Skip to content
UK SRSThe UK Sustainability Reporting Standards, ESOS, SECR and TCFD, read against the published text.HUBUK SRS GuideAn independent reference guide to UK SRS, ESG, TCFD, SECR, ESOS and the global standards.Global Reporting StandardsSustainability reporting standards worldwide: ISSB, the EU CSRD after Omnibus I, California SB 253 and SB 261, and UK SRS.UK SRS StandardsUK SRS S1 and S2 at the provision: reliefs, comply or explain, and the FCA statements.ESOS QuestESOS Phase 4 in depth: qualification, the audit, sign-off, action plans and penalties, read against the Regulations.YOU ARE HERESRS EngineeringThe data build behind a UK SRS report: metrics, owners, controls and timing.SRS ReportWhat a UK SRS report contains, how it is assembled, and how to read one.UK SRS ReportAnalysis and commentary: CDP, the DESNZ emission factors, SECR and ESOS, with every figure cited.UK SRS NewsThe cluster's news publication, and what a UK SRS report contains.UK SRS DeliveryTemplates, costs, ESOS delivery guides and readiness assessment.UK SRS FinanceFinanced emissions, PCAF and IFRS S1/S2 for banks, insurers and asset managers.SECRStreamlined Energy and Carbon Reporting: deadlines, thresholds, eligibility and guidance.Carbon CreditsCarbon credit ratings, risk analysis, valuation and market structure.Environmental RegimesThe eight UK environmental reporting regimes, their thresholds, deadlines and regulators.UK SRS ServicesThe services arm: ESOS, SECR, net zero and sustainability consultancy.

ESOS Phase 4 · Part 6A

ESOS action plans and progress updates: Phase 4 to 2031

Notifying compliance in December 2027 is the middle of ESOS Phase 4, not the end.

Part 6A of the Regulations adds an action plan and, since SI 2026/701, three annual progress updates that run to the end of 2031.

The dates

Four filings after the deadline

The action plan covers the next compliance period, 6 December 2027 to 5 December 2031, so it overlaps Phase 5.

Each progress update reports what has been implemented and the savings achieved against the plan.

The third update, due 5 December 2031, was added by SI 2026/701 for compliance periods ending on or after 5 December 2027.

Each filing is confirmed by the responsible officer and submitted through MESOS.

  1. 5 Dec 2027
    Notification of compliance
    Including savings achieved and the review of the Phase 3 plan.
    Regs 27D, 27E, 29
  2. 5 Dec 2028
    Action plan
    Measures to implement by 5 December 2031, with dates and kWh savings.
    Reg 34A
  3. 5 Dec 2029
    Initial progress update
    Reg 34B(1)(a)
  4. 5 Dec 2030
    Further progress update
    Reg 34B(1)(b)
  5. 5 Dec 2031
    Final progress update
    New in Phase 4.
    Reg 34B(1)(c)

New in Phase 4

The Phase 3 plan comes back for review

A Phase 4 ESOS report must now look backwards as well as forwards.

It states the energy savings achieved during the compliance period, measure by measure, in kWh.

And it identifies Phase 3 action plan measures that were not implemented, and are not expected to be, with the reasons.

What is public and what is not

Only the combined savings figure is published; per-measure savings and the reasons for unimplemented measures go to the scheme administrator alone.

A participant with zero energy consumption owes no action plan and no updates at all.

Enforcement

A published duty with no penalty

Regulations 34A and 34B are named nowhere in Part 8, so no civil penalty attaches to them.

That is a gap in the Regulations, and a stronger point than the regulator’s statement that it will not enforce.

The pressure is publicity: plans, updates and failures to submit are published, and Phase 3 plans already appear in the open data.

An enforcement notice requiring a plan would itself be enforceable under regulation 46.

The penalties page covers the offences that do exist, and the family’s ESOS Phase 4 compliance guide on uksrs.org.uk sets the plan in the full timeline.

