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Energy Savings Opportunities Scheme

The Energy Saving Opportunities Scheme (ESOS) is a mandatory energy assessment scheme for organisations in the United Kingdom that are regarded as a ‘large undertaking’.

Although the scheme was originally introduced to align with the EU Energy Efficiency Directive, it has since been retained and adapted under UK law through the Energy Savings Opportunity Scheme (Amendment) (EU Exit) Regulations 2018.

As we approach the third compliance phase, the requirements for Phase III of ESOS remain in force and continue to apply independently of the UK’s departure from the EU.

For more information, we have created a YouTube series of guidance to help explain ESOS and what SEPA's regulatory role.

Do the regulations apply to me?

ESOS applies to all UK companies that meet at least one of the following criteria on the qualification date (31 December 2022 for Phase III):

  • Employs 250 or more people, or
  • Has an annual turnover in excess of £44 million, and an annual balance sheet total in excess of £38 million

This criteria is also referred to as 'large undertakings' and mainly impacts businesses, however, it can also apply to not-for-profit bodies and other non-public sectors that are large enough to meet the above criteria.

If your organisation is part of a corporate group, the highest UK parent usually takes responsibility for ensuring group-wide compliance.

Organisations with a certified ISO 50001 Energy Management System covering all energy use are considered compliant but must still notify the scheme administrator.

Participating in ESOS

Completing an ESOS assessment now has additional requirements, in line with the 2023 regulations. For full details on compliance, see how to comply with the ESOS and on the Phase 3 guidance (which will update this guidance for Phase 4).

To comply with the Energy Savings Opportunity Scheme (ESOS), qualifying UK organisations must follow these key steps:

  1. Measure your total energy use – Calculate all energy consumed across buildings, transport, and industrial processes.
  2. Identify significant energy areas – Determine which assets or activities make up at least 95% of your total energy use.
  3. Choose your compliance route – This could include energy audits or ISO 50001 certification. You must appoint a registered ESOS lead assessor unless exempt.
  4. Conduct energy audits – If required, audits must be based on 12 months of verifiable data and identify cost-effective energy-saving opportunities. The ESOS Assessment Standards below has been developed to help you to improve your ESOS outputs to help avoid non-compliance.
  5. Complete your ESOS report – Summarise your assessment, including methods used and savings identified, and share it with your corporate group if applicable.
  6. Notify the Environment Agency – Submit your compliance notification via the Managing your ESOS (MESOS) system, signed off by a board-level director.
  7. Keep an evidence pack – Maintain records of how you complied, including calculations, audit findings, and assessor details.

For full guidance on how to complete an ESOS assessment are available in the main ESOS guidance on the GOV.UK website.

ESOS Assessment Standards

Pointers to improve your ESOS outputs avoiding ESOS non-compliance

What is it?

A diagram / list of the corporate group (all the undertakings that share a common ultimate parent).

What to do / include?

  • Overseas parent(s) and highest UK parents(s) of the corporate group established.
  • All active undertakings included.
  • Authorisation letters present from highest parent(s) to:
    • support aggregation / disaggregation (if applicable)
    • confirm a responsible undertaking (if not a highest UK parent)

Making it even better

  • A ‘company tree’ showing the parental structure of the corporate group on the qualification date, that includes:
    • overseas and highest UK parent(s)
    • all UK and overseas undertakings and their level
    • status of each undertaking (active, dormant or dissolved etc.)
    • whether the undertaking consumes energy
    • breakdown into participants (if applicable)
    • qualification status of each undertaking (large or relevant)
  • Information based on the date at which the ESOS assessment was carried out to highlight any company changes during the compliance period.

What is it?

TEC: All input energy consumed by the participant.

SEC: At least 90% of the TEC; the energy use that is audited or covered by an alternative compliance route.

What to do / include?

