An audit based on consumption, no longer on size
The mandatory energy audit has existed in Europe since Directive 2012/27/EU. Under that regime, it targeted large companies, which had to carry out an audit at least every four years. The 2023 recast changes the entry criterion: the obligation is no longer triggered by the size of the company, but by its energy consumption.
This rule is set out in Article 11 of Directive (EU) 2023/1791 of 13 September 2023 on energy efficiency, known as the EED. According to the European Commission, the text extends the audit obligation to all companies consuming above a certain threshold, regardless of their size. SMEs, where the savings potential is considered significant, therefore fall within scope as soon as they cross that threshold.
An energy audit is a systematic procedure that describes the energy consumption of a site, a building or an installation, then identifies and quantifies cost-effective energy savings. An energy management system is an organisational framework that sets objectives, monitors consumption and drives continuous improvement in energy performance.
For a manufacturer, a logistics operator or a service-sector group present in several countries, Article 11 becomes a common baseline. Each State transposes it into national law, but the thresholds and deadlines of the directive apply throughout the Union.
Two thresholds, two obligations
Article 11 creates two levels of obligation. The thresholds are expressed in terajoules (TJ) of average annual energy consumption, calculated over the last three years and taking all energy carriers into account: electricity, gas, heating oil, heat, fuels.
| Average annual consumption | Obligation | Deadline set by the directive |
|---|---|---|
| More than 10 TJ, without an energy management system | Energy audit, then at least every four years | First audit by 11 October 2026 at the latest |
| More than 85 TJ | Energy management system certified by an independent body | System operational by 11 October 2027 at the latest |
Above 85 TJ: the energy management system
A company whose average annual consumption exceeded 85 TJ over the last three years must implement an energy management system. The system is certified by an independent body, in line with the relevant European or international standards. The directive requires it to be operational by 11 October 2027 at the latest.
Above 10 TJ: the periodic energy audit
A company whose average annual consumption exceeded 10 TJ over the previous three years, and which has no energy management system, must be subject to an energy audit. The first audit was due by 11 October 2026 at the latest. Subsequent audits take place at least every four years.
The audit is carried out independently by qualified or accredited experts, in accordance with Article 28 of the directive. It may also be implemented and supervised by independent authorities under national legislation. A company that already carried out audits under the former regime continues at the same minimum four-year frequency.
From audit report to published action plan
The 2023 recast does not stop at the audit report. It requires the recommendations to lead to decisions, and those decisions to be visible.
The company concerned draws up a concrete and feasible action plan based on the audit recommendations. The plan identifies the measures that implement each recommendation, where technically or economically feasible. It is submitted to the company's management.
Member States then ensure that the action plan and the implementation rate of the recommendations are published in the company's annual report. This publication applies subject to the law protecting trade and business secrets. For senior management, the audit therefore becomes a monitored commitment, no longer just a technical document.
The directive also organises the flow of information. When a company exceeds 85 TJ or 10 TJ in a given year, States ensure that the information is made available to the national authorities responsible for applying Article 11. States may encourage companies to publish, in their annual report, their annual energy consumption in kWh and their water consumption in cubic metres.
Audit quality and exemptions
The value of an audit depends on its quality. The directive requires each State to define transparent and non-discriminatory minimum criteria in line with Annex VI, and to designate an authority or body that ensures deadlines and criteria are respected.
The text also protects the use of the results. An audit may not contain any clause preventing its findings from being passed on to a qualified or accredited energy service provider, provided the client does not object. The audit may stand alone or form part of a broader environmental audit. A State may require it to assess the feasibility of connecting to a district heating or cooling network.
Article 11 provides two exemptions from the obligations in its paragraphs 1 and 2:
| Company situation | Condition for the exemption |
|---|---|
| Energy performance contract in place | The contract includes the necessary elements of the energy management system and meets Annex XV |
| Certified environmental management system | The system includes an energy audit based on the minimum criteria of Annex VI |
To guide Member States, the Commission published Recommendation (EU) 2024/2002 of 24 July 2024 on the interpretation of Article 11. It notably encourages energy audit centres for SMEs and microenterprises, provided they do not compete with private auditors.
Companies below the thresholds
Article 11 does not leave smaller companies aside. States develop programmes that encourage SMEs below both thresholds to undergo audits and implement their recommendations, with technical assistance. These programmes also help SMEs quantify the multiple benefits of energy efficiency measures and build roadmaps.
States may provide support schemes covering the cost of audits and of the most cost-effective recommendations, subject to EU State aid rules. Large companies not covered by paragraphs 1 and 2 also benefit from encouragement programmes.
Finally, the audit serves as a gateway to other schemes. In countries with an obligation scheme, presented in our guide to energy savings obligations in Europe, the recommended works can often be valued. In France, that scheme takes the form of energy savings certificates.
What it means for you
For a manufacturer or a multi-site group
The consumption that counts is that of the company, across all energy carriers, not that of a single site. A group present in several States must check, country by country, how national law has transposed the thresholds and the 11 October 2026 deadline. If the first audit has not yet been carried out, it becomes a priority.
For an energy-intensive SME
An SME is no longer out of scope by default. As soon as its average annual consumption exceeds 10 TJ, it falls under the mandatory audit, just like a large company. National SME support programmes can reduce the cost of the process.
For a commercial property owner or a logistics operator
A portfolio of warehouses or offices adds up its consumption. Because the action plan and its implementation rate are published in the annual report, the quality and realism of the recommendations commit management towards shareholders and partners.
For a company that is already certified
A certified environmental management system only exempts a company from the audit if it includes an energy audit meeting Annex VI. This must be checked before concluding that the company is compliant.
Our recommendations
IHD carries out energy audits as an independent engineering consultancy. Our role is to deliver a robust audit, quantified and realistic recommendations, and an action plan that management can adopt and publish with confidence. We then support the works through to their valuation, in France and in the other markets we follow.
Three checks are needed now: the company's average annual consumption over three years, across all carriers; the national text transposing Article 11 in each country of operation; the date of the last audit carried out. Our energy audit page presents our approach, and our international markets page details the countries we follow. For an initial discussion of your situation, contact us.
