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ESOS and lighting: what large businesses should know

The short answer

The Energy Savings Opportunity Scheme (ESOS) requires large undertakings to assess their energy use and report on savings opportunities, and lighting is one of the most common opportunities identified. Phase 4 qualification is based on 31 December 2026, with notification due by 5 December 2027.

Who is in scope

Broadly, a large undertaking has 250 or more employees, or both turnover over £44 million and a balance sheet over £38 million, including relevant group companies. Phase 3 used a qualification date of 31 December 2022.

Key dates

MilestoneDate
Phase 3 second action-plan progress update5 December 2026
Phase 4 qualification date31 December 2026
Phase 4 notification deadline5 December 2027

Where lighting fits

Lighting upgrades and controls are often quick, well-evidenced measures for ESOS action plans. Our surveys give fitting counts, hours and estimated savings that feed straight into an assessment.

Questions

Does ESOS require us to install LED?

ESOS requires assessment and reporting. Phase 3 introduced action plans and progress updates, but the scheme does not itself require you to install specific measures.

Related services

Last reviewed 9 November 2026. This guide is general information, not legal, tax or engineering advice for a specific site.

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