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    ESOS explained: who qualifies for ESOS Phase 4 and how to comply

    ESOS, the Energy Savings Opportunity Scheme, is a mandatory UK energy assessment for large undertakings and their corporate groups. You qualify for Phase 4 if any UK group member has 250 or more employees, or turnover above £44 million and a balance sheet above £38 million, on 31 December 2026. Notify compliance by 5 December 2027.

    Last updated 3 November 2026 · By Ella Sustainability Team

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    What is ESOS?

    The Energy Savings Opportunity Scheme (ESOS) is a UK regulation that requires large organisations to measure their total energy use every four years, audit the areas where most of that energy goes, and identify cost-effective ways to save it. The assessment covers buildings, industrial processes and transport. The Environment Agency administers the scheme across the UK, and organisations report through the government's online system, Manage your ESOS reporting (MESOS). The legal basis is the Energy Savings Opportunity Scheme Regulations 2014, most recently amended by the ESOS (Amendment) Regulations 2026. ESOS is about energy, measured in kWh. It is not a carbon footprint, although the same bills and meter readings feed both. That overlap is the main reason to run ESOS and your SECR and Scope 1 and 2 reporting from one set of data.

    Who qualifies for ESOS Phase 4?

    You qualify for ESOS Phase 4 if, on the qualification date of 31 December 2026, your organisation meets the ESOS definition of a large undertaking. A corporate group qualifies if at least one UK group member is large, and then the whole UK group takes part. UK registered establishments of overseas companies also take part, whatever their own size, if any other part of the global group's UK activity meets the criteria. Public sector bodies usually do not need to comply.
    Who qualifies for ESOS Phase 4?
    TestPhase 4 thresholdNotes
    Employees250 or moreCounts employees, owners, managers and partners. Part-time staff count as one each
    Financial testTurnover above £44 million AND balance sheet above £38 millionBoth financial limits must be met if the employee test is not
    Accounts usedFinancial year ending on, or in the 12 months before, 31 December 2026Each UK entity is tested on its own figures, not only the consolidated group
    GroupsOne large UK undertaking brings in the whole UK groupDefined by the Companies Act 2006
    Overseas companiesUK establishments take part if the wider UK group qualifiesRegardless of the establishment's own size

    ESOS Phase 4 deadlines

    Phase 4 is the compliance period that runs from 6 December 2023 to 5 December 2027. The dates below come from the Environment Agency's Phase 4 compliance guidance. If you qualified for Phase 3, you also owe a progress update on your Phase 3 action plan by 5 December 2026, signed off by a board-level director.
    ESOS Phase 4 deadlines
    MilestoneDate
    Phase 3 action plan progress update due5 December 2026
    Phase 4 qualification date31 December 2026
    Phase 4 notification of compliance deadline5 December 2027
    Phase 4 action plan due5 December 2028
    First progress update5 December 2029
    Second progress update5 December 2030
    Third progress update (new for Phase 4)5 December 2031

    What changed in ESOS Phase 4

    The 2026 amendment regulations tightened the scheme ahead of Phase 4. The main changes are: 1. Display Energy Certificates (DECs) and Green Deal Assessments (GDAs) can no longer be used as alternative routes to compliance. The routes left are an ESOS energy audit, ISO 50001 certification, or a mix of the two. 2. Your ESOS assessment must report progress against the commitments in your previous action plan. 3. Where action plan commitments were not met, you must explain why. 4. A third annual progress update has been added, due on 5 December 2031. 5. Reasonable estimates are now allowed for energy intensity ratios where verifiable data is not available, as long as you notify the scheme administrator and record the method in your evidence pack. Phase 4 participants can also choose to include a net zero or decarbonisation assessment using PAS 51215-1:2025 and PAS 51215-2:2025. This is voluntary and MESOS does not currently accept it, so organisations that do it usually publish it themselves.

    How to comply with ESOS: step by step

    The government summarises compliance in eight steps. In practice, steps 1 to 3 are a data collection exercise and take longer than most teams expect. 1. Calculate total energy consumption across buildings, industrial processes and transport for a 12-month reference period that includes 31 December 2026. 2. Identify areas of significant energy consumption covering at least 95% of the total. 3. Calculate energy intensity ratios for buildings, transport, industrial processes and other uses, in kWh. 4. Choose your route to compliance and appoint a lead assessor from an approved register. 5. Carry out ESOS energy audits, including site visits, based on 12 months of verifiable data. 6. Complete the ESOS report and share relevant findings with every member of your corporate group. 7. Get board-level sign-off and submit the notification of compliance in MESOS by 5 December 2027. 8. Keep an evidence pack with the data, methods and estimates behind everything you submitted.
    How to comply with ESOS: step by step
    StepWhat you needCommon hold-up
    Total energy consumptionElectricity, gas, fuel and transport data for every UK site and entityBills sit with site managers, landlords and finance in different formats
    Significant energy consumptionA ranked view of energy use by site, process and fleetTeams cannot reach 95% coverage until the data is complete
    Energy intensity ratioskWh against an activity measure such as floor area or milesActivity data held outside the sustainability team
    Lead assessorAn assessor from an approved register, unless an exemption appliesBooked late in the cycle, when assessors are busiest
    Energy audits12 months of verifiable data, starting no earlier than 6 December 2022, plus site visitsMissing months on sites that changed supplier or were acquired
    Evidence packSources, estimation methods and sign-offsRebuilt from inboxes and spreadsheets at the end

