COMPLIANCE REQUIREMENTS INTRODUCED BY THE DIRECTIVE
The European Directive 2023/1791 on energy efficiency represents a key element of the European Union's strategy to support energy transition and decarbonization. The legislation places energy efficiency at the center of EU policy and highlights its importance in achieving long-term climate and energy objectives.
According to the Directive, energy efficiency improvements should be pursued across all sectors of the economy by addressing barriers affecting energy production, transmission, storage and consumption. In addition, the legislation establishes indicative national energy efficiency contributions that Member States are expected to reach by 2030.
The Directive also acknowledges ISO 50001 certification as a valuable international framework for enhancing and monitoring energy performance within organizations.
Through Article 11, specific obligations are introduced regarding the adoption of energy management systems and the performance of energy audits.
ENERGY EFFICIENCY OBLIGATIONS FOR ORGANIZATIONS
The Directive introduces a number of requirements that companies may need to address depending on their level of energy consumption.
WHEN IS AN ISO 50001 ENERGY MANAGEMENT SYSTEM REQUIRED?
Companies whose average annual energy consumption has exceeded 85 TJ over the preceding three-year period must establish an Energy Management System compliant with EN ISO 50001.
Implementation must be completed within four years from the Directive's entry into force, meaning no later than 11 October 2027.
The Energy Management System must also be certified by an independent certification body operating in accordance with the applicable European or international standards.
WHAT IS AN ENERGY AUDIT AND WHAT IS ITS PURPOSE?
An energy audit is a systematic assessment designed to develop a detailed understanding of the energy consumption profile of buildings, building portfolios, industrial facilities, commercial operations, installations, and public or private services.
The process aims to identify and quantify opportunities for cost-effective energy savings, evaluate possibilities for the efficient use or generation of renewable energy, and provide documented results and recommendations based on the analysis.
ENERGY AUDITS: TIMELINES AND REQUIREMENTS
Companies with an average annual energy consumption above 10 TJ over the previous three years and without an energy management system in place are required to carry out an energy audit by 11 October 2026.
Following the audit, organizations must prepare an action plan describing how they intend to address the identified recommendations whenever implementation is considered technically and economically feasible. To ensure the continuous assessment of energy performance, energy audits must subsequently be repeated at least every four years.
The Directive further requires Member States to define transparent and non-discriminatory criteria governing energy audits. Such criteria must reflect the provisions of Annex VI and remain aligned with relevant European or international standards.
SUPPORT INITIATIVES FOR SMALL AND MEDIUM-SIZED ENTERPRISES
To promote wider adoption of energy efficiency practices, Member States are required to establish support initiatives for SMEs that are not covered by mandatory audit requirements.
These programmes should facilitate voluntary energy audits and encourage the implementation of the resulting energy-saving measures.
WHAT IS AN ENERGY PERFORMANCE CONTRACT (EPC)?
An Energy Performance Contract is an agreement between a beneficiary and a provider responsible for implementing energy efficiency improvement measures.
The level of energy achieved is monitored and verified throughout the duration of the contract. Payment for the works, products or services provided is linked to the agreed energy performance improvement or to another predefined performance indicator, such as the financial savings generated.
EXEMPTIONS FROM ENERGY MANAGEMENT SYSTEMS AND ENERGY AUDITS
Companies operating under an Energy Performance Contract (EPC) are exempt from the obligations related to Energy Management Systems and energy audits, provided that the contract incorporates the necessary elements of an energy management system and complies with Annex XV of the Directive.
An exemption is also granted to organizations that operate a certified environmental management system, where that system includes an energy audit conducted in accordance with the requirements defined by the Directive.
Together, these measures highlight the increasing importance of structured energy management practices in supporting a sustainable and low-carbon economy.