ESOS Action Plans Explained: What They Are, What’s Required and How to Stay Compliant
The Energy Savings Opportunity Scheme (ESOS) is a government-led scheme compliance requirement for large UK based organisations to encourage them to implement energy saving measures.
ESOS Action Plans are one of the most significant changes introduced in recent phases of the Energy Savings Opportunity Scheme.
Where ESOS was once focused primarily on identifying energy‑saving opportunities, organisations are now expected to demonstrate intent, progress and accountability through a formal ESOS Action Plan and ongoing updates.
Many ESOS delivery challenges arise before action planning begins, particularly around data quality and governance.
Why is an ESOS Report Important?
ESOS Audits are carried out by businesses every four years, which look at the energy usage of their buildings, processes and transport, this is accompanied by cost-effective recommendations to help businesses reduce energy demand and improve energy efficiency.
Following on from changes made to the ESOS scheme, once organisations completed Phase 3 of the ESOS compliance scheme, they needed to complete an additional stage of producing an ESOS Energy Action Plan and Progress Update each year on how they are meeting the plans set out in their ESOS Action Plan.
Their introduction marked a clear policy shift:
- From identifying opportunities
- To demonstrating commitment and progress.
This shift continues to shape enforcement and future scheme design.
What is an ESOS Action Plan?
An ESOS Action Plan sets out how organisations plan to improve their energy efficiency and reduce their carbon emissions. An ESOS Action Plan Progress Update acts as an annual progress report for participants to publicly disclose what they have achieved so far and to encourage businesses to act on the energy saving actions they have committed to in their ESOS submission.
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 any actions the organisation did not implement over 12 months
- Whether the organisation achieved the actions implemented by the date they set
- An estimate of total energy savings achieved over 12 months
- How the organisation estimated the savings set out.
The plan must be signed off by a board level director, with the director confirming they have seen the action plan and are satisfied that the organisation has complied with the Action Plan Requirements.
For ESOS Phase 4 there is no requirement to submit a new ESOS Action Plan for Phase 4; instead, organisations must continue to report progress against their existing Phase 3 Action Plan through annual progress updates.
What Do You Need to Submit in ESOS Phase 4 (as a New Entrant)?
The UK Government has not yet published a confirmed requirement for a new Phase 4 Action Plan. Final guidance is due in early 2027. However, plan for the likelihood that regulators will expect an ‘Action Plan from Phase 3 onwards’ approach to continue.
While a formal Phase 4 Action Plan submission date has not yet been issued, it is prudent for organisations to prepare for the possibility that Phase 4 may include its own Action Plan cycle once final guidance is released. Learn more about ESOS Phase 4
An effective action plan is the foundation for turning your organisation’s goals into measurable results. The video below walks you through the essential steps setting clear objectives, breaking them into actionable tasks, assigning responsibilities, and tracking progress. Whether you’re developing your first action plan or refining an existing one, this guide will help you create a roadmap for success and keep your team accountable.
This short explainer video provides a clear, compliance focused overview of what an ESOS Action Plan is, why it is required, and what organisations need to report when demonstrating progress against their energy‑saving commitments.
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How ESOS Action Plans Are Used by Regulators
ESOS Action Plans and progress updates allow regulators to:
- Assess whether ESOS is driving meaningful action
- Identify organisations that repeatedly defer or avoid implementation
- Inform future policy development and enforcement priorities.
In practice, ESOS Action Plans are becoming a key compliance artefact, not an administrative afterthought.
Common ESOS Action Plan Mistakes
Organisations often struggle because they:
- Treat Action Plans as a box‑ticking exercise
- Over‑promise on delivery timelines
- Fail to link actions to verifiable data
- Don’t align Action Plans with wider energy or carbon strategies.
These issues can increase enforcement risk and undermine credibility.
ESOS Action Plan Submission Dates
Organisations will be expected to submit an ESOS Progress Report to provide annual updates to track whether they have achieved the energy saving actions in their Action Plan. Below, we have included the submission dates for the ESOS Action Plan:
| Submission Phase | ESOS Phase Compliance and Action Plan Results | New Action Plan | Action Plan Annual Progress Update | Action Plan Annual Progress Update |
|---|---|---|---|---|
|
Phase 3 Action Plan |
N/A |
5 December 2024* |
5 December 2025 |
5 December 2026 |
|
Phase 4 Action Plan |
5 December 2027 |
5 December 2028 |
5 December 2029 |
5 December 2030 |
The deadline for the first Energy Action Plan is the 5 December 2024, however the Environment Agency has announced an extension and will accept Action Plans submitted by the 5 March 2025.
Why Must Organisations Submit an Energy Action Plan?
The Energy Action Plan aims to help organisations to consider what actions from their ESOS audit they may want to carry out on their operations before the next ESOS assessment. The plan also encourages large businesses to commit publicly to making energy saving and energy efficiency implementations.
What if an Organisation does not Submit an Energy Action Plan?
If an organisation does not plan to take any action to reduce its energy consumption before the next ESOS compliance date, it can submit a notification with that information. However, it is important to note these will be recorded and published publicly.
If an organisation does not submit its ESOS Action Plan by the deadline, it will be published that the business does not plan to carry out any energy saving action.
Public Disclosure Risks
One of the changes to ESOS includes the requirement for public disclosure of your Action Plan and annual Action Plan progress reports.
Public disclosure can have several implications for your business:
- Reputational Impact: This can be positive if you are proactive in implementing energy saving measures. However, it could also be negative if you are perceived as not taking sufficient action.
- Competitive Sensitivity: Some businesses may be concerned about revealing information that could be used by competitors.
- Regulatory Compliance: Failure to comply with ESOS requirements, including public disclosure, can result in penalties.
It is important to ensure that your business complies with ESOS regulations and to consider how public disclosure aligns with your broader business and sustainability strategies.
Who Needs to Submit an Energy Action Plan?
All organisations that are required to comply with ESOS must submit their Energy Action Plan and provide regular updates covering every four years.
If you need to comply with ESOS, find out how our team of experts can help you meet the compliance deadline.
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