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Key Changes to ESOS Phase 4

March 5, 2025

Energy Update, Insights

Following the ESOS consultation in July 2021, the intention was for the Energy Savings and Opportunities Scheme to have more of a focus on Net Zero as well as energy efficiency.  However, due to delays with updates to the legislation and guidance and the launch of MESOS during Phase 3, the government has announced that the introduction of net zero requirements will be postponed until Phase 5 (2027-2031).

Postponement of Net Zero Requirements

The mandatory net zero requirements have been postponed to Phase 5 (2027-2031). However, there will be a voluntary net zero reporting option in Phase 4.

Removal of Certain Compliance Routes

Display Energy Certificates (DECs) and Green Deal Assessments (GDAs) will no longer be accepted as compliance routes.

Action Plan Commitments

Progress against action plan commitments must be included in the ESOS assessment. If commitments are not met, participants must provide an explanation.

Qualification Criteria

The qualification criteria for Phase 4 remain unchanged. Proposed changes to align with Streamlined Energy and Carbon Reporting (SECR) requirements will not be implemented.

New PAS Standards

Further to the above changes, two new PAS standards have been published to support voluntary net zero reporting:

  • PAS 51215-1:2025: Energy and decarbonization assessment – Process Specification.
  • PAS 51215-2:2025: Energy and decarbonization assessment – Competencies of lead assessors and assessment teams.

Further details of these changes will be provided in due course. These changes and full guidance, as well as the necessary changes to the Manage your ESOS reporting system are planned to be in place by early 2027 in advance of the notification of compliance deadline for Phase 4, which is 5th December 2027.

Ready to Navigate ESOS Phase 4?

Our team at Consultus Sustainability has been supporting businesses with ESOS compliance since its inception in 2014. We’re here to help you produce your Action Plans ahead of the 5th March deadline and ensure ongoing progress with Annual Report updates due at the end of 2025 and 2026.

Contact us today to learn more about how we can assist you with your ESOS obligations and take advantage of the voluntary net zero reporting option. Let’s work together towards a more sustainable future!

Link to ESOS guidance Energy Savings Opportunity Scheme (ESOS) – GOV.UK