ESOS Action Plan | How to Comply with Your Phase 3 Obligations

Creating an ESOS Action Plan

What to include in your plan, and why it’s needed.

If you qualify for ESOS, you need to ensure that you’re meeting the required deadlines. As part of the recent changes to the scheme, you need to create and submit an action plan based on your Phase 3 reports. There’s a lot to include, and the fact that it’s publicly disclosed adds pressure, but don’t worry, we’re on hand to help.

We run through everything you need to know to create an ESOS action plan in this guide so you can remain compliant.

What is the ESOS Action Plan?

The ESOS action plan is a requirement as part of the changes made to ESOS Phase 3. All organisations that qualify for ESOS are required to submit one.

The action plan must include specific criteria, it must detail how you’ve calculated savings but does not require further justification for chosen initiatives. It must also be signed off by a board-level director or your organisation’s equivalent.

The period covered by the Action Plan is the four years following the compliance period (which coincides with Phase 4) and covers the period from 6 December 2023 to December 2027.

However, the Environment Agency (EA) has recently announced an extension. In Issue 28 of the ESOS Newsletter the EA stated they will accept action plans as long as they’re submitted by 5th March 2025. However, organisations should try to meet the 5th December deadline where possible.

Following this, you need to submit progress updates against the commitments in your plan for the next two years. The deadlines for these updates are 5th December 2025 and 5th December 2026 and have to be signed off by a board-level director or equivalent, and submitted through the notification system.

Why is it important?

Businesses have a significant role to play in climate change. ESOS is designed to help your organisation become more energy-efficient and sustainable. It’s one thing to identify actions that could improve your organisation’s efficiency, but the action plan actually holds you accountable. You’ll need to provide an update on your progress each year, which will help you meet your targets.

Getting a plan in place will also set you up for your ESOS Phase 4 compliance. For your Phase 4 compliance submission, you will need to prepare an evidence pack and this will include methodologies and calculations. Phase 4 is expected to have a greater focus on net zero, and your Plan will help you prepare for this.

What happens if you don’t submit?

Submitted action plans will be published by the EA for the public to review. Failure to submit by the deadline will be recorded, and EA will publish that you don’t intend to carry out any energy-saving actions.

If you don’t plan on reducing your energy consumption before the next ESOS compliance date, you can submit a notification stating this – but this will also be made public.

Failure to submit a plan is likely to lead to a negative perception of your organisation and harm your reputation. Research has found that more than two-thirds of consumers will look for sustainable options for services they use. If a competitor can demonstrate that they’re taking action, they’re likely to be more appealing to consumers.

ESOS is a mandatory scheme, and even if there’s no financial penalty for failing to submit an action plan, failing to comply with the scheme can lead to fines ranging from £5,000 to £90,000.

ESOS Action Plan Progress Reports

You’ll need to provide two progress reports based on your plan. These will need to be submitted on 5th December 2025 and 5th December 2026, with the update covering the 12 months before each deadline. These updates are designed to add an extra layer of accountability. They will be published and available to the public to show progress on the actions you’ve said you’ll be taking.

If you fail to submit an update, the Environment Agency will publish an update on your behalf that says no actions have been taken and you haven’t met any targets that you’ve committed to in your action plan.

You can include goals outside of your ESOS report, but you need to make these clear in your action plan and will still have to provide updates against any commitments you make.

You can find out more about setting targets in our sustainability guide.

Targets overlapping with other schemes

The ESOS reporting period covers the same period as other energy reporting schemes. You can include these in your action plan, but you’ll need to make it clear if any targets you are including relate to another scheme. You can find the full list of energy reporting schemes here.

Schemes like GHG can help you work out energy savings for ESOS through the data collection you’ll undergo to comply with them. However, they’re unlikely to demonstrate all the savings made over the 4-year report period, as they’re not as broad.

SECR has the most crossover with ESOS as it also requires companies to report on their carbon emissions and energy usage and steps taken to increase their energy efficiency. If you’re eligible for both schemes, you can use your ESOS progress update in your SECR reporting. You may choose not to if the SECR reporting year isn’t December to December or if you want to provide different levels of reporting in each report.

Complying with other schemes does not make you exempt from ESOS. If you’re eligible, you still need to meet the deadlines.

Energy reductions & data sources

Your action plan needs to include predicted savings in kWh and how you calculated them. This should already be in your Phase 3 report – if not, your previous lead assessor or a member of the Ignite team should be able to help with collecting these.

Predicted savings should be broken down into key areas of your business, as well as savings for individual actions and a figure for the total made through your action plan. For each yearly progress report, you’ll need to include the reductions relating to each period.

You’ll need to include how the data is collected in your evidence pack. Ignite can help with your data collection and analysis.

ESOS Action Plan dates and timelines

There are several dates you need to comply with when submitting your action plan. We’ve listed these below to ensure you don’t miss a deadline.

• 5th December 2024 – Initial deadline to submit your action plan.
• 5th March 2025 – Extended deadline for submitting your action plan.
• 5th December 2025 – deadline to submit your first progress report.
• 5th December 2026 – deadline to submit your second progress report.

Energy compliance with Ignite

ESOS requires a lot of time and work to ensure you’re staying compliant. Remember why you’re doing this, to make your organisation more sustainable and the financial benefits that good PR stemming from this will bring.

But take the pressure off by allowing Ignite to handle this for you. We help you with many of the processes required for the action plan, taking the pressure off and ensuring you remain fully compliant.

Contact us by emailing enquiries@igniteenergy.co.uk or calling our team on 0333 023 2222 today.