ESOS regulations — the whole stack
There is one set of ESOS regulations — the Energy Savings Opportunity Scheme Regulations 2014 — and everything since amends it, most recently the ESOS (Amendment) Regulations 2026, in force 22 July 2026.
Those changes are law and are still not in the consolidated text. Two regulations deleted that day are still displayed there as live compliance routes.
Find the regulation that governs your question Seventeen subjects · the number, the Part, and whether the published text is currentThe ESOS regulations are one instrument and seven amendments
Every ESOS duty in the United Kingdom traces to a single statutory instrument, and no later instrument replaces it. There is no ESOS Act.
The full dates, the powers each was made under and what each one did are in the record. What matters above the crossing is that “the ESOS regulations” means SI 2014/1643 as amended, and the last amendment landed on 22 July 2026.
Finding the right regulation is the easy part.
The hard part is that the published text is not the law.
The consolidated text is out of date, and it does not say so loudly
Open SI 2014/1643 on legislation.gov.uk today and you are reading the law as it stood before 22 July 2026 [2].
The site tells you, in a grey banner most readers scroll past: “There are outstanding changes not yet made by the legislation.gov.uk editorial team to The Energy Savings Opportunity Scheme Regulations 2014.” Every one of those outstanding changes belongs to SI 2026/701 [14].
There is a second trap inside the first. The banner is provision-scoped, not instrument-scoped — so the front page of the Regulations, and regulation 4, both display the opposite message: “There are currently no known outstanding effects.” That is true of those provisions and false of the instrument, and nothing on the page explains the difference.
The practical cost is not theoretical. Regulations 32 and 34 were omitted on 22 July 2026, and both are still displayed in the contents as live provisions — so a reader who checks the primary source finds two compliance routes that no longer exist. Chapter 05 is what happened to them.
As made, revised, and the F-numbers in the margin
legislation.gov.uk serves two different documents under nearly identical URLs, and choosing the wrong one is the single most common way to cite ESOS law incorrectly.
- The instrument exactly as it was signed. It never changes.
- For SI 2026/701 this is the only text there is, and it is the operative law from 22 July 2026 [11].
- For SI 2014/1643 it is the 2014 original — it still shows euro thresholds and no action plan.
- Reads as amending instructions: “Omit regulation 32”. You need the principal Regulations open beside it.
- The editorial team's consolidation: the principal instrument with amendments woven in.
- Readable, and currently four weeks behind the law [14].
- The F-numbers in the margin are textual amendment notes. “F4 Sch. 1 para. 1A inserted (31.12.2020)” tells you which instrument put that words there and when [4].
- Quote the revised text for £44m and £38m. Quote /schedule/1/made for nothing at all — it is the euro original.
The rule that follows is short. Until the 2026 changes are applied, read both — the revised text for everything SI 2026/701 did not touch, and the as-made 2026 instrument for everything it did.
What SI 2026/701 changed, by regulation number
The ESOS (Amendment) Regulations 2026 came into force on 22 July 2026 [11].
Its own regulation numbers are not the numbers it changes, and conflating the two is the commonest error in the commentary written about it. The convention that avoids it: SI 2026/701 regulation 23 omits regulation 32 of SI 2014/1643.
Two claims about this instrument circulate and neither is true. It contains no net zero provision at all — a full-text search returns nothing. And it did not leave the penalties alone: it changed no amount, but SI 2026/701 regulation 29 narrowed the scope of the regulation 45 audit-failure penalty [13].
Regulations 32 and 34 are gone, and the website still lists them
Two compliance routes stopped existing on 22 July 2026, and this is the change most likely to be missed — because the place a careful reader goes to check still shows both.
What remains as a route to compliance is an ESOS energy audit, ISO 50001 certification covering total or significant energy consumption, or a combination of the two reaching the same floor. ESOS energy audits covers the audit route in full, and ISO 50001 and ESOS covers the certification route.
Five provisions that did not exist before 22 July 2026
Each of these is law today and none of them appears in the consolidated text you will find by searching for the ESOS regulations.
Regulation 33A is the one worth pausing on. A participant with no energy consumption at all is now deemed compliant with the assessment duties by operation of law rather than by applying for anything — and a notification is still required.
Which ESOS regulation governs what
Nobody publishes this. Every guide to the ESOS regulations describes the duties; none of them tells you the regulation number to cite, which Part it sits in, or whether the published text of it is current.
