If your organisation is in scope of the Energy Saving Opportunities Scheme (ESOS), you have until 5th March 2025 to submit your Action Plan via the MESOS, the compliance notification system.

Action Plans are a new requirement under the ESOS scheme. They require board-level sign-off, and they should set out:

  • what you intend to do to reduce energy consumption
  • when you intend to do it
  • whether it was recommended through your ESOS assessment
  • what energy savings you expect to achieve over the four-year period covered by the action plan
  • how you estimated these savings

The actions set out in your action plan may be energy savings opportunities recommended in the ESOS audit, measures recommended through an alternative compliance route, or other actions that you decide to carry out.

You will also be required to state in annual progress updates whether you achieved the actions in the action plan.

Are ESOS Action Plans mandatory?

Yes, ESOS Action Plans are mandatory for all organisations that qualified for ESOS in Phase 3, unless you had had no energy responsibility and provided a compliance notification stating this. There has been some confusion over whether organisations can opt out, but in a recent newsletter, the Environment Agency clarified:

It’s a legal requirement for organisations that qualify for ESOS to submit their action plan, by a set deadline, following submission of the notification of compliance. The Environment Agency has powers to take enforcement action to require compliance if this is not done. The Environment Agency will publish all action plans that are submitted. If no action plan is provided, there will be nothing for the Environment Agency to publish and so it will be apparent from the absence of a plan that the ESOS participant is in breach of the legal requirement.”

What if I don’t plan to carry out any energy saving measures?

If you don’t intend to take any action to reduce energy consumption before the next compliance date, you can submit a notification stating that you will take no action. This will be recorded and published. If your published action plan states that you will take no action but you do subsequently take action to reduce energy consumption, you can still submit and have published an annual progress update stating any actions you have taken.

Annual progress updates 

Once you’ve submitted your Action Plan, you’ll also need to submit two progress updates; one on 5th December 2025 and the other on 5th December 2026.

Action plans and annual progress updates will be published by the Environment Agency within 6 months of the relevant deadline.

Key dates:

Milestone

Date

Action Plan deadline

5th March 2025 (extended from 5th December 2024)

Period covered by the Action Plan

6th December 2023 – 5th December 2027

Action Plan Progress Update 1

5th December 2025

Action Plan Progress Update 2

6th December 2025

Advice and support

For tips on completing your Action Plan, check out our blog post – What makes a good ESOS Action Plan?. If you have any questions or would like support from Sustainable Energy First’s qualified ESOS Lead Assessors, get in touch with the team on the form below.

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