ESOS Phase 3 is nearly here – how will changes impact you?

We’re now just about 12 months from the ESOS Phase 3 deadline and the outcomes of the recent government consultation are here. Our team of specialists has summarised the key points to help you understand your position.

  • Display Energy Certificates (DECs) and Green Deal Assessments (GDAs) are now removed as compliance routes, leaving energy audits and ISO50001 as options.
  • ESOS reports will now need to:
    • Include an energy intensity metric (in kWh/m2, kWh/unit output, kWh/miles travelled).
    • Meet a higher standard of energy data analysis; half-hourly data from all meter types must be used where available. This builds on new policies allowing organisations to request historic half-hourly or hourly data from suppliers.
    • Provide guidance on recommendations. This is to assist ESOS participants in taking action on energy reduction.
    • Include the full group structure and, very likely, be shared with all participant subsidiaries to enable energy-saving opportunities to be realised across the group.
  • De minimis exceptions have been reduced from 10% to 5% – this may translate to an increased number of audits required compared to Phase 2, as energy use that was previously excluded may now need to be audited. The hope is that it will support participants in identifying further energy-saving opportunities.
  • Increased level of disclosure required to support compliance enforcement. We will continue monitoring the scope of disclosure and update you when the full picture is confirmed.
We think there will never be a better time to start preparing your report. The government has confirmed they are taking a tougher stance on enforcement in Phase 3, hence there will be no late entries allowed and penalties will be issued where compliance has not been met. The earlier you put a reporting plan in place, the fewer risks and complications your team will face closer to the deadline.
Visit our ESOS hub for more information or get in touch with our ESOS specialists at to explore how these changes and further updates that will impact your organisation.
Written By    Mags Kelly

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