What makes a good ESOS action plan?

All participants who qualified for ESOS in a given compliance period are required to subsequently produce an action plan and report against it. The purpose of the action plan and progress updates is to increase participants’ accountability for taking action to reduce their energy use. Participants will be required to provide updates on any measures that they intend to implement to save energy before the end of the compliance period, which follows the time they submit their notification of compliance. The period covered by the action plan is the four years following the compliance period (which coincides with the subsequent compliance period).

You should not delay in preparing your ESOS action plan. It pays to get it done now so that your organisation is ready for ESOS Phase 4 and so that you can apply the energy-saving measures that will benefit the business. Here’s how to put together a good-quality plan.

Consider all the recommendations

Your initial ESOS audit will identify many opportunities for your organisation to save energy. The official guidance says that the measures recommended should be “practical and cost-effective”. This doesn’t force you to implement every recommendation, but it does mean they are all worth consideration.

You must record the reasons for the recommendations you choose to reject. This is important for ESOS and keeping your EA records current. All this information should be included in your evidence pack.

Be clear on timescales

Once your organisation has chosen the measures to implement in the current ESOS phase, you need to work out when you will carry them out. This is one of the biggest reasons why it is ideal to complete your plan now; delaying it closer to the March 2025 deadline builds in months of unnecessary delay.

Your ESOS audit should have suggested timescales for each of the recommended measures, considering issues such as equipment obsolescence, lease renewal dates, tenancy agreements, etc.

You do not have to accept the audit’s suggested timings, but the information should help you decide what to do and when. Then, your ESOS action plan should include the list of actions your organisation intends to take and the intended timescales. For each measure, state the month and year you intend to begin.

Set realistic goals

The ESOS rules require you to submit a progress update in the 12 months following the action plan deadline and another in the 12 months after. All this information is public, so it could affect your organisation’s credibility if you make an over-ambitious ESOS plan but only achieve a small fraction of it. If your planning is thorough and realistic, you should be able to chart a course of action that is achievable but still results in significant energy savings.

State your energy savings

Your ESOS action plan must include an estimate of the energy savings you expect to achieve through each action throughout the action plan period. For Phase 3, that means up to 5 December 2027. The information you need to calculate this should be in your original audit report. If you took an alternative route to ESOS compliance, such as ISO 50001, you would need to find another way to calculate estimated savings. Give the source of the data you used in your calculations.

Add it up and break it down

The rules also require:

• A combined estimate of all the energy savings you will achieve by the end of Phase 3 if you carry out everything in your action plan.
• A breakdown of these energy savings is given according to the area of energy consumption (e.g., transport and industrial processes).

State your sources

Your ESOS audit doesn’t have to be the only source of recommendations for energy-saving measures. Your organisation may get advice from elsewhere, may be using an alternative route to ESOS compliance, or simply decide to carry out actions that are not suggested in the audit. It’s fine to include measures that are not mentioned in your ESOS audit, but you do need to clearly state the source of the recommendation. As with any other measure, you also need to include the month and year you intend to carry it out, as well as the projected energy savings in Phase 3.

Completing your action plan

To assist companies with completing the action plan, there is an Excel template that should have been sent by the EA to your main contact and can be populated. When you have completed your action plan, you will require a board-level director to review and sign off the action plan. This ensures that all plans related to the recommended measures are communicated to the main decision-makers. From this point, the notification of compliance can be completed on MESOS – a guide for completing this submission should have been sent to your ESOS contact from the EA.

Compiling a credible ESOS action plan is challenging, but your initial audit will contain information and suggestions to inform your decision-making. Your action plan is effectively a strategy for saving your organisation significant sums of money and perhaps operating more effectively, too. So don’t rush these discussions; don’t be afraid to seek expert advice.

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