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Last updated October 2026.
What an action plan is
Action plans were introduced for Phase 3 to close the gap between assessment and action. Having audited its energy use, a participant must now publish a plan stating which of the identified measures it intends to implement over the following four years, which it does not, and the energy savings it expects. The plan is submitted through the regulator’s system and made public, and each year the organisation reports progress against it.
An organisation is allowed to say it intends to implement nothing. That is a legitimate plan, and some have filed it. The point is that the decision is now visible, which changes the conversation at board level in a way that a filed audit never did.
What the plan has to contain
| Element | What is required |
|---|---|
| Measures to be implemented | Which recommendations from the assessment the organisation intends to carry out, and when, across the four years of the phase. |
| Measures not being implemented | Recommendations the organisation has decided against, with the reasons. |
| Estimated savings | Expected energy savings from the planned measures, in kWh, with the basis of the estimate. |
| Reference to the assessment | How the measures relate to the audit findings and which compliance routes they came from. |
| Director approval | The plan is approved and signed at board level, as the assessment was. |
Progress updates are shorter: each year the organisation reports which measures have been completed, the savings achieved where measured, and any changes to the plan. The updates are also public. An organisation that planned ten measures and completed none has to say so, in writing, annually.
Talk it through with us
Send us a recent bill or a quick description of your sites and we will tell you plainly what applies to you and what it would involve. No obligation.
How to write a plan you can live with
The temptation after an audit is to list every recommendation as an intention, because it looks ambitious and avoids the awkwardness of saying no. It is the wrong instinct. Four years of progress updates against an over-committed plan is a slow public admission that the plan was never real.
Frequently asked questions
Is an ESOS action plan compulsory?
Yes, since Phase 3. Every participant must publish an action plan after notifying compliance and report progress against it annually.
Can an ESOS action plan say we will implement nothing?
Yes. The plan must state intentions and reasons, and an intention to implement none of the recommendations is permitted. It is public, which is the point.
Who sees an ESOS action plan?
It is submitted to the regulator and published, so customers, investors and staff can read it alongside the annual progress updates.
What is in an ESOS progress update?
Which planned measures have been completed, the savings achieved where measured, and any changes to the plan. Updates are annual and public.
Does the action plan need a lead assessor?
The assessment does; the action plan is the organisation’s own statement, approved at board level. Many organisations ask their assessor to help shape it because they know the findings.
What happens if we do not deliver the action plan?
There is no penalty for failing to implement measures, only for failing to publish the plan and updates. The consequence of non-delivery is reputational, in public, every year.
Need help? Get in touch
Call us on 020 8036 5715, or email us, and we will take it from there.