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ESOS Phase 4 Made Simple: What Food, Pharma & Retail Businesses Need to Know

13 August 2025

What Is ESOS Phase 4, and Why Should You Care?

The Energy Savings Opportunity Scheme (ESOS) is a government programme that asks big UK businesses to take a proper look at how much energy they’re using and figure out how to use less. It’s all about finding smart ways to cut energy waste, save money, and reduce emissions.

We’re now in Phase 4, which officially kicked off on 6 December 2023 if your business uses a lot of energy, this one’s especially important.

You’ll need to submit your official compliance report by 5 December 2027. Sounds like ages away, but with audits, data collection and planning involved, the sooner you start, the easier it’ll be.

Official ESOS guidance from GOV.UK →

Who Needs to Get Involved in ESOS Phase 4

Your business will need to take part if, on 31 December 2026, you have:

  • 250 or more employees, or
  • A turnover of more than £44 million and a balance sheet over £38 million

If that sounds like you, it’s time to get ready. Especially if your operations rely on energy-hungry systems like cooling, heating, processing, or logistics.

What You’ll Need to Do

Confirm if you qualify

Check your headcount and finances as of 31 December 2026.

You’ll need to cover at least 95% of your energy consumption—from buildings to vehicles to manufacturing.

Get your energy use audited

You’ll need to cover at least 95% of your energy consumption—from buildings to vehicles to manufacturing.

Create an Action Plan

This needs to outline realistic steps your business can take to save energy. Your board has to sign it off, and you’ll need to show progress later.

Submit updates

Annual progress updates will be needed in December 2025 and December 2026. You’ll need to explain what you’ve done and why if something hasn’t happened.

Submit your final report

Everything needs to be wrapped up and submitted by 5 December 2027.

Heads up: DECs and GDAs (energy certificates some businesses have used in the past) no longer count. And while mandatory net zero planning won’t kick in until the next phase (Phase 5), it’s a good time to get ahead.

Why It Pays to Start Now

Even though the deadline is in 2027, starting early can save you a serious headache later on:

  • Lead assessors get booked up fast especially close to the deadline
  • Collecting all your energy data can take time, especially across multiple sites or systems
  • Implementing real change takes planning, especially when progress reporting is required

How Emissis Can Help

At Emissis, we’re all about making energy efficiency simple and valuable. We’ve worked with food producers, pharmaceutical firms, retailers, you name it. We can help you:

  • Carry out energy audits (and explain the findings in plain English)
  • Put together a practical Action Plan
  • Help track your energy usage
  • Offer advice on voluntary net zero reporting (if you want to get ahead of Phase 5)

Whether you’ve been through ESOS before or it’s all new to you, we’ll help make the process stress-free and valuable.

Let’s talk about how we can help you get ready for Phase 4 — Get in touch today

Quick Recap

  • ESOS Phase 4 is live and runs through to 5 December 2027
  • It applies to big organisations with 250+ staff or high turnover
  • You’ll need an energy audit, Action Plan, progress updates, and a final compliance report
  • Changes from last time: new reporting standards, no more DECs/GDAs, and more accountability
  • Emissis can help make the process smooth and turn it into a chance to cut costs and boost sustainability

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