ESOS Phase 4 energy audits and support with your action plan

We help organisations comply with ESOS Phase 4 energy audits, action plans, and progress updates. Our consultancy-led approach helps you meet requirements, identify practical energy-saving opportunities, and achieve compliance efficiently.

ESOS explained

What’s required under ESOS Phase 4

The Energy Savings Opportunity Scheme (ESOS) is a mandatory UK energy assessment framework for organisations that meet qualifying criteria. ESOS Phase 4 builds on earlier phases, placing greater emphasis on accurate energy data, documented energy action plans, and ongoing progress reporting to demonstrate compliance across operations.

For organisations in scope, ESOS requires assessment of energy use across buildings, transport, and operational activities. This includes calculating overall energy consumption, identifying areas of significant energy use, completing compliant energy audits, and preparing an action plan that sets out how identified opportunities will be addressed over time.

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Beyond compliance

Why ESOS matters for your organisation

For organisations in scope, ESOS is more than a compliance exercise. Requirements apply at group level and extend beyond completing audits to include action planning, progress reporting, and accountability. Even where assessments have been completed previously, gaps in documentation or reporting can still create compliance exposure.

When approached properly, ESOS also provides practical value. It gives organisations clear visibility of energy use, highlights realistic efficiency opportunities, and supports more informed decision-making. Used well, ESOS helps organisations manage compliance risk while taking structured steps to improve energy performance across their operations.

Act early

Why you should act on ESOS Phase 4 now

Many organisations delay ESOS activity until deadlines approach. This causes assessor bottlenecks, delays, and a shortage of lead assessors, risking harsh non-compliance penalties. Reporting ESOS early secures compliance, allows you to plan energy-saving investments over time, and avoids last-minute decisions that increase exposure and stress.

At Focus Green, we help organisations make steady, structured progress on ESOS Phase 4. By reviewing your position early, clarifying requirements, and planning activity in stages, we support compliance with confidence — giving you peace of mind, avoiding unnecessary penalties, and ensuring ESOS obligations are addressed properly rather than reactively.

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Who needs to comply with ESOS

ESOS applies to large UK organisations and corporate groups that meet qualifying criteria. Eligibility is assessed at group level and can include subsidiaries and UK establishments where applicable. Where criteria are met, organisations must assess and report on energy use every four years and develop energy action plans.

Who must comply

  • Large UK organisations operating in the public or private sector
  • Corporate groups with at least one UK establishment
  • Organisations responsible for significant energy consumption

Qualification thresholds

  • Employs 250 or more people, or
  • Has an annual turnover over £44 million and an annual balance sheet total over £38 million, or
  • Is part of a corporate group that contains at least one ‘large’ undertaking as defined above

Common eligibility triggers

  • Group structures that bring subsidiaries into scope
  • UK establishments within international organisations
  • Business growth since the last ESOS compliance phase

ESOS Phase 4 key deadlines

ESOS runs on a four-year cycle. Phase 4 is the current compliance period, but many organisations also have Phase 3 action plan reporting due in 2025 and 2026. Use the dates below to confirm what’s overdue and whether you’ll qualify for ESOS Phase 4 so you can plan early and avoid last-minute compliance pressure.

Past requirement

5 Dec 2025

Annual Progress Update 1
(Phase 3 Action Plan)

This deadline applies if you submitted an ESOS Phase 3 action plan. If your first annual progress update is still outstanding, it’s worth addressing it now to avoid a visible missing update status on the ESOS reporting record. I can help you quickly compile the update, confirm sign-off requirements, and submit it through the ESOS reporting system.

Upcoming – Act NOW

5 Dec 2026

Annual Progress Update 2
(Phase 3 Action Plan)

This is the second annual progress update tied to your ESOS Phase 3 action plan. You’ll need to confirm what’s been delivered, what’s changed, and where actions haven’t been met, and provide a short explanation. Starting early makes this far easier—especially if you need to gather evidence, energy data, or internal approvals before director sign-off.

Upcoming - Act NOW

31 Dec 2026

Phase 4 Qualification Date
(2027 Compliance Scope)

This is the date that determines whether your organisation qualifies for ESOS Phase 4. If you meet the large-undertaking criteria on 31 Dec 2026, you’ll need to complete your Phase 4 assessment and submit compliance by 5 Dec 2027. It’s worth checking eligibility early so you can plan audits, data collection, and sign-off without a last-minute rush.

Penalties for non-compliance

Failure to comply with ESOS requirements can result in enforcement action by the Environment Agency, including significant financial penalties and public naming for non-compliance. Organisations may be required to complete overdue assessments, submit missing action plans, and provide retrospective progress updates. Where issues remain unresolved, penalties can escalate.

