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ESOS Phase 2 compliance: Have you got a plan in place?

With the compliance deadline for ESOS Phase 2 just a year away – 5 December 2019 – proactive organisations have started to prepare by planning and carrying out energy audits as part of the compliance process.

With only a few exemptions for public bodies, your organisation qualifies if on the 31st December 2018, it meets the ESOS definition of a large undertaking:

  • You employ 250 staff or more
  • You have an annual turnover exceeding €50m and a balance sheet exceeding €43m

Qualifying organisations that fail to undertake an ESOS assessment will be liable for a penalty of up to £50,000 and details of non-compliance would be published.


To avoid this action, organisations are required to complete the following compliance procedures;

  1. Measure and report energy use for a continuous 12-month period (overlapping the qualification date of 31 December 2018), to include energy consumed by buildings, industrial processes and transportation activities
  2. Identify your areas of significant energy consumption. ESOS assessments must be completed to cover at least 90% of an organisation’s total energy consumption
  3. Appoint a Lead Assessor to carry out, oversee or review your energy audits and overall ESOS assessment
  4. Undertake energy assessments for your areas of significant energy consumption using one or more of the following approved routes:
    • ESOS Energy audits
    • Display energy certificates
    • An ISO 50001 Energy Management System
  5. Report compliance to the National Scheme administrator – the environmental agency in England, SEPA in Scotland, NIEA in Northern Ireland and NRW in Wales and store your records of assessment.

Don’t forget to take advantage of the energy saving opportunities identified – EVORA identified £2.8M of energy savings in Phase 1 of ESOS.

With our expertise and data management solution SIERA, we can implement energy efficiency programmes, leading to substantial reductions in energy usage and associated costs. Our energy management team typically find quick win energy savings with payback in less than a year. Read more here on how ESOS can be a long-term investment to your business.


EVORA employs qualified Lead assessors and can support you to develop a practical compliance strategy that is appropriate for your organisation.  To ensure you fully comply with ESOS Phase 2, we offer a range of practical solutions. Find out more in our ESOS Compliance Guide .

ESOS Phase 2 Practical Hints and Tips

This post follows on from the article that my colleague, Neil Dady wrote, ‘ESOS Phase 2 – It’s time to start planning‘ which provides a clear overview of requirements and further detail is available online. I’m not going to go over old ground but instead, I set out a few ESOS Phase 2 practical hints and tips.


Don’t forget the purpose – identify energy saving opportunities

ESOS was developed to help businesses identify energy saving opportunities.  Legislation often gets a bad press, however, the principles here are laudable.  A strategy that identifies savings, then importantly, acts to implement them (something missing in the legislation and a step that is up to the participants) can only be a good thing.  Reducing energy consumption has many benefits:

  • Lowered costs
  • Reduced carbon footprint
  • Improved corporate responsibility
  • The ability to wrap up into tenant engagement programmes

[clickToTweet tweet=”A strategy that identifies savings, then acts to implement them, can only be a good thing” quote=”A strategy that identifies savings, then importantly, acts to implement them (something missing in the legislation and a step that is up to the participants) can only be a good thing.”]


ISO 50001 – a structured approach to understanding and improving energy performance

If you want to get ISO 50001 up and running, start now.

The international standard for energy management, provides a structured approach to understanding and improving energy performance, however, implementation cannot be rushed through. As Neil highlights in his recent blog, organisations that wish to use ISO 50001 as the compliance route should start work now.

As many will know, organisations with ISO 50001 do not have to complete audits, however, it is a mistake to think that this simplifies matters.  ISO 50001 is not an easy way forward.  It requires completion of a baseline assessment and the establishment of objectives for improvement.  As a result, organisations that operate ISO 50001 management system will have also completed audits in some format.

As many will know, organisations with ISO 50001 do not have to complete audits, however, it is a mistake to think that this simplifies matters.

Those in real estate should also note that ISO 50001 does not count towards GRESB points, whereas ISO 14001 certification does.  Although this is something we are lobbying GRESB on, I can understand the reasoning.  GRESB is a sustainability benchmarking scheme, ISO 14001 requires consideration of all significant environmental issues, whereas ISO 50001 is focused on energy only.


Audits for compliance – beware of changing portfolios

Obligated organisations must assess energy consumption over 12 months, which must include the qualification date of 31 December 2018.  90% of energy identified must then be assessed.  As a result, auditing assets now, solely to comply with ESOS, would be a waste of time if the assets were then sold before the qualification date.


Audit anyway – the savings start to add up

Despite the above point, audits will still identify improvement opportunities that reduce energy consumption.  Subject to wider asset management plans (redevelopment, sale etc), I would recommend that audits are completed on all assets with an energy spend of over £200,000 per year – irrespective of ESOS obligations. Our audit team typically find quick win savings of 5% and often more (5% on a £200,000 spend per year equates to £10,000 – with a typical payback of less than a year).  Apply these principles to a portfolio of 10 assets and the savings start to add up significantly.

[clickToTweet tweet=”We typically find quick win savings of 5% or more. Apply this to 10 assets and the savings add up” quote=”Our audit team typically find quick win savings of 5% and often more (5% on a £200,000 spend per year equates to £10,000 – with a typical payback of less than a year).”]


EVORA employs a team of Energy Auditors and ESOS Lead Assessors.  For further information, do not hesitate to call or email.