ESOS action plan · regulation 34A
The ESOS action plan: six limbs, one nil option, read back in 2027
An ESOS action plan is the list of energy efficiency measures a participant says it will take over the next compliance period, required since Phase 3 by regulation 34A.
Its contents are fixed by the Regulations, a responsible officer confirms it, and the Environment Agency publishes it.
From Phase 4 the plan also comes back: the next ESOS report must review it, measure by measure, under regulation 27E.
The action plan cycle, 2024 to 2031
Eight dates, and the nearest is not in Phase 4
The plan filed for Phase 3 is still running, and the next live deadline anywhere in ESOS belongs to it: the second Phase 3 progress update, due 5 December 2026.
- 5 Dec 2024Phase 3 action plan
Statutory deadline under reg 34A(7)(a); the Environment Agency accepted plans until 5 March 2025.
- 5 Dec 2025Phase 3 progress update 1
The first yearly report against the Phase 3 plan (reg 34B(1)(a)).
- 5 Dec 2026Phase 3 progress update 2
The nearest live deadline in the scheme (reg 34B(1)(b)).
- 31 Dec 2026Phase 4 qualification date
Whether the Phase 4 dates below are yours is decided on this day.
- 5 Dec 2027Phase 4 notification of compliance
Now carries the action plan review (reg 27E) and the savings achieved (reg 27D).
- 5 Dec 2028Phase 4 action plan
Covering 6 December 2027 to 5 December 2031 (reg 34A(7)(b)).
- 5 Dec 2029 · 2030Phase 4 progress updates 1 and 2
Each reports the twelve months before its deadline.
- 5 Dec 2031Phase 4 final progress update
A third update, added by SI 2026/701 reg 28; also the Phase 5 compliance date.
Sources: SI 2014/1643 Part 6A · EA Phase 4 guidance §13.1 · GOV.UK ESOS page
What it is
A list of measures, dates and savings, or a nil statement
Regulation 34A(3) defines the plan as a written record setting out each measure the participant proposes to implement before the end of the relevant compliance period, or containing a statement that there is no such measure.
The nil statement is lawful: a plan may say nothing is proposed, but it must still be notified.
Action plans arrived with SI 2023/1182, in force 29 November 2023, which made Phase 3 the first phase whose duties continue after its compliance date.
SI 2026/701 put the plan’s estimates in kWh from 22 July 2026, where the earlier text said “energy measurement units”.
The measures come from the ESOS assessment, so the ESOS assessment and the ESOS energy audit are where the plan starts.
The duty follows the notification of compliance, and the choice of route does not remove it; from 22 July 2026, regulation 34A(11) switches it off for a participant deemed compliant through zero consumption under regulation 33A.
No investment figure, no cost projection and no payback period.
The plan is measures, dates, whether the audit recommended each one, savings in kWh and the method.
Source: reg 34A(3)
The template
An ESOS action plan template, built from the regulation
There is no statutory template: the plan is entered into MESOS.
This structure follows regulation 34A(3) limb for limb, so a plan drafted in it has every field the Regulations require and nothing they do not.
| Field | What goes in it | Provision |
|---|---|---|
| Measure | Each measure to improve energy efficiency that the participant proposes to implement before the end of the relevant compliance period | reg 34A(3)(a)(i) |
| Recommended by the audit? | Whether the measure was recommended by an energy audit under reg 27(1)(c) | reg 34A(3)(a)(ii) |
| Implementation date | The date by which the participant proposes to implement it | reg 34A(3)(a)(iii) |
| Total savings, kWh | The total energy savings expected in the relevant compliance period from the measure | reg 34A(3)(a)(iv) |
| Savings by purpose, kWh | How much of that saving falls to each organisational purpose: transport, industrial process, buildings, other | reg 34A(3)(a)(v) |
| Method | How the estimate was calculated | reg 34A(3)(a)(vi) |
| Basis of the estimate | Whether it rests on the audit, a deemed-compliance route or another reasonable method; for the last, describe and justify it in the evidence pack | reg 34A(4)–(5) |
| Or: nil statement | That no measure is proposed before the end of the relevant compliance period | reg 34A(3)(b) |
The Environment Agency’s documents
The Phase 4 publication page carries the guidance and its appendices, including Appendix B, the fields of the notification, and Appendix A3, an ODT template.
