ESOS Phase 3 Update: Comply by 5 June - Rule Changes

The Environment Agency has recently released information with additional details they need for your business to stay compliant. Because of the changes introduced, businesses are now required to include more information in ESOS Phase 3 reports, along with maintaining an action plan including considerations on how improvements can be implemented.

Here's what you need to know about the recent updates.

What information is now required in ESOS Phase 3 reports?

In your current ESOS Phase 3 reports, you are now required to:

• Include an annual reduction in energy consumption breakdown. This involves categorise reductions in energy consumption annually, covering areas such as energy management practices, behavioural changes, training and control improvements.
• Include a breakdown of Significant Energy Consumption (SEC). Provide a detailed breakdown of SEC by buildings, transport and industrial processes for previous phases.
• Provide an explanation of Total Energy Consumption (TEC) changes. Clarify reasons for changes in TEC figures from Phase 2 to Phase 3.
• Include a suggested energy savings measures program. Propose a program for implementing energy savings measures, outlining timescales.
• Full organisation name, number of companies in the group and corporate group structure chart (i.e. the companies, not the names of personnel) or equivalent information setting out the relationship between organisations in the group.
• Details of the board level director responsible for sign-off and any personnel involved in completing the assessment and/or the report.
• Total energy consumption in kWh, and subtotals by organisational purpose – as the ESOS Phase 3 qualification date was 31/12/2022 we would need this consumption to be for a 12-month period that includes this date
• Energy intensity ratios for each relevant organisational purpose. The intensity ratios used in any SECR reporting can be used, although this would be required to be converted to kWh.
• Documented information maintained under section 7.5 of ISO 50001 which demonstrates that 100% of the total energy consumption is covered by the scope of the ISO 50001 energy management system during the compliance period.
• Documented information which is maintained under section 7.5 of ISO 50001, setting out the outcomes of any performance evaluations under section 9 of ISO 50001 and/or any other records within the energy management system which identify improvements in energy performance indicators relating to energy spend or energy consumption over the compliance period, and what actions the organisation took to achieve these improvements, for example planned actions under section 6 of ISO 50001 to address risks and opportunities or to meet objectives and targets.
• Documented information which is maintained under section 7.5 of ISO 50001, setting out any opportunities for improving energy performance identified through energy reviews under section 6.3 of ISO 50001 and the potential improvement in energy performance indicators relating to energy spend or energy consumption that could be achieved by implementing those opportunities, where identified.

The Environment Agency will also be publishing information contained in your ESOS reports. 

What should be included in the new action plan?

After the compliance notification submission, you must prepare an action plan that includes the following:

• Energy Consumption Reduction Strategy - Specify actions intended to reduce energy consumption.
• Timeline for Implementation - Clearly define when each action will be implemented.
• ESOS Assessment Recommendations - Indicate whether the actions were recommended through the ESOS assessment.
• Expected Energy Savings - Outline anticipated energy savings over the four-year period covered by the action plan.
• Methodology for Estimating Savings - Explain the methodology used to estimate energy savings.

The action plan requires endorsement by a board-level director (or equivalent) and must be submitted through the compliance notification system by the 5 December 2024.

What next?

We will be in touch with all of our ESOS clients soon to provide detailed guidance on the additional information required. Our aim is to ensure you are fully compliant, meeting the 5 June 2024 deadline.