Pick a subject and the instrument answers all three.
Two things to carry away from it. The Part matters as much as the regulation, because Part 8 is where every penalty lives and regulation 29 is not in it. And the amendment history matters, because a regulation last touched in 2026 is one whose consolidated text you cannot yet trust.
The word “phase” is not in the ESOS regulations
A full-text check of SI 2014/1643 returns zero occurrences of “phase” and thirty-eight of “compliance period” [1].
“Phase 4” is Environment Agency guidance vocabulary and industry shorthand. It has no statutory existence, and knowing that is what lets you find the dates yourself instead of trusting a table.
Regulation 4 is a self-perpetuating rolling definition. It hard-codes two dates and generates every other one by recursion [3].
The “initial compliance period” means the period which begins on the coming into force of these Regulations and ends on 5th December 2015. A “subsequent compliance period” means a period which—(a) begins on the 6th December immediately following the end of the preceding compliance period, and (b) ends on the 5th December four years later. The “qualification date” means—(a) in relation to the initial compliance period, 31st December 2014, (b) in relation to a subsequent compliance period, the 31st December immediately preceding the compliance date for that compliance period.
Note what regulation 4(1) does not say: it gives no start date, only “the coming into force of these Regulations”. That date is 17 July 2014, and it comes from regulation 1, not regulation 4.
One honest caveat about regulation 4(3)(b), which nobody else prints. It keys the qualification date to the compliance date — and once SI 2023/1182 split the third compliance date, a literal reading against 5 June 2024 gives 31 December 2023, while the Environment Agency's guidance states 31 December 2022. The guidance is what participants were assessed against. The ESOS phases works the whole cycle through.
What SI 2023/1182 did — and the number that is often wrong
The 2023 amendment is SI 2023/1182. It is occasionally published as SI 2023/1364, which is not an ESOS instrument at all — SI 2026/701's own footnote 2 lists the amending instruments and 1182 is the one it names [9].
Made 7 November 2023 and in force 29 November 2023, it is the instrument that most of the current scheme actually comes from.
The financial limb is conjunctive, and the market publishes “or”
Qualification lives in regulation 15, regulation 16 and Schedule 1, and none of them was touched by SI 2026/701 [4].
Schedule 1 paragraph 1(a) defines a large undertaking as one which either employs at least 250 persons, or has an annual turnover in excess of amount A and an annual balance sheet total of amount B.
Amount A is £44 million and amount B is £38 million, for any qualification date on or after IP completion day — inserted as Schedule 1 paragraph 1A by SI 2018/1342 and amended by SI 2020/711 [4][10].
Published widely as “turnover over £44m or balance sheet over £38m”, which pulls into scope organisations that are not in it. The ESOS qualification test works it through with the group rules.
The assessment chain, regulation by regulation
Part 4 is where the work is, and after 22 July 2026 it runs through five chapters instead of four.
The chapter numbering is worth noticing on its own. Chapter 3B is the newest thing in the instrument, and it exists because reporting what you achieved is a different duty from reporting what you found.
Regulation 29 is notification of compliance, not penalties
This is a small error with a long life, and it has appeared on this site as well as elsewhere: civil penalties described as being “set out in regulation 29 of SI 2014/1643”.
Regulation 29 sits in Part 5 and is headed Notification of compliance. It is the duty to tell the compliance body you have complied [2].
Penalties are Part 8, headed Civil penalties and breaches: regulations 39 to 42 are the machinery and regulations 43 to 47 are the breaches and their maxima [5].
If you take one citation from this page, take that one. A brief that cites regulation 29 for a penalty is a brief whose author did not open the instrument. ESOS notification covers the regulation 29 duty itself.
The ESOS penalties, with their regulation numbers
No other page on the UK web states these figures against the regulations that create them, which is why the wrong ones circulate so freely [5].
“Fines up to £90,000” has no statutory basis. It is the arithmetic ceiling of an aggregate regulation 45 penalty — £50,000 plus £500 multiplied by eighty working days — republished as though Parliament had written it. The daily element is discretionary and starts only when a compliance notice is served.