If you have missed any ESOS deadlines, acting now is critical — and our expert team can support you in addressing compliance gaps before enforcement action increases.

What’s involved in an ESOS audit

An ESOS audit is a structured assessment of how energy is used across an organisation. It focuses on calculating overall consumption, identifying significant energy use, and assessing buildings, transport, and operational activities. The audit scope is tailored to how energy is consumed across the business.

Total energy consumption

We calculate your organisation’s overall energy consumption using verified data across buildings, transport, and operations, creating a clear baseline that supports ESOS compliance, accurate scoping, and informed assessment decisions processes.

Significant energy use

Areas of significant energy use are identified through data analysis, ensuring ESOS assessments focus on activities with the highest consumption, material impact, and greatest potential for meaningful efficiency improvement opportunities across the organisation.

Building energy audits

We assess energy use within buildings, reviewing heating, lighting, systems, and occupancy patterns to identify inefficiencies, support ESOS requirements, and highlight practical opportunities to improve building energy performance and outcomes.

Operational energy audits

For organisations with operational or industrial processes, we assess process related energy use to ensure ESOS audits reflect how energy is consumed across core activities and operational systems accurately consistently across all relevant business functions.

Lead Assessor review

All ESOS audits are reviewed and formally signed off by a qualified ESOS Lead Assessor, providing assurance that assessments meet technical standards, regulatory expectations, and audit requirements for full compliance and external scrutiny requirements.

Transport & fleet audits

Where applicable, we review transport and fleet energy use, including vehicles, mileage, and fuel consumption, ensuring transport activities are accurately captured, assessed, and included within the overall ESOS audit scope for full regulatory alignment.

Our approach

Five easy steps to ESOS reporting and action plans

Our ESOS process is designed to guide organisations through compliance with clarity and minimal disruption. From confirming eligibility to submitting action plans and progress updates, we manage each stage in a structured way—ensuring ESOS requirements are met while identifying opportunities to improve energy performance.

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Confirm scope

Review eligibility and define scope

We begin by reviewing your organisation’s structure, size, and previous ESOS position to confirm whether ESOS applies. This initial review clarifies scope, identifies gaps from earlier phases, and ensures the assessment is proportionate. It prevents unnecessary work, reduces compliance risk, and provides a clear foundation before data collection and technical assessment begin.

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Gather evidence

Collect data and complete site surveys

We gather and review energy consumption data covering buildings, transport, and operational activities across your organisation. Where required, site surveys are completed to validate usage patterns and assumptions. This step ensures the ESOS assessment is accurate and defensible, while keeping disruption to staff and day to day operations as low as possible throughout the assessment process.

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Analyse energy use

Assess energy use and identify opportunities

We carry out the ESOS assessment in line with current regulatory requirements, analysing how energy is used across your sites and activities. Findings are documented clearly and consistently to meet audit standards. This stage focuses on identifying practical, cost effective opportunities that support compliance and provide a robust evidence base for action planning and informed decision making.

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Plan improvements

Create a structured ESOS energy progress update

We develop a structured ESOS energy action plan based on assessment findings and organisational priorities. Actions are clearly defined, prioritised, and aligned with realistic timescales and responsibilities. The plan supports compliance while providing a practical roadmap for reducing energy consumption, improving efficiency, and tracking progress throughout the ESOS phase.

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Stay compliant

Submit and support ongoing reporting

We manage ESOS submissions and support ongoing reporting obligations to the Environment Agency on your behalf. This includes guidance on annual progress updates and changes affecting scope or eligibility. Ongoing support helps ensure compliance is maintained, records remain accurate, and ESOS requirements continue to be met throughout the full compliance cycle period.

Trusted ESOS partner

Why organisations choose Focus Green for ESOS

Focus Green supports organisations with ESOS compliance through experience, regulatory understanding, and a structured, assessor-led approach. Our focus is on accuracy, transparency, and long-term compliance—helping organisations meet ESOS requirements with confidence while navigating ongoing legislative change.

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Compliance-led by design

ESOS compliance underpins our approach. We focus on delivering accurate, consistent assessments, action plans, and progress updates that align with current ESOS requirements and Environment Agency expectations, helping organisations meet their obligations with clarity and confidence.

Proven ESOS delivery

We hold a 100% record of successfully completing ESOS reports and submissions on behalf of our clients. This reflects our structured process, attention to detail, and deep understanding of ESOS requirements across multiple compliance phases and complex organisational structures.

