The Government and their administrator, the Environment Agency, are tightening the scheme to prevent operators using it like tax avoidance. They now require proof that participants are actively undertaking energy reduction and decarbonisation actions to meet targets.

This update applies to all CCA scheme members and requires records to be retained of energy saving actions and measures implemented, for the duration of the target period, starting 1st of January 2024.

See 14.2.2 of the underlying agreements – 14.2 In particular, an Operator must retain: 14.2.2 records of energy saving actions and measures implemented during each target period.



The omission or late submission will potentially lead to a fine with the maximum penalty being the great of £500 or 10% of the value of CCL (climate change levy) discount in the base year (2018). Failure to submit entirely may lead to termination from the scheme.

Extract taken from the Climate Change Agreements Operations Manual, February 2022, LIT7911

Section 8 Application of financial penalties and termination.

Clause 8.1.2 Specific to regulations 15(1)(a), (c) and (d)

• failing to provide us on or before 1 May following the end of the target period with the information we need to determine whether an operator’s progress towards meeting their target is satisfactory (regulation 15(1)(a))
• failing to provide information by the date we specify, when we ask for any other information to determine whether the operator has met its target or is complying with its underlying agreement (regulation 15(1(a))

Performance reporting

Where relevant, the auditor will check the reported performance data and the supporting evidence of the TU’s performance against its targets. The auditor will check for records of energy saving actions and measures implemented, which operators must retain as part of their obligations under their underlying agreement.