Routes to ESOS compliance

There is more than one accepted route for an organisation to achieve compliance with the Energy Savings Opportunity Scheme (ESOS). However, the future of Display Energy Certificates and Green Deal Assessments as ESOS compliance routes is in doubt. Here we list the four routes that are currently valid at the time of writing (March 2022).

Energy audits

Energy audits involve carrying out a thorough assessment of your organisation’s energy use across all operations, including buildings, industrial processes and transport.

The data used in this audit should be based on a period of 12 consecutive months, which begins no earlier than 12 months before the ESOS qualification date. The qualification date for ESOS Phase 3 is 31 December 2022. This means that the earliest date your reference period could have started is 1 January 2022.

The reference period should not end after the compliance date, which for Phase 3 is 5 December 2023. This means that the latest date your reference period could start is 5 December 2022.

The aim of the audit is to measure your organisation’s total energy consumption and identify the areas of significant consumption, so that you can find possible ways to improve your energy efficiency.

Your organisation must appoint a qualified lead assessor to review the findings of your ESOS assessment. It is your choice whether you get the lead assessor to do the whole audit themselves, or do it in-house and get the lead assessor to approve it. Either way, your lead assessor must be on an approved lead assessor register.

ISO 50001

ISO 50001 is an international standard for energy management systems. If your entire organisation is covered by the standard, you don’t need to do anything else to comply with ESOS (except provide proof of ISO 50001 certification to the Environment Agency).

If you choose this route for your organisation’s ESOS compliance, it is important to allow enough time to gain ISO 50001 certification before the ESOS compliance deadline. You will need to allow time for:

  • Delays in finding and booking a qualified auditor
  • An optional “pre-audit” check to help you spot any problems before the formal audit
  • Your Stage 1 audit: information gathering and reviewing
  • Your Stage 2 audit: a thorough investigation that could involve multiple site visits
  • The possibility of failing your Stage 2 audit and needing to restart the process.

Our blog post on ISO 50001 sets out the pros and cons of using this as a route to ESOS compliance.

Display Energy Certificates

Display Energy Certificates (DECs) show the energy performance of buildings based on annual consumption. If 90% or more of your organisation’s total energy consumption is covered by DECs, you can use them to comply with ESOS without doing anything else as long as they have been issued within the relevant compliance period.

However, the government’s plans to strengthen ESOS may involve removing Display Energy Certificates as a route to compliance in ESOS Phase 3. Before considering this route to compliance you should double-check that it is still valid, and there are further caveats to note:

  • Buildings with a useful floor area of under 1,000 square metres only have to renew their DECs every 10 years – but to be a valid route to ESOS compliance, a DEC needs to have been issued within the relevant compliance period. (For Phase 3, that is between 6 December 2019 and 5 December 2023.)
  • If DECs cover less than 90% of your organisation’s energy consumption, you will need to find alternative routes to compliance for the energy not covered.
  • DECs are not available in Scotland and cannot be used as a compliance route to ESOS there. (England, Wales and Northern Ireland are fine.)
  • Energy Performance Certificates (EPCs) are not the same thing as DECs. You cannot achieve ESOS compliance through EPCs.

Green Deal Assessments

Green Deal Assessments (GDAs) were energy assessments of both domestic and non-domestic buildings, carried out through the government’s Green Deal scheme which ended in 2015. As with DECs, their future as a route to ESOS compliance is in doubt.

An Environment Agency officer told the Energy Advice Hub: “We are still awaiting confirmation from BEIS on the proposed changes to the scheme once we receive their response to the ESOS consultation. We are expecting this in the next few weeks.”

While we await the BEIS decision, it is worth remembering that even if GDAs remain on the table, you will still need to appoint a lead assessor to review your compliance. It is a good idea to find one as early as possible to allow for any delays.

Whatever your chosen route to compliance, keep an eye on the Energy Advice Hub for the latest ESOS news and up-to-date advice.