The principle: an obligation placed on energy sellers
The energy savings certificate (CEE) scheme is one of France's main tools for managing energy demand. It was created by articles 14 to 17 of law no. 2005-781 of 13 July 2005, known as the POPE law. Its rules now sit in articles L. 221-1 and following of the Energy Code.
The mechanism rests on an obligation. The public authorities require energy suppliers, called "obligated parties", to achieve a volume of energy savings over a given period. To meet it, an obligated party must hold, at the end of the period, a volume of certificates equal to its obligation. Otherwise it pays a discharging penalty for each missing kWh cumac.
Obligated parties therefore have an interest in promoting energy efficiency among consumers: households, local authorities, commercial-sector businesses, industrial firms, farmers and carriers. According to the DGEC page on the scheme, actions can be carried out in every sector. They can target the actor's own assets or those of third parties it has encouraged to act.
An obligated party has three ways to obtain certificates:
- Carry out or encourage energy-saving operations, then apply for the matching certificates;
- Buy certificates from other players who hold them;
- Contribute financially to support programmes approved by the State.
The certificate and its unit, the kWh cumac
An energy savings certificate corresponds to 1 kWh cumac of final energy. The term "cumac" contracts the French words for cumulated and discounted. The volume of an operation adds up the annual savings over the whole lifetime of the equipment. Each year after the first, the saving is divided by 1.04 compared with the previous year: the regulatory discount rate is 4%.
This convention explains why CEE volumes look high next to a building's annual consumption. A kWh cumac is not a kWh saved in one year. It is a saving accumulated over the operation's conventional lifetime.
Issued certificates are recorded in an individual account of the national CEE register, available on the Emmy website. The register also records transactions and publishes regular information on the average trading price. Since law no. 2019-1147 of 8 November 2019 on energy and climate, average purchase and sale prices are made public every month.
The players in the scheme
Several players with distinct roles take part in the scheme. Confusing them is a frequent source of misunderstandings in a project.
| Player | Role in the scheme |
|---|---|
| Obligated party | Energy seller subject to an energy savings obligation above a sales threshold |
| Delegate | Third party that receives all or part of an obligated party's obligation and becomes an obligated party in turn |
| Eligible non-obligated party | Player that can obtain certificates without being subject to an obligation, and resell them |
| Beneficiary | Household, business or local authority where the operation is carried out |
| Professional | Company that carries out the works or installs the equipment |
| PNCEE | National CEE unit (Pôle national des CEE): reviews applications, inspects and sanctions |
| Emmy register | National register where certificates are recorded and traded |
An obligated party is an energy seller whose sales exceed a threshold set by the Energy Code. The scope covers electricity, natural gas, heat and cold, domestic heating oil, liquefied petroleum gas and motor fuels.
A delegate is a person to whom an obligated party entrusts all or part of its obligation. The Energy Code strictly governs this delegation: a written contract, a minimum volume for a partial delegation, and soundness requirements for the delegate. The DGEC publishes the list of sixth-period delegates.
The National Energy Savings Certificate Unit (PNCEE) checks the eligibility of operations that lead to certificates being issued. Sanctions can be imposed in case of breach. Since the law on energy and climate, the financial penalty can reach 4% of pre-tax turnover for the last closed financial year, and 6% for a repeat breach of the same obligation.
The sixth period: 2026-2030
The scheme runs in successive periods, each with its own obligation level. The sixth period runs from 1 January 2026 to 31 December 2030. It is set by decree no. 2025-1048 of 30 October 2025.
According to the DGEC calculation note that accompanies this decree, the total obligation reaches 5 250 TWh cumac over five years, or 1 050 TWh cumac a year.
| Sixth-period obligation | Over 2026-2030 | Per year |
|---|---|---|
| Excluding energy poverty | 3 850 TWh cumac | 770 TWh cumac |
| For households in energy poverty | 1 400 TWh cumac | 280 TWh cumac |
| Total | 5 250 TWh cumac | 1 050 TWh cumac |
The "energy poverty" obligation is a separate obligation, created in 2015 by the energy transition for green growth law. For the sixth period, it equals the standard obligation multiplied by a coefficient of 0.364. The DGEC specifies that this volume matches the annual average of the fifth-period "poverty" obligation.
