
ESOS requirements state that large businesses with a registered UK address must submit an action plan by the extended deadline of 5th March. By taking a more assertive stand point ESOS are trying to demonstrate the benefits, improve the reporting and increase the uptake of sustainable energy saving measures by large UK businesses.
While this is ultimately beneficial, it does increase the administrative workload on you and your teams. The Environment Agency (EA) has made it clear that those companies not complying will be fined and the list of ‘offenders’ will be published publicly.
What is an action plan?
An ESOS action plan will be your roadmap for turning the energy audit findings into practical steps that can save money, reduce emissions and demonstrate your business’ approach to responsible energy management.
It brings together:
What you want to do
Why you’re doing it
Who will be involved
How it will be funded
When changes will take place.
What needs to be done?
If you are part of a large business in the UK you should have already undertaken an ESOS Audit with a registered Lead Assessor. If you haven’t, this should be done as soon as possible. Following this ESOS Audit, for the action plan your business will need to:
Identify each energy-saving measure
These will be revealed by your ESOS audits with assistance from an ESOS Lead Assessor then:
Categorise each of the measures (e.g. no/low-cost, capital-intensive, operational changes, etc.)
Provide basic details as to what implementation would look like. (expected costs, payback periods, estimated energy/carbon savings).
Prioritise the recommendations
These can be based on return on investment, technical complexity, strategic value or carbon impact:
Include a timeline (e.g., within 12 months, 1–3 years, 3–5 years) for planned implementation or further investigation.
State which measures your organisation plans to implement
How will you look to do this, both financially and logistically (e.g. internal budget, external financing, departmental ownership):
Responsibilities should be assigned by naming the departments, teams, or individuals who will lead on each initiative.
Identify any resource or skills requirements (e.g. need for technical consultants or specialist equipment).
Tracking your progress is vital as you will need to submit a report on how your company is performing against the targets set in your action plan. A report will need to be submitted in December 2025, December 2026 and December 2027.
What haven't you done?
You will also need to discuss the measures that you didn’t take, providing a brief rationale as to why. It is important to show that each measure was considered in good faith even if ultimately it wasn’t adopted.
Although the scheme doesn’t require you to adopt every recommendation, the new emphasis on planning and calculations is designed to guide businesses in conducting a thorough Action plan. This should leave organisations with insights into the actual cost savings that can be made, as well as the carbon savings. Breaking what can often seem like a daunting prospect, into smaller steps to sustainability.
How does an ESOS action plan relate to your Carbon Reduction Plan (CRP)?
A CRP is a more surface level, broad brush strategy outlining a company’s overall approach to reducing greenhouse gas emissions across all operations. The ESOS Action Plan, as outlined above, is a specific plan detailing energy efficiency improvements, identified through an ESOS audit. By including timescales, resources and expected costs, the ESOS Action plan is more focused on the steps to reducing energy consumption.
This will contribute to your wider carbon reduction strategy; however, the CRP won’t need to go into as much detail or specific operational actions or responsibilities.
The action plan deadline is just around the corner.
The clock is ticking, with the 5th of March fast approaching. If businesses haven’t made a start on their action plan, the ESOS fines could be on the horizon. A lot of these plans will need director level buy-in which can often be challenging with such a tight timeline. By working with a trusted expert, you can make sure that the facts and figures are calculated and presented clearly and concisely by people who understand the industry and the requirements.
Contact BFFF energy services today to make sure your business understands and submits an ESOS action plan before the deadline on 5th March.
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