The final deadline for submitting ESOS Phase 3 Action Plan Notification of Compliance was the 5th of March 2025. If you’re unsure about your organisation’s next steps, now is the time to focus on three key areas: begin implementing your energy-saving measures, collect the data for reporting action plan progression within the ESOS Phase 3 Annual Updates and begin planning ahead for ESOS Phase 4.
What you need to know about ESOS Phase 4
Large organisations that qualified for ESOS Phase 3 must submit their Annual Updates by 5th December in both 2025 and 2026, ahead of ESOS Phase 4 compliance in December 2027. The ESOS Phase 4 compliance deadline is 5th December 2027.
As part of this phase, organisations are expected to submit a new assessment demonstrating progress against their ESOS Phase 3 Action Plans. To ensure your report is accurate, it’s important to begin actively monitoring your energy data now. In addition, ESOS Phase 4 may introduce the requirement to disclose why energy-efficiency measures committed to in your ESOS Phase 3 Action Plan have not been carried out.
Businesses are also encouraged to incorporate Net Zero ambitions into their ESOS Phase 4 reporting. Although this mandatory requirement for Net Zero assessments has been deferred to ESOS Phase 5, there is still an opportunity to include a voluntary Net Zero assessment in your submission.
McGrady Clarke’s experts recommend taking advantage of this voluntary option. Proactive reporting not only supports long-term compliance but also positions your organisation to capitalise on the broader benefits such as enhanced sustainability performance, greater resilience and strategic cost reductions.
Be proactive and overcome challenges
One of the most significant challenges organisations face is the lack of accurate, reliable data. McGrady Clarke’s energy consulting, monitoring and management services are designed to simplify and strengthen your approach to energy data collection. By delivering clear, actionable insights into how and where energy is being used, we help identify areas of wasted energy and highlight further opportunities for realising energy, cost and carbon savings. As ESOS Phase 4 progresses, this level of visibility over your energy consumption will be key to driving meaningful improvements and meeting your compliance obligations with confidence.
Another common difficulty lies in the implementation of energy-saving recommendations arising from ESOS. McGrady Clarke has successfully guided many organisations through every stage of ESOS compliance, from conducting site and transport audits to producing and submitting all required reporting. Our ongoing support extends past the Notification of Compliance, as we assist with the implementation of recommendations such as LED lighting upgrades, solar PV installations and staff energy awareness training delivery.
Taking a proactive approach to reporting ensures your organisation remains ahead of regulatory changes while maximising the broader benefits that go beyond basic compliance, such as improved energy efficiency, cost savings and improved stakeholder reputation.
Contact McGrady Clarke today for support to stay on top of your continued ESOS Phase 3 reporting and get ahead with ESOS Phase 4.
Share this article:
