ESOS Phase 3 Deadline: 5 June 2024

ESOS Phase 3 Compliance

Energy Savings Opportunity Scheme for UK Large Undertakings

What is ESOS?

The Energy Savings Opportunity Scheme (ESOS) is a mandatory energy assessment scheme for large undertakings in the UK. It requires qualifying organizations to conduct comprehensive energy audits every four years, identifying cost-effective energy efficiency opportunities.

7,000+

UK Organizations Covered

90%

Of Energy Use Must Be Audited

£50,000

Maximum Penalty for Non-Compliance

4 Years

Between Each Phase

ESOS Qualification Criteria

Your organization qualifies for ESOS if it meets ANY of these criteria on the qualification date (31 December 2022):

250+

Employees

UK staff or equivalent FTE

£44m+

Annual Turnover

And £38m+ balance sheet

Part of Group

Corporate Group

If group meets above criteria

Note: These are different thresholds from SECR(£36m turnover, £18m balance sheet). Many organizations qualify for both schemes.

ESOS Phase 3 Requirements

Energy Audit Requirements

  • Audit at least 90% of total energy consumption
  • Cover buildings, industrial processes, and transport
  • Identify cost-effective energy saving opportunities
  • Calculate payback periods and lifecycle costs
  • Use 12 months of verifiable energy data

New Phase 3 Requirements

  • Action Plan: Must create energy saving action plan
  • Annual Reporting: Submit progress updates to Environment Agency
  • Energy Intensity: Report energy use per unit of output
  • Net Zero Plan: Include pathway to net zero emissions
  • Public Disclosure: Some data will be published

ESOS Compliance Process

1

Determine Qualification

Immediate

Check if your organization qualified on 31 December 2022. Consider corporate group structure and aggregation rules.

2

Appoint Lead Assessor

ASAP

Appoint an approved ESOS Lead Assessor. Can be internal (if qualified) or external consultant. Register on ESOS portal.

3

Calculate Total Energy

March 2024

Measure total energy consumption across all activities. Include electricity, gas, transport fuel, and other energy sources.

4

Conduct Energy Audits

April 2024

Audit 90% of total energy use. Follow EN 16247 standards or use ISO 50001 certification as alternative compliance route.

5

Create Action Plan

May 2024

Develop energy saving action plan with implementation timeline. Include net zero pathway and energy intensity metrics.

6

Board Sign-off

May 2024

Obtain director-level sign-off on ESOS findings and action plan. Ensure board understands energy saving opportunities.

7

Submit Notification

5 June 2024

Submit compliance notification via online portal to Environment Agency. Include all required documentation and declarations.

Alternative Compliance Routes

ISO 50001 Certification

Organizations with ISO 50001 covering all energy use are ESOS compliant. Must be certified by UKAS accredited body.

Learn about ISO standards →

Display Energy Certificates

Valid DECs and accompanying advisory reports can cover buildings energy. Must be less than 10 years old.

Public buildings route

Green Deal Assessments

Green Deal Assessments can cover domestic-type buildings. Must be conducted by qualified assessor.

Limited application

ESOS Costs & Penalties

Typical Compliance Costs

Lead Assessor fees£5,000 - £25,000
Energy audits (per site)£2,000 - £10,000
Data collection & analysis£3,000 - £15,000
Transport assessment£2,000 - £8,000
Total typical cost£15,000 - £60,000

Non-Compliance Penalties

Initial penalty£5,000
3 months non-compliance£10,000
6 months non-compliance£25,000
Additional daily penaltyUp to £500/day
Maximum penalty£50,000

Warning: Publication of non-compliance causes reputational damage

Common Energy Saving Opportunities

Buildings (40% savings potential)

  • • LED lighting upgrades
  • • HVAC optimization
  • • Building insulation
  • • Smart building controls
  • • Solar PV installation

Industrial (30% savings potential)

  • • Variable speed drives
  • • Compressed air optimization
  • • Heat recovery systems
  • • Process optimization
  • • Motor efficiency upgrades

Transport (25% savings potential)

  • • Fleet electrification
  • • Route optimization
  • • Driver training programs
  • • Telematics systems
  • • Modal shift opportunities

Average ROI: ESOS participants report average energy cost savings of 13% with typical payback under 2 years

ESOS Integration with Other Schemes

SchemeOverlap with ESOSKey Difference
SECREnergy & emissions data collectionSECR is annual reporting, ESOS is 4-yearly audits
SBTiEmissions reduction planningSBTi focuses on targets, ESOS on opportunities
CDPEnergy management disclosureCDP is voluntary, ESOS is mandatory
ISO 50001Energy management systemISO 50001 provides ESOS exemption

ESOS Frequently Asked Questions

What happens if we miss the ESOS deadline?
Missing the 5 June 2024 deadline triggers immediate penalties starting at £5,000, increasing to £50,000 maximum. The Environment Agency will publish non-compliant organizations. You must still complete ESOS requirements even after the deadline. Contact the Environment Agency immediately if you're at risk of non-compliance.
Do we have to implement the energy saving opportunities?
No, implementation isn't mandatory, but Phase 3 requires an action plan explaining what you will implement and why. You must also report annually on progress. Many organizations find the savings justify implementation - average payback is under 2 years with 13% energy cost reduction.
How does ESOS relate to net zero targets?
Phase 3 requires including a net zero pathway in your action plan. ESOS energy audits identify reduction opportunities essential for net zero. Consider aligning with Science Based Targetsand using ESOS findings to support CDP reporting.
Can we use ESOS data for SECR reporting?
Yes, ESOS energy data directly supports SECRannual reporting requirements. The detailed audits provide robust data for emissions calculations. Many organizations align ESOS and SECR processes for efficiency. Note that SECR has lower thresholds, so some SECR organizations won't qualify for ESOS.
What's changing for ESOS Phase 4?
Phase 4 (compliance date December 2027) is expected to strengthen requirements further. Anticipated changes include mandatory implementation of some measures, enhanced reporting, and stronger links to net zero planning. Start building energy management capabilities now to prepare.

ESOS Phase 3 Deadline Approaching

Ensure compliance by 5 June 2024 - Avoid penalties up to £50,000

Free ESOS Compliance Check

Verify your qualification status and get compliance roadmap