ESOS action plans · Part 6A
ESOS action plan
An ESOS action plan records intended energy-saving measures or the decision to take no action, under the applicable regulations.
The contents
What an ESOS action plan is, in six items
An ESOS action plan records intended energy-saving measures or the decision to take no action, under the applicable regulations.
- 1
Assessment
Identify opportunities from the ESOS work.
- 2
Plan
Record measures, timing and estimated savings.
- 3
Update
Report implementation and savings against that plan.
Read the detailed guidance and evidence
An ESOS action plan is the participant’s published list of the energy efficiency measures it will take, required after every notification by regulation 34A.
The Phase 4 action plan is due by 5 December 2028, followed by three progress updates to 2031.
Like the progress updates that follow it, it carries no penalty in Part 8, and it is one of the few ESOS outputs everyone can read.
An ESOS action plan is a written record of the energy efficiency measures a participant proposes to implement before the end of the next compliance period.
Regulation 34A(3) lists what it must set out for each measure, and nothing about cost or investment is on the list.
A participant that proposes nothing files a statement saying so, which is a lawful action plan.
The estimate must say whether it came from the energy audit’s own figures, from a deemed-compliance route, or from another reasonable method, and a method of the third kind must be described and justified in the evidence pack.
Since 22 July 2026 the savings are in kWh; the older phrase “energy measurement units” still appears on some pages and in some guidance, and is out of date.
The audit the measures come from is described on ESOS energy audits.
| Reg 34A(3)(a) | Each measure must show |
|---|---|
| (i) | The measure the participant proposes to implement |
| (ii) | Whether an energy audit recommended it |
| (iii) | The date it will be implemented by |
| (iv) | Estimated total energy savings in the period, in kWh |
| (v) | The savings for each organisational purpose, in kWh |
| (vi) | The method used for the estimate |
Who owes one
Who must produce an action plan
Qualifying participants generally owe plans and updates even when ISO 50001 provides their compliance route, with a separate zero-energy exemption.
Module 01 / 03
Participant
Check the qualification and reporting position.
Module 02 / 03
ISO route
Do not assume exemption from plans and updates.
Module 03 / 03
Zero energy
Check the specific exemption conditions.
Read the detailed guidance and evidence
Regulation 34A(1) is triggered by a notification of compliance under regulation 29: after notifying, the responsible undertaking must produce an action plan.
That makes it route-neutral: a participant that complied through ISO 50001 owes an action plan exactly as an audited one does.
The ISO route is covered on ISO 50001 and ESOS.
A group that disaggregated produces one plan per participant, because each participant notifies separately.
Whether an undertaking is a participant at all is the qualification test on ESOS Phase 4 thresholds, and whether the duty has force is on is ESOS mandatory.
A participant deemed compliant because its energy consumption was zero owes no action plan and no progress updates (reg 34A(11), reg 34B(9)).
The windows
Action plan deadlines, as statutory windows
Phase 4 links the 2027 compliance deadline with a 2028 action plan and three subsequent annual updates.
- 5 Dec 202701
Phase 4 compliance notification deadline.
- 5 Dec 202802
Phase 4 action-plan deadline.
- 2029–203103
Annual update deadlines on 5 December.
Read the detailed guidance and evidence
Each deadline is the last day of a window, not a single filing day.
The action plan window opens on the first day of the next compliance period and closes on the day before its first anniversary, under regulation 34A(7)(b) read with 34A(10).
For Phase 4 the next period is 6 December 2027 to 5 December 2031, so the window runs from 6 December 2027 to 5 December 2028.
The progress update windows follow the same pattern a year apart: to 5 December 2029, 2030 and 2031.
Phase 3’s plan had a date written into the regulation itself, 5 December 2024, and the Environment Agency’s overview recorded that it would accept plans until 5 March 2025.
The first date is the law; the second was the regulator’s acceptance window, and it has closed.
The one action plan date still ahead for Phase 3 participants is the further progress update, due by 5 December 2026.
- 5 Dec 202401
Phase 3 action plan
Reg 34A(7)(a).
The Environment Agency accepted plans until 5 March 2025.
- 5 Dec 202502
Phase 3 initial progress update
- 5 Dec 202603
Phase 3 further progress update
- 5 Dec 202704
Phase 4 notification
Triggers the Phase 4 action plan duty.