Report checklists are in Appendices A1 and A2, energy-saving measures in Appendix C, and contacts in Appendix D.
Two fields worth adding
A measure reference that stays the same across the plan and all its updates, so each update and the Phase 5 review can match measure to measure.
The energy-saving category of each measure, because the next ESOS report asks for it against every measure implemented (reg 27D).
The ESOS templates page lays out a fuller structure.
The ODT the Environment Agency calls a template, Appendix A3, is an example layout for the audit’s recommendations.
Those recommendations are what a plan is built from, which is why the two are confused, but A3 carries no implementation date, no kWh estimate over the relevant compliance period and no breakdown by organisational purpose.
The plan itself is entered into MESOS; the content is prepared beforehand, and that preparation is what a template is for.
Draft it
Build the plan, measure by measure
Enter each measure with its date, whether the audit recommended it, the expected kWh by organisational purpose and the estimation method.
The builder totals the savings by purpose, flags a missing field or a date after 5 December 2031, and reminds you what a non-audit method needs in the evidence pack.
Nothing you type leaves your browser.
Regulation 34A(3) · one row per measure
1 measure · 0 kWh expected in total
| Organisational purpose | kWh |
|---|---|
| Transport | 0 |
| Industrial process | 0 |
| Buildings | 0 |
| Any other purpose | 0 |
1 measure is missing a name, a date or a kWh estimate.
A Phase 4 plan is notified between 6 December 2027 and 5 December 2028, with a responsible officer’s confirmation (reg 34A(6)–(8)).
No cost or investment figure is required.
Fields follow SI 2014/1643 reg 34A(3)(a)(i)–(vi) and (b), as amended by SI 2026/701 reg 27.
A working aid, not the MESOS form; nothing here is saved.
Fields: SI 2014/1643 reg 34A(3)–(5), as amended by SI 2026/701 reg 27.
Working text, not a submission.
Choosing the measures
From the audit, from ISO 50001, or from anywhere else
A plan may include audit recommendations, measures recommended through an ISO 50001 certification, or any other measure the participant decides to take.
What the law requires is that the plan says, for each measure, whether an energy audit recommended it (reg 34A(3)(a)(ii)).
The Environment Agency’s guidance says the requirements are the same for every participant, whatever compliance route it took.
The obvious starting point is the recommendations in the ESOS report, and the guidance suggests discussing them with the lead assessor or commissioning feasibility studies, while saying neither is required.
No justification is needed for including a measure, but every measure included will be reported against in each progress update.
A measure already carried out before the relevant compliance period starts, 6 December 2027 for a Phase 4 plan, does not qualify.
Where one measure runs past the end of the period, the guidance recommends splitting it into parts that will deliver savings in time, such as a lighting upgrade taken site by site.
A large measure that cannot be split, because it will not save energy until after 5 December 2031, belongs in a later plan rather than this one.
Each measure, including any aggregated into a single line, should be recorded once, so savings already counted under another scheme are not counted twice.
Schemes the guidance names
The Environment Agency recommends bringing in measures already committed under other schemes, naming the scheme, so the plan becomes one record of everything being done.
Its list: climate change agreements, SECR, UK ETS, UN Race to Zero, the Science Based Targets initiative, carbon reduction plans for major government contracts, EPCs and GDAs.
Source: EA Phase 4 guidance §13.3.1
Estimating the savings
Four years of kWh, pro-rated from the date it goes in
The estimate is the total energy the participant reasonably expects to save from the measure during the relevant compliance period, in kWh (reg 34A(3)(a)(iv)).
For a Phase 4 plan that period is 6 December 2027 to 5 December 2031, so a measure that goes in part-way through is estimated from its start date to the end, typically by pro-rating an annual saving.
The same total is then split across the four organisational purposes: buildings, transport, industrial processes and other energy use.
The guidance calls the estimates indicative, which is a statement about precision, not permission to guess: the calculation and its data go in the evidence pack.
