Energy Action Plans vs ESOS Energy Audits

In this article, we’ve highlighted the differences between EAPs and the energy audits conducted in the previous phases of ESOS. Highlighting both the expanded scope and the strategic intent behind EAPs. 

Purpose of an EAP

The purpose of the action plan and progress updates is to increase participants’ accountability for taking action to reduce their energy use. Participants will be required to provide updates on, any measures that they intend to implement to save energy before the end of the compliance period which follows that in which they submitted their notification of compliance.

For example, organisations that are required to submit notifications of compliance at the end of the third compliance period can choose to submit an action plan and progress updates by the end of the fourth compliance period, 5 December 2027. The measures can be drawn from the ESOS audit or alternative compliance routes, but do not have to come from one of these sources.

Voluntary nature vs Compliance

In previous phases of ESOS, companies carried out  energy audits  to identify areas for improvement, but implementing any of the recommendations was not mandatory. Audits focused primarily on energy use and cost-saving opportunities. Still, businesses did not have to take any action after the assessment. 

By contrast, introducing  Energy Action Plans adds a layer of structured action, but the actions remain voluntary. This shift towards action encourages companies to transition from simple compliance to proactive energy management. 

Businesses still don’t face legal requirements to implement the energy-saving measures identified, but . The EAP provides a more transparent framework, helping them concentrate on and organise energy efficiency initiatives. 

Action plans and annual progress updates will be published by the Environment Agency within 6 months of the deadline for notifying them, or within 6 months of them being received, whichever is later. 

The strategic focus of Energy Action Plans

Unlike the traditional ESOS energy audits, which are primarily concerned with assessing energy usage and identifying cost-effective savings measures, Energy Action Plans  are strategic in nature. The aim of EAP is to: 

• Foster a culture of continuous improvement in energy management.  

• Encouraging businesses to set specific, measurable goals for energy reduction and to track their progress over time.  

• Promote innovation by encouraging businesses to explore new technologies and practices that can lead to significant energy savings.  

• Ultimately, the strategic focus of Energy Action Plans empowers businesses to take ownership of their energy management practices and establish clear, structured goals for reducing energy consumption. 

• Create a roadmap for implementing energy-saving opportunities over time.

• Align with broader sustainability and net-zero targets such as Climate Change Agreements (CCAs), Streamlined Energy and Carbon Reporting (SECR), UK Emissions Trading Scheme (ETS), UN Race to Zero, Science-Based Targets Initiative (SBTi) , which are becoming more critical for businesses and regulators. 

Including EAPs also fosters alignment with corporate sustainability objectives. This ensures that energy efficiency efforts are not treated as one-off actions. but as part of a comprehensive strategy for continuous improvement, instilling confidence in their effectiveness.  

More comprehensive coverage

Energy audits under ESOS focus mainly on identifying opportunities for improvement in specific processes or systems. EAPs will encompass a broader review of an organisation's energy management practices, policies, and performance indicators.

This comprehensive approach helps businesses better understand their energy consumption in a broader context, integrating energy efficiency into their overall business operations.

• Audits were often seen as isolated assessments, typically looking at specific sites or operations.
• EAPs involve a more holistic approach, considering the entire organisational energy footprint and how organisations can minimise energy consumption across all levels.
  

Ongoing monitoring and reviews

Under previous energy audits, once the ESOS assessment was completed, there was typically no requirement for ongoing monitoring or review until the next audit cycle. This infrequency of energy audits can be a relief, as it reduces the administrative burden.

Energy Action Plans, on the other hand, encourage a process of regular review and updating. They support the ongoing tracking of progress toward energy efficiency goals, ensuring businesses stay on course over time.

Energy Audits = One-off assessments every four years.

EAPs = Emphasise continuous improvement, with the potential for ongoing revisions and updates.

Support for implementation

Businesses would receive the audit recommendations without apparent support or structure for implementing them. Energy Action Plans change this dynamic by creating a pathway that encourages the implementation of energy-saving measures.

They provide more practical guidance on the steps needed to realise the potential savings. Moreover, how to integrate those steps into the organisation’s business model.

The transition from traditional energy audits to Energy Action Plans is a significant one. These plans, while not mandatory, represent a more strategic and comprehensive approach to energy management. They emphasize action, continuous improvement, and the integration of energy efficiency into business strategies and sustainability goals.

This is a shift from the previous focus on regulatory compliance. The voluntary nature of these plans encourages proactive energy management across industries.

Summary

To summarise, introducing Energy Action Plans (EAPs) in ESOS Phase 3 aimed to strengthen the scheme's impact. Along with addressing a key gap from previous phases. Previous energy audits identified savings opportunities, but there was no obligation to implement them. EAPs provide a structured framework to encourage businesses to take proactive steps toward energy efficiency.

Finally, EAPs align ESOS with the UK's net-zero emissions goals. They promote action to reduce energy consumption and greenhouse gas emissions. This shift ensures that ESOS supports national sustainability targets, driving meaningful contributions from businesses toward carbon reduction.

If you'd like to discuss your Energy Action Plan for ESOS then don't hestitate to get in touch with us today, our compliance team and lead assessors understand the requirements and can support you in developing your EAP so you don't miss the submission date, which is the 5th of December this year. Or if you're keen to know what's in store for the next phase of ESOS, we've summarised all you need to know about ESOS Phase 4