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Your Journey to ESOS compliance

What is ESOS?

Energy Savings Opportunity Scheme (ESOS) regulation was introduced as part of the EU Energy Efficiency Directive. ESOS is a compulsory energy assessment scheme that ensures all large companies identify energy efficiency opportunities at least once every four years. It is then up to the individual business as to whether they implement the recommendations.

The Phase 2 compliance period of ESOS closed out on December 2019 and we are now looking at Phase 3.

The qualification date for Phase 3 is 31st December 2022.

What is the critera for ESOS?

Any UK organisation must comply with ESOS if it is defined as a ‘large organisation’ and meets either one or both of the conditions below:


Your organisation has 250 or more employees, or
has a turnover of more than £44 million annually, and an annual balance sheet total of more than £38 million


Any overseas (non-UK registered) company with a UK registered establishment which has 250 or more UK employees


Organisations qualify for the third ESOS compliance period if, on 31st December 2022, they met the ESOS definition of a large undertaking. ESOS compliance predominantly applies to businesses, not-for-profit organisations and any other non-public sector undertakings that meet the criteria must also comply.

If your organisation is fully covered by ISO 50001 then you do not need to carry out an ESOS assessment – simply submit a notification to the regulator. The Environment Agency administers the scheme for the UK and regulates the scheme in England. The Scottish Environment Protection Agency, Northern Ireland Environment Agency and Natural Resources Wales regulate the scheme in their own countries. Offshore, ESOS is regulated by the Secretary of State for Business, Energy and Industrial Strategy.

How to comply?

To comply with ESOS you must carry out the following actions.

Calculate your total annual energy consumption for the past 12 months for buildings, industrial processes and transport.

Identify the areas of significant energy consumption that account for >90% of your total energy consumption.

Conduct an energy audit that is based on 12 months of consumption data, to identify cost-effective energy saving opportunities

This whole process must be managed and approved by a Lead Assessor

A report stating your compliance must be submitted to the Environment Agency by 5th December 2023.

What are the benefits?

Whilst mandatory government schemes can often be convoluted and complex, ESOS has actually been designed to help your business. ESOS not only helps raise awareness of energy consumption issues, but it also ensures that your company is running as energy efficiently as possible.

This has two significant benefits; helping to reduce your carbon emission and lower your energy bills. Essentially, ESOS is win-win – you are helping to make the planet greener whilst reducing your outgoings, which will have an impact on your business’s margins.

What happens if you do nothing?

If your company choose not to carry out ESOS, civil penalties can be issued for non-compliance and published information on the Environmental Agency website.

Penalties for non-compliance include:

  • Failure to notify the EA of compliance – £5,000 plus £500 per working day you remain in breach
  • Failure to maintain adequate records – £5,000 plus sum equivalent to compliance body costs
  • Failure to conduct an adequate energy audit – £50,000 – plus £500 per working day you remain in breach

How EM3 can help!

Implementing ESOS can take time, resources, and expertise. With over 20 years’ experience in delivering innovative energy efficiency solutions to our clients’ energy challenges, our team of engineers can support you through the entire ESOS process and beyond.


EM3 can lead an ESOS assessment for your business. We will provide you with a registered ‘Lead Assessor’ who is on hand to guide your through the entire process. This can include helping you collate all the energy data required by ESOS, including the energy consumed by your facility, transport and industrial processes.


This would be in the shape of an energy audit (ISO50002 standards) which will meet the requirements for ESOS (survey, energy analysis and breakdown of SEUs, KPI’s, opportunity list etc.)


EM3 can carry out assessment of corporate group (parent/enfant company and site that must comply with ESOS). Multiple site surveys or sampling approach can be undertaken

Get started with ESOS as early as possible to avoid any penalties for non-compliance. Get in touch with our team today and meet the deadline!

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