A method other than the audit or a deemed-compliance route might be survey data or contractor quotes, which the guidance gives as examples.
The estimate has a second life: the next ESOS report states the savings actually achieved, in kWh, and the progress updates in between report against the same measures.
The unit is kWh by law since 22 July 2026, so measures tracked in litres of diesel, therms or tonnes of steam need converting on a basis that is written down and kept the same in every later filing.
| Basis of the estimate | What the plan records |
|---|---|
| The energy audit (reg 34A(4)(a)) | That the estimate is from the audit |
| A deemed-compliance route, such as ISO 50001 (reg 34A(4)(b)) | That the estimate is from that route |
| Another reasonable estimation method (reg 34A(4)(c)) | A brief description of the method and data, with the reason for using it kept in the evidence pack (reg 34A(5)) |
The guidance’s worked example
Company A: three measures, one of them from a CCA
The Environment Agency’s Phase 4 guidance works one plan through.
Company A’s audit found ten opportunities; it takes two forward and adds a third it had already committed to under a climate change agreement.
| Measure, and when | Plan total, kWh | How it was estimated |
|---|---|---|
| Lighting upgrade with motion sensors by June 2029 | 62,500 25,000 a year × 2.5 years | From the energy audit |
| Wall, roof and window insulation by June 2030 | 75,000 50,000 a year × 1.5 years | Recommended by the audit; a later survey cut the audit’s 60,000 a year to 50,000 |
| Controls across industrial sites (CCA) by December 2029 | 8,000,000 4,000,000 a year × 2 years | Extrapolated from earlier CCA data; 300,000 buildings, 7,700,000 industrial processes |
What the example shows
The plan figure is the saving inside the period, not the annual figure from the audit.
An audit estimate can be revised before it goes in the plan, as the insulation was, provided the evidence pack records why.
What Company A kept
All its calculations, a copy of the insulation survey, the reason it commissioned the survey, and the reason the insulation estimate differs from the ESOS report.
That is the evidence pack doing its job: the next reader of the plan can trace every figure.
Evidence and optional information
What goes beside the plan, and what may go in it
Beyond the calculations, the Environment Agency recommends recording in the evidence pack why the measures were chosen, for the participant’s own benefit.
The evidence pack can also hold commitments that do not fit the plan’s format: an energy or emissions target with no specific measure attached, or a greenhouse gas measure with no energy saving.
The plan only has to cover measures to be implemented from the date it is produced.
A participant may volunteer the same information for measures implemented between the compliance date and the date it notifies the plan, and MESOS takes it.
For a measure that did not come from the audit, the participant may also say whether it came from an alternative compliance route or another source.
Both kinds of voluntary information are published by the Environment Agency, so they are a way to put earlier work on the public record.
The evidence pack itself is the subject of the Phase 4 compliance guide, which lists what it must hold.
The deadlines
Due a year after the compliance date, covering the next four
The plan covers the relevant compliance period, which regulation 34A(10) defines as the period after the one the notification of compliance related to.
It is notified within the first year of that period: from 6 December 2027 to 5 December 2028 for a Phase 4 plan, under regulation 34A(7)(b).
The Phase 3 plan was due by 5 December 2024 under regulation 34A(7)(a); the GOV.UK change note of 7 February 2025 said plans were still accepted until 5 March 2025, which was the regulator’s acceptance window, not a new statutory date.
A Phase 3 plan covers 6 December 2023 to 5 December 2027, and its second progress update is due by 5 December 2026; see ESOS Phase 3.
A Phase 4 plan covers 6 December 2027 to 5 December 2031 and carries three progress updates, the last added by SI 2026/701 regulation 28; the ESOS progress report page covers them and ESOS deadlines lists every date.
Windows from regulations 34A and 34B
Notification related to 6 December 2023 – 5 December 2027.