SI 2026/701 changed no amount here. It did change regulation 45(1)'s trigger, substituting the words from “where the” to the end with “except where regulation 33(3) or 33A applies” — so the audit-failure penalty now expressly does not reach the ISO 50001 and zero-kWh cases [13]. ESOS penalties covers enforcement practice and the Environment Agency's sanctions policy.
Four ways the assessment duty lifts, and where each one is written
None of these is an exemption from the scheme. Each removes a duty within it, and in every case a notification is still owed.
The reason the 2026 amendment touched regulation 45(1) at the same time is visible here: two of these exits now sit expressly outside the audit-failure penalty. ESOS exemptions works each route through in practice.
Who administers ESOS — the statutory names, not the trading ones
The Environment Agency is the scheme administrator under regulation 5, and separately the compliance body for England under regulation 6(1)(a) [6].
The other four are named differently in the legislation than in the guidance, and a citation should use the statutory name.
Where these rules apply, and to whom
SI 2026/701 extends to England and Wales, Scotland and Northern Ireland — the whole United Kingdom [11].
That matters because the four compliance bodies in regulation 6 are sometimes read as four schemes. They are not. There is one scheme, one set of duties and one set of penalties, administered regionally.
Offshore undertakings are the exception that proves it: they get their own compliance body in regulation 6(1)(e) rather than their own rules.
The powers behind the amendments
This is the part that changed most quietly, and it is the reason ESOS survived EU exit without needing new primary legislation.
- Made under section 2(2) of the European Communities Act 1972, implementing article 8 of the Energy Efficiency Directive.
- Retained after exit; SI 2018/1342 and SI 2020/711 repaired the references rather than replacing the instrument [10].
Do not blur the two. A brief that grounds a 2026 duty in the EU Energy Efficiency Directive is describing the scheme's ancestry, not its authority. The ESOS enabling powers covers the Energy Act 2023 provisions in full.
Five Schedules, and the two new tables
Half the operative detail in the ESOS regulations is in the Schedules, and the 2026 amendment reached two of them.
What was promised, what was enacted, and what quietly went away
The ESOS regulations have a paper trail, and reading it is the only way to know which widely-repeated Phase 5 statements are law and which are somebody's expectation.
And the dated negative, which is the most useful sentence on this page for anyone planning: as at 19 August 2026 no Phase 5 legislation, consultation, call for evidence or draft instrument has been published, and no ESOS instrument newer than SI 2026/701 exists. ESOS Phase 5 holds that watch.
Published claims about the ESOS regulations that are wrong
Every claim below was found in circulation in August 2026. Each one is checked against the instrument that governs it.
Select a claim to see what the regulation actually says.
One of these was ours. A page on this site cited regulation 29 for the civil penalties, and it was wrong for the same reason the others are wrong: the author worked from a summary rather than from Part 8.
How to cite ESOS law so that it stays right
Five rules, each of which prevents one of the errors in the previous chapter.
“ESOS regulations”, “ESOS legislation”, “the ESOS Act” — which is right
People search for all three, and only two of them exist.
The practical version: say “SI 2014/1643 as amended” when you mean the law, and name the amending instrument when you mean a change. Nearly every citation error on this page's claim checker starts with a phrase that skipped one of those two.
Twenty-two chapters, and it is still one instrument with the amendments read in.
The ESOS regulations are SI 2014/1643 as amended, most recently by SI 2026/701 in force on 22 July 2026 — and until legislation.gov.uk applies those changes, the consolidated text you find by searching is not the law you have to comply with.
You now know which instrument to open and which text to distrust. The next question is always the same one — whether any of it applies to you.
Work the qualification test against Schedule 1 Or take the duties in order — the Phase 4 guide
UKSRS — independent reference on UK sustainability and energy reporting. Every figure on this page is cited to a named primary source.
The regulations, provision by provision
Every provision of SI 2014/1643 a practitioner is likely to need, with its Part, its subject and its amendment history. Where a provision was amended on 22 July 2026 the consolidated text does not yet show the change.
Every ESOS instrument, with its dates and its powers
The principal Regulations and each amendment, in the order they were made.
Note the change of vires. The 2014 Regulations were made under European Communities Act powers; every amendment since 2023 has been made under the Energy Act 2023, which is why the scheme can be amended again without new primary legislation.
The ESOS Amendment Regulations 2026, change by change
The instrument's own regulation numbers, and the provisions of SI 2014/1643 each one changes. Verified against the instrument as made and its contents page on 19 August 2026 [11][12].
