The qualification tests
Your organisation qualifies for Phase 4 if, on 31 December 2026, it meets either of these tests:
It employs 250 or more people.
It has an annual turnover above £44 million and an annual balance sheet total above £38 million. You need to meet both figures for this second test.
The qualification criteria have not changed since Phase 3, so if you took part last time you should assume you are in again.
What about groups?
If your business is part of a larger group that meets the tests, the group is in scope. For a large organisation with subsidiaries, the parent company is the one responsible for complying. Check the position across the whole group, not just the company you work for.
What if you are close to the thresholds?
The date that matters is 31 December 2026, not today. Headcount and financial figures can move, so it is worth confirming where you will stand on that date. Please note that these thresholds are different from the ones used for SECR reporting.
What happens if you qualify?
Qualifying organisations must complete an energy assessment covering their buildings, industrial processes and transport, and notify the Environment Agency by 5 December 2027. A certified ESOS Lead Assessor must review and sign off the assessment unless your total energy use is below 40,000 kWh.
What to do now?
1. Check your headcount, turnover and balance sheet position for 31 December 2026.
2. Confirm which companies in your group are included.
3. Start collecting energy bills and fuel records for your buildings, processes and vehicles.
4. Speak to a Lead Assessor early so your audit is planned well before the deadline.
If you are unsure whether you qualify, we are happy to talk it through. See our ESOS Compliance page for more on how we support businesses through the scheme.
Douglas Energy Solutions is led by a certified ESOS Lead Assessor and approved Elmhurst Energy Surveyors. We work with UK businesses on fixed fee energy audits, ESOS, EPCs, SECR and energy monitoring. To talk about your building, call 07787 417 393, email info@douglasenergysolutions.co.uk or book a call.