The Energy Savings Opportunity Scheme (ESOS)

The Energy Savings Opportunity Scheme (ESOS) is a mandatory reporting requirement designed to make qualifying UK businesses more energy efficient. Our ESOS consultants are on hand to help you understand whether your business is required to comply with ESOS Phase 4 and if so, ensure your data is compiled correctly and your compliance notification is submitted before the 5 December 2027 deadline.

ESOS

About the scheme

What is the Energy Savings Opportunity Scheme (ESOS)?

The Energy Savings Opportunity Scheme (ESOS) is a mandatory energy audit, applicable to large organisations in the UK that fall within the qualifying criteria.

Every four years, qualifying businesses must audit their energy use, identifying cost-effective energy saving opportunities. They must then submit their data and findings to the respective regional regulator in order to avoid unwanted penalties.

Governed by the Environment Agency (EA) in the UK, the scheme was initially introduced as the Energy Savings Opportunity Scheme Regulations 2014. Now in ESOS Phase 4, if your organisation meets the size criteria on the qualification date of 31 December 2026, you must submit your notification of compliance to Manage Energy Savings Opportunities Reporting Service (MESOS) by 5 December 2027.

Preparing your audit early protects you from financial penalties and gives you time to act on any findings.

Business compliance criteria for ESOS Phase 4?

ESOS qualification criteria

Guidance from the Environment Agency states that ESOS regulations apply to large UK undertakings and their corporate groups.

This applies if by 31 December 2026 your UK undertaking has:

  • 250+ employees, or
  • an annual turnover greater than £44 million, and an annual balance sheet total greater than £38 million

What is involved with the ESOS Phase 4 survey?

The energy audit your business carries out should span a 12 month period and include:

  • Analysis of energy consumption
  • Identification and categorisation of energy saving opportunities to improve energy efficiency and which would be reasonably practical to implement
  • Estimated costs, risks and benefits of the energy saving opportunities
  • Recommendation for a programme to implement the energy savings

KEY DATES

ESOS phase 4 key dates and deadlines​

Businesses should consider both the qualification date and the compliance deadline by which the audit must be submitted.

Phase 3

5 December 2026

Phase 3 second progress update required

Phase 4

31 December 2026

Phase 4 qualification date

Key deadline

5 December 2027

Phase 4 notification of compliance deadline

Phase 4

5 December 2028

Phase 4 action plan

⚠ Failure to meet the deadline for qualifying companies may result in penalties and fines.

Our service

Leyton’s ESOS consultancy & survey support service

Our energy consultants are positioned to support with your end-to-end ESOS report.

01.

Qualification check

We review your corporate structure, group relationships and overseas entities to confirm whether you’re in scope, and advise where ‘Do Not Qualify’ notifications are needed.

02.

Energy audit and data

We help you get your energy data in order and deliver an audit covering your significant energy use across buildings, transport and industrial processes.

03.

Compliance and notification

We prepare your report, support director sign-off, and submit your notification to the Environment Agency, then support your action plan and progress updates.

04.

Continued support

We will help you submit your action plan due 5/12/2028 and subsequent annual updates until the end of phase 4.

Energy services

Explore our other energy services

We offer support across other energy reporting needs such as SECR or CBAM, alongside our range of fully managed energy tax relief services. From reviewing your eligibility for government exemptions and compensation, to auditing your processes and implementing action plans that optimise your energy performance and competitiveness.

Get in touch

Start your ESOS audit today

We’re here to help. Book a free assessment with our ESOS consultants to find out whether ESOS applies to your business and what you need to do before the deadline.

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Frequently Asked Questions

My company didn’t complete phases 1, 2, or 3 should we still comply with phase 4?

Even if your business didn’t qualify within phases 1-3, if you now meet the qualifying criteria you must comply with ESOS regulations for phase 4.

You can be liable to an initial financial penalty of up to £50,000, along with a daily penalty of £500 for each day the deadline has been breached. Penalties will also be applied for failure to notify, not just for failure to undertake the audit.

The ESOS phase 4 survey deadline is 5th December 2027, though whether you need to comply will be determined by your position on 31 December 2026.

ESOS is administered by the Environment Agency (EA), and supported in Scotland by the Scottish Environmental Protection Agency, in Wales by the Natural Resources Wales and the Northern Ireland Environment Agency for registered offices in Northern Ireland.

Your ESOS energy audit should be submitted via Manage Energy Saving Opportunities (MESOS) on the GOV.UK website.

If your business qualified for ESOS phase 3, which ran between 6 December 2019 and 5 December 2023, you must submit an annual progress update by 5 December 2026. This should correspond to the plan you submitted for ESOS Phase 3.

If one entity in a corporate group qualifies, all UK entities in that group are in scope. Additionally, if any UK-registered part of an overseas company qualifies, all of its UK-registered branches will be in scope. If you qualified in a previous phase but no longer meet the criteria, you should submit a “Do Not Qualify” notification.