Made 23 June 2026, laid before Parliament 1 July 2026, in force 22 July 2026. Made under sections 254 to 260 and 263 of the Energy Act 2023. Extends to England and Wales, Scotland and Northern Ireland. Correction slip dated 3 July 2026. No full impact assessment — de minimis [11].
Common questions answered
Sixteen direct answers on the ESOS regulations, the amending instruments, and which provision governs which duty.
The ESOS regulations are the Energy Savings Opportunity Scheme Regulations 2014, SI 2014/1643, made on 24 June 2014 and in force from 17 July 2014. They are the only ESOS instrument: every later statutory instrument amends them rather than replacing them. The amendments that changed the substance of the scheme are SI 2018/1342 and SI 2020/711 (EU exit, and the sterling qualification thresholds), SI 2023/1182 (the 95% coverage floor, the ESOS action plan and progress updates), and SI 2026/701 (in force 22 July 2026). There is no ESOS Act — the 2014 Regulations were made under section 2(2) of the European Communities Act 1972, and the 2023 and 2026 amendments under sections 254 to 260 and 263 of the Energy Act 2023.
The ESOS (Amendment) Regulations 2026 came into force on 22 July 2026. It omitted four provisions of SI 2014/1643 — regulation 32 (energy consumption not subject to an audit), regulation 34 (Display Energy Certificates and Green Deal Assessments), regulation 27B and regulation 3(2). It inserted five — a new Chapter 3B of Part 4 containing regulation 27D (an estimate in kWh of the energy savings actually achieved, broken down by organisational purpose, by measure and by category) and regulation 27E (a review of the previous ESOS action plan), plus regulation 33A (zero kWh total consumption is deemed compliance), regulation 21(2A) (the lead assessor must notify their approval body within seven days of completing an assessment) and regulation 34B(1)(c) (a third progress update). It amended more than twenty further regulations and Schedules 3 and 5. It did not amend regulation 4, regulation 15, Schedule 1, or any penalty amount, and it contains no net zero provision at all.
Because the changes made by SI 2026/701 have not yet been applied to the consolidated text. legislation.gov.uk publishes two versions of an instrument: the text "as made", which never changes, and the "latest available (revised)" text, which the editorial team updates as amendments are applied. As at 19 August 2026 the revised text of SI 2014/1643 carries the banner "There are outstanding changes not yet made by the legislation.gov.uk editorial team", and every outstanding change belongs to SI 2026/701. The practical effect is that regulations 32 and 34 are still displayed as live provisions four weeks after they were omitted. The banner is provision-scoped, so the instrument's front page and regulation 4 both display the opposite message. Until the changes are applied, read the revised 2014 text together with SI 2026/701 as made.
Part 8 of SI 2014/1643, headed "Civil penalties and breaches". Regulations 39 to 42 are the machinery — compliance notices, penalty notices, service and appeals. Regulations 43 to 47 are the breaches and their maxima: regulation 43, failure to notify, up to £5,000 plus up to £500 for each working day in breach to a maximum of 80 working days; regulation 44, failure to maintain records, up to £5,000 plus the compliance body's costs; regulation 45, failure to undertake an energy audit, £50,000 plus the daily element; regulation 46, failure to comply with a notice, up to £5,000 plus the daily element; regulation 47, a false or misleading statement, £50,000. Publication of the breach attaches to all five. Regulation 29 is not a penalty provision — it sits in Part 5 and is headed "Notification of compliance".
No. No figure of £90,000 appears anywhere in the ESOS regulations. The number is the arithmetic ceiling of an aggregate penalty under regulation 45 — the £50,000 maximum plus £500 multiplied by eighty working days — republished as though it were a statutory maximum. Two things are lost in the republication: the daily element is discretionary ("up to £500"), and it runs only from service of a compliance notice, so it is not automatic. The statutory maxima are £50,000 (regulations 45 and 47) and £5,000 (regulations 43, 44 and 46).
No. A full-text check of SI 2014/1643 returns zero occurrences of "phase" and thirty-eight of "compliance period". The instrument knows only "the initial compliance period" and "a subsequent compliance period", both defined in regulation 4. "Phase 1", "Phase 4" and "Phase 5" are Environment Agency guidance vocabulary and industry shorthand with no statutory existence. Regulation 4 is a rolling definition that hard-codes only two dates — 5 December 2015 and 31 December 2014 — and generates every later date by recursion: each subsequent compliance period begins on the 6 December following the end of the preceding one and ends on the 5 December four years later.