- 5 Dec 202805
Phase 4 action plan
- 5 Dec 202906
Phase 4 initial progress update
- 5 Dec 203007
Phase 4 further progress update
- 5 Dec 203108
Phase 4 final progress update
Reporting back
Progress updates: three in Phase 4
Progress updates record implemented measures and achieved savings using the applicable reporting provisions.
Module 01 / 03
Measure
Identify what was implemented and when.
Module 02 / 03
Saving
Record estimated achieved energy savings and basis.
Module 03 / 03
Difference
Explain the outcome against the intended plan.
Read the detailed guidance and evidence
| Reg 34B | What a progress update must include |
|---|---|
| (3)(a) | Which measures in the latest action plan were implemented since the last event, whether each met its date, and which were not |
| (3)(b) | An estimate of the reduction in energy consumption achieved or expected in the period, in kWh |
| (3)(c) | The method used for that estimate |
| (4) | Whether the method was the audit’s estimate, the action plan’s estimate, or another reasonable method |
| (5) | For another method: a description and the reason, in the evidence pack |
| (1)(c) | A final update in the three-to-four-year window, for periods ending on or after 5 December 2027 |
Regulation 28 of SI 2026/701 made five changes to regulation 34B, the most visible being the third, final update.
The Environment Agency’s Phase 4 guidance says “two” in its stages list and its section 14.3, and “three” in the rest of section 14; the instrument says three.
Each update is notified through the Notification System, with the responsible officer’s confirmation that it complies and that they have seen and considered it.
A zero-energy participant owes none, under regulation 34B(9).
Confirmation
Who confirms the plan, and what the law leaves open
Read the action-plan and update confirmation provisions separately from the assessment's director-confirmation rules.
Module 01 / 03
Draft
Prepare the required plan or update information.
Module 02 / 03
Check
Confirm accuracy and the stated savings basis.
Module 03 / 03
Submit
Record responsible-officer confirmation and notification.
Read the detailed guidance and evidence
The notification of an action plan must carry a confirmation that the responsible officer is satisfied the plan complies, and has seen and considered it.
The responsible officer is a director within section 250 of the Companies Act 2006, or a person exercising management control.
The Environment Agency’s guidance speaks of “one or more directors”, which is safe practice where the law is silent on the number.
A plan that commits to measures the organisation then does not deliver will be revisited in the next ESOS report, so the confirmation is worth more than a formality.
Regulation 34A(8) and 34B(7) speak of “the responsible officer”, singular.
The one-or-two rule in regulation 30(3) is written for the ESOS assessment, and the Regulations do not say whether it extends to plans and updates.
Publication
Published plans, and what that means in practice
The Environment Agency publishes plan and progress information under the statutory disclosure provisions.
Module 01 / 03
Record
Check information required in the submission.
Module 02 / 03
Publication
Check which reported information is disclosed.
Module 03 / 03
Review
Explain gaps and corrections before submission.
Read the detailed guidance and evidence
Regulation 10(1) requires the scheme administrator to publish each ESOS action plan and each progress update.
The Environment Agency’s Phase 3 published data on data.gov.uk holds the action plans, the first progress updates and the notifications of compliance.
The second post-implementation review counted 5,403 Phase 3 action plans among 8,581 notifying groups, and 4,716 with at least one saving action.
So a plan is also a public statement, readable by customers, lenders and anyone comparing what a company said in its annual report.
A published plan that disagrees with the energy narrative in the annual report is an avoidable inconsistency.
Phase 4
The action plan review: the plan comes back
Phase 4 requires the ESOS report to address earlier achieved savings and unimplemented opportunities, alongside the new assessment.
- 1
Previous plan
Identify measures and recorded progress.
- 2
2027 report
Record achieved savings and review missed opportunities.
- 3
Next plan
Record the participant's intended Phase 4 measures.
Read the detailed guidance and evidence
SI 2026/701 made the last action plan part of the next ESOS report, through a new regulation 27E.
The review must identify the measures in the current action plan that have not been, and are not expected to be, implemented before the end of the compliance period, and explain why.
It is included in the ESOS report, notified to the regulator, kept in the evidence pack, and not published.
Beside it, regulation 27D requires the energy savings actually achieved in the compliance period, in kWh, and the combined figure is published.
