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.
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).
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.
Your ESOS Action Plan must set out:
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.
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.
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.
The basic information required in the progress update includes:
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.
If you want to share more about your energy or carbon savings, consider including the following in your progress update:
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.