The relevant compliance period is therefore 6 December 2027 – 5 December 2031.
| Duty | Window, and its last day |
|---|---|
| Action plan reg 34A(7)(b) | 6 December 2027 – 5 December 2028 by 5 December 2028 |
| Initial progress update reg 34B(1)(a) | 6 December 2028 – 5 December 2029 by 5 December 2029 |
| Further progress update reg 34B(1)(b) | 6 December 2029 – 5 December 2030 by 5 December 2030 |
| Final progress update reg 34B(1)(c), inserted by SI 2026/701 reg 28 | 6 December 2030 – 5 December 2031 by 5 December 2031 |
Each date is the last day of a statutory window, not a single filing day.
Submission
Confirmed by an officer, filed through MESOS, then published
Regulation 34A(6) requires the plan to be notified through the Notification System, which the Environment Agency runs as MESOS, together with the confirmation required by regulation 34A(8).
That confirmation is by the responsible officer: that the plan complies and that they have “seen and considered” it.
A responsible officer is a director within section 250 of the Companies Act 2006, or a person exercising management control, and regulation 34A(8) itself speaks of one officer.
The Environment Agency’s guidance (§13.3.6) sets the number to match the notification of compliance: two where an internal lead assessor reviewed the assessment, or where no lead assessor was appointed because consumption was under 40,000 kWh.
The officers need not be the same individuals who signed the notification.
The confirmation is that they have seen and considered the plan and are satisfied, to the best of their knowledge, that the requirements for it have been met.
The guidance says further instructions on submitting the plan through MESOS will be provided closer to the time.
Regulation 10 makes the scheme administrator publish every action plan, within six months of the deadline for notifying it or of its notification, whichever is later.
Plans are public documents, so measure descriptions can be written at a level suited to disclosure without losing the substance.
The notification that comes first is covered on ESOS notification, and the wider reporting cycle on ESOS reporting.
The order matters in practice: the action plan follows the notification of compliance under regulation 34A(1), so a participant still owing its notification has that to file first, and the notification is the duty that carries a civil penalty.
Who owes it
The responsible undertaking, whatever the route
The duty falls on the responsible undertaking that submitted the participant’s notification of compliance, which produces, submits and updates the plan.
It follows any notification under regulation 29(1), so a participant that complied through ISO 50001 owes an action plan like any other.
The one carve-out is regulation 34A(11): a participant deemed compliant under regulation 33A, because its total energy consumption was zero, owes no plan.
A participant that reported under 40,000 kWh, and so had no lead assessor, still owes one.
Where a qualifying undertaking is bought by a non-qualifying group in that window, the guidance says the new group’s highest parent currently has no duty to provide a plan, so the undertaking provides its own unless there is an agreement.
Whether an organisation is in Phase 4 at all turns on the Phase 4 qualification test, applied on 31 December 2026.
An undertaking that leaves the group between the compliance date and the action plan deadline still owes a plan.
It may comply with its old group or its new one by agreement, or file on its own behalf, using the relevant parts of the original ESOS report, other information, or a nil statement.
A participant acquiring a qualifying undertaking in that window may include it by agreement; changes to the participant’s membership are notified with the plan.
Source: EA Phase 4 guidance §13.2.1
The Phase 4 review
Regulation 27E: the plan, read back
SI 2026/701 regulation 17 inserted a new Chapter 3B, and in it regulation 27E: the ESOS report must contain an action plan review.
The review identifies any measure in a current action plan “which have not been implemented, and are not expected to be implemented, before the end of the compliance period”, and explains why.
The words “are not expected to be” make it a forward judgement: a measure still nominally on the capital plan, which will not land in time, belongs in the review with its reason.
Where none of the undertakings that were required to produce a current action plan did so, the review confirms that instead (regulation 27E(2)(c)).
Beside it, regulation 27D asks for the energy savings actually achieved during the compliance period, in kWh, by organisational purpose and by measure.
The reasons a measure did not happen are known now by the people who decided it, so recording them against the measure as they arise is most of the work; the Phase 4 compliance guide sets out the rest of the report.
The Environment Agency’s guidance (§10.5) adds that a participant which owed a Phase 3 plan must review every relevant undertaking in it, and that the review is not needed for undertakings that owed no Phase 3 plan, or where total consumption is zero.
