Energy Audit, EnEfG & New Thresholds: What Companies Need to Do Now

How are the obligations for your company changing?

With the draft bill for the Act to Accelerate the Implementation of the Energy Efficiency Directive (EED III), a significant adjustment of the regulatory framework for companies in Germany is approaching. The aim is to transpose the European Energy Efficiency Directive into national law.

In this context, the Energy Services Act (EDL-G) and the Energy Efficiency Act (EnEfG) are being revised in particular. The key innovation is a shift in the relevant thresholds – away from company size towards actual energy consumption.

The most important changes and their implications for companies are summarized below.

EDL-G: Energy audit obligation to depend on energy consumption in the future

Until now, only large companies were required to conduct an energy audit in accordance with DIN EN 16247-1 every four years. Small and medium-sized enterprises (SMEs) were generally exempt.

With the amendment, this SME privilege will be removed. In the future, actual energy consumption will be decisive:

• Companies with more than 2.77 GWh average annual final energy consumption will be required to conduct an energy audit – regardless of their size.
• The threshold is based on the average of the last three completed calendar years.
• Companies affected for the first time benefit from a transitional period until 11 October 2026.

This significantly shifts regulatory attention towards energy-intensive medium-sized enterprises.

Practical perspective: Our analyses of 57 conducted energy audits show that identified measures enable a median energy saving of approximately 6% of final energy consumption. Energy audits are therefore not only a regulatory obligation but also offer tangible economic benefits.

EnEfG: Adjustment of the obligation to introduce management systems

The thresholds under the EnEfG are also significantly adjusted:

• New obligation to introduce an energy or environmental management system (ISO 50001 or EMAS) from 23.6 GWh annual final energy consumption
• This represents a significant increase compared to the previous threshold of 7.5 GWh

Impact: The number of obligated companies decreases, while the focus shifts more strongly to particularly energy-intensive companies.

EnEfG: Publication of implementation plans

In addition to the audit obligation, the requirement to publish implementation plans is also adjusted:

• New threshold: 2.77 GWh (previously 2.5 GWh)
• Adjustment to align with the audit obligation
• Applies to companies with consumption between 2.77 GWh and 23.6 GWh

Core requirement:

• For all economically viable energy efficiency measures, implementation plans must be prepared and published within three months after the audit.

Exception:

• Companies with consumption above 23.6 GWh (subject to management system obligations) are exempt.

Overview of future obligations

Note on funding opportunities

At present, a funding program for energy audits for SMEs is still available (BAFA Module 1: Energy Audit according to DIN EN 16247). However, in the course of the upcoming revision, this funding is expected to be phased out. Companies should therefore assess existing funding opportunities and make use of them in the short term – we would be happy to support you.

Support by FfE

FfE provides comprehensive experience in implementing regulatory requirements in industrial environments:

• Conducting energy audits according to DIN EN 16247-1, efficiency and waste heat potential analyses, etc.
• Supporting the implementation and maintenance of energy management systems in accordance with ISO 50001
• Preparation and evaluation of implementation plans for energy efficiency measures

Our approach is strongly practice-oriented: We combine regulatory requirements with concrete economic potential and support companies in efficient, targeted implementation.

We are happy to clarify in a non-binding initial consultation which obligations are relevant for your company and which next steps are advisable.

Further Information

• FfE-Energy Audits
• Energiemanagementsystems acc. to ISO 50001