Starting from the third compliance period, the Energy Savings Opportunities Scheme (ESOS) introduced additional reporting requirements. After submitting your compliance notification, you must produce an ESOS Action Plan and report annual progress updates.
What is an ESOS Action Plan?
An ESOS Action Plan is a strategic document developed after completing your ESOS energy audits. It must outline practical measures to improve energy efficiency and lower carbon emissions. It is essential for compliance and optimising your energy performance. You must submit an ESOS Action Plan within 12 months of the end of each compliance period. The action plan for the third compliance period must be submitted by the 5th of December 2024, but failing to do so you now have up until the 5th of March 2025, following a recent extension announced by the Environment Agency (EA).
Who should submit an ESOS Action Plan?
All ESOS participants (except those whose compliance notification reported zero total energy consumption during the reference period) must, following submission of their notification of compliance, submit an action plan and updates against the action plan which cover the subsequent four years, termed the relevant compliance period. The responsible undertaking which submitted the participant’s notification of compliance is responsible for producing and updating the action plan.
Any undertakings that leave their qualifying highest parent group or participant during the relevant compliance period are still required to comply with the requirements relating to an action plan and progress updates if they met the criteria for ESOS on the qualification date.
The essential components of an ESOS Action Plan
Your ESOS Action Plan must set out:
- All the actions you intend to take to save energy before the end of the action plan period (which for action plans relating to the third compliance period is the 5th of December 2027)
- For each action, a timeline for implementation
- For each action, whether it was recommended by the ESOS audit
- For each action, an estimate of the total energy savings you will achieve
- For each estimate, the source of data used for the estimate
- A combined estimate of the total energy savings you will achieve during the action period
- A breakdown of these savings by organisational purpose (buildings, transport, industrial processes and other energy use) Failure to take action or submit an action plan by the deadline will be recorded and published, highlighting non-compliance.
What to include in your ESOS Action Plan
To identify what to include, you must first examine your ESOS report and the results of your energy audits, or consider alternative compliance routes. Action plan requirements are the same for all, regardless of compliance route. However, the source from which recommended action/energy savings are drawn must be clearly stated. Trident can help you assess the results of your audit and support any additional feasibility studies that may be required.
Additional things to include in your ESOS Action Plan
Beyond the basics, you can publish other voluntary or mandatory actions to save energy and/or greenhouse gas emissions outside of ESOS. This could be specific actions you plan to take or your commitment to reduce consumption/emissions by a specific amount or percentage, in order for example, to match commitments or targets already made for a different purpose or scheme.
Other voluntary or mandatory schemes could include:
Targets or plans that relate specifically to another government scheme or alternative initiatives should be clearly set out in the action plan and identified as being outside of the ESOS recommendations.
By including additional actions, targets or commitments, you clearly demonstrate your commitment to save energy and reduce emissions.
Annual progress updates
Once you’ve submitted your action plan, you’re required to provide annual progress updates on your commitments over the next two years. These updates are due 12 months after the action plan deadline, and again 12 months after the first progress update submission. For the third compliance period, these deadlines are the 5th of December 2025 and the 5th of December 2026.
Each update covers the 12 months leading up to its deadline.
These progress updates aim to publicly report on the actions taken by ESOS participants and encourage them to follow through on their energy-saving commitments. Each update must be approved by a board-level director (or equivalent) and submitted through the ESOS notification system.
Failure to submit a progress update by the deadline will result in a default record indicating no energy-saving actions were taken.
What to include in your annual progress update
The basic information required in the progress update includes:
- A list of energy-saving actions outlined in the action plan that have been implemented over the previous 12 months
- A list of any actions that you did not implement
- For each successful action, whether it was implemented by the deadline set in the action plan
- For each action, an estimate of the total energy savings that you expect to achieve over the previous 12 month period
- For each estimate, the source of the data
- A combined estimate of the total energy savings you have achieved from these actions
If you do not submit an annual progress update by the deadline for the relevant annual progress update, it will be published that you took no actions to save energy during this period.
Additional information for your ESOS progress update
If you want to share more about your energy or carbon savings, consider including the following in your progress update:
- Actions taken to reduce energy consumption during the update period that weren't in your original action plan, along with estimates of the energy saved.
- For the first progress update, include actions taken between the compliance date and the action plan deadline (for the third compliance period, include actions from 6 December 2023 onwards) and the estimated energy savings from these actions.
- For the second progress update, provide additional estimates of energy saved from actions reported in the first update.
- Any actions taken to save carbon (even without energy savings) during the update period, and the resulting carbon savings.
Get support with your ESOS Action Plan
Navigating the complexities of ESOS requirements can be a challenge. Trident’s team of ESOS lead assessors will guide you through every step, from interpreting your energy audit results to crafting a comprehensive action plan that meets all regulatory requirements.
We’ll ensure that your ESOS Action Plan is not only compliant but also strategically designed to optimise energy performance and reduce carbon emissions. Our experts will support you in conducting additional feasibility studies and initiating or integrating voluntary actions to demonstrate your commitment to sustainability.
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