Preparing for ESOS Phase 4: Our Consulting Approach and How We Can Help You Comply with Confidence
The Energy Savings Opportunity Scheme (ESOS) has become a key regulatory requirement for large UK organisations. With ESOS Phase 4 now underway, thousands of businesses must once again assess their energy use, identify efficiency opportunities, and submit a compliant notification to the Environment Agency.
At Clear Bridge and with the help of our partners in carbon reporting, we guide organisations through every stage of ESOS compliance—ensuring accuracy, minimising administrative burden, and unlocking real energy savings. Below is our approach for supporting organisations through ESOS Phase 4, including qualifying criteria, key dates, our ESOS 3 loyalty discount, and the risks of non-compliance.
Who Qualifies for ESOS Phase 4?
An organisation is in scope for ESOS Phase 4 if, on the qualification date (31 December 2026), it meets any of the following criteria:
Large Undertaking Criteria
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250 or more employees,
OR -
Annual turnover above £44 million AND an annual balance sheet total above £38 million
These thresholds apply to individual UK undertakings and to groups where any UK entity meets the definition of a large undertaking. Most large organisations qualifying for ESOS 3 will remain in scope for ESOS 4.
Key Periods for ESOS Phase 4
To remain compliant, organisations must meet the following timeline:
Compliance Period
6 December 2023 – 5 December 2027
Qualification Date
31 December 2026
Compliance Deadline
5 December 2027
Energy Reference Period
A 12-month period for energy-use data that:
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Must include the qualification date (31 December 2026), and
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Must end before the compliance deadline (5 December 2027)
This means organisations can choose a reference period such as 1 January 2026 – 31 December 2026, or March 2026 – February 2027, depending on what best aligns with internal reporting cycles.
Our ESOS Phase 4 Consulting Approach
We provide a structured, end-to-end service designed to simplify compliance while maximising the operational benefits of ESOS.
1. Eligibility Review & Gap Assessment
We begin by confirming your qualification status and assessing ESOS 3 findings, exemptions, and organisational structure.
This ensures the scope is accurate from the start.
2. Data Collection & Validation
We gather and validate energy consumption data across:
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Buildings
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Industrial processes
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Transport operations
We streamline data requests and liaise with internal teams to minimise disruption.
3. Energy Audits & Opportunity Identification
Our qualified Lead Assessors conduct detailed site audits where required, identifying:
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Cost-effective energy-saving measures
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Operational efficiencies
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Technology-based improvements
All savings estimates follow ESOS-compliant calculation methodologies.
4. Consolidated ESOS Report & Evidence Pack
We prepare the full evidence pack, including:
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Full audit findings
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Total energy consumption calculations
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Significant energy use identification
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Compliance statements and data records
This ensures you have a robust audit trail if the Environment Agency requests evidence.
5. Sign-off & Notification
We coordinate Director sign-off and submit the final ESOS notification to the regulator ahead of the deadline.
Special Offer: 20% Discount for ESOS 3 Clients
If your organisation previously undertook ESOS Phase 3, we will provide a 20% discount compared with what you paid for your last ESOS compliance project—regardless of who delivered it.
This applies to:
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Existing clients
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New clients who can provide ESOS 3 invoice evidence
What Happens If You Get ESOS Wrong?
The Environment Agency has increased its enforcement activity in recent phases. Non-compliance can lead to:
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Failure to notify: Penalties typically starting around £5,000 plus daily fines
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Failure to maintain adequate records: Fines up to £5,000 plus publication of your non-compliance
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Failure to undertake an energy audit: Fines up to £50,000 plus £500 per day
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False or misleading statements: Significant fines for providing inaccurate information
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Public naming: The regulator publicly publishes non-compliant organisations
Beyond financial penalties, non-compliance can damage an organisation’s credibility with regulators, investors, and supply-chain partners increasingly focused on ESG performance.
Why Work With Us?
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Proven ESOS experience across multiple sectors
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Qualified Lead Assessors
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Practical, business-focused audit recommendations
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Transparent pricing
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A 20% ESOS 3 loyalty discount
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Fully managed compliance, reducing the effort required from your internal teams
