Find out if ESOS Phase 4 and SECR apply to your organisation
Your size decides whether you need an ESOS assessment by December 2027, and whether your annual report must include SECR energy and carbon disclosures. Answer 8 quick questions to see where you stand on both schemes, and what to do next.
Check your status
The Phase 4 track
- 5 Dec 2026Next upPhase 3 action plan progress update
- 31 Dec 2026Next upQualification date
- 5 Dec 2027Next upCompliance deadline
- 5 Dec 2028Next upAction plan due
Qualification date
31 December 2026
The qualification date has passed. Your size on 31 December 2026 now decides whether you must comply.
Compliance deadline
5 December 2027
The Phase 4 compliance deadline has passed. If you qualified and haven't notified, contact the Environment Agency as soon as possible.
Took part in ESOS Phase 3? Your action plan progress update is due by 5 December 2026.
Find your company
Search Companies House and we'll fill in what we can. This is optional, and you can skip it.
Which best describes your organisation?
Choose the legal form of the organisation you're checking.
Is your organisation part of a corporate group?
A group means a parent company and its subsidiaries, as defined by the Companies Act.
Does any other UK company in your group have 250 or more employees, or turnover above £44m together with a balance sheet above £38m?
How big is your organisation?
Use your accounts for the financial year ending on, or in the 12 months before, 31 December 2026. If you don't have a figure to hand, tick "Not sure".
Include part-time staff, owners, managers and partners. Staff employed directly by a UK company but based abroad also count.
This is your total gross assets, before any liabilities are deducted.
ESOS large undertaking test
Enter your figures to see how they compare.
Has your size been stable over your last 2 financial years?
Both schemes only change your status once you've been above or below the thresholds for 2 consecutive accounting periods.
How much energy does your organisation use in a year?
Add together electricity, gas, other fuels and fuel used in company vehicles. Your supplier statements show annual kWh.
How many sites do you operate in the UK?
Count offices, factories, warehouses, stores, venues and any other premises you run.
Did your organisation take part in ESOS Phase 3?
Phase 3 had a qualification date of 31 December 2022 and required an action plan.
Do you hold ISO 50001 certification?
ISO 50001 is the international standard for energy management systems.
What ESOS Phase 4 asks of you before December 2027
If you qualify, you'll need 12 months of verifiable energy data, an audit or ISO 50001 cover for at least 95% of your energy use, and a board director's sign off before you notify the Environment Agency.
Measure everything you use
Your total energy consumption covers buildings, industrial processes and transport, measured over a 12 month reference period that includes 31 December 2026.
Show what happened to your last action plan
New for Phase 4, your assessment must report progress against your Phase 3 action plan commitments and explain any you didn't deliver.
Fewer shortcuts to compliance
Display Energy Certificates and Green Deal Assessments no longer count as compliance routes, so more of your estate needs a proper energy audit or ISO 50001 cover.
How ESOS and SECR differ
Many organisations fall under both schemes, but they ask for different things on different timescales.
| ESOS Phase 4 | SECR | |
|---|---|---|
| Who is in scope | 250 or more employees, or turnover above £44m together with a balance sheet above £38m. If one UK company in a group qualifies, the whole UK group is in. | UK companies and LLPs exceeding 2 of these 3: more than 250 employees, turnover above £36m, balance sheet above £18m. All UK quoted companies are in, whatever their size. |
| What you have to do | Audit at least 95% of your energy use, get a board director to sign it off and notify the Environment Agency. | Publish your energy use, Scope 1 and 2 emissions, an intensity ratio and your efficiency actions in your directors' report. |
| How often | Every 4 years | Every financial year |
| Next deadline | 5 December 2027 | With your next annual report |
Turning your ESOS findings into savings you can evidence
An ESOS assessment tells you where you could save energy. We deliver the measures that make those savings real, and give you the metered data to prove it when you next report progress.
Pulse Energy Management System
Live, site level energy data that supports your consumption figures, intensity ratios and SECR disclosures, with IPMVP verified savings you can show your board and the regulator.
Measures your audit is likely to flag
Voltage optimisation, KBR Energy Saver for refrigeration and commercial solar PV, all delivered by our own teams rather than subcontractors.
Evidence for your action plan
Measured before and after results for every measure we install, so the progress you report against your action plan stands up to scrutiny.
ESOS Phase 4 and SECR questions
When is the ESOS Phase 4 deadline?
If your organisation qualifies on the Phase 4 qualification date of 31 December 2026, you must submit your notification of compliance to the Environment Agency through MESOS by 5 December 2027. An action plan is then due by 5 December 2028.
Who qualifies for ESOS Phase 4?
ESOS applies to large UK undertakings and their corporate groups. A large undertaking employs 250 or more people, or has an annual turnover above £44 million together with an annual balance sheet total above £38 million. If any UK undertaking in your group is large, your entire UK group must take part. Public bodies are generally excluded. Read the full ESOS Phase 4 guidance on GOV.UK.
What has changed in Phase 4?
Display Energy Certificates and Green Deal Assessments can no longer be used as compliance routes. Your assessment must also report progress against your Phase 3 action plan commitments and explain any that weren't met.
What are the penalties for not complying?
The Environment Agency can issue civil penalties, including up to £50,000 for failing to undertake an ESOS assessment and up to £5,000 for failing to notify, plus up to £500 for each working day the breach continues, capped at 80 working days. It can also publish details of the non-compliance.
Is SECR the same as ESOS?
No. SECR is an annual disclosure of your energy use, emissions and efficiency actions in your directors' report, while ESOS is an assessment carried out every 4 years. Many organisations fall under both, and the same energy data can support each. The government's environmental reporting guidelines set out exactly what SECR requires.
Did the April 2025 company size changes take us out of SECR?
Probably not. The Companies Act size thresholds rose on 6 April 2025, but SECR kept its own tests. An unquoted company is in scope if it exceeds 2 of these 3: more than 250 employees, turnover above £36 million and a balance sheet above £18 million. You can be medium-sized for your accounts and still have to report under SECR.
Not sure where you stand on 31 December?
The checker takes 2 minutes and tells you whether ESOS and SECR apply to you, with the dates that matter for your organisation.
Start the checker
This checker is a guide based on Environment Agency and DESNZ guidance published up to September 2026. It isn't legal advice, and borderline cases, complex group structures and public body status should be confirmed with the Environment Agency ESOS helpdesk or your advisers.
Walk Into Your ESOS Assessment With Savings to Show.
Your assessment will measure how much energy you use, and your report will show what you've done about it. We help you get both in order before your lead assessor arrives, with metered data from every site and savings you can prove.
- Metered energy data by site, covering your 12 month reference period
- Consumption broken down so your assessor can calculate intensity ratios
- Savings measures installed before your assessment, not just listed in it
- Every saving verified to IPMVP, so your progress stands up to scrutiny
Powerhub energy team
Energy data and savings
Your lead assessor carries out the ESOS assessment, and we make sure you're ready for it. We'll look at your sites and bills, show you where your data has gaps, and cost the measures that would make the biggest difference to your report.
- A clear view of any gaps in your energy data
- A costed plan of savings you can deliver before your assessment
- 30 minutes, no obligation, no sales script
