FREE WEBINAR: Maximising ESOS Action Plans for Net Zero

Maximising ESOS Action Plans for Net Zero
If you didn't make it to the live stream, you can now catch up on everything you missed!
Link to the recording here
Thanks to everyone who joined us for this insightful webinar. We had some great questions during the session that we didn't have time to answer, so we have gathered the answers from our experts. Please find them below.
- Can I amend the ESOS Action Plan that I've already submitted?
You must submit the Action Plan by the relevant deadline for that compliance period. Amending your Action Plan should still be possible before the final deadline of that compliance period, as long as:
- The amendments are well-documented and justified.
- The amended plan complies with the ESOS regulations and is supported by valid energy audit data.
- What if there are any changes to the group structure over the next 4 years?
Changes to the organisation, occurring between the 5th Dec 2024 and the 5th Dec 2027, need to be recorded in the evidence pack when they happen and need to be reported in the next plan update submission.
Records should be kept of whether the legal entity leaving/joining is either joining in on the action plan of the new parent group, stays with the old parent group for ESOS action plan reporting or is reporting on its own for the remainder of the action plan period, which would include written agreements with the relevant group if applicable.
See section 13.5 of the guidance
- What are the qualifying criteria for ESOS, including turnover, number of employees, and other factors?
Qualification Criteria for ESOS
- Large undertakings: Your organisation qualifies if, on the qualification date, it meets any of the following:
- Employee threshold: 250 or more employees.
- Turnover and Balance Sheet:
- Annual turnover exceeds £44 million, and
- An annual balance sheet total exceeds £38 million.
- Corporate groups:
- If a corporate group contains at least one qualifying undertaking, all UK-based group members must participate in ESOS, regardless of their size.
- Not-for-profits and charities:
- These qualify if they meet the same employee and financial thresholds.
- Public sector:
- Public sector organisations are not required to comply with ESOS, but organisations that are partly public/private (e.g., trusts) may need to comply.
- Small and medium enterprises (SMEs):
- SMEs are exempt unless they are part of a corporate group that qualifies under the above criteria.
Exemptions
Certain organisations can be exempt from ESOS if they are fully covered by alternative schemes, such as ISO 50001-certified energy management systems.
- How should energy savings be calculated? Are they based on annual savings or the total savings achieved over the four-year action plan period? Can you share where this is in the ESOS guidance, please?
See ESOS guidance section 12.3. Extract of 12.3.3 and 12.3.5 below specifically states that the savings estimates must be for the savings achieved in the 4 year action plan period, not the annual savings. See below:
12.3.3 Estimating savings
Having considered what actions to take, for each action you must estimate the total energy that you would expect to save from taking that action by the date of implementation.
The savings must be estimated from the date of implementation over the four years of the action plan period, which for the third compliance period is 6 December 2023 to 5 December 2027. If an action is to be implemented by 6 December 2023, then the savings can be estimated for the full action plan period.
If you expect to take the action part way through the action plan period, you should estimate the energy that you expect to save over the period between the date you expect to implement the action and 5 December 2027, for example by calculating a pro-rata saving based on estimated annual savings.
Example: Company A uses the estimate in their ESOS report for the lighting upgrade, which has an estimated annual saving of 25,000 kWh per year in their ESOS report. They expect to have installed this upgrade 2.5 years before the end of the action plan period, so their estimated saving for the whole period is 25,000 x 2.5 = 62,500 kWh.