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ESOS · Reporting and data

ESOS reporting: the report and the carbon data

ESOS reporting produces two things: an ESOS report that the organisation keeps, and a notification of compliance that it submits to the Environment Agency (SI 2014/1643).

Both are measured in energy, not carbon: the Environment Agency’s guidance says in terms that “CO2 is not an energy unit” (§4.1).

This page sets out what an ESOS report contains, what is published, and how its kWh become the tCO2e that SECR and UK SRS ask for.

The ESOS report

What goes in an ESOS report in Phase 4

Sources: SI 2014/1643 as amended by SI 2023/1182 and SI 2026/701; EA report checklists (Appendices A1 and A2).
ContentWhat it recordsWhere
Energy consumptionTotal energy consumption over the reference period, and the areas of significant consumption if identifiedRegs 22, 25
Energy intensity ratiosOne for each organisational purpose: transport, industrial processes, buildings, any other purposeReg 25C
Audit findingsThe energy audits’ savings opportunities, with estimated savings in kWhRegs 27, 27A
Savings achievedNew in Phase 4: measures implemented in the period, the kWh saved by each, and each measure’s categoryReg 27D
Action plan reviewNew in Phase 4: measures from the last action plan not implemented, and whyReg 27E
ConfirmationsThat the responsible officer or officers have seen and considered the findingsRegs 30, 31

The ESOS report is kept in the evidence pack and shared with group undertakings; it is not uploaded, and the Environment Agency’s checklists set out every item section by section.

What reaches the Environment Agency is the notification of compliance, made through MESOS by 5 December 2027 for Phase 4.

An organisation on the full ISO 50001 route, or with zero energy consumption, produces no ESOS report but still notifies; ESOS Phase 4 covers who is in and when.

Our sister reference site walks the whole Phase 4 route in its ESOS Phase 4 compliance guide.

What becomes public

Phase 4 publishes more than Phase 3

The scheme administrator must publish each action plan and each progress update, and selected fields of each notification set out in Schedule 3 (SI 2026/701).

Phase 4 adds the combined energy saving achieved across all measures to what is published, and keeps the per-measure figures private as commercially sensitive.

The Phase 3 data is on data.gov.uk: action plans, first progress updates and notifications, as at a 5 June 2026 data cut.

Phase 3 data should not be read as a guide to what Phase 4 will publish, because Schedule 3 was rewritten.

SI 2014/1643 reg 10(1) and Sch 3 as amended by SI 2026/701 regs 5, 31.
ItemPublished?
Action plansYes
Progress updatesYes
Combined kWh savings achievedYes
Savings per measureNo
Action plan review narrativeNo
Notification details on the full ISO 50001 routeNo

From kWh to tCO2e

ESOS energy data is carbon activity data

The conversion is multiplication: energy in kWh, or litres of fuel, times the DESNZ factor for that energy, divided by 1,000 for tonnes.

The factors are the government’s conversion factors for company reporting, published by DESNZ each June.

The factor year follows the activity: the 2026 methodology paper says the 2026 set is for activity data “entirely or mostly within 2026”.

An ESOS reference period that straddles two years therefore spans two factor sets, and each month’s energy takes its own year’s factor.

Report purchased electricity as Scope 2 on the generated factor; transmission and distribution losses are a separate Scope 3 factor.

The 2026 electricity factor is 26% below 2025’s, partly because DESNZ changed its method; UK emissions factors explains the break.

500,000
kWh of grid electricity used in 2026
Illustrative
× 0.13096
kgCO2e per kWh, 2026 set, generated
DESNZ 2026 methodology paper, Table 9
65.5 t
tCO2e of location-based Scope 2
500,000 × 0.13096 ÷ 1,000

Mapping purposes to scopes

Four ESOS purposes, three GHG scopes

Sources: SI 2014/1643 reg 2(1); EA Phase 4 guidance §§4.3, 4.3.3, 4.3.4; SI 2008/410 Sch 7 ¶20D; GHG Protocol Corporate Standard.
ESOS energyTypical GHG Protocol scopeSECR (unquoted / LLP)Note
Buildings — grid electricityScope 2RequiredLocation-based on the DESNZ factor
Buildings and processes — gas and other fuels burnedScope 1Gas required; other fuels not listedQuoted companies report all fuel combustion
Transport — fleet and company cars supplied with fuelScope 1RequiredESOS and SECR both key on who is supplied with, or buys, the fuel
Transport — personal or hire cars on business useScope 3Required where the company buys the fuelESOS includes them; the GHG Protocol treats them as Scope 3
Industrial processes — self-generated electricityScope 1 (the fuel)Via the fuel burnedESOS counts the incoming fuel, not the electricity generated
Any other purposeDepends on the sourceDepends on the sourceThe catch-all fourth purpose

The four organisational purposes are transport, industrial processes, buildings, and any other purpose; “buildings, transport and processes” drops the fourth.

The GHG Protocol sorts the same energy by who owns or controls the source, which is why a personal car on business use is ESOS transport energy but Scope 3 in a carbon inventory.

ESOS audit vs SECR

Where ESOS data stops short

ESOS is four-yearly; SECR and UK SRS are annual, so ESOS data covers one year in four.

ESOS counts UK energy only; a quoted company’s SECR figures and UK SRS figures are worldwide.

ESOS lets up to 5% of consumption be de minimis; SECR has no de minimis inside the figures, only the low-energy relief for the whole report.

The ESOS reference period is twelve months including the qualification date; SECR follows the financial year.

So ESOS data is the best-evidenced starting point for a carbon inventory, not a finished one; ESOS and SECR sets out the full comparison.

Annual SECR reporting sits in the directors’ report under SI 2018/1155.