    ESOS penalties

    Regulators can issue compliance notices, enforcement notices and civil penalties. The ranges below are from section 15 of the Phase 4 guidance. Regulators can also publish the names of organisations that are penalised. They do not take enforcement action for a missing action plan or progress update, but that failure is published.
    ESOS penalties
    BreachMaximum penalty
    Failure to undertake an energy auditUp to £50,000, plus £500 per working day for up to 80 days
    Failure to notify complianceUp to £5,000, plus £500 per working day for up to 80 days
    Failure to keep recordsUp to £5,000, plus the cost of the regulator's audit work
    Failure to comply with a noticeUp to £5,000, plus £500 per working day for up to 80 days
    False or misleading statementUp to £50,000

    ESOS vs SECR: what is the difference?

    Most companies that qualify for ESOS also report under Streamlined Energy and Carbon Reporting (SECR). They use the same raw data but answer different questions, on different timetables and with different size tests.
    ESOS vs SECR: what is the difference?
    ESOSSECR
    What it isEnergy assessment and auditAnnual energy and emissions disclosure
    How oftenEvery 4 years, plus action plan updatesEvery year, in the annual report
    Size test250+ employees, or turnover above £44m and balance sheet above £38mTwo of: £36m turnover, £18m balance sheet, 250 employees (plus all quoted companies)
    UnitkWhkWh and tCO2e
    Who signs offBoard-level director, plus an approved lead assessor in most casesDirectors, as part of the directors' report
    Where it goesMESOS, with most data published by the Environment AgencyCompanies House filing

    Where ESOS projects go wrong

    Our view, from working with sustainability teams at large UK groups, is that the audit is rarely the hard part. The hard part is the twelve months of data underneath it. Three patterns come up again and again. Groups that have made acquisitions find that new entities fall inside ESOS the moment they join, but their bills still go to the old finance team. Shared offices and fleets are reported once at group level, so nobody can split energy by entity when the assessor asks. And energy data gets collected twice, once for SECR in the spring and again for ESOS, by different people using different spreadsheets. The fix is boring and effective. Collect energy data once, by site and entity, with the source document attached to every number. Then ESOS, SECR, your carbon footprint and any customer questionnaire all draw from the same records, and the evidence pack builds itself as you go. If you are also a listed company, the same data will feed your UK SRS climate disclosures from 2027, which we cover in our blog on UK SRS comply or explain.

    How Ella helps with ESOS

    Ella is AI-native ESG and carbon accounting software, built as an agent. For ESOS it handles the data work that sits before and around the lead assessor: - Sends collect links to site managers, landlords and finance contacts, chases them and tracks every missing response - Reads energy bills, fuel cards and spend exports you drag and drop, and pulls in data from integrations - Sets your organisational boundary from how the business actually operates, entity by entity - Keeps the source on every number and logs any estimate with its method, ready for the evidence pack - Produces SECR summaries, Scope 1 and 2 figures and reduction roadmaps from the same data You still appoint an approved ESOS lead assessor for the audit and sign-off. Ella's sustainability team supports you through the data and the reporting so the assessor receives a complete, sourced dataset on day one.

    What happens next for ESOS

    The government's Modernising Corporate Reporting consultation, published on 7 September 2026, states that the Department for Energy Security and Net Zero will consult later in 2026 on both SECR and ESOS. Until any changes are made, the Phase 4 dates and rules above apply. Plan on qualifying on 31 December 2026 and notifying by 5 December 2027.

    How Ella helps

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    Frequently Asked Questions

    What is ESOS?

    ESOS, the Energy Savings Opportunity Scheme, is a mandatory UK energy assessment. Large undertakings and their corporate groups must measure total energy use, audit at least 95% of it, identify savings and notify compliance every four years.

    Who needs to comply with ESOS Phase 4?

    Any UK undertaking with 250 or more employees, or with turnover above £44 million and a balance sheet above £38 million, on 31 December 2026. If one UK group member qualifies, the whole UK group takes part.

    What is the ESOS Phase 4 deadline?

    The notification of compliance for Phase 4 is due by 5 December 2027. The Phase 4 action plan is then due by 5 December 2028, with progress updates in 2029, 2030 and 2031.

    What changed in ESOS Phase 4?

    Display Energy Certificates and Green Deal Assessments are no longer accepted as compliance routes, you must report progress against your previous action plan and explain missed commitments, and a third annual progress update has been added.

    What are the penalties for not complying with ESOS?

    Failure to carry out an energy audit can bring a fine of up to £50,000 plus £500 per working day for up to 80 days. Failing to notify can bring up to £5,000 plus daily penalties. Regulators can also publish the names of organisations fined.

    What is the difference between ESOS and SECR?

    ESOS is a four-yearly energy assessment and audit submitted to the Environment Agency. SECR is an annual energy and emissions disclosure in the directors' report. They use the same energy data but have different size tests and deadlines.

    Do I need an ESOS lead assessor?

    Usually yes. You must appoint a lead assessor from an approved register unless your total energy use is under 40,000 kWh or the relevant energy consumption is fully covered by ISO 50001 certification.

    Can software do ESOS for me?

    Software cannot replace the approved lead assessor or the site visits. ESG software such as Ella can collect and clean the energy data, split it by site and entity, keep the evidence and produce SECR and carbon reports from the same records.

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