The split of the effort between energies is based on volumes sold between 2021 and 2023. According to the same note, motor fuels account for 44.76% of the base, electricity for 28.49% and natural gas for 18.72%. Domestic heating oil, heat and cold, and LPG share the remainder.
Three routes to obtain certificates
Standardised operations
The most common operations are covered by standardised operation sheets, published by order after the opinion of the Conseil supérieur de l'énergie. A standardised operation sheet is a fixed amount. For a typical operation, it sets the eligibility conditions and the volume of certificates issued, expressed in kWh cumac.
The sheets are gathered in the order of 22 December 2014, which sorts them into six sector annexes: agriculture, residential, commercial, industry, networks and transport. Their code follows this classification: BAR for residential, BAT for commercial buildings, IND for industry, AGRI for agriculture, TRA for transport. According to the DGEC page on standardised operations, updated on 24 September 2026, the catalogue contains 221 sheets.
Each sheet includes a framework describing the operation, "part A", reused in the statement of honour signed by the beneficiary and the professional. The same sheet serves both standard CEE and energy poverty CEE.
Specific operations
Savings made outside the standardised sheets fall under specific operations. Their volume is not a fixed amount. It is calculated and justified for each project, against a reference situation. This route is used notably for industrial projects, whose processes are too varied to fit a sheet.
Support programmes
An obligated party can also obtain certificates by contributing financially to programmes approved by the administration: information, training, innovation, the fight against energy poverty. Each programme is created by order.
A fast-changing catalogue
The catalogue of sheets is not fixed. The State revises sheets to follow technology and the market, creates new ones and removes others. Since 2019, an energy-saving operation that leads to higher greenhouse gas emissions can no longer give rise to certificates.
Two recent decisions illustrate this movement. The order of 18 September 2026, published in the Journal officiel on 23 September 2026, removed two sheets: TRA-SE-104, on tyre inflation stations, and AGRI-EQ-110, on solar drying of agricultural and forestry products with hybrid solar panels. According to the DGEC flash info of 23 September 2026, applicants had to send the list of their committed operations not yet filed by 3 October 2026.
In parallel, a draft order open to public consultation until 12 October 2026 provides for the removal of 27 other sheets. We detailed its content in our analysis of the draft order removing CEE sheets.
One rule protects ongoing projects: the date an operation is committed determines the applicable version of the sheet. When a sheet is removed, operations already committed remain eligible if they are recorded in the form and within the deadlines set by the order.
Inspections and file quality
The scheme has clearly strengthened its inspections since 2019. The law on energy and climate requires applicants to show that inspections were carried out at their own expense on certain operations. The order of 28 September 2021, amended several times, sets the rules. If a State inspection finds a non-compliance rate above 10% of the inspected volume, the applicant may be required to have other operations checked by an accredited inspection body.
The period during which facts can be prosecuted has gone from three to six years. A CEE file must therefore stay solid long after the certificates are issued.
What this means for you
For a project owner, a landlord or a local authority
CEE can fund a significant share of energy efficiency works: insulation, heating, controls, lighting, ventilation. The applicant must nevertheless prove its prior active and incentivising role. Under the order of 4 September 2014, its written commitment is sent to the beneficiary before the date the operation is committed. For an individual or a co-ownership association, this period extends to fourteen days after commitment, and always before works begin.
For an industrial firm or a farmer
The IND and AGRI sheets cover many process and utility items. Beyond them, a specific operation allows a tailor-made project to be valorised. The catalogue changes quickly, however: a sheet used today may be revised or removed before a future project is committed.
For an installer or a contractor
File compliance determines valorisation: statement of honour, part A, qualification, supporting documents. Tighter on-site inspections make each non-compliance more costly, for the applicant and for the company alike.
For an obligated party or a delegate
The sixth period sets a high obligation level, with the poverty share kept at 280 TWh cumac a year. The technical quality of files becomes a direct financial issue, because of inspections and sanctions.
What we recommend
A project funded by CEE is prepared before anything is signed. You need to identify the applicable sheet and its current version, check that the active and incentivising role will be established in time, and gather technical justifications that can withstand an inspection.
This is IHD's business. As an independent engineering consultancy, we support project owners, industrial firms and installers from the technical study through to the valorisation of certificates. We produce rigorous sizing notes, like those required for sizing a collective heat pump, and we follow changes to the catalogue day by day.
To learn about our approach to energy auditing and engineering, or to have a project's eligibility reviewed, contact us.
