ESOS compliance audits are underway – what you need to know (and how to stay compliant)
The Environment Agency (EA) has confirmed that it is now auditing companies for ESOS (Energy Savings Opportunity Scheme) compliance.
If your organisation qualifies, this is an important moment to check that your compliance obligations are fully met. Here’s what you need to know – and how Concept can help you avoid enforcement action.
A quick refresher: ESOS compliance requirements
The ESOS legislation requires all qualifying organisations to:
- Submit a Notification of Compliance (NOC) to the EA (or the relevant regulator in Scotland, Wales and Northern Ireland)
- Keep an evidence pack, including all required information relating to your eligibility, audit strategy, energy audits and action plans as detailed in the ESOS Phase 3 scheme guidance.
- Submit an Action Plan and two annual Progress Updates, even if you don’t plan to implement any energy-saving measures
Who is the EA auditing?
We know that the EA is pursuing organisations that are likely to qualify for ESOS but have not yet submitted their NOC.
It is also auditing companies that have submitted an NOC, to check that their submission and supporting information is accurate. This could include a check of evidence pack material, such as your corporate group structure and eligibility, data to support the calculation of total and significant energy consumption, energy audits and identified energy saving measures, and director sign off.
The risks of non-compliance
Non-compliance can lead to significant financial penalties. The fines depend on the type of breach, but range from £5,000 for failure to maintain records, and up to £50,000 plus daily penalties of £500 (to a maximum of 80 days/£40,000) for failure to undertake an energy audit. Any false or misleading statements may attract a fixed penalty of up to £50,000.
How we can help
If you’re worried about whether your ESOS submission would stand up to an audit, you’re not alone. Phase 3 was challenging for many organisations – from gathering data across multiple sites and corporate entities to making sense of the reporting requirements.
We work with organisations across the UK to make ESOS compliance (and other schemes) manageable and stress-free. Here’s how we can help right now:
- Audit support
If you’ve been contacted by the EA, we can step in quickly to review your submission with you, identify gaps, and help you respond in a way that resolves any issues and gets you compliant.
- Action Plan Progress Update support
The deadline for submitting your Action Plan Progress Update is 5th December 2025. We can help you prepare this in good time, ensuring it meets all requirements.
- Getting ahead for Phase 4
If Phase 3 was challenging, we can make Phase 4 easier. We’ll help you streamline your data collection process now – reducing admin burden, avoiding last-minute panic, and allowing a more strategic approach to energy management that will deliver long-term cost savings.
Why work with Concept?
Concept is a trusted partner to some of the UK’s largest and most complex organisations, combining deep technical expertise with a practical, friendly approach. Our accredited ESOS Lead Assessors have been helping organisations achieve compliance since the scheme launched in 2014.
If you’re unsure about your ESOS status, or if you’ve received communication from the Environment Agency, don’t wait for enforcement action.
Book a quick call with our team to discuss your situation – whether you just want peace of mind, or need some help filling the gaps. The sooner you act, the easier – and less costly – it is to get everything in order.
