainability disclosures. Its first two standards – IFRS S1 (general sustainability) and IFRS S2 (climate-related disclosures) – are now live and expected to be adopted into UK SDR regulations.

ISSB’s approach to emissions reporting:

• Builds on TCFD: ISSB incorporates all TCFD pillars and expands them with more detailed guidance.
• Requires scope 1, 2, and 3 emissions: Including methodologies, assumptions, and boundaries.
• Industry-specific guidance: Tailored metrics for transport, logistics, and fleet-heavy sectors.
• Forward-looking data: Emphasis on transition plans, scenario analysis, and future emissions trajectories.

Why it matters for fleet management

For fleet managers, these frameworks mean emissions reporting is no longer just a compliance task – it’s a strategic lever. They:

• Shape how fleet decarbonisation is communicated to stakeholders.
• Influence investment decisions, procurement policies, and risk assessments.
• Provide a structure for aligning Vision Zero, EV transition, and Scope 3 supplier engagement with broader ESG goals.

What good practice reporting looks like

To move beyond compliance and toward strategic emissions management, fleet operators should adopt the following best practices:

Establish clear boundaries.
Define which vehicles, sites, and activities fall within your reporting scope. Include grey fleet (employee-owned vehicles used for work) and subcontracted transport where relevant.

Use reliable data sources.
Avoid manual entry wherever possible. Integrate telematics, fuel card data, and EV charging logs to automate data capture and improve accuracy.

Apply consistent methodologies.
Use recognised standards such as the Greenhouse Gas Protocol or DEFRA conversion factors. This ensures comparability and credibility in your reporting.

Report by scope and activity.
Break down emissions by scope, vehicle type, fuel source, and operational activity. This helps identify hotspots and prioritise interventions.

Benchmark and track progress.
Set baselines and targets. Monitor year-on-year changes and align reporting with broader ESG or net zero strategies.

Engage stakeholders.
Ensure finance, procurement, HR, and operations understand their role in emissions reduction. Reporting should be a cross-functional effort, not a siloed task.

Invest in digital tools.
Make sure you have the right digital platforms and tools for tracking, analysing, and reducing fleet emissions.

Practical steps for fleet managers.

• Conduct a fleet emissions audit to identify Scope 1, 2, and 3 sources
• Transition from spreadsheets to digital platforms with automated data feeds
• Train staff on emissions scopes and reporting obligations
• Collaborate with suppliers to gather Scope 3 data
• Use reporting insights to inform vehicle procurement, route planning, and driver behaviour programmes

These five steps are broken down in the next section.

How to implement emissions reporting best practice

As emissions reporting becomes a strategic priority for fleet operators, translating high-level advice into actionable steps is essential. This guide breaks down each of the recommended actions from the 'Practical steps for fleet managers' section into clear, implementable tasks.

1. Conduct a fleet emissions audit

Objective: Identify all sources of Scope 1, 2, and 3 emissions across fleet operations.

How to do it:

Determine applicability

• SECR: Applies to large UK companies (quoted, unquoted, LLPs) meeting size thresholds.
• SDR: Emerging but expected to apply to listed companies and large private firms under FCA and ISSB-aligned rules.

Assign responsibility

• Appoint a cross-functional ESG lead or steering group (fleet, finance, procurement, operations, comms).
• Ensure board-level oversight and integration into risk and governance frameworks.
• Inventory your fleet assets and include all vehicles – owned, leased, and grey fleet.
• Map fuel and energy use to capture fuel types, volumes, and charging data.

Audit existing data

• Review current energy use, fuel consumption, and vehicle emissions reporting.
• Identify gaps in Scope 1 (direct fleet emissions), Scope 2 (electricity), and Scope 3 (supply chain, employee travel).
• Include indirect activities: Account for outsourced logistics, business travel, and commuting.
• Use recognised frameworks: Apply the Greenhouse Gas Protocol or DEFRA guidelines to quantify emissions.
• Document assumptions: Record data sources, conversion factors, and any exclusions.

2. Data capture and systems integration

Objective: Improve data accuracy, reduce manual effort, and enable real-time insights.

How to do it:

• Evaluate record keeping systems: Move away from speadsheets and paper-based systems to digital management systems that will integrate multiple data feeds and perform automatic calculations and analysis.
• Integrate data feeds: Connect telematics, fuel cards, and EV charging systems.
• Automate reporting workflows: Set up dashboards and alerts for anomalies or trends.
• Align with reporting standards.
• SECR: Include energy use, emissions, intensity ratios, and narrative on efficiency actions.
• SDR: Prepare for ISSB-aligned disclosures – governance, strategy, risk management, metrics & targets.
• Integrate with financial reporting: Ensure sustainability data is auditable and aligns with annual accounts, and collaborate with finance teams to embed disclosures into statutory filings.
• Ensure data security and compliance: Choose systems that meet GDPR and ISO standards.

3. Train staff on emissions scopes and reporting obligations.

Objective: Build internal capability and ensure consistent understanding across teams.

How to do it:

• Run workshops or webinars: Focus on Scope 1, 2 and 3 definitions and relevance to fleet. Define and communicate fleet-specific emissions reduction goals (e.g. % reduction by 2030)
• Communicate with stakeholders: Publish clear, accessible reports for clients, investors, and employees. Use dashboards, infographics, and case studies to show progress.
• Include reporting as part of onboarding: Make emissions literacy part of fleet, procurement and operations training.
• Use real-world examples: Show how poor reporting can lead to reputational or financial risk.

4. Collaborate with suppliers to gather Scope 3 data

Objective: Capture emissions from outsourced and upstream activities.

How to do it:

• Identify key partners: Focus on logistics providers, vehicle manufacturers, and fuel suppliers.
• Request emissions disclosures: Ask for carbon intensity data or lifecycle assessments, and work with your suppliers to ensure consistent reporting.
• Include reporting clauses in contracts: Make emissions transparency a procurement requirement.
• Use industry benchmarks: Where direct data isn’t available, apply sector averages from sources like DEFRA or SBTI.

5. Use reporting insights to inform strategy

Objective: Turn data into decisions that reduce emissions and improve efficiency.

How to do it:

• Analyse hotspots: Identify vehicles, routes, or behaviours with high emissions.
• Model interventions: Simulate the impact of EV adoption, route optimisation, or driver training.
• Align with wider ESG goals: Ensure fleet actions support corporate sustainability targets.
• Report progress internally and externally: Use dashboards, board reports, and public disclosures to share impact.

Conclusion

Each of these steps builds toward a more credible, efficient, and future-proof fleet operation. Emissions reporting is no longer a tick-box exercise – it’s a strategic imperative. By embedding emissions reporting into daily practice, not just annual compliance, fleet operators can meet regulatory requirements while also unlocking operational and reputational value.