What will happen to ESOS after Brexit?

What will happen to ESOS after Brexit?

As the UK approaches ‘exit day’ from the European Union on 29th March, businesses have been asking whether they still need to complete ESOS and, if so, will there be any changes to the scheme. At Elmhurst Energy Consultancy, we have been keeping a very close eye on all developments relating to how our exit from the EU may impact ESOS and other environmental legislation in the UK.

The good news, at present, is that ESOS will continue post Brexit, and even better news for those already underway with ESOS Phase 2, or looking to start their audit soon, is that there are only two, very minimal, changes to be expected. 


  1. The current financial thresholds are published in Euros (€), and as anticipated, these thresholds will be converted to GBP (£). This small change will actually make it easier for UK based companies who have previously had to convert their annual turnover and balance sheet into Euros.
  2. There are several routes to compliance for ESOS, including obtaining and maintaining ISO50001 – an industry recognised framework that supports commercial facilities, industrial facilities, and entire organisations in using their energy more efficiently. Currently, the EU have stated that the new framework ISO50001: 2018 cannot be used to prove compliance with ESOS, and the old framework ISO50001: 2011 must be adhered to. Once the UK leave the EU, the national accreditation body (UKAS) have stated that they will allow the new ISO50001: 2018 framework to be used. Another small change that will actually make it easier for those companies using the updated framework to comply with ESOS.

Other than the two points mentioned above, current guidance suggests there will be no other changes, and ESOS will continue to be reviewed on a 5 yearly basis. This means that, as Phase 2 is already underway, with just over 10 months until the deadline (5th December 2019), companies need to be taking action if they haven’t already. ESOS involves a full audit of 12 months consecutive data, site visits, the production of the report, including evidence and recommendations and the notification of compliance, to be submitted to the Environment Agency.

Data released from a review of Phase 1 of the scheme highlighted that only 6800 companies were compliant by the deadline, leaving 2800 business missing the deadline and facing fines ranging from £1,500 to £45,000, which have been enforced in the form of civil penalties.

Elmhurst Energy Consultancy would like to reinforce that ESOS remaining in place post Brexit should not be viewed as just another administrative and financial burden to organisations, it actually holds the potential to create real energy and cost savings. A BEIS interim evaluation report found that 79% of compliant companies reported energy-efficient improvements in the 18 months after Phase 1. It is true that some of these energy efficiency improvements will require initial investments, and payback can take a short time to pay back, but once return on investment is achieved, businesses benefit from substantial savings. The advice of our ESOS Lead Assessors is to look to implement the zero or low-cost recommendations in the first instance and then prioritise other improvement based on cost analysis, and payback potential. These details can all be found within the high standard reports produced by our assessors, and our team of experienced energy management consultants are available to advise further.

If you are yet to start your ESOS Phase 2 compliance, there is no time like the present to get in contact with one of the team to discuss the various routes to compliance available to you. There is also plenty of guidance on our website, including our ESOS newsletter, full guide, and our ESOS Overview Video, which gives you all you need to know in less than 2 minutes!

With over 25 years of experience, Elmhurst Energy Consultancy specialises in the provision of building regulation and standards compliance for new establishments. Our professional energy consultant team provides assessments to organisations that require energy audits or want to reduce their energy consumption across their buildings, transport and industrial processes.  For any enquiries, give us a call on 01455 883 259 or fill out this form to get a free quote.

Article published 28th January

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