ESOS action plan — what to include, deadlines, submission
Action plans are an ongoing ESOS obligation under Part 6A of the regulations — a board-signed statement of the energy-saving measures you intend to take, followed by annual progress updates. The next date is 5 December 2026 (progress update 2), before the cycle repeats with Phase 4.
What is an ESOS action plan?
A board-signed, forward-looking document under Part 6A — the measures you intend to take, the savings you expect, and the timescales you commit to.
ESOS action plans were introduced as Part 6A of the ESOS Regulations by the ESOS (Amendment) Regulations 2023 (SI 2023/1182) 1. They turn ESOS compliance from a four-yearly audit into a continuous cycle: after each compliance notification, participants must state what they intend to do with the savings opportunities their energy audit identified — and then report progress against those commitments every year, in public, with board-level director sign-off.
The GOV.UK ESOS guidance 2 confirms the rhythm for the current cycle: the Phase 3 action plan was due 5 December 2024, with annual progress updates on 5 December 2025 and 5 December 2026, before the Phase 4 notification on 5 December 2027 starts the pattern again.
What an ESOS action plan must include
There is no downloadable statutory template — the MESOS form structures the content. This walkthrough covers every field a compliant plan needs.
Organisations searching for an ESOS action plan template should know there is no official downloadable document: the plan is entered into the MESOS service 3 against the categories set by SI 2023/1182. Preparing the content below before opening the form is the practical equivalent of a template.
- Statement of intentRequired
- Whether the organisation intends to reduce its energy consumption over the phase. A plan may state that no measures will be taken — but that statement is published, so most participants commit to at least the cost-effective measures their audit identified.
- Energy-saving measuresRequired
- The specific measures the organisation intends to implement, drawn from (or going beyond) the opportunities identified in the ESOS assessment — e.g. LED retrofits, heating controls, fleet efficiency, process optimisation.
- Estimated energy and cost savingsRequired
- Quantified estimates for each measure — energy reduction (kWh) and the associated cost saving (£) — with the estimation method noted so progress updates can report against the same baseline.
- Implementation timescalesRequired
- When each measure will be delivered within the phase. Timescales should be realistic: unmet commitments must be explained in progress updates and in the Phase 4 submission.
- Breakdown by organisational purposeGood practice
- Allocating measures and savings across buildings, transport and industrial processes, mirroring the audit's consumption profile. This makes annual progress reporting substantially easier.
- Investment and monitoringGood practice
- Capital cost estimates, payback periods and a monitoring & verification approach for tracking actual savings against estimates. Not a statutory field, but the difference between a plan that survives two public progress updates and one that does not.
ESOS action plan deadline — and the dates still to come
The Phase 3 action plan deadline (5 December 2024) has passed. The live obligations are the annual progress updates, then a new plan after Phase 4.
- 5 DEC 2024Phase 3 action plan deadline
- 5 MAR 2025Late submission window closed
- 5 DEC 2025Progress update 1
- 5 DEC 2026Progress update 2
- 5 DEC 2027Phase 4 notification — new plan follows
The headline ESOS action plan deadline for the Phase 3 cycle was 5 December 2024, with the Environment Agency accepting late submissions without remedial action until 5 March 2025. Both dates are now history — any Phase 3 participant that has still not submitted should file immediately, since enforcement powers apply. The dates that matter now are the two annual progress updates (5 December 2025, passed, and 5 December 2026, next due) confirmed in the GOV.UK ESOS guidance, and the Phase 4 cycle beyond — all tracked on the ESOS deadlines page.
Next action plan date: progress update 2
Covers 6 December 2025 to 5 December 2026 — implementation status per measure, actual energy and cost savings achieved, explanations for any variance, revised timelines, and any additional measures beyond the original plan.
Board-level director sign-off required.
ESOS action plan submission — via MESOS
Plans and progress updates go through the Environment Agency's MESOS service, in a fixed sequence that starts with the compliance notification.
ESOS action plan submission is online only, through the Manage your ESOS reporting (MESOS) service — the same Environment Agency portal used for the compliance notification. The sequencing constraint matters for late compliers: MESOS will not accept an action plan or progress update until the underlying phase notification has been filed, so outstanding notifications must be cleared first.
ESOS action plan guidance
Where the authoritative guidance lives, and how to read it together.
