ISO 50001 is recognised as a valid route to compliance with the Energy Savings Opportunity Scheme (ESOS). But recent updates to the Phase 3 requirements could catch out some businesses.
ISO 50001 is an international standard for energy management systems in buildings. Up to now, if your ISO 50001 certification covered all your building emissions then you did not have to produce a separate ESOS report.
This is no longer the case. If your business is in scope of ESOS and you are using ISO 50001 as your route to compliance, you have to produce an ESOS report in Phase 3. This is a significant change from how things worked in Phases 1 and 2.
Who is affected?
The change applies to organisations which have been using ISO 50001 to cover all their energy consumption. ESOS Phase 3 allows you to exclude up to 5% of your organisation’s energy consumption and write it off as “de minimis”. So in practice, this means any organisation with ISO 50001 covering 95% or more of its energy. In previous ESOS phases, having ISO 50001 certification covering basically all your consumption meant that you did not have to write an ESOS report. You just had to fill in a checklist and submit information which would have been gathered anyway for your ISO 50001 compliance. Now you must also submit an ESOS report.
What do you need to do?
Section 10.1 of the official ESOS Phase 3 guidance lists what information you need to include in your ESOS report. This includes:
- Organisation name and structure
- Who is involved in completing and signing off the assessment
- Total energy consumption, broken down by organisational purpose
- Energy intensity ratios for each organisational purpose
- Proof that 100% of your total energy consumption is covered by ISO 50001
You will also need to submit some information which you will have already gathered for the purposes of your ISO 50001 certification. This includes:
- Outcomes of any evaluations of the performance of your energy management system
- Any other evidence of performance improvements
- What actions your organisation took to bring about these improvements
- Opportunities for potentially improving energy efficiency in future and how these could affect your organisation’s energy consumption/spending
This is less than you would include in a full ESOS report, but still a new responsibility that you need to take seriously to be ESOS compliant.
If you’re using ISO 50001 as a partial route to compliance
Some organisations have been using ISO 50001 to cover some, but not all, of their organisation’s energy consumption. If this is the case for your organisation, nothing will change. As with Phases 1 and 2, you need to assess what percentage of your energy consumption is covered by ISO 50001. Then you will need to carry out an ESOS audit for the remainder and submit a report based on this.
Sharing information with group undertakings
If your organisation is part of a corporate group, the ESOS rules require the “responsible undertaking” to share information with other parts of the group if it is relevant to them. For example, if your ESOS report includes data on a site’s energy consumption and related recommendations, you need to share it with the part of the organisation that runs that site.
If ISO 50001 covers all your energy consumption, you only need to share information that is relevant to the undertaking and recorded as part of your ISO 50001 compliance.
Lead assessors
If ISO 50001 is your complete route to compliance, you still do not need to appoint a lead assessor for ESOS Phase 3.
If ISO 50001 only covers some of your organisation’s energy consumption, you will already be aware that you have to appoint an ESOS lead assessor, and this has not changed.
As ever, you are advised to read the official guidance carefully and seek professional advice to ensure there are no unforeseen problems with your ESOS compliance.
The 5th June ESOS deadline has passed, but organisations have a grace period until 6th August to submit their notification of compliance. For advice on ESOS or for support with your submission, get in touch with the experts at Sustainable Energy First.
