HOW EU DIRECTIVE 2023/1791 STRENGTHENS ENERGY EFFICIENCY REQUIREMENTS
The EU Directive 2023/1791 on energy efficiency is a central component of the European Union’s approach to advancing the energy transition and decarbonization. By making energy efficiency a core principle of EU energy policy, the Directive reinforces its role in meeting Europe’s long-term climate and energy targets.
To support these objectives, energy efficiency improvements are expected across every sector of the economy, with particular attention to removing barriers associated with energy production, transmission, storage and consumption. The Directive also sets indicative national energy efficiency contributions that Member States are expected to achieve by 2030.
Within this framework, ISO 50001 certification is recognized as an internationally established approach for organizations seeking to manage, monitor and improve their energy performance.
In particular, Article 11 defines specific requirements for energy management systems and energy audits, establishing different obligations according to an organization’s energy consumption.
WHICH ENERGY EFFICIENCY REQUIREMENTS APPLY TO COMPANIES?
The obligations established by the Directive vary according to a company’s average annual energy consumption. Depending on the applicable threshold, organizations may be required to implement an energy management system or perform recurring energy audits.
WHICH COMPANIES MUST IMPLEMENT AN ISO 50001 ENERGY MANAGEMENT SYSTEM?
Organizations with an average annual energy consumption of more than 85 TJ during the previous three years are required to implement an Energy Management System that complies with EN ISO 50001.
The system must be implemented within four years of the Directive entering into force and therefore by 11 October 2027 at the latest.
In addition, the Energy Management System must be independently certified by a certification body operating in accordance with the relevant European or international standards.
ENERGY AUDITS: WHAT ARE THEY AND WHY ARE THEY IMPORTANT?
An energy audit provides a structured and detailed assessment of how energy is used across buildings, groups of buildings, industrial facilities, commercial operations, installations, and public or private services.
Its purpose is to identify and quantify opportunities to achieve cost-effective energy savings, while also assessing potential options for the efficient use or generation of renewable energy. The audit process must result in documented findings and recommendations based on the analysis carried out.
WHO MUST CARRY OUT AN ENERGY AUDIT AND BY WHEN?
Companies whose average annual energy consumption exceeds 10 TJ over the previous three years, and which do not have an energy management system in place, must complete an energy audit by 11 October 2026.
Once the audit has been completed, organizations are required to develop an action plan explaining how they intend to follow up on the recommendations identified, provided that their implementation is technically and economically feasible.
Energy performance must continue to be assessed over time. For this reason, energy audits must be repeated at least once every four years.
The Directive also requires Member States to establish transparent and non-discriminatory criteria for energy audits. These criteria must take into account the requirements set out in Annex VI and remain consistent with applicable European or international standards.
HOW DOES THE DIRECTIVE SUPPORT ENERGY EFFICIENCY IN SMEs?
The Directive also addresses small and medium-sized enterprises that are not subject to mandatory energy audit requirements.
To encourage broader adoption of energy efficiency measures, Member States must establish support initiatives for SMEs. These programmes are intended to promote voluntary energy audits and facilitate the implementation of the energy-saving measures identified through them.
HOW DOES AN ENERGY PERFORMANCE CONTRACT WORK?
An Energy Performance Contract (EPC) is an agreement between a beneficiary and a provider that is responsible for implementing measures designed to improve energy efficiency.
The energy performance achieved is monitored and verified for the entire duration of the contract. Payment for the works, products or services delivered is linked either to the energy performance improvement agreed between the parties or to another predefined performance indicator, such as the financial savings achieved.
WHEN DO EXEMPTIONS FROM ENERGY MANAGEMENT AND AUDIT REQUIREMENTS APPLY?
Organizations operating under an Energy Performance Contract (EPC) may be exempt from requirements concerning Energy Management Systems and energy audits, provided that the contract includes the necessary elements of an energy management system and complies with Annex XV of the Directive.
An exemption also applies to organizations with a certified environmental management system, as long as that system includes an energy audit performed in accordance with the requirements established by the Directive.
Overall, these provisions reinforce the growing role of structured energy management and continuous energy performance improvement in the transition towards a more sustainable, low-carbon economy.