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Energy Savings Opportunity Scheme: Ensure Compliance for ESOS Phase 3 & 4
Discover the requirements and benefits of the Energy Savings Opportunity Scheme. Download our helpful ESOS compliance checklist to see if your business is on its way to compliance on time. It’s a must-read for UK businesses.

Expert ESOS guidance for UK organisations
The Energy Savings Opportunity Scheme (ESOS) is a mandatory energy assessment and energy savings identification scheme for large organisations in the UK. The scheme is designed to encourage enterprises to identify cost-effective energy savings measures and ultimately contribute to the UK’s efforts in reducing carbon emissions.
As we approach ESOS Phase 3 and look forward to Phase 4, qualifying businesses must understand the requirements, deadlines, and how to create an actionable ESOS action plan to ensure compliance and avoid hefty fines.
To qualify, an organisation must be a “large undertaking” in the UK with 250+ employees, an annual turnover exceeding £44 million, and an annual balance sheet total exceeding £38 million.
Download our checklist to make sure you stay ahead of the compliance deadline.
Value we deliver
In-house expertise
We were among the first UK consultants to offer ESOS-compliant Lead Assessors, ensuring early compliance.
Guaranteed success rates
While the environment agency found 63% of Phase 2 evidence packs required corrective action, 100% of our clients achieved compliance.
Beyond compliance
ESOS is more than a box-ticking exercise. We help implement sustainable solutions that reduce energy costs and improve efficiency.
Start saving early
Identifying energy-saving opportunities early makes commercial and environmental sense, especially with high energy prices.
Preparing your ESOS action plan
Completing an ESOS assessment now has additional requirements per the 2023 regulations. In addition to completing ESOS assessments every four years, businesses must submit an ESOS action plan and report annual progress updates to the Environment Agency (EA). Starting from the third compliance date, following the submission of the compliance notification, you must produce an action plan setting out the following:
- Steps to reduce energy consumption
- Implementation timelines
- Recommendations from your ESOS assessment
- Expected energy savings over four years
- Methods to estimate these savings
A board-level director must approve and submit the action plan.
Looking ahead to ESOS Phase 4
Phase 4 of the Energy Savings Opportunity Scheme (ESOS) has commenced, with key deadlines as follows:
- Qualification Date: 31st December 2026
- Start of Compliance Period: 6th December 2023
- End of Compliance Period/Final Compliance Date: 5th December 2027
Businesses can start their ESOS Phase 4 work as early as 6th December 2023, when the compliance period begins. This phase introduces a mandatory energy reduction action plan and annual reporting requirements. Large undertakings must report their progress against these action plans by 5th December of each interim year (2025 and 2026), leading to the Phase 4 assessment 2027.
The Environment Agency recommends starting early to ensure compliance and avoid penalties. Being proactive and starting early will give your organisation a head start in understanding and implementing the changes.

ESOS Phase 3 checklists & tips to prepare for ESOS Phase 4
The deadline for phase 3 of ESOS is 6th August 2024. Our helpful checklist walks you through the steps for completing compliance. Our checklist covers everything from understanding the scheme’s eligibility criteria to conducting energy audits and implementing energy-efficient measures.
Fill out the form below to get your checklist.
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FAQs
What will ESOS Phase 4 look like?
The government has stressed that Phase 4 will focus on covering Net Zero as well as energy efficiency, to support the Net Zero 2050 target.
What else will Phase 4 include?
Certain data will become mandatory to be made public. Examples include carbon reduction targets and Net Zero assessments.
What are the penalties for not complying?
A fixed penalty of £5,000 plus an additional £500 per day until notification is completed. Other penalties could be damage to reputation for not complying and cost of lost opportunity from failing to identify energy saving measures.
Has the ESOS Phase 3 deadline changed?
Yes, the deadline was extended to 5th June 2024 in June 2023 due to the increased data requirements announced a month earlier. This six-month extension is to give ESOS-qualifying organisations more time to fulfil their compliance. The Environment Agency made no changes to the qualification criteria.
Is it harder to submit ESOS Phase 3 data than it is for ESOS Phase 1 or 2?
Yes, you now need to submit significantly increased levels of data to completely fulfil your ESOS phase 3 compliance compared to both Phase 1 and Phase 2. This was due to the Environment Agency announcing an increase in the ESOS Phase 3 data requirements in May 2023 followed by a 6-month ESOS Phase 3 deadline extension to 5th June 2024.