Environment Agency releases ESOS Phase 4 guidance and Action Plan statistics
The Environment Agency has warned ESOS participants over missing Phase 3 Action Plans and Progress Updates.
Businesses that have yet to complete their ESOS Phase 3 requirements are being urged to act after the Environment Agency confirmed that non-compliant organisations are being investigated and could face enforcement action.
In its latest Energy Savings Opportunity Scheme (ESOS) newsletter, the Environment Agency confirmed that more than 86% of ESOS participants are now compliant with requirements relating to Notifications of Compliance, Action Plans and initial Progress Updates.
However, that leaves a proportion of qualifying organisations that still need to address outstanding ESOS requirements.
The Environment Agency has made clear that organisations which have not submitted the required Notification of Compliance, Action Plan or initial Progress Update, are being investigated by the relevant compliance bodies, and that enforcement action may be taken.
ESOS Action Plans are a legal requirement
Under Phase 3 of ESOS, qualifying organisations are required to submit an Action Plan setting out the energy-saving measures they intend to implement, as well as annual action plan updates.
Importantly, an Action Plan is still required even where an organisation does not propose to implement any energy-saving measures.
The Action Plan provides greater visibility over how businesses intend to turn the opportunities identified through ESOS into practical energy and carbon savings.
Need support with your ESOS Action Plan? Contact our team today to discuss what you need to do and how we can help, at [email protected] or 01756 794951.
What’s changing for ESOS Phase 4?
ESOS Phase 4 introduces several important changes. One of the main changes is to the ISO 50001 compliance route. During Phase 3, ISO 50001 certification needed to cover 100% of an organisation’s total energy consumption to avoid appointing a Lead Assessor. For Phase 4, this reduces to 95% of Significant Energy Consumption (SEC), making this route more accessible. Where coverage is below 95%, organisations can still use a combination of ISO 50001 and Lead Assessor-led energy audits.
The Environment Agency will also publish more information following an organisation’s Notification of Compliance. This will include Total Energy Consumption (TEC), Significant Energy Consumption, energy intensity ratios, consumption by organisational purpose and the energy-saving opportunities identified during Phase 4.
There are also new requirements for Lead Assessors. Following completion of the Notification of Compliance, the Lead Assessor must notify their professional body that they completed the ESOS assessment and provide customer contact information for quality-control purposes.
Other changes include the removal of Display Energy Certificates and Green Deal Assessments as compliance routes, while the proposed Net Zero requirement under PAS 51215-1:2025 has been delayed until Phase 5. Voluntary participation through the MESOS platform is also being removed.
Overall, the Phase 4 changes increase transparency and reporting requirements, making early preparation and good-quality energy data increasingly important.
If you need support understanding how the Phase 4 changes affect your organisation or completing your ESOS compliance, get in touch with our team today at [email protected] or 01756 794951.
