ESOS Phase 2 Compliance

Achieve ESOS Phase 2 Compliance
If your business needs to be ESOS Phase 2 compliant then we can help, identifying energy saving opportunities and helping to delivering performance upgrades for your business.
Act now to comply with ESOS Phase 2
At amber energy, we can help your business to maximise savings and make the most of ESOS Phase 2.
Achieve ESOS Phase 2
Beat the December 2019 deadline for ESOS by booking in a date with our ESOS Lead Assessors.
We have seen a huge increase in the number of businesses looking for an audit, so act now to ensure your business needs are covered.

ESOS Phase 2 FAQ
What is ESOS?
The energy savings opportunity scheme or ESOS, is a mandatory government initiative to promote energy efficiency in large businesses.
Does my business need to comply?
Or a turnover of €50 million and an annual balance sheet more than €43million.
Or is part of a larger organisation which meets the above criteria.
What exactly is ESOS compliance?
Essentially, ESOS compliance is a measurement of your total energy consumption, combined with audits that look into your energy efficiency (delivered by an accredited ESOS lead assessor), which is fed back in a standardised report to your national scheme administrator.

Understanding ESOS Phase 2: What’s Changed and Why It Matters
ESOS Phase 2 builds on the foundations of Phase 1, but with tightened requirements and a renewed focus on tangible energy savings. While the core obligation remains – identifying energy efficiency opportunities through audits – Phase 2 places greater emphasis on the quality of data, the scope of assessment, and the credibility of the evidence you submit. The deadline for compliance is 5 December 2019, and the compliance period covers energy data from the 12-month reference period ending on 31 December 2018. Organisations that qualified for Phase 1 are likely to qualify again, but the criteria have been clarified: if your organisation (or any part of a corporate group) has 250 or more employees, or an annual turnover exceeding €50 million and an annual balance sheet total exceeding €43 million, you are in scope.
One of the most significant shifts in Phase 2 is the increased scrutiny from the Environment Agency and other UK regulators. They are no longer accepting superficial audits or incomplete data. Enforcement action, including fines and public naming, has become a real risk for non-compliant businesses. Beyond the regulatory stick, there is a compelling carrot: ESOS audits consistently reveal savings opportunities of 5–15% of total energy spend. For a large industrial or commercial organisation, that can translate into hundreds of thousands of pounds per year. Acting early not only secures compliance but also unlocks these savings sooner.
At amber energy, we have been guiding businesses through ESOS since its inception. Our team of accredited Lead Assessors understands the nuances of Phase 2, from the requirement to cover at least 90% of your total energy consumption to the need for a board-level director to sign off the compliance notification. We combine technical rigour with practical, actionable recommendations that align with your business goals.
How the ESOS Phase 2 Process Works: A Step-by-Step Guide
ESOS compliance is a structured process that demands careful planning and execution. Here is how we approach it at amber energy:
- Scoping and qualification: We first confirm whether your organisation falls within the ESOS criteria. This includes assessing corporate group structures, as the rules apply at the highest UK parent level. If you are part of a larger group, the entire group’s energy consumption must be considered.
- Data collection and energy profiling: We gather 12 months of energy data across all sites, fuels, and transport. This includes electricity, gas, oil, and any other fuels, as well as fleet fuel use. We compile a comprehensive energy profile, identifying the significant energy consumption areas.
- Audit and site assessments: Our ESOS Lead Assessors conduct audits covering at least 90% of your total energy consumption. This may involve site visits, interviews with key personnel, and analysis of building and process energy use. We use a range of techniques, from energy surveys to data analytics, to identify inefficiencies.
- Identifying energy saving opportunities: We quantify and prioritise opportunities, estimating costs, savings, and payback periods. These may include lighting upgrades, HVAC optimisation, process improvements, or behavioural change programmes.
- Reporting and compliance notification: We prepare a comprehensive ESOS report and support you in submitting the compliance notification to the Environment Agency (or appropriate regulator) by the deadline. We ensure all evidence is robust and audit-ready.
- Implementation support (optional): Beyond compliance, we can help you implement the identified measures, leveraging our energy procurement and project management expertise to deliver real savings.