Regulation 15 read with Schedule 1. Schedule 1 paragraph 1(a) defines a large undertaking as one which either employs at least 250 persons, or has an annual turnover in excess of amount A and an annual balance sheet total of amount B. Paragraph 1A, inserted by SI 2018/1342 and amended by SI 2020/711, sets amount A at £44 million and amount B at £38 million for any qualification date on or after IP completion day. The financial limb is conjunctive — turnover and balance sheet, not either — and it is widely published the other way, which pulls organisations into scope that are not in it. Neither regulation 15 nor Schedule 1 was amended by SI 2026/701. Regulation 16 is the exclusion provision, and it was widened in 2026.
Regulation 33A was inserted into SI 2014/1643 by SI 2026/701 regulation 25 and has been in force since 22 July 2026. It applies where, in a compliance period, a responsible undertaking has calculated the participant's total energy consumption as zero kWh. In that case the participant is deemed to comply with regulation 20 (the duty to undertake an ESOS assessment), regulation 21 (the lead assessor), regulation 21A(2)(b), Chapters 2A to 4 of Part 4, and Part 6A. It operates automatically rather than on application, and a notification of compliance is still required. SI 2026/701 regulation 29 amended regulation 45(1) at the same time so that the audit-failure penalty does not reach a regulation 33A case.
No. Regulation 34, which provided for Display Energy Certificates and Green Deal Assessments, was omitted by SI 2026/701 regulation 26 with effect from 22 July 2026. Regulation 32, on energy consumption not subject to an audit, was omitted by regulation 23 of the same instrument. The routes that remain are an ESOS-compliant energy audit, ISO 50001 certification covering total or significant energy consumption under regulation 33, or a combination of the two reaching the same statutory floor — with the new regulation 33A zero-kWh case alongside them. Any guidance still listing DECs or Green Deal Assessments is describing the law as it stood before 22 July 2026, and legislation.gov.uk's consolidated text is currently in that category.
SI 2023/1182 — the Energy Savings Opportunity Scheme (Amendment) Regulations 2023, made on 7 November 2023 and in force from 29 November 2023. It is sometimes published as SI 2023/1364, which is not an ESOS instrument. SI 2026/701's own footnote 2 lists the relevant amending instruments as SI 2018/1342, SI 2020/711 and SI 2023/1182. SI 2023/1182 introduced the 95% significant-energy-consumption floor, the ESOS action plan and progress updates in Part 6A, the 40,000 kWh lead assessor floor at regulation 21(3), and the substituted regulation 4(4) that split the third compliance date three ways.
SI 2014/1643 was made under section 2(2) of the European Communities Act 1972, implementing article 8 of the EU Energy Efficiency Directive. SI 2018/1342 and SI 2020/711 repaired the instrument for EU exit rather than replacing it. Both SI 2023/1182 and SI 2026/701 were made under sections 254 to 260 and 263 of the Energy Act 2023, which are the standing powers to amend the scheme — so a further amendment needs no new primary legislation. SI 2026/701 extends to England and Wales, Scotland and Northern Ireland, carries a correction slip dated 3 July 2026, and has no full impact assessment because it is de minimis.
No. As at 19 August 2026 there is no ESOS instrument on legislation.gov.uk newer than SI 2026/701, and no Phase 5 legislation, consultation, call for evidence or draft instrument has been published by DESNZ, the Environment Agency, SEPA, Natural Resources Wales or the Northern Ireland regulator. The GOV.UK ESOS guidance page was last updated on 16 February 2026, and the Environment Agency's "How to comply with ESOS phase 4" was published on 30 July 2026 and has not been updated since. What has not happened is that the 22 July 2026 changes have still not been applied to the consolidated text of SI 2014/1643.
In two places at once, until legislation.gov.uk finishes consolidating. The revised text of SI 2014/1643 at legislation.gov.uk/uksi/2014/1643 is the readable version and is current for everything SI 2026/701 did not touch — regulation 4, regulation 15, Schedule 1 and every penalty amount. For everything it did touch, the operative text is SI 2026/701 as made, at legislation.gov.uk/uksi/2026/701/made. The changes-affected table at legislation.gov.uk/changes/affected/uksi/2014/1643 lists exactly which provisions are outstanding. Do not use legislation.gov.uk/uksi/2014/1643/made for anything: that is the 2014 original, and it still shows euro qualification thresholds and no action plan.