For a Phase 3 participant, the plan filed by 5 December 2024 and its two progress updates are the record the Phase 4 review will be tested against.
The full set of Phase 4 changes is on ESOS Phase 3 vs Phase 4, and how the report fits the sequence on ESOS compliance.
Enforcement
The penalty gap, and the route around it
Part 8's assessment and notification penalties should not be relabelled as a standalone action-plan fine.
Module 01 / 03
Duty
Identify the specific unmet provision.
Module 02 / 03
Notice
Read the regulator's enforcement notice and deadline.
Module 03 / 03
Penalty
Identify the separate power and maximum where applicable.
Read the detailed guidance and evidence
Part 8 penalises failing to notify, failing to keep records, failing to undertake the assessment, failing to comply with a notice, and false statements.
It names neither regulation 34A nor regulation 34B, so a missed action plan or progress update carries no penalty of its own.
The Environment Agency says regulators “will not take enforcement action or issue a penalty relating to the non-submission of an action plan or progress update”, and that the failure will be published.
The route around the gap is regulation 46: if a regulator served an enforcement notice requiring the plan, failing to comply with the notice is penalised at up to £5,000 plus £500 per working day, for up to 80 working days.
The rest of the penalty table is on ESOS penalties.
The instruments behind Part 6A are the 2023 amending Regulations, which inserted it from 29 November 2023, read with the 2014 Regulations.
Frequently asked
ESOS action plans: questions people ask
What does ESOS mean?
ESOS stands for the Energy Savings Opportunity Scheme, the UK scheme under which large undertakings and their groups assess their energy use every four years.
Since Phase 3, each assessment is followed by an action plan and progress updates.
What is the ESOS Phase 4 action plan deadline?
The Phase 4 action plan must be notified in the window from 6 December 2027 to 5 December 2028.
It covers the following compliance period, 6 December 2027 to 5 December 2031.
The deadline follows from regulation 34A(7)(b) and (10).
What must an ESOS action plan contain?
Under regulation 34A(3), each energy efficiency measure the participant proposes to implement before the end of the next compliance period; whether an audit recommended it; the date it will be implemented by; the estimated energy savings in kWh, in total and for each organisational purpose; and the estimation method.
Or, instead, a statement that no measure is proposed.
There is no statutory cost or investment requirement.
Who has to produce an ESOS action plan?
Every responsible undertaking that notifies compliance under regulation 29, whichever route it used, including the ISO 50001 route.
The only participant carved out is one deemed compliant because its energy consumption was zero (regulation 34A(11)).
How many ESOS progress updates are there?
Three for Phase 4 action plans: by 5 December 2029, 5 December 2030 and 5 December 2031.
The third was added by regulation 28 of SI 2026/701.
Phase 3 action plans have two, due by 5 December 2025 and 5 December 2026.
Is there a penalty for missing the ESOS action plan?
No penalty in Part 8 names regulation 34A or 34B.
The Environment Agency says it will not take enforcement action for non-submission and publishes the failure instead.
An enforcement notice requiring a plan would be enforceable under regulation 46 if ignored.
Is there an ESOS action plan template?
The Regulations prescribe the contents, not a template: regulation 34A(3) lists what the plan must set out, and the plan is entered and notified through MESOS.
A plan built around those six items meets the statutory content.
Are ESOS action plans published?
Yes.
Regulation 10(1) requires the scheme administrator to publish each ESOS action plan and each progress update.
The action plan review that goes into the next ESOS report is notified but not published.
Fictional example
A fictional lighting measure
A fictional participant records one planned lighting upgrade with timing and an energy-saving estimate.
Module 01 / 03
Measure
Identify the premises and equipment.
Module 02 / 03
Timing
Record intended implementation dates.
Module 03 / 03
Saving
Record annual kWh savings and estimation basis.
Read the detailed guidance and evidence
A fictional participant records one planned lighting upgrade with timing and an energy-saving estimate.
Editorial preparation
Close the evidence loop
An editorial plan record connects the opportunity, approval, installation and reported result.
- 1
Opportunity
Retain the original assessment evidence.
- 2
Implementation
Record completion and deviations.
- 3
Outcome
Support the savings reported in the update.
Read the detailed guidance and evidence
An editorial plan record connects the opportunity, approval, installation and reported result.
