A European obligation, national schemes
French energy savings certificates (CEE) are not a national exception. They are France's response to an obligation set by European Union law. Each Member State must prove, year after year, that it generates new energy savings among final consumers.
This obligation now sits in Directive (EU) 2023/1791 of 13 September 2023 on energy efficiency, known as the Energy Efficiency Directive (EED). This text is a recast: it takes over and strengthens the rules of the 2012 directive, which had introduced the end-use energy savings obligation.
For an industrial company, a social landlord or an energy service company, understanding this common framework changes how foreign markets read. National schemes differ in name, unit of account and players. Yet they follow the same logic, set by Articles 8, 9 and 10 of the Directive.
What Article 8 of the EED requires
Article 8 sets a minimum volume of cumulative end-use energy savings. Final energy is the energy delivered to the consumer: electricity at the meter, gas at the boiler, fuel at the pump. The volume is calculated as a percentage of annual final energy consumption, based on the average of the three years preceding 1 January 2019.
The pace steps up in stages until 2030:
| Period | New annual savings required |
|---|---|
| 2021 to 2023 | 0.8% of final energy consumption |
| 2024 and 2025 | 1.3% of final energy consumption |
| 2026 and 2027 | 1.5% of final energy consumption |
| 2028 to 2030 | 1.9% of final energy consumption |
Cyprus and Malta benefit from a derogating regime of 0.45% per year between 2024 and 2030. After 2030, the Directive provides that States continue at a rate of 1.9% over ten-year periods.
According to the European Commission, the revised Directive more than doubles the annual energy savings obligation by 2028. This obligation is one of the main instruments serving the European target of reducing final energy consumption by at least 11.7% in 2030, compared with the projections made in 2020.
Articles 5 to 11 of the Directive, which carry these obligations, had to be transposed into national law by 11 October 2025 at the latest.
Two routes to reach the required volume
The Directive does not dictate the tool. Article 8, paragraph 2, lets each State choose between two routes, or combine them.
The energy efficiency obligation scheme
An obligation scheme is a mechanism where the State requires players in the energy sector to fund or deliver a volume of savings among consumers. Under Article 9, obligated parties are chosen from among transmission and distribution system operators, energy distributors, retail energy sales companies and fuel distributors or retailers.
Article 9 also frames how these schemes work:
- obligated parties may, if the State allows it, count certified savings achieved by energy service providers or by other third parties;
- certification must follow an accreditation process that is clear, transparent and open to all market players;
- savings obtained in a given year may be counted towards any of the four previous or three following years, without going beyond the end of the obligation period;
- States publish each year the savings achieved by each obligated party and the total for the scheme.
Finally, the text requires independent control. Measurement, control and verification of savings are carried out independently of the obligated parties, on a statistically representative proportion of the measures.
Alternative policy measures
The second route, set out in Article 10, relies on public tools: grant programmes, fiscal measures, voluntary agreements, regulation. For any measure other than a fiscal one, the State sets up a measurement, control and verification system independent of the participating or entrusted parties. For a fiscal measure, it must demonstrate the effectiveness of the price signal.
Energy poverty at the heart of the scheme
The 2023 recast strengthens the priority given to low-income households. Article 8, paragraph 3, requires States to achieve a share of the savings volume among people affected by energy poverty, vulnerable customers and low-income households.
This share is at least equal to the proportion of households in energy poverty assessed in the national energy and climate plan. In an obligation scheme, Article 9 allows States to impose this share directly on obligated parties.
Article 9 also provides that States ensure measures are eligible for every dwelling located in a multi-apartment building. Lastly, the text opens the possibility of financially supporting SMEs and microenterprises against the effects of carbon pricing.
France and Italy: two obligation schemes under the microscope
France and Italy are clear examples of the first route. Both countries have built a market for tradable certificates, with design differences that matter to a project owner.
| Criterion | France — CEE | Italy — Certificati Bianchi |
|---|---|---|
| Unit of account | 1 CEE = 1 kWh cumac of final energy | 1 certificate = 1 tonne of oil equivalent saved |
| Obligated parties | Energy suppliers, known as obligated parties | Electricity and natural gas distributors with more than 50 000 final customers |
| Non-obligated players | Eligible non-obligated players, who can sell their certificates to obligated parties | “Soggetti volontari”: energy service companies, companies with an expert or a certified energy management system |
| Administrator | Departments of the ministry in charge of energy | GSE for recognition, GME for issuance and the market |
| Horizon | Sixth period, from 2026 to 2030 | Annual targets set from 2025 to 2030 |
In France, the energy savings certificates scheme was created by the POPE Act of 13 July 2005. It rests on an obligation imposed on energy suppliers. They carry out operations, fund them at third parties or buy certificates from other players. The term “cumac” refers to savings cumulated over the lifetime of the equipment and discounted.
In Italy, Certificati Bianchi, also known as energy efficiency certificates (TEE), are the main incentive mechanism for energy efficiency in industry, networks, services and transport. For 2026, the target set for distributors reaches 1.0416 million TEE on end uses of electricity and 0.6384 million on those of natural gas. Certificates are traded on the GME platform or through bilateral contracts.
Other States have made other choices. We have detailed, for example, the reform of the Spanish certificate system.
What this means for you
For an industrial company or project owner operating in several countries
The same heat recovery or heat pump project will not be valued the same way in Lyon, Milan or Madrid. The unit of account, the player who buys the saving and the document required before works change from one country to another. Reasoning country by country, from the study phase, avoids losing value because a document was not filed in time.
For an installer or an energy service company
The Directive opens the door to savings certified by third parties, but each State decides whether it allows this and under which accreditation process. Your right of access to the market therefore depends on the national text, not on the Directive alone.
For an obligated party or a delegatee
The rise of the annual rate to 1.9% from 2028 weighs on the volumes to be covered. The share reserved for energy poverty and the requirement for independent control strengthen the value of solid, verifiable files.
What we recommend
IHD follows these schemes country by country, based on official texts. Our role as an independent engineering consultancy is to identify, for each project, the applicable scheme, the player who will value the saving and the documents that will secure the file through to valuation.
Before committing to works outside France, we advise checking three points: the national scheme chosen by the State, the access conditions for non-obligated players, and the required filing timetable. Our international markets page presents our approach, and our energy audit serves as the basis for valuation. For France, our analysis of the draft removal of CEE sheets shows that the catalogue changes quickly. For a specific project, contact us.
