Energy Savings Opportunity Scheme (ESOS) Phase 4 Qualification Deadline & Dates

Energy Savings Opportunity Scheme (ESOS) Phase 4 Qualification Deadline & Dates

Begin your ESOS Phase 4 submissions

Are there any changes with ESOS Phase 4? 

Following the outcome of the UK’s Government’s Energy Saving Opportunity Scheme consultation, a number of changes were made to enhance the quality of the compliance and increase the carbon and cost saving made. In addition to these changes, the Government discussed what may be included in Phase 4 of the scheme.

What is the deadline for ESOS Phase 4? 

The deadline for ESOS Phase 4 is 5 December 2027, however, with the 4 year compliance phase beginning on 6 December 2023, you can now start your ESOS Phase 4 work. 

Who needs to comply with ESOS Phase 4?

Companies will need to comply with ESOS Phase 4 if they are:

  • Registered or based in the UK or a UK establishment
  • Employ 250 people or more or
  • Have an annual turnover greater than £44m, and an annual balance sheet greater than £38m

From Phase 4 onwards, the Government will change the ESOS balance sheet and turnover thresholds to align with the Streamlined Energy and Carbon Reporting (SECR), requiring more organisations to report on their ESOS. 

Organisations that are part of a corporate group which contains at least one large undertaking will also continue to be in scope.

ESOS Phase 4 Qualification Date, Compliance Period and Deadlines

 Qualification Date4 Year Compliance PhaseCompliance Date
Phase 431 Dec 20266 Dec 2023 – 5 Dec 20275 Dec 2027

What can we expect from ESOS Phase 4?

To support the UK Government’s target to be Net Zero by 2050, Phase 4 will focus on how organisations are addressing their energy efficiency AND how they plan to become net zero. New changes to Phase 4 of the ESOS scheme could include:

  • With a focus on net zero, organisations may need to explore their net zero commitments and targets and the actions they need to take to achieve them
  • Organisations may need to also identify the potential risks in moving to net zero and emission reduction trajectories
  • Information to support organisations in creating a carbon reduction plan (CRP) or helping them to meet their existing carbon reduction strategies
  • Businesses may be expected to increase clarity and guidance on site audit sampling, including most likely a minimum threshold for both the number of buildings audited and percentage of total energy consumption sampled
  • Reports may need to meet either ISO 50002 or EN 16247 auditing standards. Currently, this is only a recommendation in Phase 3 guidance
  • Display Energy Certificates (DEC) and Green Deal Assessments will be removed as a route to compliance
  • For organisations not in scope for SECR, a reporting function on the ESOS web portal may be developed to allow for annual progress reporting. From Phase 4 onwards a requirement may be introduced that if the goal has not been met, the participant must explain why
  • Following Streamline Energy and Carbon Reporting (SECR), it may become mandatory for some data, such as a minimum energy or carbon reduction targets and net zero assessments to be made public
  • ESOS reports may be required to improve the collection and monitoring of energy data, setting of controls, and appropriate staff training, both within the descriptive element of the ESOS report and within audit recommendations
  • Businesses may be expected to be alert to their future electricity demand in the context of system impact will be considered as part of the net zero assessment from the Phase 4 compliance period
  • In a similar way to Phase 3, the data in organisation’s ESOS submissions will be made publicly available
  • Phase 4 of the ESOS scheme is expected to require more data from organisations compared to previous phases

The start of the ESOS Phase 4 compliance period began on 6 December 2023, our expert energy ESOS consultants are knowledgeable and up to date with ESOS compliance legislation and what will be required from organisations. Throughout your review we will help you collate data for your building, transport, and process energy use, analysing the data and reviewing your portfolio.

We will carry out your building’s energy surveys, produce the ESOS survey reports and ensure you can maximise the benefits of the scheme through conducting the ESOS review, verification and sign off. Our team of lead assessors will include any necessary changes to your audit and report introduced to the scheme by the Environment Agency.

The deadline for Phase 4 of the ESOS scheme is 5 December 2027, with a compliance period of 6 December 2023 – 5 December 2027. However, it is never too early to get started, site energy audits can start from January 2024. If you need support with any of the ESOS Compliance Phases, our ESOS consultants will help guarantee your compliance.

If a qualifying organisation misses the deadline, they can expect to receive a basic fine of £50,000, plus an additional fine of £800 per day up to a maximum of 80 days.

For more information, you can speak to a member of the team on 01908 041501 or contact us online and we will get in touch with a quote.

ESOS Phase 4 Action Plan submission dates

Organisations will be expected to submit Energy Action Plans to provide annual progress updates to track whether they have achieved the energy saving actions in their plan. Find out more about the Energy Action Plan and how we can help. 

Below, we have included the submission dates for the ESOS Action Plan:

Submission Phase Action Plan Reporting Deadline Action Plan Reporting Deadline Action Plan Reporting Deadline
Phase 4
5 December 2027
5 December 2028
5 December 2029

Meet our ESOS Consultants

Our in-house, experienced, ESOS consultants will help you fully understand the ESOS scheme and what it means for your business. Each consultant has the breadth of skills, expertise and sector experience to help you make the most of the ESOS energy scheme.

BSc (hons), Approved EnCO Practitioner, ESOS Lead Assessor

MSc, BSc (Hons), ESOS Lead Assessor

BSc (Hons), EnCO Consultant, ESOS Lead Assessor

Speak to an ESOS Consultant

Call 01908 036 488 to find out how our consultants can help you make the most of ESOS 


Streamlined Energy and Carbon Reporting

Energy Savings Opportunity Scheme (ESOS) Compliance

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