The 40,000 kWh boundary runs opposite ways

ESOS needs no lead assessor where consumption is less than 40,000 kWh.

SECR’s low-energy relief applies at 40,000 kWh or less, and for unquoted companies only in the UK.

At exactly 40,000 kWh the two give opposite answers.

UK SRS

From ESOS energy to UK SRS emissions

UK SRS S2 asks for gross Scope 1, 2 and 3 emissions under the GHG Protocol, and requires location-based Scope 2, with market-based permitted.

ESOS data can supply the UK part of Scope 1 and 2; overseas operations, a full annual series and Scope 3 have to come from elsewhere.

The FCA’s final rules (PS26/19, 30 September 2026) require listed companies in scope to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

CP26/5 had proposed making S2 mandatory apart from Scope 3; the final rules adopted comply-or-explain throughout, with a one-year relief for Scope 3.

UK SRS and the FCA covers the listing rules, and UK SRS Scope 3 reporting the part ESOS cannot supply.

Frequently asked

ESOS reporting: questions people ask

What is an ESOS report?

The document that records the outcome of an organisation’s ESOS assessment: its energy consumption and areas of significant consumption, an energy intensity ratio for each organisational purpose, the energy audit findings and savings opportunities, and, in Phase 4, the energy savings achieved during the compliance period and a review of the previous action plan. It is kept in the evidence pack and shared with group undertakings; the notification of compliance is what is submitted.

Is ESOS a carbon reporting scheme?

No. ESOS is measured in energy, in kWh or in energy spend, and the Environment Agency’s guidance says CO2 is not an energy unit. It produces no emissions figure. Its energy data is, though, exactly the activity data that carbon reporting under SECR or UK SRS converts into tonnes of CO2 equivalent.

How do I convert ESOS kWh into tCO2e?

Multiply each energy stream by the matching DESNZ conversion factor for the year the energy was used, then divide by 1,000 to get tonnes. For UK grid electricity in 2026 the location-based factor is 0.13096 kgCO2e per kWh, so 500,000 kWh gives 65.5 tCO2e of Scope 2. Fuels burned on site use the fuel factors and are Scope 1.

What is the difference between an ESOS audit and SECR?

ESOS is a four-yearly energy assessment for large undertakings, notified to the Environment Agency, that identifies savings opportunities. SECR is an annual disclosure in the directors’ report of energy use, emissions, an intensity ratio and efficiency measures, for quoted companies and large unquoted companies and LLPs. The tests for who is in each are different, and so are the intensity ratios: ESOS asks for an energy ratio per organisational purpose, SECR for one emissions ratio.

What does the Environment Agency publish from ESOS?

Each action plan and each progress update, and selected fields of the notification, including in Phase 4 the combined energy savings achieved across all measures. Per-measure savings and the action plan review narrative are not published. The Phase 3 data is on data.gov.uk.

Can ESOS data be used for UK SRS reporting?

As a starting point. UK SRS S2 asks for gross Scope 1, 2 and 3 emissions under the GHG Protocol, with location-based Scope 2 required. ESOS supplies UK energy data for Scope 1 and 2 but is four-yearly, UK-only, allows a de minimis, and says nothing about Scope 3. Listed companies in scope of the FCA’s final rules report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.

Checked against 14 sources fromlegislation.gov.ukEnvironment AgencyEnvironment Agency, via data.gov.ukDepartment for Energy Security and Net ZeroGreenhouse Gas ProtocolDepartment for Business and Trade
  1. legislation.gov.uk
    The Energy Savings Opportunity Scheme Regulations 2014 (SI 2014/1643)

    The ESOS report (regs 27A, 27D, 27E), intensity ratios (reg 25C), publication (reg 10, Sch 3).

  2. legislation.gov.uk
    SI 2014/1643, regulation 25C — energy intensity ratios

    One ratio for each organisational purpose.

  3. legislation.gov.uk
    The ESOS (Amendment) Regulations 2026 (SI 2026/701)

    Savings achieved (reg 27D), the action plan review (reg 27E), what is published (Sch 3).

  4. Environment Agency
    How to comply with ESOS phase 4 (30 July 2026)

    §4.1: total consumption in kWh or £ — "CO2 is not an energy unit"; the ESOS report.

  5. Environment Agency
    Appendices A1 and A2: report checklists for participants

    The ESOS report checklist, section by section.

  6. Environment Agency
    ESOS: find out if you qualify and how to comply

    Phase 4 dates, the four organisational purposes.

  7. Environment Agency, via data.gov.uk
    Energy Savings Opportunity Scheme — published data

    Phase 3 action plans, progress updates and notifications.

  8. Department for Energy Security and Net Zero
    Government conversion factors for company reporting

    The factors that turn ESOS kWh into tCO2e.

  9. Department for Energy Security and Net Zero
    2026 conversion factors methodology paper, ¶¶1.10, 3.1, Table 9

    Year rule; generated factor 0.13096 for Scope 2; T&D losses in Scope 3.

  10. Greenhouse Gas Protocol
    Corporate Accounting and Reporting Standard

    Scopes 1 to 3 and organisational boundaries.

  11. legislation.gov.uk
    SI 2018/1155 — the SECR Regulations (as made)

    The annual disclosure ESOS data most often feeds.

  12. Department for Business and Trade
    UK SRS S2, ¶29(a) and ¶¶B30–B31

    Gross Scope 1, 2 and 3; location-based Scope 2 required.

  13. Financial Conduct Authority
    PS26/19: Aligning listed issuers’ sustainability disclosures with international standards

    Final rules, 30 September 2026: comply or explain from 1 January 2027 periods.

  14. Financial Conduct Authority
    CP26/5 — the consultation PS26/19 finalises

    Had proposed mandatory S2 excluding Scope 3; the final rules did not adopt that.

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