Aligned with regulatory change

ESOS requirements continue to evolve. We actively monitor legislative updates, guidance changes, and enforcement expectations to ensure our advice and reporting remain accurate, relevant, and fully aligned with both current and emerging ESOS obligations across all sectors and compliance phases.

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Supporting sustainability goals

While ESOS is a compliance framework, our recommendations are aligned with broader sustainability and net-zero objectives. This ensures compliance actions support long-term energy efficiency and carbon reduction goals without compromising regulatory accuracy or audit defensibility requirements.

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Experienced ESOS specialists

Our team brings extensive experience supporting organisations through ESOS assessments, reporting, and action planning. This expertise ensures technical accuracy, clear documentation, and practical guidance that stands up to scrutiny and audit requirements across complex organisational structures.

Prepared beyond submission

ESOS does not end at submission. We support organisations beyond initial compliance by helping them manage action plans, progress updates, and organisational changes—reducing risk and ensuring continued alignment throughout the compliance cycle and future regulatory requirements.

Portal access

Get access to the NZC portal for ESOS compliance tracking

NZC Portal is a single platform to manage ESOS compliance without spreadsheets or scattered updates. It’s being developed to give you clear visibility of progress, key deadlines, and reporting status in one view, helping you stay organised throughout Phase 4. Everything is tracked, structured, and aligned to ESOS requirements.

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Compliance progress

The NZC Portal provides a structured ESOS workflow that clearly shows where you stand at every stage of Phase 4. From qualification through audits to action planning, each step is visible on a single dashboard. This removes guesswork, keeps stakeholders aligned, and ensures your compliance journey remains organised, transparent, and fully controlled.

ESOS Compliance Dashboard for National Logistics Ltd showing phase timeline with qualification date 31 Dec 2026, 660 days remaining, total energy 148.1 GWh, progress updates not started, and option to upload energy data.

ESOS dashboard

The ESOS dashboard brings your entire compliance journey into one structured view. It displays phase timelines, qualification and compliance dates, progress status, energy coverage, and audit milestones in a single interface. This gives you immediate visibility, clearer oversight, and confidence that every requirement is being tracked properly.

Progress Update 2 interface showing sections for reporting period with start and end date fields, summary narrative textbox, and buttons to add measure or import from action plan.

Action plan control

The portal tracks energy-saving opportunities, action plans, and annual progress updates in a single, structured system. Measures, savings, responsibilities, and reporting status are recorded clearly, creating a documented compliance trail. This helps demonstrate progress, supports the director's sign-off, and strengthens your position in ESOS reporting.

Benefits of ESOS

ESOS compliance with practical benefits

While ESOS is a regulatory requirement, completing it properly delivers wider benefits for organisations. A structured ESOS assessment provides clarity on energy use, supports risk management, and creates a practical foundation for improving efficiency, planning future actions, and maintaining compliance across the business.

Compliance assurance

Meet ESOS obligations accurately and on time, reducing enforcement risk, penalties, and reputational exposure while ensuring assessments, action plans, and progress updates align with regulatory expectations across all qualifying organisations.

Clear visibility of energy use

Gain clear visibility of energy consumption across sites, operations, and activities, using verified data to support informed decision making, prioritise improvements, and strengthen understanding of organisational energy performance over time.

Structured energy action planning

Translate ESOS assessment findings into a structured energy action plan with defined priorities and timescales, enabling coordinated implementation, measurable progress tracking, and clear accountability throughout the full compliance cycle.

Lead assessor review and sign-off

Benefit from Lead Assessor review and formal sign off, ensuring ESOS reports meet regulatory standards, technical requirements, and audit expectations while providing confidence that submissions are complete, accurate, and defensible throughout.

Data-led energy insights

Receive hands on support to measure, interpret, and act on energy consumption data, helping translate complex findings into practical insights that inform decisions, prioritise actions, and support effective energy management across your organisation.

Costed efficiency cases

Develop costed business cases for energy efficiency projects, providing clear financial justification, realistic savings estimates, and evidence based recommendations that support investment decisions, asset planning, and long term operational improvements.

Future-ready compliance

Build long-term readiness for regulatory change by putting clear, repeatable compliance processes in place, reducing disruption and helping your organisation adapt smoothly to future ESOS requirements and ongoing reporting obligations across the compliance cycle.

Sustainability alignment

Align ESOS compliance activity with broader sustainability and net zero objectives, ensuring energy efficiency actions support carbon reduction strategies and longer term environmental goals without compromising regulatory accuracy or audit defensibility.

Qualified assessors

Built to support organisations nationwide

Our approach to ESOS compliance is designed to scale across organisations. With nationwide coverage, accredited assessors, and dedicated project management, we provide consistent, well-coordinated support—ensuring clarity, accountability, and confidence throughout the ESOS assessment and compliance process nationwide.