It also says, in terms, that the review information goes in the ESOS report and the notification of compliance “but will not be published”.
| In the Phase 4 report | Notified | Published |
|---|---|---|
| Combined energy savings achieved, kWh (reg 27D(1)) | Yes | Yes |
| Savings by measure, with category (reg 27D) | Yes | No |
| Measures not implemented, and the reasons (reg 27E) | Yes | No |
Draft the review
Compose your regulation 27E review, a measure at a time
List the measures in your current plan and mark each one: implemented, due before 5 December 2027, or not implemented and not expected to be.
The tool asks for a reason for every measure in the last group and produces draft text for the review.
Nothing you type leaves your browser.
Regulation 27E · the action plan review
List the measures in your current (Phase 3) action plan, then mark where each stands against the end of Phase 4.
Draft review, as it would read
(a) Measures in the current ESOS action plan not implemented, and not expected to be implemented, before 5 December 2027: Heat pump to replace gas boilers, head office.
(b) Reasons: Heat pump to replace gas boilers, head office: [reason needed]
1 dropped measure has no reason yet; limb (b) requires one for each.
Measures implemented, or still expected by 5 December 2027, do not go in the review.
The review sits in the ESOS report and evidence pack and is notified with the notification of compliance, but Schedule 3 Table J marks it as not published.
Limbs from SI 2014/1643 reg 27E(2)–(3), inserted by SI 2026/701 reg 17.
The example rows are illustrative; nothing you type is saved.
Working text, not a submission: the notification’s wording is the participant’s, and a false or misleading statement in it is an offence under regulation 47, with a maximum of £50,000 and publication (SI 2014/1643 Part 8).
What SI 2026/701 changed
Four amendments, all about the plan already filed
Each change in force since 22 July 2026 turns something narrative into something with a unit, a category or a required explanation.
| SI 2026/701 | What it does to action plans | Effect |
|---|---|---|
| reg 17 | Inserts Chapter 3B: reg 27D (savings achieved) and reg 27E (action plan review) in the ESOS report | The plan is read back at the next notification |
| reg 27 | Substitutes kWh in reg 34A(3)(a)(iv) and (v); inserts reg 34A(11) | One unit for every estimate; no plan after a zero-consumption notification |
| reg 28 | Adds a final progress update and puts the update’s estimate in kWh | Three updates for a Phase 4 plan, the last by 5 December 2031 |
| reg 31 | Rewrites Schedule 3, including new Table J for the review and achieved savings | Only the combined achieved saving is published |
How the 2014, 2023 and 2026 instruments fit together is set out on the ESOS legislation page.
Publication
What the Environment Agency publishes, and what it does not
| Item | Filed | Published |
|---|---|---|
| The action plan, its measures and estimates | With the plan, by 5 December 2028 | Yes (reg 10) |
| Voluntary information on earlier measures and their source | With the plan | Yes (EA guidance §13.3.5) |
| Each progress update | Yearly, to 5 December 2031 | Yes (reg 10) |
| Combined energy savings achieved, kWh | In the next notification of compliance | Yes (Sch 3 Table J row 1) |
| Savings by measure, with category | In the next notification of compliance | No |
| The action plan review: measures not implemented and the reasons | In the next notification of compliance | No (EA guidance §10.5) |
Writing for the register
Plans and updates are public documents, so a measure can be described at the level of detail suited to publication without losing what it is.
Commercially sensitive per-measure savings in the next report stay out of the published record by design.
Phase 3 is not a guide to Phase 4
The published Phase 3 data follows Schedule 3 as it stood before 22 July 2026.
Regulation 31 of SI 2026/701 rewrote the publication tables, so what a Phase 4 filing discloses has to be read from the amended Schedule 3, not inferred from last phase’s data.
The Phase 3 record
What 7,062 published plans show about the year after
The Environment Agency’s Phase 3 open data, from its 5 June 2026 data cut, holds the published action plans and first progress updates.
Read together, they show where plans go wrong once they meet a progress update.
Of 5,549 first updates with a readable submission date, 80.6% were filed in the final 30 days and 11.2% after the 5 December 2025 deadline.
