Environment Agency
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February 2024 update
Phase 4 changes
The government has decided to postpone some changes announced in the previous governments response to the ESOS consultation. See below for full details of which changes will and will not go ahead in Phase 4 (compliance deadline 5 December 2027).
Action plans
Participants should note that the deadline for submitting an action plan for the third compliance period passed on 5 December 2024. Action plans can still be submitted after this deadline via the Manage your ESOS reporting system. No remedial actions will be considered for action plans submitted up until 5 March 2025.
ESOS latest updates
Phase 4 changes
The following changes announced in the previous governments response to the ESOS consultation will not go ahead for Phase 4:
- changes to refocus the scheme to cover net zero as well as energy efficiency (responses to questions 16, 17, 18 and 19)
- change to qualification thresholds to better align with Streamlined Energy and Carbon Reporting (SECR) (response to question 23)
Following delays to the introduction of Phase 3 legislation and guidance, and in order to give sufficient time for such a major change to ESOS, the new government has decided to postpone the introduction of net zero requirements until Phase 5.
The following changes announced in the previous governments response to the ESOS consultation are intended to go ahead for Phase 4, subject to parliamentary time and scrutiny:
- removal of Display Energy Certificates (DECs) and Green Deal Assessments (GDAs) as compliance routes (response to question 10)
- progress against action plan commitments to be included in the ESOS assessment (response to question 20)
- where action plan commitments have not been met, participants must provide an explanation (response to question 20)
Further details of these changes will be provided in due course. These changes and full guidance, as well as the necessary changes to the Manage your ESOS reporting system are planned to be in place by early 2027 in advance of the notification of compliance deadline for Phase 4, which is 5 December 2027.
Publication of new PAS standards
On 7 February the British Standards Institution (BSI) published two new standards which were referenced in the government response to the ESOS consultation:
- PAS 51215-1:2025 Energy and decarbonization assessment Part 1: Process Specification
- PAS 51215-2:2025 Energy and decarbonization assessment Part 2: Competencies of lead assessors and assessment teams Specification
Participants will be able to use these standards on a voluntary basis for ESOS compliance. Further guidance on voluntary use of these standards will be published in due course.
The existing competency standard, PAS 51215:2014 Energy efficiency assessment: Competence of a lead energy assessor Specification, will continue to be used as the competency standard for ESOS lead assessors for Phase 4.
The new PAS 51215-2:2025 competency standard can be used on a voluntary basis by organisations wanting to determine whether an assessor is suitable to carry out an assessment according to PAS 51215-1:2025.
ESOSaction plan
If you were required to submit a notification of compliance for the third compliance period (deadline 5 June 2024), you must also submit an action plan and progress updates during the subsequent relevant compliance period. If you did not qualify for ESOS for the third compliance period, you do not need to complete an action plan or progress updates in the subsequent compliance period.
For details aboutESOSaction plans, seeSection 12 in the full guidance.
The action plan must be signed off by a board level director (or equivalent), and submitted via the Manage your ESOS reporting system by the action plan deadline. For the third compliance period this deadline was5 December 2024, which has now passed.
If you have not yet submitted an action plan, you can still submit this using the Manage your ESOS reporting system. No remedial actions will be considered for action plans submitted up until 5 March 2025.
Annual progress updates
Following submission of the action plan, you must submit an annual progress update against your action plan commitments in the 2 subsequent years.
The deadline for submitting an annual progress update is 12 months after the action plan deadline, and then 12 months after the submission deadline for the first progress update. For the third compliance period, the deadlines are5 December 2025and5 December 2026.
The progress update must be signed off by a board level director (or equivalent), and submitted via the Manage your ESOS reporting system.
For full details ofESOSannual progress updates, seeSection 13 of the guidance.
Aboutthe Energy Savings Opportunity Scheme (ESOS)
ESOSis a mandatory energy assessment scheme for organisations in the UK that meet the qualification criteria. The Environment Agency is the UK scheme administrator.
Organisations that qualify forESOSmust carry out ESOS assessments every 4 years. These assessments are audits of the energy used by their buildings, industrial processes and transport.
The ESOS audit is designed to identify tailored and cost-effective measures to allow participating businesses to save energy and achieve carbon and cost savings. The audit costs are estimated to be significantly outweighed by the savings from implementing the recommendations.
For full details of how to comply withESOSrequirements see: