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Energy Savings Opportunity Scheme (ESOS)

Government was consulting on proposed changes to improve and strengthen ESOS, following a review in 2020. The scheme is for the largest companies to measure and report their energy usage, and it is intended to provide the information to inform and motivate them to take action to reduce their energy usage and associated emissions.

The consultation sought views on proposals to strengthen the Scheme to improve uptake of energy efficiency measures and increase benefits for participating businesses, in particular:

  • improving quality of audits through increased standardisation of reporting requirements
  • inclusion of a net zero element in audits
  • requiring public disclosure of high-level recommendations

BEIS also sought views and evidence on two additional improvements in the longer term:

  • extending the scope of the scheme to include medium sized businesses
  • mandating action on audit recommendations

To access the consultation and the accompanying impact assessment document go to

The consultation closed on 28 Septemebr 2021.

CIBSE response

CIBSE welcome the proposals, including:

  • Building the proposals on evaluation of what has been achieved with previous ESOS phases.
  • Extension of the scheme to medium enterprises.
  • Improving the quality of audits and reports.
  • The intent to better encourage action that leads to measurable emissions reductions.
  • The statement that ESOS proposals will be developed in coherence with operational ratings and other relevant policies.
  • New proposals for ESOS to drive decarbonisation, as well as energy efficiency.

We think that more proposals are required to drive action, including through support for competition and market-driven action (e.g. a league table) but also, ultimately, regulations. This may not be regulation to implement ESOS recommendations, but (our preference) to achieve certain levels of energy and carbon performance.

Whilst we recognise that regulation should not be adopted where a voluntary scheme could offer similar benefits, experience over the past four decades has shown that where there is a clear need for action then a voluntary scheme acts as a tax or burden on the law abiding and is evaded by the least compliant. The only way to avoid this is to regulate and then to enforce.

To read the CIBSE response, follow the link below:

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