Most landlords, funds and property companies already hold an energy policy. When we review one with a client, the wording is rarely the issue. Commitments to measure, improve, buy energy responsibly and work with occupiers are usually there. What tends to be missing is the governance that turns those commitments into decisions someone can evidence. With ESOS now running as a cycle of action plans and progress updates, and SECR asking directors to describe the energy efficiency measures taken in the year, that governance has become part of the compliance work itself.
Five things we put in place first
- An accountable owner. One named person senior enough to direct spending and asset-level work, with a deputy for continuity.
- A defined scope. The entities, funds and buildings the policy covers, how it treats landlord-controlled and occupier-controlled energy, and what happens on acquisition or sale.
- A board approval record. The date of approval, who approved it, and the date of the next review, kept with the policy rather than in a separate minute book.
- A short action register. Each action has an owner, a target date, a status and the evidence that will show it is complete.
- A review that actually happens. We set the review to fall before the ESOS progress update and the SECR year end, so the policy is current when it is needed.
Using the policy to carry ESOS
ESOS assessments identify energy saving opportunities, and since Phase 3 qualifying groups also set out an action plan and report progress against it. That turns ESOS from a four-yearly audit into a standing commitment. The simplest way to manage it is to make the action plan a subset of the policy's action register. When the lead assessor reviews progress, or a director is asked to sign off an update, the status and evidence are already recorded in one place. Our ESOS service and the guide to the Phase 3 progress update cover that sign-off step in more detail.
Using the policy to carry SECR
For companies in scope, the SECR section of the directors' report describes the principal energy efficiency measures taken in the financial year. Directors are signing that description, so it should come from the same register as everything else, not from a year-end email round. If the measures listed in the SECR narrative match the completed actions in the policy register and the ESOS progress update, the three documents support each other and are easier to defend.
Portfolio scope, not head-office scope
For property businesses, most of the energy sits in the buildings, not the head office. A useful portfolio policy says how it applies to managed buildings, how responsibilities split between landlord and occupier under the lease, and how a new acquisition is brought into scope. That is where policy meets asset management: each asset-level action should trace back to a commitment the board approved. It also gives a clean starting point for wider ESG strategy and net zero strategy work, because targets and pathways need the same owner, scope and review discipline.
Questions to take to the next board meeting
- Who owns our energy policy, and when was it last approved?
- Which entities, funds and buildings does it cover, and which does it leave out?
- What actions did it produce this year, and which can we evidence as complete?
- Do our ESOS action plan and SECR narrative point back to the same register?
- Is the next review timed ahead of the next ESOS progress update and SECR year end?
How NZC Consultants can help
We review existing energy policies against these points, draft or update the policy and action register where needed, and align them with ESOS and SECR so one set of evidence supports both. The policy remains the board's: we advise and prepare, and the client's directors approve it. If you would like a second view on your current policy, talk to NZC Consultants.
Primary sources
- ESOS: find out if you qualify and how to comply (GOV.UK)
- Environmental reporting guidelines, including SECR (GOV.UK)
General guidance only. It is not legal advice and does not determine whether your organisation is in scope for ESOS or SECR.