There may be changes to ESOS Phase 4!

There may be changes to ESOS Phase 4!

Recently the government has proposed changes to the ESOS legislation, which may come into effect before the start of the Phase 4 cycle.


In July of this year, the government declared its intent to change current ESOS legislation.  If the changes are accepted after going through the parliamentary process, some will come into force before the Phase 3 compliance deadline which you can learn more about in our previous blog here, but in today’s blog, we will discuss those which may come into force before phase 4.

ESOS legislation was first introduced in 2014 as a way for large companies to audit their estates and establish opportunities, for saving energy.

ESOS legislation applies to your organisation if:

  • You employ more than 250 employees
  • Has an annual turnover of more than £44 million or an annual balance sheet total of more than £38 million
  • You are within a corporate group where an organisation within the group qualifies for ESOS

Although the qualification date for Phase 4 is not until the 31st of December 2026, the changes to Phase 4 will include:

Display Energy Certificates (DECs) and Green Deal Assessments will no longer be included as a route to compliance.

When ESOS was first introduced there were many compliance routes that could be included within an ESOS submission, including DECs and Green Deal Assessments. Under the new changes, DECs and Green Deal Assessments will no longer be accepted as compliance routes.

Including Net Zero Plans in ESOS submissions.

Previous ESOS cycles focused on energy efficiency, but future ESOS cycles will focus on both energy efficiency and Net Zero. Although the government has yet to decide how Net Zero plans will be presented in ESOS submissions we expected further information to be released in due course. It is anticipated that the Net Zero plans could include information on any potential risks to businesses from moving to Net Zero.

The use of existing auditing standards such as ISO 50002 or EN 16247.

Currently, there is no requirement to use an auditing standard within ESOS submissions however, from Phase 4 the introduction of using an established auditing standard such as ISO 5002 or EN 16247 will be introduced to be included within the ESOS submission.

Becoming more aligned with SECR legislation.

After Phase 4, the ESOS qualification benchmarks will change to align more with SECR legislation. If organisations fall into the scope of having at least 250 employees, a balance sheet of at least £18 million or a turnover of at least £36 million, then they will have to submit an ESOS submission.

How Can We Help?

Compliance365 recognises that changes to established legislation can be confusing to organisations, but we are here to help, if you would like to read more about ESOS then click here to read our dedicated page on ESOS.

If you would like help understanding the changes to ESOS better then get in touch at 01924 669940 or e-mail and speak to one of our highly experienced ESOS experts.