After the ESOS Action Plan: What’s next for organisations?

If your organisation is in scope of ESOS, the Action Plan deadline has now passed – 5th March 2025 was the final date for compliant submissions to the Environment Agency. This is a legal requirement, so if you’ve not yet submitted your Plan, we’d advise you to do so as soon as possible to minimise the risk of enforcement action.

Organisations must now shift their focus to implementing the measures set out in their Action Plans – and preparing for the next compliance deadline: the Progress Update, due in December 2025.

What is the ESOS Action Plan Progress Update?

The Progress Update is a new requirement. It is intended to demonstrate the steps organisations have taken to implement the energy efficiency measures identified in their Action Plans.

What should the Progress Update include?

The update must cover:

• A summary of progress made so far in delivering the energy-saving actions outlined in your ESOS Action Plan.
• Any barriers encountered in implementing measures, and how these are being addressed.
• An overview of any savings achieved to date.

Your Progress Update must be submitted to the Environment Agency by 5th December 2025.

Will ESOS Action Plans and Progress Updates be made public?

Yes – both your Action Plan and subsequent Progress Update will be made publicly available. This marks a major shift from previous ESOS phases, adding a layer of transparency and increasing scrutiny on organisations’ energy efficiency commitments.

What about ESOS Phase 4? Key dates and milestones

While your Action Plan is part of Phase 3 compliance, we are already officially in ESOS Phase 4. The compliance period for Phase 4 began on 6 December 2023, and you can start data gathering now.

Getting ahead with early preparation can spread costs, reduce compliance risks, and ensure you have robust data processes in place for future reporting.

Here’s a brief timeline of ESOS milestones:

To find out more about ESOS Phase 4, you can read our dedicated guide: ESOS Phase 4: what to expect.

Advice and support

Sustainable Energy First is supporting businesses to finalise and submit outstanding Action Plans, implementation of Action Plan measures, and planning ahead for Phase 4. If you need help with any aspect of your ESOS obligations, get in touch.