Starting from the third compliance period, the Energy Savings Opportunities Scheme (ESOS) now requires additional reporting. After submitting your compliance notification, you’ll need to create an Energy Action Plan (EAP) within 12 months of the end of each compliance period and provide annual progress updates.
As your partner in planet-first energy, Trident can guide you at each step of the way.
What is an Energy Action Plan?
Once you’ve submitted your ESOS compliance notification, the next step is to create an Energy Action Plan. This plan highlights real, actionable ways you intend to reduce energy use and carbon emissions before the next ESOS assessment.
The entity that was responsible for filing the compliance notification is responsible for compliance with the Action Plan and the subsequent progress updates. If a company leaves its parent group but was part of ESOS on the qualification date, it must continue meeting the requirements of its Energy Action Plan and reporting.
Failure to act or submit your Action Plan by the deadline will be recorded and publicly reported as non-compliance. (The initial deadline to submit Energy Action Plans for the third compliance period was 5 December 2024, extended to 5 March 2025. If you haven’t yet submitted your Action Plan and are unsure what to do next, please get in touch, we’re here to help).
The essentials of an Energy Action Plan
Your Energy Action Plan must outline all the energy-saving actions you will take throughout the plan period (which for action plans relating to the third compliance period, this covered actions from 6 December 2023 to 5 December 2027).
It must include:
- A timeline for implementing each action
- Whether each action was recommended in your ESOS compliance notification
- Estimated total energy savings for each action
- The data sources used for these estimates
- A combined estimate of total energy savings over the action period
- A breakdown of savings by category (buildings, transport, industrial processes, and other energy use)
What else to include in your Energy Action Plan
Beyond the required measures, you can also highlight other voluntary or mandatory steps your business is taking to save energy and reduce greenhouse gas emissions.
These could include:
- Specific energy-saving initiatives you plan to implement
- Commitments to cut energy use or emissions by a set amount or percentage
- Actions that align with existing sustainability targets or industry schemes
Other voluntary or mandatory schemes may include:
- Climate Change Agreements (CCAs)
- UK Emissions Trading Scheme (ETS)
- UN Race to Zero
- Science-Based Targets Initiative (SBTi)
Including these details can help demonstrate your broader commitment to energy efficiency and environmental responsibility.
Make sure to submit annual progress updates
Once your Action Plan is submitted, you’re required to provide annual progress updates on your commitments. The first progress update is due 12 months after the action plan deadline, and the second is due 12 months after your first progress update submission.
What to include in your annual updates
Your annual ESOS progress update should include:
- A list of energy-saving actions from your Action Plan that were implemented in the past 12 months
- Any planned actions that were not implemented
- Whether each completed action met its planned deadline
- Estimated total energy savings achieved over the 12-month period
- The data sources used for these estimates
- A combined estimate of total energy savings from all actions
You can also include additional details on energy and carbon savings, such as actions taken outside your original plan, estimated savings from early actions, and updates on previously reported measures. You may also report carbon-saving actions, even if they didn’t reduce energy use.
Why ESOS progress updates matter
Progress updates help track and publicly report the energy-saving actions taken by ESOS participants, encouraging follow-through on commitments.
Each update must:
- Be approved by a board-level director (or equivalent)
- Be submitted through the ESOS notification system
Failing to submit an update by the deadline will result in a default record stating that no energy-saving actions were taken.
Your partner in Energy Action Plans
Energy Action Plans and updates can be tricky, but with Trident's team of experienced ESOS lead assessors and Consultant Engineers, you’re accessing more than 100 years of energy industry experience. We provide guidance through every step, from interpreting your energy audits to crafting a comprehensive action plan.
As your partner in planet-first energy, we’ll make sure your Energy Action Plan is not only compliant but also designed to optimise energy performance and reduce carbon emissions.