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Nationwide ESOS coverage

We support organisations across the UK, including complex and geographically dispersed commercial property portfolios, ensuring consistent ESOS audit delivery, coordination, and compliance support regardless of location or portfolio scale.

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Accredited assessors

Our multi-skilled assessment team holds recognised industry accreditations and completes regular training to maintain technical expertise, regulatory knowledge, and up-to-date understanding of evolving ESOS requirements and best practice.

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ESOS project management

Each organisation is assigned a dedicated ESOS Project Manager who acts as a single point of contact, coordinating delivery, managing timelines, and ensuring clear communication throughout the ESOS assessment and compliance process.

Structured approach

What to expect during an ESOS audit process

An ESOS audit follows a defined and structured process designed to ensure compliance while minimising disruption. Throughout each stage, we work closely with your team, acting as a trusted extension of your business and providing the expertise and guidance needed to achieve ESOS compliance with clarity and confidence.

1

Lead Assessor appointment

We appoint a qualified ESOS Lead Assessor suited to your organisation, ensuring the assessment is overseen and formally signed off in line with ESOS regulatory requirements from the outset appropriately and consistently.

2

Review of existing ESOS activity

Any previous ESOS reports, audits, and recommendations are reviewed to understand your current position, identify gaps, and determine what remains relevant for the current compliance phase and future reporting requirements.

3

Energy data calculation

We calculate and validate your organisation’s energy consumption, including electricity, heating fuels, fleet fuel, and company vehicles, ensuring a complete and accurate dataset for ESOS compliance.

4

Identification of significant energy use

Using verified data, we identify areas of significant energy consumption to ensure the ESOS audit focuses on activities with the greatest material impact and improvement potential across the wider organisation.

5

ESOS-compliant energy audits

Where required, high quality onsite ESOS energy audits are carried out across buildings, transport, and operational activities, in line with ESOS requirements and recognised audit standards for full regulatory compliance.

6

Action plan and submission

We work collaboratively to agree ESOS action plan priorities, then support completion of documentation and notification of compliance to the Environment Agency, ensuring submissions are accurate and complete.

Frequently asked questions

ESOS requirements can be complex, especially for organisations with multiple sites or group structures. The questions address common areas of uncertainty around eligibility, audits, action plans, deadlines, and compliance responsibilities under ESOS Phase 4. If you still have questions, please contact our team will be happy to help.

What is ESOS Phase 4?

ESOS Phase 4 is the current compliance phase, building on earlier phases with greater emphasis on accurate energy data, documented action plans, and progress reporting. It requires organisations to demonstrate not only assessment but also structured follow-through across the compliance cycle.

Who needs to comply with ESOS?

ESOS applies to large UK organisations and corporate groups that meet qualifying criteria, including employee numbers or financial thresholds. Eligibility is assessed at group level and can include subsidiaries and UK establishments, even where individual sites or entities appear relatively small.

What does an ESOS audit involve?

An ESOS audit assesses how energy is used across buildings, transport, and operational activities. It includes calculating overall consumption, identifying areas of significant energy use, and completing compliant energy audits, all reviewed and signed off by an ESOS Lead Assessor.

Are ESOS action plans mandatory?

Yes. Organisations in scope must prepare an ESOS energy action plan setting out how identified opportunities will be addressed. Progress against the action plan must then be reviewed and reported annually, making action planning a core requirement of ESOS Phase 4.

When should we start our ESOS assessment?

It is advisable to start ESOS activity well ahead of statutory deadlines. In previous phases, organisations that delayed faced assessor shortages, compressed timelines, and avoidable compliance pressure. Early engagement allows for better planning, reduced risk, and smoother delivery.

What are the penalties for ESOS non-compliance?

Failure to comply with ESOS can lead to enforcement action by the Environment Agency, including financial penalties, daily fines for ongoing non-compliance, and public disclosure. Inaccurate or misleading submissions may result in significantly higher penalties.

Enquire about an ESOS energy audit or action plan today

If you’re unsure about your ESOS obligations, deadlines, or next steps, a conversation with an ESOS assessor can provide clarity. We’ll review your position, answer your questions, and outline what’s required to achieve and maintain compliance. There’s no obligation — just clear, expert guidance to help you move forward with confidence.

Get an ESOS review from our Consultants

Whether you want to understand how to develop an energy action plan, review your sites for ESOS, or speak with a Lead Assessor, we can help.

Complete the form, and we’ll answer your questions, outline the next steps toward ESOS compliance, and provide a quick, no-obligation quote — all with clear, expert guidance throughout.

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