The regimes map · membership bodies and associations

Environmental regimes for membership organisations: what reaches you

None of the eight UK environmental regimes is written for membership bodies, so each reaches a professional body, trade association or members’ club only through its legal form, its size or what it does.

Two regimes turn on form and size: SECR and ESOS.

Others turn on activity: packaging supplied, premises in England and any building work.

The rest almost certainly pass a typical membership body by.

Form and size →What the body does Almost certainly not

Checked against 26 sources fromlegislation.gov.ukEnvironment AgencyDefra and Environment AgencyGOV.UKFCASee the sources

Form and size

How the body is constituted decides two regimes

SECR defines who it covers by corporate form, not by sector.

It has three populations: quoted companies, large unquoted companies and large LLPs.

There is no fourth population for charities, associations or trade bodies.

A membership body that is a company limited by guarantee and not quoted is an unquoted company, and the question is whether it is large.

It is large if it exceeds at least two of turnover of £36 million, a balance sheet total of £18 million and 250 employees, a test written into the paragraph’s own table at paragraph 20B(2).

ESOS asks a different question of the same body: is it an undertaking, and is that undertaking large?

The definition in section 1161(1) of the Companies Act 2006 takes in a body corporate or partnership, and an unincorporated association carrying on a trade or business, “with or without a view to profit”.

Being a not-for-profit body therefore does not, by itself, take an organisation outside ESOS.

A large undertaking employs at least 250 persons, or has turnover over £44 million and a balance sheet total over £38 million, and both money limbs must be exceeded (Schedule 1).

The Phase 4 qualification date is 31 December 2026, and notification of compliance is due by 5 December 2027.

Both regimes have group rules, so a body with a trading subsidiary should test the group, not only itself.

Source: SI 2008/410 Sch 7 Part 7A · SI 2008/1911 reg 12B · CA 2006 s.1161
How the body is constituted	SECR	ESOS
Company limited by guarantee, not quoted	Caught if large	Caught if large
LLP	Caught if large	Caught if large
Quoted company	Caught at any size	Caught if large
Unincorporated association	Not named in the text	Only if it carries on a trade or business

A trap for membership bodies

The accounts limits are not the SECR test

The Companies Act size limits rose on 6 April 2025; SECR’s did not.

Regulation 10 of SI 2024/1303 moved the Companies Act accounts limits to £54 million turnover and £27 million balance sheet total.

The SECR test sits in Part 7A, which that instrument left alone, so it stays at £36 million, £18 million and 250 employees.

Medium for the accounts, still in scope for SECR

Since 6 April 2025 a company can be medium-sized for its accounts under section 465 and still be in scope for SECR on the same figures.

A body that reads “large” as “over £54 million” will wrongly conclude that it is outside SECR.

ESOS has its own, higher money limbs, so a body can be inside SECR and outside ESOS.

What the body does

Packaging, premises and building work decide the rest

These regimes ignore corporate form and look at activity.

Our summary of SI 2024/1332 reg 24, SI 2025/140, TCPA 1990 Sch 7A, WRA 1991 s.27 and WIA 1991 s.118, as at 31 October 2026.
What the body does	Regime	The test	Where
Supplies packaged goods	Packaging EPR	Small producer: turnover over £1m and more than 25 tonnes of packaging. Large producer: over £2m and more than 50 tonnes	UK
Has premises where it produces waste	Simpler Recycling	Separate dry recyclables, food waste and residual waste; micro-firms (fewer than 10 full-time-equivalent employees) have until 31 March 2027	England
Builds or extends	Biodiversity net gain	A 10% gain, as a deemed condition of planning permission; exemptions include householder, de minimis, sites up to 0.2 ha and temporary development	England
Takes water or discharges trade effluent	Water licensing and consent	Abstraction over 20 cubic metres in 24 hours needs a licence; trade effluent to a public sewer needs the undertaker’s consent	England and Wales

Packaging EPR has seven classes of producer, including a seller and a service provider, and each tier needs both the turnover and the tonnage.

A body under £1 million turnover is outside both tiers whatever its tonnage, according to regulation 24.

Small producers pay no disposal fees, and regulation 60 makes disposal fees a large-producer cost that never falls on a seller.

The sources behind this page record no packaging rule specific to membership bodies or charities, so a body near the thresholds should confirm its position with the regulator.

On workplace waste, regulation 4(1) of SI 2025/140 speaks of waste collected from businesses, and the sources here do not settle whether a body not run for profit counts as one.

