Are You Ready to Submit Your ESOS Plan? 

If your business qualifies for the third phase of the Energy Savings Opportunity Scheme (ESOS), you must submit your action plan by the 5^{th of} March this year. 

Not sure what you need to do? We’ve put together this quick guide to help you stay compliant. 

See what other energy legislation deadlines you need to get ahead of this year. 

What is an ESOS Action Plan? 

ESOS is a UK government regulation (managed by the Environment Agency) that requires large businesses to assess their energy consumption and identify how to reduce it.  

Energy consumption includes combustible and renewable energy, as well as fuel used in company vehicles and personal vehicles used for business. 

If you qualified as a large business under phase three of ESOS and had to submit a notification of compliance last summer, you need to submit an action plan.  

This action plan must show: 

• How you plan to reduce energy consumption 

• When you plan to do it 

• What savings you expect to achieve 

The original deadline for action plans was 5^th December 2024, but the Environment Agency has agreed to accept action plans until the 5^th of March. 

What Happens if I Don’t Submit a Plan? 

If you don’t submit an ESOS action plan by the deadline, you may face a fine for non-compliance. You may also be ‘named and shamed’ on the Environment Agency website. 

Bear in mind that you can submit an action plan that says you don’t plan to take action to reduce your energy consumption. 

However, ESOS action plans will be made public, and anyone will be able to see that you have chosen not to take steps to reduce the amount of energy you use. 

This could have a negative impact on your business. 

Who Needs to Complete and Sign Off on My ESOS Plan? 

Anyone in your business can create and submit an ESOS plan. 

However, your action plan must be signed off by a board-level director or equivalent (the ‘responsible officer’.) 

You also need a qualified lead assessor to sign off on your action plan unless: 

• You use less than 40,000kWH of energy 

• You’re ISO 50001 certified 

(If you’re exempt, you need two board-level directors to sign off on your ESOS action plan.) 

This lead assessor can be external or internal, as long as they are on an approved body register. 

What Do I Need to Include in My ESOS Plan?

The first step is to carry out an assessment.

During this assessment, you must calculate an energy intensity ratio for each energy use (for example, by building or industrial process). This helps you calculate a baseline so you can see how your business is improving in the future.

When you have this data, you need to identify what changes you can make within your business to reduce energy consumption and how much energy you will save as a result.

Your lead assessor can help you carry out your assessment and build your action plan.

Keep hold of any documentation you gather while carrying out your assessment and action plan – the Environment Agency may ask to see it.

How Do I Submit My Action Plan? 

You need to submit your ESOS action plan through the Government’s Manage Your ESOS Reporting System (MESOS). 

How Long Does an ESOS Plan Take to Complete? 

It’s tricky to say, as it depends on the size of your business and how many sites you have. However, there are some things you can do to save time. 

You only have to report on 95% of your energy consumption, so you can exclude certain areas of activity as long as they fall under the 5% threshold. 

If you have a lot of different sites you don’t have to report on all of them – you can take a sample approach.  

What Are the Next Deadlines? 

Once you’ve submitted your action plan, you need to submit an annual progress report over the next two years.  

In these progress reports you’ll need to identify what actions you achieved and what your energy savings were, as well as which actions you were unable to implement and why. 

These reports are due in December 2025 and December 2026, but there might be flex on these deadlines given that there was a three-month extension on the action plan. 

Like your action plan, these progress reports must be signed off by a board-level director and will be available to view online. 

Not Sure Where to Start? 

We understand that compiling and submitting an ESOS action plan can be challenging, especially if you’ve not thought about how you can reduce your energy consumption as a business. 

While it might feel like a lot of additional paperwork, creating an action plan can help you identify how to reduce your energy consumption and save on your energy bills.  

Consider it your blueprint to becoming a more sustainable organisation! 

If you need a little extra support, we’re here to help. We can double-check that your business is eligible for ESOS, recommend the best assessors, and talk you through how to submit your report on the Government’s web portal. 

Energy doesn’t have to be complicated – get in touch with us today.