ESOS Phase 3 – Have You Completed Your Energy Action Plan?

Following recent changes to the ESOS legislation, organisations which qualified and submitted compliance for Phase 3 are now also required to complete an additional stage by producing and ESOS Energy Action Plan and then report progress against it on an annual basis.

The purpose of the ESOS Energy Action Plan is to assist organisations to identify what actions from their ESOS Phase 3 audit they may want to conduct on their operations before the next Phase 4 ESOS audit and commits it publicly to making energy saving and energy efficiency implementations.

What should be Reported?

The Energy Action Plan progress update must include:

• A list of all the energy saving actions included in the action plan that the organisation has implemented over 12 months;
• A list of actions the organisation did not implement over 12 months;
• Whether the organisation achieved the actions implemented by the date it set;
• An estimate of total energy savings achieved over 12 months;
• How the organisation estimated the savings made.

The action plan must be signed off by a board level director (or equivalent) and submitted via the compliance notification system.

When should ESOS Energy Action Plans be Submitted?

The formal deadline for submission of ESOS action plans is 5^th December 2024, however, due to delays with the MESOS digital service and the functionality to submit an action plan, the Environment Agency and Regulators for the Devolved Administrations have confirmed that they will accept submitted action plans provided that these are submitted to them by no later than 5^th March 2025.

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 are 5 December 2025 and 5 December 2026.

An organisation may choose not to take any actions to reduce its energy consumption before the ESOS Phase 4 notification period but must still notify this intention via the MESOS Portal accordingly. It is important to note this notification will be recorded and published publicly.

What happens if ESOS Energy Action Plans are not Submitted?

The amended ESOS Regulations now includes the requirement for public disclosure of your Action Plan and Annual Action Plan progress reports.

If your organisation does not submit its ESOS Action Plan by the deadline, it will be published that your organisation does not plan to conduct any energy saving actions, which may impact both on your organisations reputation and regulatory compliance.

If you would like to discuss how we can support your organisation with ESOS Energy Action Plan compliance, please get in touch.

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