Part 6A Requirements
ESOS Action Plan: Requirements, Deadlines & What to Include
Complete guide to ESOS action plan obligations introduced in Phase 3, covering deadlines, content requirements, progress updates and Phase 4 integration.
ESOS Action Plan Overview
1 ESOS action plans were introduced as Part 6A of the scheme through the ESOS (Amendment) Regulations 2023, requiring organizations to document forward-looking energy saving measures identified during their Phase 3 assessment.
Action plans represent a significant enhancement to ESOS, moving beyond simple energy auditing to require systematic planning for energy efficiency improvement with annual progress reporting and board-level accountability.
2 Plans must detail specific energy saving measures, expected savings, implementation timelines, and investment requirements broken down by organizational purpose.
Action Plan Content Requirements
3 ESOS action plans must be forward-looking documents focusing on measures and expected savings rather than general energy management policies.
Plans should demonstrate systematic approach to energy efficiency improvement with clear quantification of opportunities and realistic implementation pathways.
All measures must be broken down by organizational purpose with specific attention to expected energy savings (kWh/year) and cost savings (£/year) to support investment decision-making and progress monitoring.
Energy Saving Measures Identified
Detailed description of specific energy saving opportunities identified during ESOS assessment, including technical specifications and implementation approaches
Expected Energy and Cost Savings
Quantified estimates of energy consumption reduction (kWh/year) and associated cost savings (£/year) for each identified measure
Implementation Timeline
Realistic timescales for delivery of energy saving measures broken down by organizational purpose and operational requirements
Investment Requirements
Capital expenditure estimates, payback periods, and financing arrangements for energy efficiency measures across organizational activities
Organizational Purpose Breakdown
Allocation of measures across different organizational purposes demonstrating systematic approach to energy efficiency improvement
Monitoring and Verification Plan
Framework for tracking implementation progress and measuring actual energy savings achieved against projected targets
Action Plan Deadlines and Timeline
4 The Phase 3 action plan deadline was 5 December 2024, with a late submission window extending to 5 March 2025 without remedial action consideration.
Key Timeline:
• 5 December 2024 — Primary action plan deadline
• 5 March 2025 — Final late submission deadline
• 5 December 2025 — First annual progress update
• 5 December 2026 — Second annual progress update
• 5 December 2027 — Phase 4 compliance (including progress reporting)
Organizations that missed the primary deadline should submit immediately to demonstrate regulatory compliance and organizational commitment to energy management.
Annual Progress Updates
5 Organizations must submit annual progress updates on 5 December 2025 and 5 December 2026 reporting implementation progress against action plan commitments.
Progress updates require board-level director sign-off and are subject to public disclosure, creating transparency around organizational energy efficiency implementation.
Progress update content should address:
• Implementation status for each committed measure
• Actual energy and cost savings achieved
• Variance explanations where targets not met
• Revised timelines for delayed measures
• Additional measures implemented beyond original plan
Board Accountability
Both action plans and progress updates require board-level director sign-off, demonstrating senior management accountability for energy efficiency improvement.
This requirement aligns ESOS with corporate governance expectations around environmental performance and climate-related risk management.
Public Disclosure Requirements
6 Action plans and progress updates are subject to public disclosure, with high-level energy saving recommendations published by the Environment Agency.
7 Public disclosure supports market transparency and knowledge sharing around energy efficiency best practice across sectors.
Organizations should ensure action plan content is appropriate for public disclosure while maintaining commercial sensitivity around specific operational details.
ESOS Public Register
The Environment Agency maintains a public register of ESOS participants including compliance status and high-level energy saving opportunities identified.
This creates market accountability for energy efficiency performance and supports stakeholder assessment of organizational environmental management.
Phase 4 Integration Requirements
8 Phase 4 ESOS assessments must include reporting on action plan progress, creating direct linkage between Phase 3 commitments and Phase 4 compliance obligations.
Where action plan commitments have not been met, organizations must provide explanation in their Phase 4 compliance submission, ensuring continuity of energy efficiency improvement efforts.
This integration creates accountability for action plan implementation and supports systematic energy efficiency improvement across ESOS cycles rather than isolated assessment exercises.
Missed Commitments
Organizations that fail to deliver action plan commitments must provide detailed explanation in their Phase 4 assessment covering:
• Reasons for non-implementation
• Alternative measures undertaken
• Revised implementation plans
• Lessons learned for future planning
This requirement ensures accountability while recognizing legitimate business reasons for plan modifications.
Current Enforcement Position
Currently there are no specific penalties for action plan or progress update submission failure, but non-compliance is identified through public disclosure creating reputational and stakeholder accountability.
9 The ESOS Post-Implementation Review 2025 noted that enforcement approach may evolve as the scheme matures and action plan implementation data becomes available.
Organizations should submit action plans and progress updates to demonstrate regulatory compliance and organizational commitment to energy efficiency improvement.
What is an ESOS action plan and when was it introduced?
When is the ESOS Phase 3 action plan deadline?
What are ESOS progress updates and when are they due?
How do action plans connect to Phase 4 requirements?
Are there penalties for not submitting an action plan?
Related guides & references
ESOS Phase 4: Requirements and Deadlines
How Phase 3 action plan progress integrates with Phase 4 compliance
What Is the ESOS Scheme?
Complete overview of Energy Savings Opportunity Scheme requirements
UK SRS S2 — Climate-related Disclosures
How ESOS action plans support climate transition planning disclosures