ESOS and SECR · reporting
ESOS and SECR reporting: where they meet, and where they do not
ESOS and SECR share data but not reports: an ESOS progress report is its own notification to the Environment Agency under Part 6A of the ESOS Regulations, and the SECR disclosure lives in the accounts.
This page sets out what an ESOS action plan and progress update must contain, when they are due, and how the same measures can be described consistently in the SECR report.
The short answer
Two reports, one set of measures
An organisation in both schemes produces two separate things.
Under the ESOS Regulations 2014 it notifies the Environment Agency of an action plan and then of progress updates, each confirmed by a responsible officer and submitted through the Notification System, which the Agency runs as MESOS.
Under SECR it discloses, in its directors’ report each year, the principal energy efficiency measures it took, alongside its energy use and emissions.
The Environment Agency’s Phase 4 guidance lists SECR among the schemes whose participation “does not automatically count as ESOS compliance”.
What connects the two is content: the measures in an ESOS action plan are often the measures a SECR report later describes as taken, and the energy records behind both are the same.
How the two schemes differ in scope, thresholds and penalties is on ESOS vs SECR.
The SECR report is not a way to file an ESOS progress update.
Regulation 34B(6) requires each update to be notified through the Notification System, and the Environment Agency says SECR participation does not automatically count as ESOS compliance.
ESOS action plans
What the action plan must contain
Action plans and progress updates were added to ESOS by SI 2023/1182, which inserted Part 6A into the Regulations from 29 November 2023, so they first applied in Phase 3.
An ESOS action plan is a written record of the measures the participant proposes to take, as set out in the table.
It does not have to include investment figures or cost projections; the statutory content is measures, dates, estimated energy savings and the estimation method.
The responsible undertaking notifies the plan through the Notification System, with the responsible officer’s confirmation.
For Phase 4 the action plan is due by 5 December 2028 and covers the next compliance period, 6 December 2027 to 5 December 2031.
A participant with zero energy consumption is deemed to have complied with Part 6A and owes no action plan or progress updates.
| reg 34A(3) | The action plan sets out |
|---|---|
| (a)(i) | Each energy efficiency measure the participant proposes to implement before the end of the relevant compliance period |
| (a)(ii) | Whether an energy audit recommended it |
| (a)(iii) | The date by which it will be implemented |
| (a)(iv) | An estimate of the total energy savings expected in the period, in kWh |
| (a)(v) | The share of those savings for each organisational purpose |
| (a)(vi) | The method used for the estimate |
| (b) | Or a statement that there is no such measure |
ESOS progress reports
The ESOS progress update, and when it is due
Regulation 34B requires a progress update each year of the action plan’s period. Phase 4 adds a third.
Each deadline below is the last day of a one-year window, not a single filing date.
| Duty | Window | Due by | Provision |
|---|---|---|---|
| Second progress update on a Phase 3 action plan | 6 Dec 2025 – 5 Dec 2026 | 5 December 2026 | reg 34B(1)(b) |
| Phase 4 action plan | 6 Dec 2027 – 5 Dec 2028 | 5 December 2028 | reg 34A(7)(b) |
| Initial progress update | 6 Dec 2028 – 5 Dec 2029 | 5 December 2029 | reg 34B(1)(a) |
| Further progress update | 6 Dec 2029 – 5 Dec 2030 | 5 December 2030 | reg 34B(1)(b) |
| Final progress update | 6 Dec 2030 – 5 Dec 2031 | 5 December 2031 | reg 34B(1)(c), added by SI 2026/701 reg 28 |
An ESOS progress update must set out which measures in the latest action plan have been implemented since the relevant event, whether each met the date in the plan, and which have not.
It must give an estimate of the reduction in energy consumption achieved, or to be achieved, during the relevant reporting period, in kWh since SI 2026/701.
And it must identify the method behind that estimate: an estimate from an energy audit, the estimate in the latest action plan, or another reasonable method, which must then be described and justified in the evidence pack.
The update is notified through the Notification System, with confirmation that the responsible officer is satisfied it complies and has seen and considered it.
The third update exists because regulation 28 of SI 2026/701 inserted it; parts of the Phase 4 guidance still describe two updates, and the regulations govern.
There is no penalty for a missed update: none of the civil penalties in Part 8 names regulations 34A or 34B, and the guidance says regulators will not take enforcement action for non-submission.
The scheme administrator publishes the failure instead, and a regulator could still serve an enforcement notice whose breach would be penalisable.
New in Phase 4
Savings achieved, and the action plan review
Phase 4 adds two duties to the ESOS report and notification of compliance, both inserted by SI 2026/701 as a new Chapter 3B.
Regulation 27D requires an estimate of the energy savings actually achieved during the compliance period, in kWh, for each organisational purpose and each measure.
