With the compliance deadline for ESOS Phase 3 passing in August 2024, organisations should be shifting their focus to what comes next. Phase 4 is already on the horizon, and the expectations are rising – from stronger action plans to public disclosure and tighter links with Net Zero.
In this blog we outline what businesses should do now to prepare, and how Optimal Monitoring can help you stay ahead of compliance while unlocking lasting energy savings.
What Is ESOS, and Where Are We Now?
The Energy Savings Opportunity Scheme (ESOS) is a mandatory energy assessment and energy-saving identification programme for large UK organisations. It requires qualifying businesses to:
- Measure total energy consumption across buildings, transport, and processes
- Carry out energy audits to identify cost-effective energy-saving opportunities
- Report compliance to the Environment Agency
ESOS Phase 3 placed greater emphasis on improving data accuracy and identifying cost-effective energy-saving opportunities. It also introduced more robust audit standards and required organisations to demonstrate clearer oversight of their energy use.
With that deadline behind us it’s time to be looking ahead, Phase 4 will conclude in December 2027, but with enhanced requirements, and so the time to act is now.
What’s Still Required Under Phase 3?
Although the compliance notification window for ESOS Phase 3 has closed, many organisations still have ongoing obligations. The scheme now includes mandatory follow-up reporting to show that energy-saving opportunities identified during audits are being acted upon.
Here’s a summary of what’s required:
| Requirement | What You Need to Do |
Deadline
|
|
Action Plan
|
Submit a board-approved plan outlining the energy-saving measures you intend to implement, including timelines and savings.
|
5 December 2024
|
|
Annual Progress Update 1
|
Report on which measures have been completed, what’s been delayed, and why. Include actual savings where known.
|
5 December 2025
|
|
Annual Progress Update 2
|
Provide a second update showing progress over the following year and any additional measures taken.
|
5 December 2026
|
|
Public Disclosure
|
Both the Action Plan and updates will be published by the Environment Agency, excluding sensitive details. | Within 6 months of each submission |
These reports must be submitted through the ESOS IT portal and signed off by a board-level director.
If you’re behind on Phase 3 planning, now is the time to catch up. We can help you build your Action Plan, track progress, and automate updates — turning a compliance task into a meaningful energy-saving strategy.
What to Expect from ESOS Phase 4
Although final guidance is still to come, the government has already outlined several expected changes for Phase 4. These include:
- A stronger focus on implementation planning, not just identifying savings opportunities
- A new requirement to publicly disclose actions taken in response to audit findings
- A closer tie between ESOS and Net Zero strategies
- Mandatory use of standardised templates for submissions, via the new online ESOS portal
These changes reflect the UK’s broader decarbonisation goals and will place a greater emphasis on turning audit recommendations into real, reportable outcomes.
Why You Should Start Preparing Now
Too many businesses treat ESOS as a last-minute compliance deadline. But those that act early can gain much more, including:
- Better control and visibility over energy data
- Time to plan and budget for meaningful energy efficiency projects
- The ability to align ESOS compliance with ESG reporting and Net Zero roadmaps
- Reduced audit stress by embedding data capture and reporting into day-to-day processes
Waiting until 2027 will only compress timelines and increase risk. By acting now, you can build a phased plan and make data-backed decisions that benefit your business in the long term.
How Optimal Monitoring Helps You Stay Ahead
At Optimal Monitoring, we believe energy compliance should be more than a box-ticking exercise. Our EMMA AI platform helps you turn energy data into action – without the CapEx.
Here’s how we support organisations preparing for ESOS Phase 4:
- Sub-metering and data migration for high-quality, accurate energy usage data
- A user-friendly central data portal to monitor, visualise, and report energy consumption
- Automated alerts and reporting to support audits and internal ESG tracking
- Identification of quick wins and long-term opportunities to reduce energy waste
- Support from real experts to guide your team through audits and strategy development
Whether you’ve just finished Phase 3 or are looking to future-proof your energy approach, we help you get more value from your data – and your time.
Start Early, Save More
The next ESOS deadline may feel distant, but Phase 4 will demand more than just compliance. It’s about action, transparency, and accountability.
Businesses that prepare now will not only stay ahead of regulation, they’ll gain real commercial and environmental benefits along the way.
Ready to make your energy data work harder?