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Who needs to comply with ESOS Phase 4?
The Energy Savings Opportunity Scheme (ESOS) Phase 4 applies to large UK undertakings as at the qualification date of 31 December 2026, with compliance due by 5 December 2027.
An organisation qualifies for ESOS Phase 4 if, on the qualification date, it:
- Employs 250 or more people in the UK, OR
- Has an annual turnover above £44 million AND a balance sheet above £38 million, OR
- Is part of a corporate group where another UK undertaking meets either threshold.
Public bodies and registered charities are generally excluded unless they meet the threshold tests in their own right.
What qualifying organisations must do:
- Audit their total energy consumption (buildings, transport, processes) covering at least a 12-month reference period.
- Identify energy-saving opportunities with payback periods, costs, and savings.
- Have the assessment signed off by a board-level director.
- Submit a compliance notification to the Environment Agency by 5 December 2027.
If your organisation crossed the threshold during 2025 or 2026, you are likely in scope for the first time. Vital Direct can scope and deliver ESOS Phase 4 assessments. Contact Vital Direct to discuss.