The Defra and Environment Agency guidance is headed workplace recycling in England, and the Environment Agency enforces it.

Biodiversity net gain bites only on development in England granted planning permission, so it matters to a membership body only when it builds or extends premises (exemptions changed on 6 August 2026).

Scotland, Wales and Northern Ireland run their own versions of several of these regimes, which this page does not cover.

Events and premises

No regime is written for events

The regimes map holds nothing specific to running conferences, exhibitions or member events.

An event reaches the map through activities the body already has: the packaging it supplies, the waste at premises it occupies in England, and any building work it commissions.

Who is responsible for waste at a hired venue is not something the sources behind this page settle.

A body that runs large events should therefore read its packaging position and its premises position separately, and not expect a single events rule.

Almost certainly not

The regimes that pass most membership bodies by

Each applies to a named category of operator, and a typical membership body is not in it.

Our reading of SI 2016/1154 reg 8, reg 61, the digital waste tracking service, the UK ETS overview, PS26/19 and FA 2021 s.55.
Regime	Who it names	It reaches a membership body only if
Environmental permits (EPR 2016)	Operators of the classes of regulated facility in regulation 8(1), in England and Wales only	it operates one, for instance a medium combustion plant or a specified generator
Pollution Inventory	A person served with a regulation 61(1) notice, plus a few site types the guidance lists separately	the regulator serves it a notice, or it runs a site of one of those types
Digital waste tracking	Waste receivers that must hold a permit or licence to receive waste	it receives waste under a permit or licence
UK Emissions Trading Scheme	Heavy industry, power, aviation and domestic maritime	it operates in one of those sectors
UK SRS under FCA PS26/19	Listed companies in the categories the final rules name	it is a listed company
Plastic Packaging Tax	Producers and importers of plastic packaging components	it produces or imports finished plastic packaging components at the section 55 registration level of 10 tonnes

“Almost certainly not” is our reading of each regime’s scope, not a determination about any one body.

Environmental permitting extends to England and Wales only, and further classes of regulated facility are being inserted by SI 2026/873, whose text we have not read.

A Pollution Inventory return follows a notice or a listed type of site, not the holding of a permit, so it is no concern to a body that has been served no notice and runs no such site.

A first sort

Four questions, in this order

Is the body a company, an LLP, or neither?

That settles whether SECR can reach it, and whether it is an undertaking for ESOS.

How many employees, and what turnover and balance sheet, including any group?

Those figures decide whether it is large for each of the two regimes, on different limits.

Does it supply packaging, and how many tonnes?

Below £1 million turnover the packaging regime does not apply at all.

Does it occupy premises or commission building work in England?

That is the route into workplace recycling and biodiversity net gain.

The full map, with every threshold and deadline, is on the environmental regimes map, and it includes a short scope checker.

Beyond the regimes

What this page does not cover

This page is only about which environmental regimes can reach a membership body.

It says nothing about how a body wins or keeps its members.

Our sister site Membership Quest covers how bodies approach membership acquisition, which is independent of this site’s regimes analysis.

This page is independent reference material, not legal advice; to talk your position through, you can book a free 15-minute call.

Frequently asked

Questions people ask

Do UK environmental reporting regimes apply to membership organisations?

Only through the body’s legal form, its size or what it does. None of the eight core regimes has a category for associations, professional bodies or trade bodies, so each one asks the same question of a membership body as of any other organisation: are you the kind of entity it names, over its threshold, doing the thing it regulates.

Does SECR apply to a company limited by guarantee?

It can. A company limited by guarantee that is not quoted is an unquoted company, and SECR applies if it is large: it exceeds at least two of turnover of £36 million, a balance sheet total of £18 million and 250 employees, under SI 2008/410 Schedule 7 paragraph 20B(2). A body that is neither a company nor an LLP does not appear in the SECR text at all.

Does ESOS apply to a charity or a not-for-profit body?

It can. ESOS applies to an undertaking, which the Companies Act 2006 section 1161(1) defines as a body corporate or partnership, or an unincorporated association carrying on a trade or business, with or without a view to profit. A large undertaking employs at least 250 persons, or has turnover over £44 million and a balance sheet total over £38 million.

Do packaging rules apply to a membership body that sells publications or merchandise?

Only if it is a producer above the thresholds. Packaging EPR counts a small producer as one with turnover over £1 million that supplies more than 25 tonnes of packaging, and a large producer as one with turnover over £2 million that supplies more than 50 tonnes. The sources behind this page record no separate rule for membership bodies or charities.

