What UK Businesses need to know about ESOS for 2023–2027

The Energy Savings Opportunity Scheme (ESOS) is back for its fourth phase, bringing new requirements and opportunities for large UK organisations. If your business met the criteria in previous phases, it’s time to prepare for the latest cycle—running from December 6, 2023, to December 5, 2027.

What Is ESOS Phase 4?

ESOS is a mandatory energy audit scheme designed to help large organisations identify cost-effective ways to save energy. The scheme operates in four-year cycles, and Phase 4 is now underway. The lead regulator is the Environment Agency (England), with devolved bodies overseeing compliance in Scotland, Wales, and Northern Ireland.

Who Needs to Comply?

You must participate in ESOS Phase 4 if your organisation qualifies as a “large undertaking” on the qualification date: December 31, 2026. This includes:

  • UK-registered companies or UK establishments of overseas companies.
  • Corporate groups where any member meets the criteria.
  • Organisations with either:
    • An annual turnover greater than £44 million and an annual balance sheet total over £38 million, or…
    • 250 or more employees.

If you were in scope for Phase 3, you’re likely still required to comply.

Key Deadlines for ESOS Phase 4:
  • Start date: December 6, 2023.
  • Compliance deadline: December 5, 2027.
What’s New in Phase 4?

While the core requirements remain, Phase 4 introduces several important updates:

  • Corporate groups: Now, if any group member meets the criteria, the whole group must comply.
  • Action Plans: If your Phase 3 audit identified significant savings, you’ll need to submit action plans.
  • Progress Updates: Regular updates are now required, with the first due in December 2025.
  • Stricter enforcement: Expect higher penalties for non-compliance.
  • Potential changes: Some updates under the Energy Act 2023 have been postponed, but further changes may be on the horizon.
  • Decarbonisation focus: There’s an increased emphasis on net zero journeys and Climate Change Agreement (CCA) compliance extensions.
What Do You Need to Do If you Qualify for ESOS Phase 4?

To comply with ESOS Phase 4, organisations must:

  • Measure total energy consumption across buildings, transport, and industrial processes.
  • Conduct energy audits or use ISO 50001 certification.
  • Submit a compliance notification to the regulator.

If you’re unsure whether your organisation qualifies, now is the time to assess eligibility and prepare a compliance roadmap.

How Can We Help?

Whether you need a detailed analysis of your energy consumption, a comprehensive list of energy-saving measures, or just basic compliance support, there are a range of solutions available. We can help you with a light-touch compliance solution, or a deep-dive into accomplishing maximum energy efficiency.

Ready to get started?

Get in touch to determine if you qualify and decide which solution is right for your organisation.

Ready for ESOS Phase 4?