8 steps to ESOS compliance

How can energy monitoring software assist in ESOS compliance?

The Energy Savings Opportunity Scheme (ESOS) is the latest government legislation for mandatory carbon reporting. The scheme will affect more organisations than any previous legislation; if your organisation employs more than 250 staff or if your turnover is greater than €50m then you will need to comply or risk financial penalties.

At present ESOS demands the identification of energy savings opportunities. The implementation of these opportunities is not compulsory, though it makes financial sense for an organisation, particularly when ESOS compliance incurs a cost that could easily be recouped.


What is the best route to ESOS compliance?

Ultimately, your chosen path towards ESOS compliance should be the one that best fits your organisation’s medium and long-term objectives. The final approach will be agreed with your lead auditor but here we have provided a rough guide with 8 steps.

  1. Appoint a Lead Auditor – your lead auditor will approve the compliance approach and sign off any surveys and audits taken. 
  1. Consider ISO 50001 – the only exemption to ESOS compliance is if you have an ISO 50001 certified Energy Management System that covers all relevant energy consumption sources. If you do not already have ISO 50001 and are simply looking to comply with ESOS then this probably isn’t the right solution for you; ISO 5001 is a long-term commitment to continual improvement.
  1. Choose a route – there are a number of routes to compliance with ESOS. The policy has been designed with an element of flexibility that enables you to build on any existing audits and certification you may already have in place. For example, if you are already using DECs (Display Energy Certificates) or the Green Deal, then you may have suitable analyses that can be used. If you need to conduct audits then your Lead Auditor will advise the best process. 
  1. Decide on the audit structure and evidence required – before you begin the audit process it is important to decide how the information will be presented to the Lead Auditor and scheme administrator. There is a range of advanced software available that can be used to gather, analyse and present data in a user-friendly format
  1. Gather data – the data required for ESOS must cover all operational sources, including transport and production. The data must cover a 12 month period and is used to create energy-use profiles for benchmarking. The best way to do this is through an automatic approach that gathers data from multiple sources like AMR, billing, manual meter reads and bulk purchases etc.
  1. Complete your audits – there is no legal requirement for your audits to be carried out externally. Your Lead Auditor just needs to approve them. When selecting a Lead Auditor, look for a provider with a flexible approach that will enable you to carry out audits internally or externally to suit. A centralised software system will make it easy to access and produce reports from any location. Your Lead Auditor should also be able to help you devise templates for internal audits that can be deployed across a range of departments (FM, Health and Safety, Environment) throughout your organisation.
  1. Internal presentation and Director sign off – ESOS demands a legal responsibility from the Director to sign off checks that all information is factual and correct. You can incur fines of £5,000 with an additional £500 per day for mis-declaration of compliance. Another benefit to using a centralised software system for ESOS compliance is that the sign off process can be quickly and easily managed through the internal audit system.
  1. Register compliance with the Administrator – the final step is to self-declare your organisation’s compliance. Once declared, you may be externally audited by the administrator or an appointed agent.


In summary, ESOS compliance is a reasonably flexible process that allows you to build on any existing systems you already have in place. The key to ensuring compliance is in the selection of a suitably qualified Lead Auditor who can provide the right monitoring and reporting software to keep the validation and presentation of your evidence consistent and easily accessible.


GMI Energy can assist in a number of ways:

  • Providing a Lead Auditor working on your behalf to your brief
  • Install a fully integrated management software system
  • Ensuring the best mix of internal and external resource
  • Offer a route to full ISO 50001 compliance if desired
  • Ensure transparency and encourage wider stakeholder engagement