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ESOS phase 4: who must comply and where solar fits

ESOS is a mandatory energy assessment for large UK undertakings, every 4 years. For phase 4, you qualify if on 31 December 2026 the organisation employs 250 or more people, or has turnover above £44 million and a balance sheet above £38 million. The notification of compliance is due by 5 December 2027. Solar is not a compliance route, but it is one of the measures an audit can lead to. Checked on GOV.UK on 2 November 2026.

Updated 3 minute read

What ESOS is and who must comply

GOV.UK describes ESOS as "a mandatory energy assessment scheme for organisations in the UK that meet the qualification criteria". It applies to large UK undertakings and their corporate groups, mainly businesses, but also not-for-profit bodies large enough to qualify (GOV.UK).

ESOS phase 4 qualification, from GOV.UK (checked 2 November 2026)

Test Rule
Qualification date 31 December 2026
Large undertaking A UK company employing 250 or more people, or with turnover above £44 million and balance sheet total above £38 million
Groups A corporate group qualifies if at least one UK member is a large undertaking
Overseas companies UK registered establishments take part if their global group's UK activities qualify
Public sector Usually does not need to comply
Notification deadline 5 December 2027

Phase 4 dates and duties

  • Total energy consumption: Calculate the energy used by buildings, industrial processes and transport
  • Significant energy consumption: Identify the areas covering at least 95% of the total, to be audited
  • Energy intensity ratios: For buildings, transport, industrial processes and other uses
  • Route to compliance: An energy audit or ISO 50001 certification; DECs and Green Deal assessments no longer count
  • Lead assessor: Sign-off by an ESOS lead assessor, unless an exemption applies
  • Audit data: Verifiable consumption over a 12-month period beginning no earlier than 6 December 2022
  • Board sign-off: By one board level director, then notify through the online system
  • Action plans: Progress against action plan commitments must be included, with reasons where they weren't met

Source: GOV.UK. The regulator can issue civil sanctions, including financial penalties, where an organisation does not meet its obligations. Phase 3 participants also owe an annual progress update on their action plan by 5 December 2026.

What an ESOS audit recommends

An ESOS audit looks at where the organisation uses energy and identifies energy saving opportunities. The notification records the opportunities identified, and the scheme administrator publishes most of the information in it (GOV.UK). For a building with a large daytime electricity load and a suitable roof, on-site solar is one of the measures that can come up, alongside lighting, controls, heating and process efficiency. Phase 4 also lets participants include net zero considerations voluntarily, using the PAS 51215-1 and -2:2025 standards.

Acting on solar recommendations

If your audit points to solar, the next step is a site survey for each building that matters: the roof, the electricity supply, the network operator's limits and how much of the output the site will use. A survey turns a recommendation into a costed proposal your board can approve, and into progress you can report.

  • Start with the biggest daytime users: Sites with the largest daytime electricity load usually give the best return
  • Use your audit data: The same 12 months of consumption data sizes the system: see half-hourly data
  • Check the paperwork: Leases, planning and the network operator, before committing
  • Consider how to pay: Buying outright, finance, or a PPA with no upfront cost

See half-hourly data, solar PPAs, SECR and scope 2 emissions and choosing an installer.

Note: General information from GOV.UK, not compliance advice. Your ESOS lead assessor confirms what applies to you.

Sources

GOV.UK's ESOS page (updated 2 September 2026 for phase 4) was read on 2 November 2026. The full rules are in the ESOS Regulations 2014 as amended in 2026 and the phase 4 compliance guidance linked from it.

Frequently asked questions

What is ESOS?

The Energy Savings Opportunity Scheme: a mandatory energy assessment for large UK undertakings and their corporate groups. GOV.UK says qualifying organisations must carry out an assessment every 4 years, including an audit of the energy used by their buildings, industrial processes and transport.

Who has to comply with ESOS phase 4?

An organisation qualifies if, on 31 December 2026, it meets the ESOS definition of a large undertaking: a UK company that employs 250 or more people, or has an annual turnover above £44 million and an annual balance sheet total above £38 million. Corporate groups qualify if at least one UK group member is a large undertaking. Public sector organisations usually don't need to comply.

What is the ESOS phase 4 deadline?

GOV.UK says the deadline for submitting a notification of compliance for phase 4 is 5 December 2027. Phase 3 participants also have an annual progress update on their action plan due by 5 December 2026.

What changed for ESOS phase 4?

Display Energy Certificates and Green Deal assessments can no longer be used as compliance routes; progress against action plan commitments must be included in the assessment, with an explanation where commitments have not been met. Participants can also voluntarily include net zero considerations using the PAS 51215-1 and -2:2025 standards.

Does installing solar count towards ESOS?

Solar is not a route to compliance: you still need the assessment. But an ESOS audit identifies energy saving opportunities, and on-site generation is a measure many organisations consider alongside efficiency. Acting on the opportunities, and reporting progress against an action plan, is what phase 4 asks about.

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See what your business could qualify for

Find out which grants, tax relief (capital allowances) and finance options your business may qualify for, and roughly what solar could save. It comes from a free call with us and a free survey with one MCS certified installer.

Tell us about the site in under two minutes. We review every enquiry, call you to understand the building and your electricity use, and if the site looks suitable we arrange a free survey with one MCS certified installer matched to it. We match you with one of 130+ MCS certified installers across the UK, and only those who pass our checks.

  • On site or by video callWhichever suits the project and its stage.
  • Roof, structure, grid and energy useThe four things that decide whether solar works.
  • A clear proposalSystem size, cost range, savings and payback for your board.
  • One installer onlyYour details are not passed around a list of companies.

Want the detail first? Read how a survey works and what the survey includes.

See what your business could qualify for

Grants, tax relief and finance your business may qualify for, and roughly what solar could save. Six quick questions.

Step 1 of 7
Question 1 of 6: What kind of site is it?
Question 2 of 6: Do you own the building, or is it leased?
Question 3 of 6: Roughly what do you spend on electricity a month?
Question 4 of 6: Is this your first time looking into solar?
Question 5 of 6: When are you hoping to go ahead?
Question 6 of 6: What kind of survey would you like?
Where is the site, and who should we ask for?

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