Among implemented measures whose estimate came from the action plan, 436 reported the plan’s four-year total as the twelve-month figure, and 124 reported more saving in twelve months than the whole plan expected.
Both are signs of a plan written without the update in mind: a four-year estimate that cannot be divided into years, and a measure reference that does not survive into the next filing.
Source: Environment Agency, ESOS Phase 3 open data (data.gov.uk); figures computed from the action-plan and first-progress-update workbooks.
More on the ESOS Phase 3 page.
Test the common claims
Seven things said about action plans, checked against the law
True or false?
01An ESOS action plan must state how much each measure will cost.
02A plan that proposes no measures is lawful.
03Every measure in the plan must come from the ESOS audit.
04A participant on the ISO 50001 route does not need an action plan.
05The Phase 4 action plan review is published with the participant’s name.
06Missing an action plan carries a civil penalty.
07Savings in a Phase 4 plan are estimated for the whole four years, not per year.
7 statements.
Pick an answer to see the provision behind it.
Answers rest on the provisions named beside each one.
Nothing you pick is saved.
If it is missed
No penalty for the plan, but not no consequence
Part 8 names no offence for regulation 34A, and the Environment Agency’s Phase 4 guidance says regulators will not take enforcement action or issue a penalty for non-submission of an action plan; the failure is published.
A regulator may still serve an enforcement notice, and failing to comply with a notice is an offence under regulation 46, at £5,000 plus £500 a working day.
In Phase 4 a missing plan also surfaces in the next report: where no plan was produced by the undertakings required to produce one, the action plan review must confirm it.
A false or misleading statement in a notification is an offence under regulation 47, so the review is a document to get right; the ESOS penalties page covers every offence.
The same data elsewhere
An action plan beside other reporting
A plan is quantified, dated, confirmed by an officer and published, which makes it useful evidence well beyond ESOS.
Listed companies reporting against UK SRS S2 disclose climate targets and transition plans, set out on UK SRS transition plans, and ESOS and UK SRS maps where ESOS data fits.
The energy efficiency narrative in a SECR report can draw on the same measures; see the SECR reporting guide.
Tracking measures, dates and kWh across four years and four filings is the kind of record carbon reporting software is built to hold.
Most plans are drafted from the assessment by the organisation itself, often with its lead assessor reviewing them; ESOS consultants and assessors describes the market for outside help.
The full duty set is on ESOS requirements, the instruments on ESOS legislation, the official documents compared on ESOS compliance guidance, and the scheme on the Energy Savings Opportunity Scheme; the Regulations themselves are at legislation.gov.uk.
After the plan
Three updates against it, even if it proposed nothing
Once notified, the plan is reported against every year under regulation 34B: by 5 December 2029, 2030 and 2031 for a Phase 4 plan.
The Environment Agency’s guidance (§14) says the updates are owed even where the plan stated that no measures were proposed.
An update may report measures that were never in the plan, so a nil plan followed by real work is recorded as real work.
Each update covers the twelve months before its deadline, and the guidance encourages filing close to the deadline so savings from measures implemented late in the year are not left out.
A measure missing its planned date has to be identified in the update, which is why an optimistic date in the plan becomes a public explanation a year later.
The fields of each update, and a builder for drafting one, are on the progress update page.
Where the documents disagree
Three places the guidance and the law do not quite match
The list of required information in §13.3 of the Phase 4 guidance still says savings are estimated “in energy measurement units”, while §13.3.2 of the same guidance, and regulation 34A(3) as amended, say kWh.
The law governs: estimates are in kWh.
The guidance asks for the month and year by which each measure will be implemented, where the regulation asks for “the date”; a month and year satisfies both, and a full date is never wrong.
The guidance’s worked example labels some savings as “business energy use”, which is not one of the four organisational purposes in regulation 2; a plan should use buildings, transport, industrial processes or other.
None of these changes what a participant must do, but each is a place where a plan copied from the guidance rather than from Part 6A could come out slightly wrong.