Regulation 27E requires an action plan review: the measures in the previous action plan that have not been, and are not expected to be, implemented, and the reasons why.
Only the combined kWh saving is published; the per-measure figures and the review of measures not implemented are notified but not published.
These are the ESOS figures that most closely resemble what a SECR report describes, which is why the measures should be described consistently in both.
What Phase 3 shows
Most updates are filed at the last minute
The Environment Agency has published the Phase 3 ESOS data — action plans, first progress updates and notifications — on data.gov.uk.
Our analysis of the 5 June 2026 data cut counts 7,062 published action plans and 5,609 first progress updates, so 1,453 organisations (20.6%) filed a plan and then no update.
Of the updates with a readable submission date, 80.6% were filed in the final 30 days and 11.2% after the 5 December 2025 deadline.
The data is Phase 3; Phase 4 changes what is published, so it is not a guide to what Phase 4 filings will show.
For the SECR side, DESNZ’s evaluation of SECR found that only 25% of in-scope compliers said SECR had led to a reduction in their energy use, and only 33% felt heightened internal pressure to cut it.
ESOS is the scheme built around identifying and acting on measures; SECR is the one that reports the result.
Where SECR fits
The SECR efficiency narrative is the meeting point
| ESOS progress update | SECR efficiency narrative | |
|---|---|---|
| Provision | SI 2014/1643 reg 34B | SI 2008/410 Sch 7 ¶15(3D) (quoted) and ¶20D(4) (unquoted, LLP) |
| Period | A reporting year ending 5 December | The company's financial year |
| What it covers | Measures from the latest action plan: implemented or not, on time or not | The principal measures taken to increase energy efficiency |
| Figures | An estimate of the energy reduction, in kWh, and the method | None required for the measures; energy and emissions are reported separately |
| Where it goes | Notified to the Environment Agency through MESOS | The directors' report, filed with the accounts |
| Published by | The scheme administrator | Companies House, with the accounts |
Paragraph 20D(4) requires a large unquoted company that has taken measures to increase its energy efficiency in the financial year to describe the principal ones; paragraph 15(3D) does the same for quoted companies.
An organisation implementing an ESOS action plan will usually be describing some of the same measures in its SECR report, and the two descriptions should match.
The periods differ, so the figures will not: a progress update estimates the saving in a year ending 5 December, and the SECR report covers the financial year.
Keeping one register of measures — what it is, where, when it was implemented and the estimated saving — lets both reports draw on the same record.
The SECR side of that, including an illustrative efficiency paragraph, is on SECR reporting, and every SECR disclosure is listed on SECR requirements.
Timing
Aligning the ESOS reference period with the financial year
ESOS measures total energy consumption over a reference period set by regulation 22(5): twelve consecutive months that include the qualification date and end on or before the compliance date.
For Phase 4 that means a period including 31 December 2026 and ending no later than 5 December 2027, using verifiable data where reasonably practicable.
A financial year that includes 31 December 2026 and ends by 5 December 2027 — a calendar 2026 year, or one ending on 31 March 2027 — can therefore serve as the ESOS reference period as well as the SECR year.
The energy audit itself has a separate data window: the GOV.UK ESOS page says the 12-month period it is based on must begin no earlier than 6 December 2022 and no earlier than 24 months before the audit starts.
SECR’s own dates, by year end, are on SECR deadlines.
Sign-off
Responsible officers and directors
ESOS sign-off belongs to responsible officers: one where the lead assessor is independent of the participant, two in any other case, including where no lead assessor was needed.
The action plan and each progress update are confirmed by the responsible officer; the regulations do not state whether the one-or-two rule extends to them, and do not require a lead assessor for either.
SECR sign-off is the directors’: the disclosure is approved with the directors’ report, or for an LLP by the members.
The government’s SECR guidance, the environmental reporting guidelines, was last updated on 29 March 2019 and does not deal with ESOS action plans at all, which postdate it.
Getting support
Support for ESOS and SECR reporting
The ESOS assessment needs a lead assessor from one of the approved registers unless an exemption applies; the action plan, progress updates and SECR disclosure do not name a qualified role.
The full ESOS route is set out in the ESOS Phase 4 compliance guide.
DESNZ intends to consult on SECR and ESOS together later in 2026, according to the Modernising corporate reporting consultation; that consultation has not been published as at 30 September 2026.
To talk through how the two fit together for a particular organisation, you can book a free 15-minute call.
Frequently asked
ESOS and SECR reporting — frequently asked
What is an ESOS progress report?
It is the ESOS progress update required by regulation 34B of the ESOS Regulations 2014: a written record of the action taken since the action plan (or the previous update) to implement the energy efficiency measures in it, with an estimate of the energy saving achieved and the method used. It is notified to the Environment Agency through the Notification System, MESOS, and published by the scheme administrator.
