EED & ESOS Compliance

Meet your Energy Efficiency Directive and ESOS obligations with a clear, audit-ready plan, and turn compliance into lasting energy savings.

The recast EU Energy Efficiency Directive (EED) and the UK's Energy Savings Opportunity Scheme (ESOS) are changing how organisations audit and manage their energy use. Under the EED, enterprises above 10 TJ of average annual energy consumption must complete an energy audit every four years, and those above 85 TJ must operate a certified energy management system. ESOS Phase 4 applies to qualifying UK organisations, assessed on 31 December 2026.

CGBC helps you work out which rules apply to you, close the gaps and meet every deadline. For many organisations, ISO 50001 certification is the most efficient route, because one certified energy management system can satisfy the EED and ESOS together.

Whether you operate in Ireland, across the EU, in the UK or in all three, your dedicated CGBC consultant will guide you from first assessment to audit-ready evidence.

What is required of your organisation?

Under the EED

• Work out your average annual energy consumption over the previous three years, across all energy carriers and all sites.
• Above 10 TJ (roughly 2,778 MWh a year) without a certified energy management system: complete an energy audit at least every four years, then prepare and publish an action plan.
• Above 85 TJ (roughly 23,611 MWh a year): implement an energy management system certified by an independent body by 11 October 2027.
• In Ireland, the Sustainable Energy Authority of Ireland (SEAI) oversees energy audit compliance.
• Confirm whether you qualify on the 31 December 2026 qualification date. Corporate groups are assessed together, so a group can qualify even if no single company does.
• Carry out ESOS energy audits covering your energy use, with a lead assessor reviewing the assessment.
• Notify the Environment Agency of compliance by 5 December 2027.
• Publish your action plan by 5 December 2028, then submit progress updates in December 2029, 2030 and 2031.
• You are an EU enterprise using more than 10 TJ of energy a year → an energy audit is required under the EED
• You are an EU enterprise using more than 85 TJ a year → a certified energy management system is required by October 2027
• You are a UK organisation with 250+ employees, or turnover above £44m and a balance sheet above £38m → ESOS Phase 4 applies to you
• You already hold ISO 50001 → you may already be compliant, or very close, under both regimes

The first EED audit deadline, 11 October 2026, has now passed. If you have not yet completed your audit, or you are unsure whether you are in scope, speak to us now.

Does ISO 50001 satisfy EED and ESOS obligations?

For many organisations, ISO 50001 isn't just best practice, it's becoming the most efficient route to legal compliance. Under the EU's recast Energy Efficiency Directive (EED), enterprises with average annual energy consumption above 10 TJ over the previous three years must carry out a mandatory energy audit every four years, with the first due by 11 October 2026 — unless they already operate a certified energy management system. Enterprises above 85 TJ must go further and implement a certified EnMS, such as ISO 50001, by 11 October 2027. Certification effectively removes the audit obligation, since a certified EnMS already meets the Directive's requirements.

Organisations with UK operations should also check their position under the Energy Savings Opportunity Scheme (ESOS). ESOS Phase 4 qualification is assessed on your position as of 31 December 2026, with a compliance deadline of 5 December 2027. You qualify if you employ 250+ people, or have turnover above £44m and a balance sheet above £38m. Here too, ISO 50001 is a recognised compliance route - if it covers 100% of your energy consumption, you're exempt from the usual lead assessor sign-off requirement. 

ISO 50001 for ILAC Dublin

After several renovations and expansions, the Ilac Shopping Centre set out to become a more sustainable, environmentally responsible space by pursuing ISO 50001, ISO 14001 and ISO 45001 certification.

CGBC performed a gap analysis, drafted a business case and delivered a project plan to achieve certification and implement an integrated management system.

With ISO 50001 fully adopted, Ilac has seen a 34% decrease in electricity consumption and is on track to become Net Positive by 2030.

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