Terms
The vocabulary of Part 6A
| Term | Meaning | Where |
|---|---|---|
| ESOS action plan | The written record of proposed measures, dates and kWh savings, or a nil statement | reg 34A(3) |
| Relevant compliance period | The compliance period after the one the notification related to: 6 Dec 2027 – 5 Dec 2031 for a Phase 4 plan | reg 34A(10) |
| Responsible undertaking | The undertaking that notified compliance for the participant and produces the plan | reg 34A(1), (6) |
| Responsible officer | A director within s.250 Companies Act 2006, or a person exercising management control | reg 30(2) |
| Organisational purpose | Buildings, transport, industrial processes, or any other purpose | reg 2(1) |
| Progress update | The yearly report against the plan; three for a Phase 4 plan | reg 34B |
| Action plan review | The part of the next ESOS report naming measures not implemented, with reasons | reg 27E |
| Notification System | The statutory name for what the Environment Agency runs as MESOS | reg 34A(6) |
Frequently asked
ESOS action plans, answered
What is an ESOS action plan?
A written record, required by regulation 34A of the ESOS Regulations 2014, setting out each energy efficiency measure the participant proposes to implement before the end of the next compliance period, whether an audit recommended it, the date, and the estimated savings in kWh overall and by organisational purpose, with the method used. It may instead state that no measure is proposed.
It is notified through MESOS after the notification of compliance and published by the Environment Agency.
What must an ESOS action plan include?
Under regulation 34A(3), for each measure: the measure; whether it was recommended by an energy audit under regulation 27(1)(c); the date by which it will be implemented; the total energy savings expected in the relevant compliance period, in kWh; the savings expected for each organisational purpose, in kWh; and the method used for the estimate.
There is no statutory investment or cost limb.
Is there an ESOS action plan template?
There is no statutory template.
The plan is entered into MESOS against the fields the Regulations set, and the Environment Agency publishes Appendix B listing the notification fields.
A working template can be built directly from the six limbs of regulation 34A(3), as this page does.
When is the ESOS action plan deadline?
For Phase 4, the plan may be notified from 6 December 2027 and must be notified by 5 December 2028, under regulation 34A(7)(b) and (10).
For Phase 3 the statutory deadline was 5 December 2024, and the Environment Agency accepted plans until 5 March 2025.
What period does the action plan cover?
The relevant compliance period, which regulation 34A(10) defines as the compliance period following the one the notification of compliance related to.
A Phase 3 plan covers 6 December 2023 to 5 December 2027; a Phase 4 plan covers 6 December 2027 to 5 December 2031.
Who signs off an ESOS action plan?
Regulation 34A(8) requires confirmation by the responsible officer that the plan complies and that they have seen and considered it.
A responsible officer is a director within section 250 of the Companies Act 2006, or a person exercising management control.
The regulation does not itself fix how many must confirm.
What is the ESOS action plan review?
A new part of the Phase 4 ESOS report under regulation 27E, inserted by SI 2026/701.
It identifies each measure in the current action plan that has not been implemented, and is not expected to be implemented, before the end of the compliance period, and explains why. It is notified to the Environment Agency but not published.
Is there a penalty for not submitting an ESOS action plan?
No. Part 8 of the Regulations creates no offence for the action plan duty, and the Environment Agency’s Phase 4 guidance says regulators will not take enforcement action or issue a penalty for non-submission; the failure is published.
A regulator could serve an enforcement notice, and failing to comply with a notice is an offence under regulation 46.
How many directors must sign off an ESOS action plan?
Regulation 34A(8) speaks of the responsible officer.
The Environment Agency’s Phase 4 guidance (§13.3.6) says the number is the same as for the notification of compliance, though they need not be the same people: two where an internal lead assessor reviewed the assessment, or where no lead assessor was appointed because total energy consumption was under 40,000 kWh, and one otherwise.
Do ESOS action plan savings have to be in kWh?
Yes.
SI 2026/701 regulation 27 substituted kWh for “energy measurement units” in regulation 34A(3)(a)(iv) and (v) from 22 July 2026, and the Environment Agency’s guidance on estimating savings says they must be stated in kWh.
A plan tracking litres, therms or tonnes of steam converts them, and keeps the conversion basis in the evidence pack.