Sources: SI 2014/1643 Part 8; reg 10.
FilingPenalty in Part 8?Published?
Notification of complianceYes — reg 43Yes
Action planNoYes, and failure published
Progress updatesNoYes, and failure published

In figures

The tail of Phase 4 in numbers

4
filings after the notification
Regs 34A, 34B
3
progress updates, one more than Phase 3
Reg 34B(1)(c)
2,031
the year the final Phase 4 update is due
Reg 34B
0
civil penalties attached to plans or updates
Part 8

Frequently asked

Questions people ask

When is the ESOS Phase 4 action plan due?

By 5 December 2028, within the first year of the following compliance period, under regulation 34A.

It sets out the energy efficiency measures the organisation proposes to implement by 5 December 2031, with dates and estimated savings in kWh.

How many ESOS progress updates are there in Phase 4?

Three, due by 5 December 2029, 5 December 2030 and 5 December 2031.

SI 2026/701 added the third.

The Environment Agency’s guidance says two in some places and three in others; the Regulations require three.

What is the ESOS action plan review?

New in Phase 4: the ESOS report and notification must identify measures in the previous action plan that have not been and are not expected to be implemented, and explain why. That review is notified to the scheme administrator but not published.

Is there a penalty for not submitting an ESOS action plan?

No. None of the five civil penalties in Part 8 attaches to regulations 34A or 34B.

The failure is published by the scheme administrator, and if a regulator served an enforcement notice requiring a plan, failing to comply with that notice would be penalisable.

Are ESOS action plans published?

Yes.

Regulation 10 requires the scheme administrator to publish each action plan and each progress update.

Phase 3 action plans and first progress updates were released as open data in June 2026.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner.

Secondary commentary is never the source for a number.

Checked against 11 sources fromlegislation.gov.ukEnvironment AgencyEnvironment Agency / GOV.UKdata.gov.uk
  1. legislation.gov.uk
    SI 2014/1643 Part 6A — action plans and progress updates

    Regulations 34A and 34B.

  2. legislation.gov.uk
    SI 2014/1643 regulation 34B — progress updates

    Three progress updates for periods ending on or after 5 December 2027.

  3. legislation.gov.uk
    The Energy Savings Opportunity Scheme (Amendment) Regulations 2026 (SI 2026/701), in force 22 July 2026

    Every Phase 4 change: routes, savings reporting, the action plan review, the third progress update.

  4. legislation.gov.uk
    SI 2026/701 — Explanatory Note

    The government’s own summary of what the 2026 amendments do.

  5. legislation.gov.uk
    The Energy Savings Opportunity Scheme Regulations 2014 (SI 2014/1643)

    The scheme itself. The consolidated text does not yet show the 2026 amendments.

  6. legislation.gov.uk
    SI 2014/1643 regulation 4 — compliance periods, qualification and compliance dates

    Generates 6 Dec 2023 – 5 Dec 2027, 31 Dec 2026 and 5 Dec 2027.

  7. legislation.gov.uk
    SI 2014/1643 Part 8 — civil penalties (regulations 39–47)

    Five offences; none attaches to action plans or progress updates.

  8. Environment Agency
    How to comply with the Energy Savings Opportunity Scheme (ESOS) phase 4 (30 July 2026)

    The regulator’s guidance; a restatement of the Regulations, never the master.

  9. Environment Agency / GOV.UK
    Energy savings opportunity scheme (ESOS): find out if you qualify and how to comply (updated 2 September 2026)

    The GOV.UK hub, now a Phase 4 page, and the approved lead assessor register list.

  10. data.gov.uk
    Energy Savings Opportunity Scheme — published notifications and action plans

    What the scheme administrator publishes.

  11. legislation.gov.uk
    SI 2014/1643 regulation 33A — zero energy consumption

    Inserted by SI 2026/701: deemed compliance, but a notification is still made.

Book a free consultation