Chapter 3B of Part 4 is the newest thing in the instrument. It was inserted by SI 2026/701 regulation 17 and has been in force since 22 July 2026, and it contains two regulations. Regulation 27D requires a responsible undertaking to produce an estimate, in kWh, of the energy savings actually achieved during the compliance period, broken down by organisational purpose, by measure and by energy-saving category. Regulation 27E requires the previous ESOS action plan to be reviewed, identifying the measures that were proposed and not implemented and are not expected to be, with the reasons. Together they change what an ESOS report is: it now reports what happened as well as what was found. Neither regulation appears in the consolidated text on legislation.gov.uk.
Regulation 21, in Part 4 Chapter 1. Regulation 21(3), inserted by SI 2023/1182, disapplies the requirement where total energy consumption calculated under Chapter 2 is less than 40,000 kWh. Regulation 33 discharges it where ISO 50001 certification covers total or significant energy consumption, and the new regulation 33A discharges it where total consumption is zero kWh. Since 22 July 2026 regulation 21 also carries a new paragraph (2A), inserted by SI 2026/701 regulation 8: within seven days beginning the day after notification under regulation 21(2)(b), the lead assessor must notify their approval body that the assessment is complete, giving the responsible undertaking's registered name and address and contacts for at least two individuals, one of them the responsible officer. Note the recipient — the assessor's approval body, not the compliance body.
Yes. SI 2026/701 extends to England and Wales, Scotland and Northern Ireland, and there is one scheme with one set of duties and one set of penalties across the United Kingdom. What differs is who enforces it. Regulation 6(1) names five compliance bodies: the scheme administrator (the Environment Agency) for England; the Chief Inspector constituted under regulation 8(3) of the Pollution Prevention and Control (Industrial Emissions) Regulations (Northern Ireland) 2013 for Northern Ireland; the Scottish Environment Protection Agency for Scotland; the Natural Resources Body for Wales for Wales; and the Secretary of State for Energy Security and Net Zero for offshore undertakings. Use the statutory names — the guidance calls two of them something else.
The terms, in their statutory sense
Twelve terms this page uses exactly as the ESOS regulations use them.
Every source, and the claims it carries
Which primary source supports which statement on this page. Nothing on the page rests on a search snippet, a summary, or an earlier version of this site.
How this page was checked
Every claim here was established by opening a primary source on 19 August 2026. None of it comes from a search result, a consultancy summary, or an earlier version of this site.
This is a reference site with no clients, no certifications and nothing to sell. If something here is wrong, it is worth telling us — the correction costs us nothing and the error costs a reader a citation.
Where each duty is covered in full
This page maps the instrument. These pages work the duties.
The ESOS qualification test
The conjunctive financial limb, the 250-person limb, and the group rules in Schedule 2.
Regulation 4ESOS compliance periods
Every period and every date derived from regulation 4, including the three-way split.
The current periodESOS Phase 4 compliance
The duties in the order they arrive, to the 5 December 2027 deadline.
Part 8ESOS penalties and enforcement
How the compliance bodies actually use regulations 43 to 47, and the sanctions policy.
Part 4 Chapter 3ESOS energy audits
What regulations 26 and 27 and Schedule 4 require an audit to cover.
Regulation 21ESOS lead assessors
The approved registers, and the new seven-day notification at regulation 21(2A).
Part 6AESOS action plans
Regulations 34A and 34B, and the new regulation 27E review of the previous plan.
Regulation 29ESOS notification of compliance
The regulation everybody miscites for penalties, and what it actually asks for.
Part 6ESOS exemptions and deemed compliance
ISO 50001, the 40,000 kWh floor, insolvency, and the new zero-kWh case.
Energy Act 2023The ESOS enabling powers
Sections 254 to 260 and 263 — the powers under which the scheme is amended.
The next periodESOS Phase 5
What is law, what is guidance, and what is being asserted about 2027 to 2031.
The schemeESOS explained
The Energy Savings Opportunity Scheme end to end, for a first reader.