Can an action plan include measures from SECR, a CCA or a net zero target?
Yes.
Measures need not come from the audit.
The Environment Agency recommends including measures committed under other schemes, such as climate change agreements, SECR, UK ETS, SBTi targets or carbon reduction plans, naming the scheme, so the plan is a single record; each measure should be recorded once to avoid double counting.
What if a measure will not be finished before the end of the period?
The Environment Agency recommends breaking it into smaller parts that will deliver savings within the relevant compliance period, for example lighting site by site.
A large measure that cannot be broken down should be left out and can go in a later plan for a different four-year period.
Can measures already completed go in the action plan?
A measure carried out before the start of the relevant compliance period does not qualify.
Measures implemented between the compliance date and the date the plan is notified may be added voluntarily, and the Environment Agency publishes that voluntary information.
Who produces the action plan in a group?
The responsible undertaking that submitted the participant’s notification of compliance produces, submits and updates the plan.
An undertaking that leaves the group before the action plan deadline still owes one, either with its old or new group by agreement or on its own behalf, and changes to the participant’s membership are notified with the plan.
Is the ESOS action plan published?
Yes.
Regulation 10 requires the Environment Agency to publish action plans and progress updates within six months of the deadline for notifying them or of their notification, whichever is later.
The Phase 4 action plan review in the next ESOS report is not published; from the achieved-savings statement only the combined kWh figure is.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- legislation.gov.ukSI 2014/1643, Part 6A — regulation 34A, the ESOS action plan
Consolidated with the 2026 amendments: the six limbs of reg 34A(3), notification, confirmation, the zero-consumption carve-out.
- legislation.gov.ukSI 2014/1643, regulation 34A
reg 34A(7): the Phase 3 and later deadlines; reg 34A(10): the relevant compliance period.
- legislation.gov.ukThe Energy Savings Opportunity Scheme (Amendment) Regulations 2023 (SI 2023/1182)
Inserted Part 6A, in force 29 November 2023.
- legislation.gov.ukThe Energy Savings Opportunity Scheme (Amendment) Regulations 2026 (SI 2026/701)
kWh for plan estimates (reg 27), the zero-consumption carve-out, the final update.
- legislation.gov.ukSI 2026/701, regulation 17 — new Chapter 3B: regs 27D and 27E
Savings achieved and the action plan review in the Phase 4 report.
- legislation.gov.ukSI 2026/701, regulation 28 — progress updates
The third, final update for Phase 4 plans.
- legislation.gov.ukSI 2014/1643, regulation 10 — publication
Every action plan is published, within six months (reg 10(2)(b)).
- legislation.gov.ukSI 2014/1643, Part 8 — civil penalties
No offence attaches to reg 34A.
- Environment AgencyHow to comply with the Energy Savings Opportunity Scheme (ESOS) phase 4
Action plans, the review, and the statement that regulators will not penalise non-submission.
- Environment AgencyAppendix B: information to provide through the ESOS notification system (ODT)
The notification fields, including the action plan review block.
- GOV.UK (Environment Agency)Energy savings opportunity scheme (ESOS): find out if you qualify and how to comply
The 5 March 2025 acceptance window for Phase 3 plans.
- Environment AgencyComply with the Energy Savings Opportunity Scheme (ESOS): phase 3
The Phase 3 action plan and the second progress update, due 5 December 2026.
- Environment Agency (data.gov.uk)Energy Savings Opportunity Scheme — Phase 3 open data
The published Phase 3 action plans and first progress updates, 5 June 2026 data cut.
- legislation.gov.ukSI 2014/1643, Schedule 3 — information published
The publication tables, rewritten for Phase 4 by SI 2026/701 reg 31.
- Environment AgencyAppendix A3: example template of phase 4 ESOS recommendations (ODT)
A template for audit recommendations, not for the action plan.
- Environment AgencyAppendix C: advice for complying with ESOS
Energy-saving measures and a worked compliance timetable.
- legislation.gov.ukSI 2026/701, regulation 27 — action plans amended
kWh in reg 34A(3)(a)(iv)–(v) and the reg 34A(11) carve-out.