Business Energy Compliance Deadlines: What Still Matters in 2025

For energy-intensive businesses, the second half of 2025 is less about preparing for what’s ahead and more about managing what’s already in motion. Enforcement is now live for some schemes, while others are open for applications or entering new phases. Whether you’re catching up or planning ahead, now is the time to take stock.

ESOS: Penalties for Phase 3 Non-Compliance Are Being Issued

The extended deadline for ESOS Phase 3 action plans passed on 5 March 2025. Since then, the Environment Agency has begun issuing fines to organisations that failed to comply. This includes fixed penalties of up to £50,000, plus daily fines of £500 for continued failure to submit. Some non-compliant companies have already been named publicly.

If your business didn’t meet this deadline, it’s not too late to act. Submitting a late action plan, supported by a qualified Lead Assessor, can help mitigate further penalties. The most common challenges we hear include delays gathering consumption data, uncertainty around the level of detail needed, and difficulties securing assessor support on time. If that sounds familiar, we can help you move forward quickly and get compliant.

Looking ahead, Phase 4 of ESOS is already taking shape. Businesses must qualify by 31 December 2026, and submit their full compliance notification by 5 December 2027. Starting the process now (particularly if Phase 3 was rushed or missed) gives you time to plan audits properly and explore meaningful energy-saving measures.

SECR: Rolling Deadlines Based on Financial Year-End

There have been no legislative changes to Streamlined Energy and Carbon Reporting (SECR) during 2025, but that doesn’t mean the pressure is off. SECR applies to large UK-incorporated companies and LLPs that meet two or more of the following: £36 million turnover, £18 million balance sheet total, or 250 employees.

SECR reporting is due within three months of your financial year-end, typically submitted alongside annual accounts. Many businesses struggle to coordinate SECR data across departments, particularly when financial teams are focused on audit and filing. 

Inconsistent or unclear submissions can lead to scrutiny, especially where energy usage jumps or carbon factors are misapplied. If you’re unsure whether your latest filing meets expectations, or if you’re still working from spreadsheets, we can help you streamline the process.

CCA: TP6 Reporting Has Passed, but New Entrant Window Is Open

If you’re already part of the Climate Change Agreements (CCA) scheme, your Target Period 6 performance data should have been submitted by 1 May 2025. This covers the energy efficiency improvements made during the period running from 1 January 2023 to 31 December 2024. If your sector association has since asked for corrections or clarification, it’s important to respond quickly to avoid losing eligibility for levy discounts.

If you’re not yet part of the scheme, a key opportunity is still open. The new entrant application window runs from 1 May to 31 August 2025. This is likely to be one of the final windows before the scheme closes in March 2027. Qualifying sectors include food manufacturing, plastics, chemicals, metals and more. Joining requires submitting baseline consumption data, agreeing to energy reduction targets, and completing administrative registration with your sector association.

We’ve helped clients navigate both entry and compliance, including cases where records were incomplete or mixed across sites. If you’re unsure whether you qualify, we can check eligibility and advise on next steps.

UK ETS: 2024 Cycle Complete, 2025 Planning Now Essential

The reporting cycle for the 2024 UK Emissions Trading Scheme (ETS) compliance year is now complete. The key dates were:

• 31 March 2025 – deadline to submit 2024 verified emissions report
• 30 April 2025 – deadline to surrender allowances for 2024 emissions
• 30 June 2025 – deadline to submit baseline data for free allocation and small emitter status for 2026–2030

If you missed any of these dates, the next step is to assess your risk exposure and respond to any notices from the scheme administrator. Missed surrender deadlines can result in financial penalties and reputational risk, particularly if you’re involved in international supply chains or investment reviews.

For businesses that met their obligations, now is the time to review internal processes for the 2025 cycle. This includes refreshing monitoring plans, verifying measurement tools, and identifying any operational changes that may affect emissions totals. 

Public Sector Sustainability Reporting: Pressure Is Building on Suppliers

New government guidance on sustainability reporting will become mandatory for central public bodies from the 2026–27 reporting year, but many organisations are already preparing ahead of time. The updated framework aligns more closely with TCFD principles, requiring structured disclosures around emissions, energy use, and climate-related risks.

While this guidance isn’t yet mandatory for private businesses, it’s increasingly influencing supplier expectations. Many public sector tenders are now requesting SECR-style reporting or proof of net zero targets as part of pre-qualification.

This trend is particularly visible in education, healthcare, infrastructure and social housing sectors. If you supply into any of these, now is the time to assess your reporting position and prepare the kind of clear, evidence-backed documents that public bodies are starting to demand.

Not Sure Where to Start? We’re Here to Help

Understanding and managing your energy compliance obligations doesn’t need to be overwhelming. Whether you’re dealing with ESOS penalties, planning for Phase 4, catching up on SECR or considering entry into the CCA scheme, Tritility can help.

We work with energy managers, finance directors and operations leads across multiple sectors, supporting everything from data capture to Lead Assessor coordination and audit preparation. Our role is to help you stay ahead of regulation while identifying opportunities to improve efficiency and reduce costs.

If you’re unsure what applies to your business, or you’re facing pressure from regulators, customers or procurement teams, get in touch. We’ll help you make sense of it, and get it sorted.