New EU Energy Efficiency Directive
Energy efficiency is becoming one of the key priorities of the European economy. With the revised Directive (EU) 2023/1791 on energy efficiency, the European Union introduces new requirements for companies aimed at reducing energy consumption, improving competitiveness and achieving climate targets.
One of the biggest changes is the way obligations are determined. Instead of focusing primarily on company size, the average annual energy consumption over the previous three years is taken into account. This means that the new rules may also apply to companies that have not previously had obligations related to energy audits or energy management systems.
For company management, this is not only a matter of compliance. It is also an opportunity to gain better control over costs, processes and energy-related risks.
Key change
From company size to actual energy consumption
Obligations are determined based on the combined consumption of all energy sources and the average over the previous three years. It is therefore essential that the data is complete, comparable and reliable.
Previous approach
Company size and status
Focus on organisational criteria.
New approach
Average annual energy consumption
The decisive factor is the actual consumption of all energy sources over the previous three years.
Why the revision?
Energy efficiency as part of business management
The European Union aims to significantly improve energy efficiency and reduce overall energy consumption by 2030. At the same time, it seeks to encourage companies to improve energy management, accelerate digitalisation and reduce operating costs.
More efficient processes
Identifying losses and improving energy use in industry.
Lower costs
Better control over consumption, peaks and energy costs.
Digitalisation
A unified, transparent and automated energy data flow.
Competitiveness
Decisions based on actual indicators and comparable data.
Climate targets
A measurable contribution to reducing consumption and emissions.
Two thresholds
Two different obligations for companies
The Directive defines two key thresholds based on the average annual energy consumption over the previous three years, taking all energy sources into account.
Key deadlines
Deadlines companies should not overlook
By 11 October 2026
First energy audits for companies with an average annual energy consumption above 10 TJ that do not have an energy management system in place.
By 11 October 2027
Certified energy management system (EnMS) for companies with an average annual energy consumption above 85 TJ.
First step
Start by understanding your energy consumption
Many companies first think about an energy audit or ISO 50001 certification. In practice, the first step is much more fundamental: collecting and verifying the data needed to determine whether the company exceeds an individual threshold.
What was the average annual energy consumption over the previous three years?
Is the data for all locations complete and reliable?
Are all energy sources and significant energy consumers included?
Are energy management processes, responsibilities and targets already in place?
Data for decision-making
Why does data quality determine the quality of measures?
Most companies already collect some energy data. The key question is whether the data is sufficiently connected, accurate and transparent to support business decisions and demonstrate compliance.
Collection
Locations, metering points, energy sources and processes.
Verification
Completeness, quality, time alignment and comparability.
Analysis
KPIs, deviations, peaks, costs and significant energy uses.
Decision
Energy audit, ISO 50001 or targeted improvement measures.
ISO 50001 and Directive (EU) 2023/1791
ISO 50001 as a response to new European requirements
ISO 50001 helps companies establish a structured approach to energy management. Its value lies not only in certification, but also in clear responsibilities, measurable targets and regular performance reviews.
The importance of high-quality energy data is also increasing due to new European energy efficiency requirements. Directive (EU) 2023/1791 defines company obligations according to their average annual energy consumption over the previous three years, taking all energy sources into account.
Companies with an average annual energy consumption above 85 TJ, or approximately 23,611 MWh, must establish an energy management system by 11 October 2027 at the latest. The system must be certified by an independent body in accordance with the relevant European or international standards.
For companies with an average annual consumption above 10 TJ, or approximately 2,778 MWh, that do not have an energy management system in place, the Directive requires an energy audit at least every four years. The first audit must be carried out by 11 October 2026 at the latest.
ISO 50001 is an internationally recognised standard for establishing an energy management system and enables companies to meet the requirements of Directive (EU) 2023/1791 while continuously improving energy performance.
Clear management direction and responsibilities.
Understanding the processes with the greatest impact.
Measurable KPIs and target values for improvement.
Measures, owners, deadlines and expected results.
Regular reporting and comparison with baselines.
Verification of system and process effectiveness.
Operational discipline and energy awareness.
Plan, implement, check and improve.
Digital support
How does GemaLogic support preparation and energy management?
GemaLogic connects energy data from different sources into a single overview. It enables companies to monitor consumption, costs and indicators while providing the data foundation for energy audits, ISO 50001 and regular management reporting.
- automated data collection from meters, sensors and business systems
- overview of consumption by location, process and energy source
- energy KPIs, baselines and target values
- alerts for deviations and unusual consumption
- standardised reports and overview of implemented measures
- support for continuous improvement of energy performance
Business value
Energy management as a competitive advantage
The new Directive does not only represent an additional obligation. It is also an opportunity for companies to better understand their energy consumption, reduce operating costs, improve energy efficiency and manage risks in a timely manner.
Companies that establish well-organised processes, high-quality data and systematic energy management will find it easier to meet regulatory requirements. At the same time, they will gain better control over operations and a clearer basis for investment and operational decisions.
Frequently asked questions
What do companies most often want to know?
Is only electricity taken into account in the calculation?
No. All energy sources must be taken into account together, including electricity, gas, fuel and others, as well as the average annual consumption over the previous three years.
What should you do if the data is not collected in one place?
First, prepare an inventory of locations, energy sources and metering sources. Then standardise the data and check for missing periods so that the calculation is reliable enough for further decision-making. Tools such as GemaLogic make this step easier by connecting data from different sources into a single overview.
Does an energy audit replace ISO 50001?
They are different approaches. An energy audit is a periodic analysis of energy consumption and opportunities for improvement, while ISO 50001 establishes a permanent management system and continuous improvement process.
When is the right time to start preparing?
As soon as possible. The first energy audits for companies above 10 TJ must already be completed by 11 October 2026, while collecting and verifying data often takes longer than deciding on the next step.
Do you know whether the new Directive also applies to your company?
Check your average annual energy consumption and determine whether you need an energy audit or the implementation of an energy management system. The Solvera Lynx team can help you assess your current situation and choose the most appropriate path.
This content is provided for informational purposes only and does not constitute legal advice. When determining your obligations, check the applicable national legislation, transposition deadlines and official guidance issued by the competent authorities.