Do You Qualify?
UK ESOS Phase 4 applies to large UK organisations. You qualify if you meet any of the three tests below. Qualification date: 31 December 2026. Compliance deadline: 5 December 2027.
Employee Test
Your organisation employed 250 or more people in the UK, on average, across the group (including subsidiaries) on the qualification date.
Turnover Test
Businesses qualify for this test if their yearly income exceeds 44 million pounds. This requirement must be met in conjunction with the balance sheet test outlined below.
Balance Sheet Test.
Businesses qualify for this test if their total assets on the balance sheet exceed 38 million pounds. Additionally, this qualification must be combined with meeting the yearly income test specified above.
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What is ESOS? The Energy Savings Opportunity Scheme (ESOS) is a mandatory UK government energy assessment scheme for large organisations, requiring qualifying businesses to audit their energy use and identify cost-saving opportunities every four years.
What does compliance actually involve? A qualifying organisation must carry out an energy audit (or use an alternative compliance route such as ISO 50001), covering at least 90% of total energy consumption, and submit a compliance notification confirming this to the Environment Agency.
What happens if I qualify but don't comply? The Environment Agency can issue civil penalties for non-compliance, including for failing to notify, failing to maintain evidence, or submitting a false or misleading compliance notification.
Am I definitely exempt if I don't meet these thresholds? Not necessarily. Group aggregation rules mean the test applies to your whole UK corporate group, not just one entity — a smaller subsidiary can still qualify if its wider group meets the thresholds. If you're unsure, request a callback and we'll help you check.
What are the key ESOS Phase 4 dates? Qualification is assessed as at 31 December 2026. If you qualify, your compliance deadline is 5 December 2027.
How can H-DEUX help? We help organisations confirm ESOS eligibility, carry out compliant energy audits, and manage the notification process end to end. Request a callback above and we'll walk you through it.