Article 10 – Energy Management Systems and Energy Audits. - Antaris Consulting

Article 10 – Energy Management Systems and Energy Audits.

This blog series is aimed at providing a summary of key elements of the recast Energy Efficiency  Directive (EU) 2023/1791, which was adopted by the European Parliament and the Council earlier this year, has been published in the EU Official Journal on 20th September and came into force 20 on the 10th October 2023. After its entry into force, EU Member States will have two years to transpose most of the different elements in the directive into national law. 

This fifth blog sets out to tackle the key points of Article 11. 

Enterprises with an average annual energy consumption exceeding 85 TJ (terajoules) or 23.611 GWh across all energy sources are required to implement a certified energy management system by 11  October 2027. 

Enterprises with an average annual energy consumption higher than 10 TJ or 2.777 GWh, which do not have an energy management system in place, are subject to mandatory energy audits. These audits must be conducted by qualified experts or independent authorities and repeated at least every four years. 

Information about the energy consumption of such enterprises should be made available to national authorities. 

Member States may encourage enterprises to include information about their energy and water consumption in their annual reports. 

Member States should promote high-quality, cost-effective energy audits conducted by qualified experts or independent authorities. These audits can also be carried out by in-house experts,  provided they meet specific quality criteria. 

Programs should be developed to encourage and support Small and Medium-sized Enterprises  (SMEs) in conducting energy audits and implementing recommended energy efficiency measures.  Examples of this in Ireland include the Support Scheme for Energy Audits (SSEA) which is administered by the SEAI. 

SMEs should receive support in quantifying the multiple benefits of energy efficiency measures,  developing energy efficiency roadmaps, and establishing energy efficiency networks. 

Programs should also encourage non-SME enterprises to undergo energy audits and implement their recommendations. 

Energy audits can comply with the directive when conducted independently based on certain criteria or under voluntary agreements between stakeholders and a body appointed and supervised by the  Member State or another authorized body. 

Enterprises that implement an energy performance contract covering necessary elements of the energy management system are exempt from the energy management system requirements.

Enterprises with certified environmental management systems are exempt from the energy management system and energy audit requirements provided that their environmental management systems include energy audits. 

Energy audits may be part of a broader environmental audit, and Member States may include an assessment of the feasibility of connecting to district heating or cooling networks. Incentives and support schemes for implementing audit recommendations may also be provided. 

Energy audits under this Article must satisfy the requirements outlined in Annex VI of the Directive. 

National legislation to transpose the above Article must be implemented by 11 October 2025 in all  Member States.

Download our brochure

Download now