Does running events create an environmental reporting duty?

Not as such. The eight core regimes include nothing specific to events. An event can bring a body into packaging EPR through the packaging it supplies, into workplace recycling rules through premises in England, or into biodiversity net gain if it builds a venue.

Which regimes almost certainly do not apply to a membership body?

Environmental permits and the Pollution Inventory, digital waste tracking, the UK Emissions Trading Scheme, UK SRS under the FCA rules and Plastic Packaging Tax, unless the body operates a regulated facility, receives waste under a permit, works in a covered sector, is a listed company or produces plastic packaging components.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.

legislation.gov.uk
SI 2008/410, Schedule 7, Part 7A — large unquoted companies
Applies to unquoted companies; paragraph 20B(2) holds the £36 million, £18 million and 250 test.
legislation.gov.uk
SI 2008/410, Schedule 7 — matters in the directors’ report
Part 7 covers quoted companies, with no size test.
legislation.gov.uk
SI 2008/1911, regulation 12B — large LLPs
The LLP route: an energy and carbon report prepared by the members.
legislation.gov.uk
SI 2024/1303 — the 2024 size-limit changes
Moved the Companies Act accounts limits, not the SECR test.
legislation.gov.uk
Companies Act 2006, section 465
The accounts test at £54 million and £27 million, which is not SECR’s test.
legislation.gov.uk
Companies Act 2006, section 1161 — “undertaking”
Body corporate, partnership, or unincorporated association carrying on a trade or business, with or without a view to profit.
legislation.gov.uk
SI 2014/1643 (ESOS), regulation 2 — definitions
Gives “undertaking” the meaning in section 1161(1).
legislation.gov.uk
SI 2014/1643 (ESOS), Schedule 1 — the size test
At least 250 persons, or turnover and balance sheet both over the money limits.
legislation.gov.uk
SI 2014/1643 (ESOS), regulation 4 — Phase 4 dates
Qualification date 31 December 2026; compliance date 5 December 2027.
Environment Agency
How to comply with ESOS phase 4
The scheme administrator’s guidance on qualification and the 95% rule.
legislation.gov.uk
SI 2024/1332 (packaging EPR), regulation 24 — small and large producers
Turnover and tonnage, both required within each tier.
legislation.gov.uk
SI 2024/1332, regulation 15 — the seven classes of producer
Brand owner, packer/filler, importer, distributor, online marketplace operator, service provider, seller.
legislation.gov.uk
SI 2024/1332, regulation 60 — liable producers for disposal fees
Large producers supplying household packaging; never sellers.
legislation.gov.uk
The Separation of Waste (England) Regulations 2025 (SI 2025/140)
Regulation 4(1): micro-firms have until 31 March 2027.
Defra and Environment Agency
Simpler recycling: workplace recycling in England
Three waste streams; micro-firms have fewer than 10 full-time-equivalent employees; the Environment Agency enforces.
legislation.gov.uk
Town and Country Planning Act 1990, Schedule 7A — biodiversity gain
The 10% objective and the deemed pre-commencement condition, in England.
legislation.gov.uk
SI 2026/790 — biodiversity gain exemptions changed from 6 August 2026
New exemptions for sites up to 0.2 hectares and temporary development; self-build exemption omitted.
legislation.gov.uk
Water Resources Act 1991, section 27 — small-quantity abstraction
20 cubic metres in 24 hours, lost where part of a continuous operation or series.
legislation.gov.uk
Water Industry Act 1991, section 118 — trade effluent
Discharge to a public sewer needs the sewerage undertaker’s consent.
legislation.gov.uk
SI 2016/1154 (environmental permitting), regulation 1 — extent
England and Wales only.
legislation.gov.uk
SI 2016/1154, regulation 8 — regulated facilities
The classes of regulated facility; further classes are inserted by SI 2026/873.
legislation.gov.uk
SI 2016/1154, regulation 61 — information notices
The legal hook for the Pollution Inventory return.
Defra and Environment Agency
Digital waste tracking service
Mandatory for waste receivers that must hold a permit or licence.
GOV.UK
UK Emissions Trading Scheme: a policy overview
Covers heavy industry, power, aviation and domestic maritime.
FCA
PS26/19 — aligning listed issuers’ sustainability disclosures
Final rules for listed companies, comply-or-explain, periods from 1 January 2027.
legislation.gov.uk
Finance Act 2021, section 55 — Plastic Packaging Tax registration
10 tonnes of finished plastic packaging components.