This process can take several months, especially for complex organisations. Starting early is critical to avoid last-minute pressure and to ensure a quality outcome. Many businesses underestimate the effort required to gather accurate data from multiple sites and subsidiaries.
Common Pitfalls and How to Avoid Them in ESOS Phase 2
Phase 1 saw a number of common mistakes that led to non-compliance or poor-quality submissions. Phase 2 is your chance to get it right. Here are the pitfalls we see most often:
- Incomplete data: Failing to capture all energy sources, including transport, or missing data from certain sites. This can lead to an audit that covers less than 90% of consumption, which is a direct breach.
- Relying on display energy certificates (DECs) or green deal assessments alone: While these can contribute, they are not a substitute for a full ESOS audit unless they meet specific criteria and are approved by a Lead Assessor.
- Lack of board-level engagement: ESOS requires a director to sign off the notification. If the board is not engaged, the process can stall, and the quality of the submission may suffer.
- Treating it as a tick-box exercise: The real value of ESOS is in the savings identified. Organisations that view it purely as a compliance burden miss out on significant cost reductions.
- Using unaccredited assessors: Only a registered ESOS Lead Assessor can conduct the audit and sign off the report. Using an unaccredited consultant can invalidate your compliance.
At amber energy, we mitigate these risks through a rigorous project management approach. We use our data analytics capabilities to ensure data completeness and accuracy, and we engage with your leadership team early to secure buy-in. Our Lead Assessors are fully accredited and experienced across a wide range of sectors.
Maximising Value from ESOS: Turning Compliance into Cost Savings
ESOS is not just a regulatory hurdle; it is a strategic opportunity to reduce operating costs and improve competitiveness. The audits we conduct often uncover savings that go far beyond the obvious. For example, a manufacturing client discovered that compressed air leaks were costing them over £50,000 per year in wasted electricity. Another retail chain identified that a simple change in HVAC control settings across their estate could save 8% on gas consumption with no capital investment.
To maximise value, we recommend integrating ESOS findings with your broader energy management strategy. This could involve:
- Prioritising no-cost and low-cost measures: Many opportunities, such as adjusting set points, fixing leaks, or improving maintenance schedules, require minimal investment and deliver immediate savings.
- Developing a capital investment plan: For larger projects, we can help you build a business case and access funding options, including energy performance contracts.
- Engaging employees: Behavioural change programmes can yield 5–10% savings in many organisations. We can design and deliver training and awareness campaigns.
- Monitoring and verification: Using our energy bureau service, we can track consumption post-implementation to verify savings and identify further opportunities.
By treating ESOS as a catalyst for continuous improvement, you can create a culture of energy efficiency that pays dividends year after year. Our team can support you from audit to implementation, ensuring that the recommendations don’t sit on a shelf.
Why Choose amber energy for ESOS Phase 2 Compliance?
With the December 2019 deadline approaching, choosing the right partner is critical. amber energy brings a unique combination of technical expertise, practical experience, and a commercial mindset. Here’s what sets us apart:
- Accredited Lead Assessors: Our assessors are registered with a professional body and have extensive experience across industrial, commercial, and public sector organisations.
- Data-driven approach: We leverage advanced data analytics to ensure your energy profile is accurate and comprehensive, reducing the risk of compliance gaps.
- End-to-end support: From initial scoping to final submission, and beyond into implementation, we are with you every step of the way.
- Integration with energy procurement: As experts in energy procurement and risk management, we can align your ESOS findings with your energy buying strategy to maximise savings.
- Proven track record: We have helped numerous organisations achieve compliance and realise significant cost reductions.
Don’t wait until the last minute. The sooner you start, the more time you have to conduct a thorough audit and implement savings. Contact our team today to book your ESOS Phase 2 assessment and turn compliance into a competitive advantage.
Frequently Asked Questions: ESOS Phase 2 Specifics
What is the deadline for ESOS Phase 2 compliance?
The compliance deadline is 5 December 2019. You must submit your notification of compliance to the Environment Agency (or your national regulator) by this date. The qualification date is 31 December 2018, meaning your organisation must meet the criteria on that date.
What energy data do I need to collect?
You need to collect 12 months of verifiable energy data covering all energy used by your organisation, including electricity, gas, oil, solid fuels, and transport fuels. The data must cover a continuous 12-month period that includes the qualification date (31 December 2018). This data forms the basis of your energy profile and determines the scope of your audits.
Can I use ISO 50001 certification to comply with ESOS?
Yes, if your organisation has a certified ISO 50001 energy management system that covers all your significant energy consumption, you may be deemed compliant without the need for a separate ESOS audit. However, the certification must be issued by an accredited body and cover the entire organisation. Many businesses still choose to conduct an ESOS audit to identify additional savings.
What happens if I miss the deadline or fail to comply?
Non-compliance can result in significant penalties. The Environment Agency can issue enforcement notices, impose fines (up to £50,000 for certain breaches), and publish details of non-compliant organisations. In addition, you may be required to undertake remedial action. The reputational damage can be substantial. It is far better to comply on time.
How much does ESOS compliance cost?
The cost varies depending on the size and complexity of your organisation, the number of sites, and the quality of your existing energy data. At amber energy, we offer competitive pricing and can tailor our services to your needs. The cost of compliance is often outweighed by the savings identified in the audit.