  • TEC to include all input energy from buildings, processes and transport for the participant.
  • The same compliant reference period is used to collate the TEC across the participant.
  • TEC displayed in a data summary table supported by verifiable primary evidence (invoices, half hourly data, manual reads, etc.).
  • Data in a common energy unit or £s.
  • Conversion factors stated and referenced.
  • Where verifiable data is not available estimates are used supported by calculations and explanations.
  • Rationale for SEC/de-minimus selection provided.

Making it even better

  • Compliant reference period selected that best represents the expected future business direction of the participant.
  • Data summary, primary evidence, conversions factors and estimate calculations easily accessible from evidence pack.
  • Use of estimates minimised and justification recorded.
  • Breakdown of TEC into energy using areas.
  • Record of any sites/activities that are excluded from the TEC and justification provided.

What is it?

All sites, assets and activities that use energy including transport.

What to do / include?

  • All sites, assets and activities considered (including transport fleets and private vehicles).
  • Responsibility for landlord tenant situations determined.
  • Premises moves during compliance period considered.

Making it even better

  • For landlord tenant situations, supplies are broken down individually and responsibility determined by operational control.
  • For premises moves during the compliance period supplies are broken down individually and activities which are continued are considered.

What is it?

A methodology for selection of site visits to support the energy audits.

What to do / include?

  • Sampling approach is representative of SEC.
  • Variations in; activity, building type, size etc. are all considered.

Making it even better

  • Robust sampling approach used with a large number of ‘site visits’ carried out at for each variation in; activity, building type, age, size, etc.
  • Site audit selection takes into consideration future business direction of the participant and previous energy audit work.

What is it?

Audit(s) of the participants SEC that meet the minimum ESOS energy audit criteria.

What to do / include?

  • 12 months of energy audit data is used in line with the minimum ESOS energy audit criteria.
  • Displayed in data summary tables supported by primary evidence.
  • Conversion factors stated.
  • Estimates supported by calculations.
  • This can be the same as the TEC data.
  • Analysis conducted on the data for each of the sites that were visited (including transport), e.g. a breakdown of supply type by area/activity/appliance.
  • Energy Profiling carried out where appropriate and reasonably practicable.
  • Any compliance by alternative routes is supported by valid certificates.

Making it even better

  • Strategic selection of compliant 12 months of energy data to increase the benefit of the assessment, such as optimisation of ‘actual’ data (noting audit data can differ from the TEC).
  • Data summary, primary evidence, conversions factors and estimate calculations easily accessible from evidence pack and all correlate with each other.
  • Suitable justification for use of estimates recorded.
  • Where relevant additional analysis methods such as degree day analysis and bench marking are utilised.
  • Use of energy profiling is maximised.
  • Justification provided for any areas where further analysis is unsuitable.

What is it?

Reasonably practicable opportunities that will save energy for the participant once implemented.

What to do / include?

  • All reasonable opportunities identified for each visited site and transport.
  • Cost benefit calculations provided for each individual opportunity, either Simple Payback Period (SPP) or Life Cycle Cost Analysis (LCCA), as appropriate.
  • Cost benefit calculations extrapolated to non-visited sites within the SEC (where applicable).
  • Lead Assessor discloses any opportunity types which they have a commercial interest in.

Making it even better

  • Lead Assessor and participant agree and document what constitutes a reasonable energy savings opportunity.
  • Justification provided for any obvious opportunities that are missing.
  • Each opportunity can be traced back to the corresponding energy audit analysis work, with clear calculations, which resulted in its identification.
  • Use of LCCA is maximised, particularly for high capex or long life projects, were appropriate and justification for use of SPP is provided.
  • If the implementation of one opportunity effects the benefits of another this should be taken into account to avoid double counting.
  • Opportunities are ranked into a logical order to assist presentation to board members e.g. lowest cost, shortest payback, biggest savings potential.

What is it?

Sign off of ESOS assessment.

What to do / include?

  • Lead assessor sign off present, to confirm assessment meets the ESOS Regulations including lead assessors registration body.
  • Board director sign off present, to confirm assessment has been reviewed by the board. If the director is notat board level, then justification must be provided.