When is the ESOS progress report due?
For organisations with a Phase 3 action plan, a progress update is due by 5 December 2026. For Phase 4, the action plan is due by 5 December 2028 and three progress updates follow, due by 5 December 2029, 5 December 2030 and 5 December 2031. Each deadline is the last day of a one-year window.
What must an ESOS progress update contain?
Which measures in the latest action plan have been implemented since the relevant event, whether each met the date in the plan, and which have not been implemented; an estimate of the reduction in energy consumption achieved or to be achieved during the reporting period, in kWh; and the method used to produce that estimate, identified as one of the three methods the regulation allows.
Can ESOS progress be reported in the SECR report instead?
No. Each ESOS progress update must be notified to the scheme administrator through the Notification System under regulation 34B(6), with the responsible officer's confirmation. A paragraph in the directors' report is not that notification, and the Environment Agency's guidance says SECR participation does not automatically count as ESOS compliance. The SECR report can describe the same measures, but it does not replace the update.
Is there a penalty for missing an ESOS progress update?
No. None of the civil penalties in Part 8 of the ESOS Regulations applies to the action plan or progress updates, and the Phase 4 guidance says regulators will not take enforcement action or issue a penalty for non-submission. The failure is published by the scheme administrator. If a regulator served an enforcement notice requiring one, failing to comply with that notice could be penalised.
What must an ESOS action plan contain?
Each energy efficiency measure the participant proposes to implement before the end of the next compliance period, whether an energy audit recommended it, the date by which it will be implemented, an estimate of the total energy savings expected and the share for each organisational purpose, and the method used to estimate them — or a statement that there are no such measures.
Do ESOS and SECR use the same energy data?
They start from the same bills, meter readings and fuel records, but they use them differently. ESOS measures all energy across four organisational purposes over a reference period that includes the qualification date; SECR reports specified sources for each financial year. The Environment Agency says data from another scheme can help calculate ESOS consumption but will usually need additional work.
Are ESOS action plans and progress updates published?
Yes. Regulation 10 requires the scheme administrator to publish each ESOS action plan and each progress update, and the Environment Agency released Phase 3 data through data.gov.uk. In Phase 4 the combined energy saving achieved is also published, while the action plan review of measures not implemented is not.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- legislation.gov.ukThe Energy Savings Opportunity Scheme Regulations 2014 (SI 2014/1643)
The ESOS instrument; regs 10, 22, 30 and Part 6A.
- legislation.gov.ukSI 2014/1643, Part 6A — action plans and progress updates
Regs 34A and 34B as consolidated with the SI 2026/701 amendments.
- legislation.gov.ukSI 2014/1643, regulation 34A — the ESOS action plan
¶(3): what an action plan contains; ¶(6): notification through the Notification System.
- legislation.gov.ukSI 2014/1643, regulation 22 — the reference period
¶(5): 12 months including the qualification date, ending on or before the compliance date.
- legislation.gov.ukSI 2014/1643, Part 8 — civil penalties
None attaches to regs 34A or 34B.
- legislation.gov.ukSI 2023/1182 — ESOS (Amendment) Regulations 2023
Inserted Part 6A, in force 29 November 2023.
- legislation.gov.ukSI 2026/701 — ESOS (Amendment) Regulations 2026
In force 22 July 2026: kWh throughout; savings achieved (reg 27D); action plan review (reg 27E).
- legislation.gov.ukSI 2026/701, regulation 28 — the third progress update
Inserts reg 34B(1)(c): the final update, due by 5 December 2031 for Phase 4.
- Environment AgencyHow to comply with ESOS phase 4 (30 July 2026)
§4.5 (other schemes do not count), §14 (progress updates), §15.1 (no enforcement for non-submission).
- Environment AgencyESOS: find out if you qualify and how to comply
Rewritten for Phase 4 on 2 September 2026; the audit data window.
- Environment Agency via data.gov.ukEnergy Savings Opportunity Scheme — Phase 3 open data
Action plans, first progress updates and notifications; the 5 June 2026 data cut.
- legislation.gov.ukSI 2008/410, Schedule 7 — SECR disclosures
¶15(3D) and ¶20D(4): the principal energy efficiency measures taken.
- legislation.gov.ukSI 2008/410, Schedule 7 paragraph 20D
The unquoted-company energy and emissions duties.
- GOV.UKEnvironmental reporting guidelines, including SECR requirements
The SECR guidance, last updated 29 March 2019.
- Department for Energy Security and Net ZeroIndependent evaluation of SECR (29 January 2026)
What SECR changed inside companies — and what it did not.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation (7 September 2026)
¶150: DESNZ intends to consult on SECR and ESOS later in 2026.