ESOS – is it time to comply?

The qualification date for Phase 3 of the Energy Savings Opportunity Scheme (ESOS) is fast approaching and the compliance deadline is only months away. Ian Guest's Blog explains how to find out if your business is obligated, next steps and how Valpak can help.

We’re almost half way through 2022, meaning the qualification date for Phase 3 of the Energy Savings Opportunity Scheme (ESOS) is fast approaching and the compliance deadline is now only months away.


An announcement on ESOS reforms for Phase 3 was expected to have been published by now; however, it is likely that the results of the consultation and the requirements of compliance will not be published until July 2022 at the earliest.

We anticipate that organisations that meet the large undertaking criteria are still likely to be required to undergo compulsory energy audits by qualified auditors. We also anticipate that there may be exclusions depending on level of energy usage and that there may be more responsibility on organisations to deliver energy saving opportunities identified and to incorporate these into a Net Zero Greenhouse Gas Emissions plan. It will therefore be even more important to choose a well-qualified and experienced ESOS auditor.

Despite the delay in details of Phase 3, the deadlines for audit completion will not change.

You may be thinking you have a while to get your ducks in a row, but, if your business is obligated, we would strongly encourage you to book in a Lead Assessor as soon as possible to avoid delays in completion of the ESOS Assessment.

Is my business obligated?

Before acting you need to find out if your business needs to comply.

If your company, or any one UK company within the corporate group, meets the definition of a large undertaking it has an ESOS obligation.

A large undertaking is a company which on 31 December 2022 has 250 or more employees, or a balance sheet exceeding £38 million and a turnover of £44 million.

For companies that have grown, the ‘two-year rule’ will need to be considered, meaning you need to look at the company size over a consecutive two-year accounting period. If the business meets the criteria for the first time in the accounting period ending on or before the 31 December 2022, it is likely it will not need to comply.

I know my business is obligated. What are the next steps?

Now is the time to make sure energy monitoring is in place to capture an accurate 12 months’ data and calculate total energy usage.  This needs to include the 31 December 2022 and all energy consumption and sources should be captured. There are NO exceptions!  You may already have records for main consumption, such as electricity, but is monitoring in place for smaller or ad hoc supplies?  Some companies have needed to put new mechanisms in place to ensure they have adequate records. For example, staff expensed mileage.

You should also identify your energy auditor and, if different, your Lead Assessor (LA).  In the previous phase, due to Lead Assessor demand, we saw fees increase as the compliance date got closer. It is therefore prudent to identify your LA sooner rather than later.

Valpak can help

To ensure compliance with the Energy Savings Opportunity Scheme (ESOS) companies should act now! We have developed a service to fulfil all of your ESOS compliance requirements. If you would like to find out more, please do not hesitate to contact us on 03450 682 572 or email [email protected].  If you’re unsure if your business needs to comply, why not visit our ESOS web page.


We are hosting a free Preparing for the next stages of ESOS & SECR webinar on 19 July 2022, which will discuss and explore the requirements of ESOS and detail the actions that need to be taken. Visit our events page to book your place.