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Energy Savings Opportunity Scheme (ESOS)

Get ready for ESOS Phase 4

Is your business prepared for the next phase of the Energy Savings Opportunity Scheme? Phase 4 is here, and it's essential to stay compliant to avoid penalties and benefit from energy savings.

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ESOS compliance

What is the Energy Savings Opportunity Scheme (ESOS)?

ESOS is a mandatory energy assessment scheme for large organisations in the UK. If you are one of the 12,000 businesses that meet the criteria, you must carry out regular energy audits and identify cost-effective energy-saving measures.

As Phase 3 draws to a close and we look ahead to Phase 4 of the scheme, it is important to be aware of the next reporting deadline which is fast approaching on the 5th of December 2024.

Completing an ESOS assessment now has additional requirements, in line with the 2023 regulations. In addition to completing ESOS assessments every 4 years, businesses are required to submit an ESOS action plan and report annual progress updates to the Environment Agency (EA).

The EA has announced an extension and will accept Action Plans submitted by the 5th of March 2025.

We’ve helped over 100 businesses achieve ESOS compliance.

Download our helpful checklist
ESOS Phase 3 & 4

Start crafting your ESOS Action Plan

Starting from the third compliance date, following the submission of the compliance notification, you must produce an action plan, setting out:

  • what you intend to do to reduce energy consumption
  • when you intend to do it
  • whether it was recommended through your ESOS assessment
  • what energy savings you expect to achieve over the four years covered by the action plan
  • how you estimate these savings

The action plan must be approved by a board-level director (or equivalent) and must be submitted through the compliance notification system by the 5th December 2024.

Recently, the Environment Agency (EA) has announced an extension and will accept Action Plan submissions up until the 5th of March 2025.

Get support with your action plan

Key milestones

6th August 2024
Phase 3 deadline

5th December 2024
Phase 3 action plan deadline

5th March 2025

Action Plan submission extension

5th December 2025
Phase 4 progress update

5th December 2026
Phase 4 subsequent progress update

5th December 2027
Final ESOS Phase 4 Submission

Summary of key changes to the scheme

The headline change to the ESOS scheme is the introduction of a mandatory energy reduction action plan, designed to ensure energy assessments lead to tangible improvements in energy performance. For the first time, ESOS brings in an annual reporting requirement. Large undertakings must report against their action plans by the 5th of December of each interim year (2025 and 2026), leading up to the Phase 4 assessment by the 2027 deadline.

Changes to the scheme will result in estimated savings of £1.12 billion over 2023-2037 through reduced energy bills.

ESOS regulation and penalties

Your environmental regulator is responsible for compliance and enforcement activities. It may issue civil sanctions, including financial penalties if an organisation does not meet the scheme’s obligations.

 

What are the benefits of complying with ESOS?

If your organisation fulfils the survey, then you will benefit from:

  • A reduction in your energy consumption
  • Identify several cost-saving opportunities
  • Understand ways to lower your carbon emissions

Value we deliver

In-house expertise

We were among the first UK-based consultants to offer ESOS lead assessors, helping organisations to meet requirements as early as possible.

Guaranteed success rates

An audit by The Environment Agency found a shocking 63% of Phase 2 evidence packs were only partially compliant and required some corrective action. We are proud to declare that 100% of our customers achieved compliance through our ESOS guidance.

Beyond compliance

We can help you implement sustainable solutions that reduce energy costs and optimise energy efficiency.

Start saving now

By taking action today you can reap the benefits sooner from your energy-saving opportunities. With energy prices high this makes good commercial sense as well as being good for our environment!

What our clients think

When faced with the compliance requirements, our business did not hesitate to contract the services of Trident yet again to steer us through the requirements of both Phase 1 compliance and subsequently Phase 2.

M Hegarty - Greenergy Biofuels Ltd
Trident Utilities ESOS compliance checklist
Download form

ESOS compliance checklist

For more information, please fill out the form below to download our helpful ESOS phase 3 compliance checklist. 

FAQs

Does my business have to comply with ESOS?

An organisation qualifies if it is classified as a large UK undertaking or part of one of its corporate groups. Corporate groups qualify if at least one UK group member meets the definition of a large undertaking.

Large undertakings

For the qualification date for the fourth compliance period (31st December 2026) a large undertaking is any UK company that either:

  • employs 250 or more people
  • has an annual turnover over £44 million, and an annual balance sheet total over £38 million

If you qualify and your organisation is fully covered by ISO 50001, you do not need to carry out an ESOS assessment. You just need to notify the Environment Agency that you’re compliant.

What are the penalties for non-compliance?

Your environmental regulator is responsible for compliance and enforcement activities. It may issue civil sanctions including financial penalties if an organisation does not meet the scheme’s obligations.

Read the Environment Agency’s approach to ESOS regulation and penalties in their enforcement and sanctions policy (annex 2, section D). Other scheme regulators apply a similar approach - see section 15 of the full guidance.

A summary of the penalties imposed is available on data.gov.uk.

What are the deadlines for compliance?

Your organisation's status on the relevant qualification date determines if you must participate in ESOS. If you qualify, you need to notify compliance to the Environment Agency by the compliance date at the end of each compliance period.

Here is a summary of the compliance periods, qualification dates, and compliance dates:

Compliance Period

Qualification Date

Compliance Period Dates

Compliance Date

4

31 December 2026

From 6 December 2023 to 5 December 2027

5 December 2027

 

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Learn the key dates for ESOS Phase 3 in 2024 and ensure your UK business remains compliant with the mandatory Energy Savings Opportunity Scheme. Learn about qualification criteria and how Trident can assist in managing your energy audits and improving efficiency.