Energy Savings Opportunity Scheme (ESOS)


New Compliance Requirements

Now that the Energy Act 2023 has come into force, there are extra requirements for ESOS compliance.

  • ESOS Action Plan
  • Annual Progress Updates

ESOS Action Plan

From the third compliance period onwards, ESOS includes additional compliance stages following the submission of the compliance notification: ESOS action plans and ESOS annual progress updates.

Following the submission of the compliance notification, you must produce an action plan, setting out:

  • What you intend to do to reduce energy consumption
  • When you intend to do it
  • Whether it was recommended through your ESOS assessment
  • What energy savings you expect to achieve over the four year period covered by the action plan
  • How you estimated these savings

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

You do not need to justify your reasoning for choosing to include any particular action in the action plan, but you will subsequently be required to state in annual progress updates whether you achieved the actions in the action plan.

The purpose of the action plan is to require participants to consider what actions from the ESOS Audit they may wish to carry out before the next ESOS assessment, as well as plan future action to implement energy savings that they will make a public commitment to.

Annual Progress Updates

Following submission of the action plan, you must submit an annual progress update against your action plan commitments in the two subsequent years.

The deadline for submitting annual progress updates 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 5th December 2025, and 5th December 2026. Each progress update relates to the 12-month period preceding the deadline.

The purpose of the progress updates is for ESOS participants to report publicly on what they have done and to encourage participants to take the energy saving actions they have committed to.

The progress update must be signed off by a board level director and submitted through the notification system. The annual progress update will be published via the new ESOS IT system. If you do not submit a progress update by the relevant deadline, by default it will be recorded and published that you did not carry out any energy saving actions.

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