The completion of ESOS Phase 3 marked a critical milestone for businesses committed to improving energy efficiency and meeting regulatory standards. However, the journey does not end there! Between ESOS Phases 3 and 4, organisations are required to maintain momentum by submitting ESOS Action Plans and Annual Progress Updates, ensuring a clear trajectory towards meaningful energy savings. The disclosure portal for submission is now open, so we’d recommend starting as soon as possible to comply and capitalise on the energy savings you’ve identified.
After complying with ESOS Phase 3, businesses are expected to focus on the potential energy-saving actions identified during the ESOS audits, therefore are required to periodically submit compliance notifications. These include submitting an ESOS action plan and ESOS annual progress updates.
An ESOS action plan sets out to state intended energy efficiency measures, anticipated implementation dates, and projected savings. The action plan covers a four-year period (6th December 2023 – 5th December 2027) and demonstrates a long-term commitment to improving energy performance.
The Annual Progress Updates aim to track and document the implementation of these actions, providing a transparent view of achieved energy reductions and the overall impact. These include details on which actions have been implemented, when they were undertaken, and the measurable outcomes achieved. Annual Progress Updates must be submitted annually until the next phase, ESOS Phase 4, which has the deadline of 5 December 2027.
Compliance with ESOS goes beyond fulfilling a regulatory obligation. It publicly signals an organisation’s willingness to align with legislative frameworks, reinforcing trust with stakeholders, clients, and the public.
The creation and implementation of an ESOS Action Plan provides businesses with a clear pathway to reducing energy consumption. Periodic reviews and annual progress updates allow organisations to assess their success, adapt their strategies, and maximise energy efficiency gains over time.
By publicising transparent energy-saving initiatives, organisations can position themselves as leaders within the broader Net Zero and sustainability conversation. Engaging internal and external stakeholders fosters collaboration and helps drive impactful change across sectors.
The current deadlines according to the Environment Agency at the time of writing (November 2024) are as follows:
Further information on deadlines can be found on the Government website here.
*Whilst this is the official deadline, The Environmental Agency announced that ESOS Action Plan submissions up until the 5th March 2025 will still be accepted.
We will always encourage organisations to comply as soon as possible to reap the benefits of implementing energy-saving actions.
Developing and maintaining an ESOS Action Plan and Annual Progress Update is a systematic process designed to ensure consistency across reporting periods. The core requirements include:
This straightforward approach ensures that businesses not only stay on track with compliance but also derive substantial long-term benefits.
ESOS reporting is a legislative requirement, providing organisations with a framework to make measurable energy improvements. While the process may seem like a continuation of previous phases, it serves as a powerful tool for achieving genuine energy reductions and driving business growth through sustainability.
By approaching ESOS Action Plans and Progress Updates as more than just a requirement, businesses can transform regulatory compliance into an opportunity for innovation, efficiency, and stakeholder engagement.
Our team of experts have the latest in-depth knowledge about the requirements and guidelines of ESOS. At Energise, we have a strong team of 5 qualified Lead Assessors ready to support you to take the next step for your energy saving opportunities.
With the disclosure portal now open for ESOS Action Plan submissions, get started today to demonstrate your action to The Environmental Agency, keep momentum and avoid the rush nearer the deadlines.
Take the first step and book a complimentary call and discover how we can support your organisation’s ESOS Action Plan:
Written By Emma Lane 
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Between ESOS Phases 3 and 4, organisations are required to submit ESOS Action Plans and Annual Progress Updates, ensuring a clear trajectory towards energy savings. The disclosure portal for submission is now open, so we’d recommend starting as soon as possible to comply and capitalise on the energy savings you’ve identified.