Prepare the evidence
ESOS action plan: from a requirement to a reporting pack
Use this preparation sequence alongside the detailed requirements on this page.
An editorial workflow, not a statutory schedule.
- Stage 0101
Qualification record
Resolve the undertaking and group position at the qualification date.
- Stage 0202
Energy period
Retain the chosen reference period and its source records.
- Stage 0303
Assessment coverage
Document the audit coverage, exclusions and compliance routes used.
- Stage 0404
Assessor review
Check whether a lead assessor is needed for the chosen compliance route.
- Stage 0505
Approval and notification
Retain the applicable director sign-off and notification evidence.
- Stage 0606
Action plan
Use the assessment findings to support the applicable action plan and progress record.
Read the applicable instrument: ESOS Regulations 2014, Part 6A (regulations 34A–34B) — action plans and progress updates
A practical brief
An evidence pack, with a clear review trail
Ask for a pack that lets the next reviewer retrace the scope decision, follow the evidence and understand the limitations.
This describes a useful handover; it does not certify compliance or establish that a vendor or adviser delivers it.
Module 01 / 04
Applicability record
Write down the entity, reporting route and relevant period, including why the route applies.
Module 02 / 04
Evidence register
Attach each reported figure or statement to its source, method, version and limitations.
Module 03 / 04
Review trail
Name the preparer, reviewer, open questions and decisions taken before publication.
Module 04 / 04
Usable handover
Retain the working files and unresolved actions so the next reporting cycle can reuse the evidence.
View the preparation diagram
- Prepare01
Create the traceable pack
Keep the input records, calculation files and narrative together.
- Challenge02
Resolve questions before publication
Record the assumptions challenged and any limitations still unresolved.
- Retain03
Make the next cycle reproducible
Keep the approved version and the actions carried forward.
Continue your research
Related guides, one question at a time
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- legislation.gov.ukESOS Regulations 2014, Part 6A (regulations 34A–34B) — action plans and progress updates
Consolidated to 22 July 2026: contents, windows, kWh basis, the third progress update, the zero-energy carve-out.
- legislation.gov.ukSI 2026/701, regulation 27 — kWh in reg 34A, and the zero-energy carve-out (reg 34A(11))
- legislation.gov.ukSI 2026/701, regulation 28 — the third progress update (new reg 34B(1)(c))
- legislation.gov.ukThe Energy Savings Opportunity Scheme (Amendment) Regulations 2026 (SI 2026/701)
Made 23 June 2026, in force 22 July 2026: the Phase 4 changes. Made under Energy Act 2023 ss.254–260 and 263.
- legislation.gov.ukThe Energy Savings Opportunity Scheme (Amendment) Regulations 2023 (SI 2023/1182)
In force 29 November 2023: the Phase 3 changes — action plans, the 95% line, site visits, intensity ratios.
- legislation.gov.ukThe Energy Savings Opportunity Scheme Regulations 2014 (SI 2014/1643), revised text
In force 17 July 2014. Consolidation of the 2026 amendments is partial — read with SI 2026/701.
- legislation.gov.ukESOS Regulations 2014, regulation 29 — notification of compliance
The notification that triggers the action plan duty.
- legislation.gov.ukESOS Regulations 2014, Part 8 (regulations 39–47) — civil penalties
The five penalties and publication; regulations 34A and 34B are named nowhere in Part 8.
- Environment AgencyHow to comply with the Energy Savings Opportunity Scheme (ESOS) phase 4
Published 30 July 2026. A restatement of the Regulations, never the source over them; where it and the SI differ, the SI governs.
- Environment AgencyComply with the Energy Savings Opportunity Scheme (ESOS) phase 4 — publication page
- Environment Agency / GOV.UKEnergy savings opportunity scheme (ESOS): find out if you qualify and how to comply
Rewritten for Phase 4 on 2 September 2026; seven approved lead assessor registers; PAS 51215-1 and -2:2025 voluntary.
- Department for Energy Security and Net ZeroThe ESOS Regulations 2014 — second Post Implementation Review (18 July 2025, PDF)
¶19: 9,871 groups believed to qualify for Phase 3; 8,581 notified; 5,403 action plans. Recommendation: keep.
- Environment Agency / data.gov.ukEnergy Savings Opportunity Scheme — Phase 3 published data
Action plans, first progress updates and notifications of compliance, as published.