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De Minimis Exemption (ESOS)

In ESOS, the de minimis exemption lets an organisation exclude up to 5% of its total energy consumption from energy auditing, provided its areas of significant energy consumption still cover at least 95% of the total.

E4An ESOS Phase 4 term. See the ESOS Phase 4 hub for the full platform, workflow and deadlines.

What is De Minimis Exemption (ESOS)?

ESOS recognises that auditing every minor energy source would add cost without materially improving the assessment. The de minimis rule therefore allows up to 5% of total energy consumption to be left out of the audited areas of significant energy consumption. In other words, the audited AoSEC must reach 95%, and the residual 5% or less is the de minimis portion. The 2023 ESOS amendment reduced the de minimis margin from 10% to 5%, so it applies from Phase 3 onwards.

The exemption is about audit coverage, not about excluding energy from the total. An organisation still measures all of its energy to establish the total against which the 95% threshold is judged; it simply does not have to carry out detailed audits on the small, fragmented sources that fall within the de minimis margin.

Used sensibly, de minimis keeps ESOS proportionate. Small remote sites, minor fuel uses or immaterial processes can be set aside so audit effort focuses where the energy and the savings actually are. Organisations should document which sources they treated as de minimis so the basis is clear to their Lead Assessor.

Practical Examples

1

An organisation excludes a handful of small remote sites that together account for 4% of energy as de minimis, auditing the 96% that makes up its areas of significant energy consumption.

2

A company treats minor on-site fuel uses as de minimis, keeping audit focus on its buildings and main processes.

3

A multi-site retailer documents that the smallest 4% of its store energy is de minimis, with the remaining 96% audited.

How Climatise Helps

Climatise ranks energy consumption across all sources, making it clear which minor sources fall within the 5% de minimis margin and which belong in your audited areas of significant energy consumption, with the rationale retained as evidence.

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