ESOS – The Challenges Last Time

I am Lead ESOS Assessor and was very busy during the first round of ESOS (the Energy Savings Opportunity Scheme legislation). Some of my clients started nice & early, but many came to me very late so I had to work extra hard to get everything done for them in time.

Indeed, many companies only started to look at ESOS a couple of months before the deadline, so there was a huge rush and a lot of frayed nerves.

Apart from the lack of assessors & short timescales, I noticed trends from ESOS Phase 1. I’m sharing these now, so that hopefully Phase 2 can run more smoothly for you.

These are the sorts of challenges I saw:

Company structure – this could be a problem, particularly for large groups with complicated ownership structures. Find all the companies in a group, the company registration numbers, all the sites, who is the Board member to sign off.

Missed companies – although ESOS requires large undertakings to participate, small companies within a larger group may also need to be included. These can fall off the radar.

Audits or ISO 50001 – some companies wanted to put in an Energy Management System (EnMS) to ISO 50001, but just didn’t have time. An EnMS needs time to run before certification, plus there are limited certification bodies for this standard.

Good quality data – finding the information was quite tricky & co-ordinating the data collection processes needs attention. Additionally, data should be verified to ensure it is accurate. It’s not enough to simply provide a total figure – need more detail to allow consumption patterns to be understood & anomalies explained.

Transport data – many of my ESOS clients were Energy Managers; they could find energy consumption data OK, but the transport data was more tricky. The expenses system may hold business mileage, but other issues like fuel cards & hire car records were a challenge. Either way, getting colleagues to retrieve & present the data in time required negotiation!

Sample of sites – it is not necessary to audit every single site, especially if there are similarities. Sampling is allowed (particularly useful if there was not enough time to do them all), however this means that you miss anomalies or nuances.

Director signing off – it is a requirement that the ESOS findings are signed off by a board level director; this often slowed the whole ESOS project down or even stalled it. Getting time in the diary of a busy director was a challenge, for them to review the assessment, understand the findings & sign off to confirm compliance. They also need to understand their responsibilities.

Time challenges for late starters – many companies didn’t get started soon enough & there was a lot of angst as the deadline approached. Starting Phase 2 nice & early, planning the project & getting everyone on-board, will help next time.


The Environment Agency is now investigating cases from ESOS Phase 1 and has already served over 300 Enforcement Notices on organisations that are particularly breaching the rules.

Additionally the EA is auditing a sample of participants to check they are fully meeting the requirements. The majority of participants were deemed to be compliant or compliant with remedial actions (although some have also received Enforcement Notices). Typical areas where remedial actions are required include:

  • Organisational Structure
  • Sampling approach to deciding which & how many sites to audit
  • Identification of energy saving opportunities & cost benefit analysis
  • Extrapolation of energy savings to non-visited sites

So do think about these issues to help ensure your ESOS Phase 2 projects go smoothly. Even better speak to me first!

More info on ESOS can be found here.



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