Energy Saving Opportunities Scheme (ESOS)

ESOS Phase 3 - Are you compliant?

The Energy Savings and Opportunities Scheme, or ESOS, is a government directive aimed at encouraging businesses to reduce their carbon emissions and increase their energy efficiency. ESOS, unlike the yearly Streamlined Energy and Carbon Reporting (SECR) obligations, occurs in phases.

The various phase qualification and compliance dates are as follows:

Please note the phase three deadline has been extended from 5 December 2023 to 5 June 2024.

Phase Qualification date Compliance period Compliance date
1 31 December 2014 From 17 July 2014 to 5 December 2015 5 December 2015
2 31 December 2018 From 6 December 2015 to 5 December 2019 5 December 2019
3 31 December 2022
From 6 December 2019 to 5 December 2023
5 June 2024 (extended from 5 December 2023)
4 31 December 2026
From 6 December 2023 to 5 December 2027
5 December 2027


For organisations qualifying for Phase 3 of ESOS, the deadline for submitting a compliance notification is 5 June 2024 and organisations should still look to meet this compliance notification deadline where possible.

However, the Environment Agency and Regulators for the Devolved Administrations have confirmed that they will not take enforcement action against you if you do not comply with this legal requirement, provided that you meet both of the following conditions:

  • registration of your account in the new MESOS IT system has been completed by 5  June 2024, and
  • you submit your notification of compliance by 6  August 2024

This regulatory enforcement extension period will cease after 6 August 2024.

To be eligible for Phase 3 of ESOS, your business must have more than 250 employees or an annual turnover exceeding £44m and a balance sheet exceeding £38m. If you’re part of a corporate group, any member of that group who is eligible means the entire group is eligible.

For Phase 3 onwards, ESOS will include additional compliance stages following the submission of the compliance notification: ESOS action plan and ESOS annual progress updates.

The action plan must be signed off by a board level director (or equivalent) and submitted via the compliance notification system by the action plan deadline for the third compliance period, which is 5 December 2024.

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.

Not sure if you qualify? Contact us to determine your status

Failure to comply with ESOS can lead to fines of up to £50,000 and then £800, up to a maximum of 80 days, until you are compliant, making it vital that you undertake an ESOS audit if you anticipate that your company falls within the eligibility criteria any time before 31st December 2022, the Phase 3 Qualification Date.

How can we help?

We provide two cost-effective solutions to achieve ESOS compliance.

ESOS Audits can be undertaken as a separate activity by compiling your information and submitting your reports.  This information will need to be compiled and assessed prior to the compliance date and follows the following typical stages;

  • Identify if you’re eligible – you may not be eligible at the moment, but if your business grows to meet the criteria in accordance with the qualification dates outlined above, you must comply or risk fines.
  • Identify your total energy consumption, then your significant energy consumption (90% of your total energy consumption).
  • Audit your significant energy consumption to identify savings opportunities.
  • Have the audit reviewed by our fully qualified lead assessors and signed off by your companies Directors.
  • Notify the environment agency of ESOS completion.

These steps can vary in complexity depending on the size, scope and general organisation of your business.

ISO 50001 encourages a framework for your utility consumptions to be recorded, thus making the reporting under ESOS a much simpler and hassle-free process.

It also allows your organisation to manage its utility consumptions in the most cost-effective manner, reducing waste and in turn providing financial and environmental benefits.

This route is audited by an external UKAS accredited certifying body and provides you with the ISO50001 Energy Management Certification.

You are still required to submit your reports under ESOS and you will find the process much simplified.

The Department of Energy Security and Net Zero have proposed changes to ESOS which are expected to apply during Phase 3 of the scheme, although any changes are currently subject to final Parliamentary Approval. We will provide further updates once more details are released.

Whatever the route, we can manage the process for you taking all of the effort and worry away from your business, leaving you to focus on what you do best while we use our expertise to ensure your ESOS obligations are followed.

If you would like to discuss how we can support your organisation, please get in touch.

“Businesses need to be aware of the impact they have on their environment. Working with you has helped us to understand and manage our environmental impacts. You quickly understood our business and we have seen real benefits as a result of your support, advice and guidance.”

Martin Rigley, MD

Lindhurst Airlift

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JKP Metal Packaging Solutions achieve ISO 9001

JKP Metal Packaging Solutions is an independent family business, manufacturing tinplate components for the metals packaging sector in a modern factory setting in North Nottinghamshire. This case study explains how FPA Consulting assisted them to achieve ISO 9001 accreditation.

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