- GOV.UK ESOS guidancePrimary guidance
- The Environment Agency / DESNZ ESOS guidance on GOV.UK covers action plan and progress-update expectations, deadlines and the MESOS process. It is the first reference for any content question.
- SI 2023/1182 — the legal textStatutory basis
- Part 6A of the regulations, inserted by the 2023 Amendment Regulations, is the binding source for what a plan must contain and when it must be filed. See ESOS legislation for how the 2014 and 2023 instruments fit together.
- Practical supportWho can help
- Most organisations prepare plans in-house from their assessment, with review by their lead assessor — useful where implemented measures go beyond the original recommendations and savings need robust quantification.
ESOS Phase 4 action plan — what comes next
Phase 3 commitments feed the Phase 4 submission, and a new action plan follows the 5 December 2027 notification.
The action plan obligation repeats every phase. The Phase 4 assessment (notification due 5 December 2027) must report progress against the Phase 3 action plan — where commitments were not met, the submission must explain why, what alternative measures were taken, and how plans have been revised 1. A new ESOS Phase 4 action plan then follows the notification, with its own annual progress updates running through to Phase 5.
For organisations that also report climate disclosures, this cycle is an asset rather than a burden: a well-maintained action plan provides quantified, board-approved evidence for UK SRS transition planning and SECR energy-efficiency narratives, using the same underlying data — see the wider ESOS compliance guide for how the regimes connect.
ESOS action plan — frequently asked questions
Direct answers on content requirements, deadlines, progress updates, templates, submission and enforcement.
What is an ESOS action plan?
An ESOS action plan is a board-signed, forward-looking document required under Part 6A of the ESOS Regulations (inserted by the ESOS (Amendment) Regulations 2023).
It sets out whether the organisation intends to reduce its energy consumption, the specific energy-saving measures it plans to implement, the estimated savings, and the timescales for delivery.
It is submitted to the Environment Agency via the MESOS service after the compliance notification and is followed by annual progress updates.
When was the ESOS action plan deadline?
The Phase 3 ESOS action plan deadline was 5 December 2024, with the Environment Agency accepting late submissions without remedial action until 5 March 2025.
That deadline has now passed — the live obligations are the annual progress updates (5 December 2025 and 5 December 2026), and a new action plan cycle will follow the Phase 4 notification deadline of 5 December 2027.
When are ESOS action plan progress updates due?
Phase 3 participants must submit two annual progress updates: the first was due 5 December 2025 and the second is due 5 December 2026.
Each covers the preceding 12 months, reports implementation progress against the action plan commitments, requires board-level director sign-off, and is publicly disclosed.
What must an ESOS action plan include?
A compliant action plan states whether the organisation intends to reduce energy consumption, then sets out the energy-saving measures it will take, the estimated energy and cost savings for each, implementation timescales, and how savings will be measured.
In practice a robust plan also covers investment requirements and a breakdown across organisational purposes (buildings, transport, industrial processes).
It must be signed off by a board-level director and be suitable for public disclosure.
How do you submit an ESOS action plan?
Action plans and progress updates are submitted through the Environment Agency's Manage your ESOS reporting (MESOS) online service — the same portal used for compliance notifications.
The underlying compliance notification must be filed first; the action plan and progress update forms only become available once it is.
Board-level director sign-off is required before submission.
Is there an official ESOS action plan template?
There is no downloadable statutory template.
The MESOS submission form itself structures the content: intentions, measures, estimated savings and timescales, entered against the categories in the regulations.
The section 'What an ESOS action plan must include' on this page walks through each required field so you can prepare the content before opening the MESOS form.
Are there penalties for not submitting an ESOS action plan?
Submission is a legal requirement, and the Environment Agency can use its compliance and enforcement notice powers to compel filing, escalating to civil penalties under its published stepped approach for continued breach.
In practice the most immediate consequence is public: plans and updates are published, so a missing submission is visible to customers, investors and procurement teams on the public register.
Related guides & references
ESOS compliance — the full guide
Qualification, routes, sign-off and notification, step by step
ESOS Phase 4 compliance guide
How Phase 3 action plan progress rolls into the Phase 4 submission
ESOS deadlines — all key dates
Progress updates, Phase 4 qualification and notification in one tracker
ESOS reporting and notification
MESOS submission mechanics and board approval requirements
UK SRS transition plans
How ESOS action plans support climate transition planning disclosures