When an organisation asks AI who can do its ESOS Phase 4 audit, is your firm named?

Last reviewed 14 October 2026

Part of Energy efficiency and compliance. For ESOS lead assessors and the energy consultancies that sell SECR, energy audits and carbon reduction plans.

ESOS Phase 4: the dates

The qualification date for ESOS Phase 4 is 31 December 2026, and the deadline for submitting a notification of compliance is 5 December 2027.

A large undertaking is a UK company that employs 250 or more people, or has an annual turnover above £44 million and an annual balance sheet total above £38 million.

Phase 4 no longer lets you use Display Energy Certificates or Green Deal assessments as alternative compliance routes.

Organisations in scope need an assessor. The question for your firm is whether it is named when they search, in Google or in an AI assistant.

What we measured: 303 assessors and consultancies

In September 2026 we measured the AI citations of 303 UK ESOS assessors and energy consultancies. The median firm was cited zero times. 196 of the 303 (65%) had no AI citations at all, and only 16 had 20 or more. Figures are Ahrefs UK data, collected on 5 and 28 September 2026.

Being on the EMA ESOS Lead Assessor Register does not change this: of the 28 register firms we could match to a website, the median was also zero and 15 had no citations.

A broker with seven staff (Apollo's estimate) was cited 188 times, and the pages behind that are live wholesale gas and electricity prices.

Our reading: size does not decide it, and a small firm with one good dated page can be quoted. Most have not written that page.

SECR: who reports, and what buyers ask

SECR applies to UK-registered quoted companies and to large unquoted companies and LLPs. In the government's 2026 review of the SECR regulations, large means meeting at least two of these: turnover of £36 million or more, a balance sheet total of £18 million or more, or 250 or more employees.

For "secr reporting" (900 searches a month), Google's AI Overview on 28 September 2026 cited three sources, all carbon-software vendors. Our view: a consultancy should not compete on the definition. It should write for groups that are also in ESOS.

Energy audits outside the ESOS cycle

Buyers who must audit under ESOS also search for audits in between. UK searches per month, Ahrefs, 6 October 2026.

Carbon reduction plans, and the NHS change on 1 April 2027

PPN 006 says a supplier's carbon reduction plan can be taken into account in procuring in-scope central government contracts above £5 million a year including VAT, subject to the Procurement Act 2023.

From 1 April 2027 NHS England's new guidance replaces its previous carbon reduction plan guidance and requirements. A 2027 NHS carbon reduction plan applies to procurements of £5 million a year and above, including VAT, and to all new frameworks run by in-scope organisations. A second tier covers lower-value procurements, below £5 million a year including VAT.

On 8 October 2026 we crawled the homepages of 64 vendors of carbon reduction plans and carbon measurement. 18 linked to a page about carbon reduction plans, and 3 mentioned 2027. Our view: few of them have written up the two NHS tiers.

Multi-site estates

A multi-site retailer or restaurant group with 250 or more employees meets the large-undertaking test.

On 8 October 2026 we measured 32 UK vendors of multi-site energy services, such as energy bureaux and monitoring platforms. 53.1% of them (17 of 32) had no AI citations.

What buyers search for

Eight of the most-searched questions UK buyers type about ESOS, SECR, carbon reduction plans and ISO 50001:

Source: Ahrefs keyword data for the UK, retrieved 13 October 2026. Monthly search volume shows how often a question is typed into Google; it does not show which firm an AI engine cites.

What we do for ESOS firms

We find the questions organisations ask before they appoint an assessor, then measure who is named. We build the pages and outside references that change it. The SEO & AI Search Sprint is the first step: see what it includes.

Written by Martin Holliday, founder of SuccessClick: an energy engineer (BEng (Hons) Energy Engineering, MSc) with ten years in the energy market and experience in building services.

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