ESOS – Escaping the Cycle

ESOS has always had alternative routes to compliance, in Phase 4 we see two of these being removed, but the third strengthened.  DECs and GDAs are no longer an option for deemed compliance, but ISO 50001 is.

ISO 50001 certification can be used as an alternative route to ESOS compliance, removing the need to appoint a lead assessor if:

  1. The ISO 50001 certification covers either the total or significant energy consumption.
  2. The ISO certificate was issued on or after the start date of the compliance period (6th December 2023) and must remain valid on the compliance date (5th December 2027).

Your energy management system must be certified by one of the following:

  • a UKAS accredited certification body
  • a body accredited by an EU member state’s national accreditation body
  • a body accredited by a member of the International Accreditation Forum

If only part of your significant energy consumption is covered by your certificate then you must appoint a lead assessor and undertake energy audits to appropriately capture your SEC.

If you do comply via ISO 50001 you still have to:

  • calculate your total energy consumption and, as applicable, significant energy consumption
  • calculate energy intensity ratios
  • get a director (or equivalent) to confirm that the information required for the notification of compliance is correct
  • submit a notification of compliance through MESOS
  • keep an evidence pack

There are many benefits to ISO accreditation and the pursuit of a compliant energy management system, reducing the cost of ESOS compliance is only a small part of the picture.  If you feel your organisation might be ready then it may be too late to use it for compliance for ESOS Phase 4 but getting a gap analysis is a great first step and will bring savings for Phase 5.

ESOS Phase 4 – who’s captured and what’s changed?

It feels like yesterday the ESOS 3 Action Plans were being drafted, but here we are again preparing for the next cycle of the Energy Savings Opportunities Scheme.  So what’s new in the fourth iteration of the scheme?  Not as much as we were expecting in the end!

During consultation we were expecting this phase to operate quite differently to ESOS P3.  The government consulted on:

  • improving the quality of audits through increased standardisation of reporting requirements
  • the inclusion of a net zero element to audits
  • requiring public disclosure of high-level recommendations by participants

Most of the items were approved, with varying timelines, some to be implemented immediately for Phase 3, others to delay until Phase 4.

https://www.gov.uk/government/consultations/strengthening-the-energy-savings-opportunity-scheme-esos

Since then, we have had government changes and the outcome of the consultation has not been applied as expected.  Changes from ESOS P3 that are planned to go ahead are:

  • removal of Display Energy Certificates (DECs) and Green Deal Assessments (GDAs) as compliance routes
  • progress against action plan commitments to be included in the ESOS assessment
  • where action plan commitments have not been met, participants must provide an explanation

Due to delays in legislature the items which were previously planned to align ESOS with Net Zero and SECR have been pushed to Phase 5.  These would have been:

  • changes to refocus the scheme to cover net zero as well as energy efficiency
  • change to qualification thresholds to better align with Streamlined Energy and Carbon Reporting (SECR)

Here at Ethical Sustainability we will be operating to the newer PAS 51215-1:2025, and PAS 51215-2:2025 standards voluntarily.  Our priority remains tailoring our surveying and your recommendations to align with your business strategy and manufacturing priorities.

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