Making it even better

  • Lead assessor selected that has experience within the participants sector.
  • Board level director sign off present against the four bullet points.
  • Presentation of ESOS assessment findings delivered to board.

What is it?

Online confirmation of compliance to Environment Agency.

What to do / include?

  • Notify the Environment Agency of compliance after the ESOS assessment is complete and before the compliance deadline for the Phase.
  • Answer the compliance questions using the information collated from the sections above.

Making it even better

  • At least one of the primary or secondary contacts should be from the participant organisation as opposed to the lead assessor organisation.
  • A copy of the notification retained within the evidence pack.
  • Answers to all voluntary questions provided.

What is it?

A folder on a server or hard copy where you keep copies of the information that supports your ESOS assessment.

What to do / include?

  • Documents all records from the above sections.
  • The location of any documents not held directly in the evidence pack (e.g. invoices) should be referenced.
  • Be in the hands of the participant not just the third party lead assessor organisation.

Making it even better

  • A contents page.
  • Document control.
  • The evidence pack ‘is’ the ESOS assessment and should show the approach taken by the participant to comply with the scheme.

Latest updates to ESOS

The government has decided to postpone some changes announced in the previous government’s response to the ESOS consultation.

Changes to Phase 4

Some planned changes like adding net zero requirements and aligning ESOS with Streamlined Energy and Carbon Reporting (SECR) thresholds have been postponed until Phase 5 to give organisations more time to prepare. These changes will no longer apply in Phase 4.

What’s still going ahead

For Phase 4 - compliance deadline is 5 December 2027, the following updates are still expected:

  • You can no longer use Display Energy Certificates (DECs) or Green Deal Assessments (GDAs) to comply.
  • You must report on progress against your ESOS action plan or explain why targets haven’t been met.

New standards and action plans

British Standards Institution (BSI) have published two new voluntary standards to support better assessments:

If you submitted a compliance notification for Phase 3, you must also submit an action plan and provide progress updates during Phase 4. The action plan must be signed off by a board-level director and submitted via the Manage your ESOS reporting system.

For details about ESOS action plans please refer to section 12 in the available guidance on the GOV.UK website.

Enforcement and penalties

As the regulator for businesses registered in Scotland, we have the power to issue civil sanctions, including financial penalties, if an organisation does not meet the scheme’s obligations.

For more information see our Enforcement page.

Business benefits of implementing ESOS

The Energy Savings Opportunity Scheme (ESOS) is designed to help large businesses uncover the financial and operational benefits of energy efficiency and is more than just a compliance tick box exercise.

It’s a chance to cut costs, reduce risk, and boost performance through smarter energy use. SEPA’s One Planet Prosperity strategy encourages businesses to go beyond compliance by embracing innovation and resource efficiency.

The UK Government have developed A guide to implementing Energy Savings Opportunities to support businesses in implementing the opportunities identified from ESOS assessments.

While implementing energy-saving measures identified in your ESOS audit isn’t mandatory, they often present a strong business case. If you need help taking action, a range of free support is available:

Energy Saving Trust (EST)

Scottish Enterprise (SE)

Highlands and Islands Enterprise (HIE)

Scottish Manufacturing Advisory Service (SMAS) (An SE / HIE service)

Business Energy Scotland

  • Online Guidance on raw materials, waste, energy and water, developing a business case for your resource efficiency projects
  • Tools: Lighting and boiler replacement calculators
  • Staff awareness, engagement and training
  • Due to funding criteria, tailored advice is only available to SME’s. However, large businesses are able to access online guidance and attend event and webinars

Carbon Trust

SEPA

  • Advice and guidance on environmental regulation
  • NetRegs – Free online environmental guidance and best practise
  • Support for innovation and measures to go beyond compliance

Contact us

If you have any questions or require any further information or advice on any aspect of ESOS, please contact us.