Feb 26, 2026

ESOS PHASE 4 PLANNING: WHAT YOU SHOULD DO IN 2026

ESOS phase 4 The official deadline for ESOS Phase 4 compliance is 5 December 2027 and we have covered what this means for 2026 in previous blogs. The blog covered late ESOS phase 3 submissions, action plans and progress updates.

This blog is about specific updates for ESOS phase 4. It is difficult to know exactly what the changes are because formal guidance has not been issued. But Government consultations and announcements do give some clues as to what to expect.

ESOS reporting 2026

NEW ITEMS FOR ESOS PHASE 4

According to the Government website, the following changes are intended to apply to Phase 4, subject to parliamentary time and scrutiny:

· Removal of Display Energy Certificates DECs and Green Deal Assessments GDAs as compliance routes the rationale is “concerns of the Environment Agency that using these compliance routes alone do not meet ESOS best practice standards, we will be removing DECs and GDAs as compliance routes for ESOS in Phase 4”

· Progress against Action Plan commitments to be included in the ESOS assessment this means that as part of an ESOS assessment will involve looking at previous action plans that: “Progress against targets and action plans between from one phase to the next should also form part of ESOS assessments.”

· Net zero assessments will not be part of phase 4, but will form part of phase 5 nevertheless participants can do this voluntarily and good environmental consultancies such as SHIFT Environment can do this as a separate project to ESOS

START ENERGY AUDITS IN 2026

If you want to get ahead of the curve, 2026 is the ideal time to start site energy audits. There are provisions within the formal guidance that allow for site audits to be conducted before the qualification date. Doing so:

· Reduces pressure as the compliance deadline approaches

· Identifies cost effective energy saving measures sooner

· Allows you to implement changes earlier and start saving earlier

In practice, we typically identify energy savings worth at least three times our fee, making audits a commercial opportunity rather than just a compliance exercise.

MAKING PHASE 4 PAINLESS AND VALUABLE

ESOS is much more than a box ticking exercise. With the right planning, it can be a powerful driver of cost savings, operational efficiency, and carbon reduction.

If you would like to make your ESOS Phase 4 journey painless and effective, feel free to get in touch for an informal chat: https://shiftenvironment.co.uk/contact/