Upcoming changes to ESOS: What you need to know

Changes to ESOS

The majority of changes are suggested for implementation in Phase 4 with a qualification date of 2026. However, there are a number of changes that will apply from Phase 3 onwards that businesses will be required to follow.

What’s changing in Phase 3?

• The de minimus limit (The limit for exemption from reporting) will reduce to 5% of total energy consumption (previously 10%). Reducing the de minimus limit will bring more energy uses under the scope, force smaller sites into the audit process and will increase the potential energy savings.
• ESOS reports should include an overall energy intensity metric within the overview section of the report in terms of kWh/m2 for buildings kWh/unit out for industry and kWh/miles for transport.
• DECs (Display Energy Certificates) and Green Deal Assessments will no longer be a compliance route in Phase 4 but are also not encouraged for use in Phase 3 as they do not meet ESOS best practise standards.
• A standardised template for including compliance information in the ESOS report will be available.
• ESOS reports will need to provide more information on next steps for implementing recommendations.
• Collecting additional data for compliance monitoring and enforcement will be required.

What’s changing in Phase 4 onwards?

• ESOS balance sheet and turnover thresholds will be updated to align with Streamlined Energy and Carbon Reporting.
• A new Net Zero Carbon element for the energy audits will be introduced. BSI is working on producing a Publicly Available Specification (PAS), setting out the net zero requirements for an ESOS audit. ESOS assessments will be expected to include recommendations that look to reduce GHG emissions even where these do not currently generate a direct energy cost saving.
• A requirement will be introduced that if the audit recommendations have not been met, the participant must explain why.
• Display Energy Certificates (DECs) and GDAs will be removed as compliance routes for ESOS.

What’s changing in Phase 5 onwards?

• The government is also considering extending the scope of the scheme to include medium-sized businesses which is expected to be introduced at a later phase.

Impact of ESOS changes

By including a Net Zero Carbon element and measuring GHG emissions, recommendations that may not have fallen under ESOS scope before, will now be incorporated and their implementation will be monitored. For example the elimination of fossil fuels such as a gas boiler, or on-site renewable energy generation might not have previously been ESOS recommendations, but they will be considered now. This, as well as including medium-sized organisations down the line, will help the UK reach its 2050 Net Zero carbon targets.

Compliance with such policies will entail CAPEX costs for businesses. With this in mind, Government-led financial incentives to support this transition would be welcomed. Also, the huge cost savings that can be gained from ESOS would provide much needed help to tackle current rising energy costs.