Energy audit (SMé): Breaking down the new regulatory requirements for businesses.

Discover the new requirements of Decree No. 2025-1382 on energy audits and the SMé. Learn how to calculate your liability based on your consumption and prepare for the October 2027 deadline for ISO 50001 certification.

Laëtitia Evrard
EHS Consultant
Publication: 
11.02.2026
Contents
Example H2
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🔎 Things to remember

Here are the key points of the new energy requirements:

  • Calculation of liability: based on the average final energy consumption over the last three years, including renewable self-consumption.
  • Mandatory SMé ($\ge$ 23.6 GWh): implementation of an ISO 50001-certified system by October 11, 2027, for the largest consumers.
  • Mandatory audit ($\ge$ 2.75 GWh): energy audit every 4 years for companies below the SMé threshold.

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As a reminder, an energy management system (EMS) must be implemented and certified in companies whose average annual final energy consumption is greater than or equal to 23.6 GWh. An energy audit must be carried out by a competent auditor every four years in companies whose average annual final energy consumption is greater than or equal to 2.75 GWh and which have not implemented an EMS.

https://www.tennaxia.com/blog/nouveau-perimetre-des-audits-energetiques-et-du-sme

Enacted pursuant to the law of April 30, 2025 (DDADUE) and transposing the European Energy Efficiency Directive, Decree No. 2025-1382 of December 29, 2025 specifies the procedures for conducting energy audits and implementing Energy Management Systems (EMS). Calculation of liability, exemptions, scope, and reporting: here are the key points to remember.

Calculation of liability

First and foremost, the company's average annual final energy consumption (SIREN level) must be calculated in order to determine its obligations.

The decree now specifies that the average annual final energy consumption:

  • Corresponds to the average of the previous three calendar years.
  • Includes energy consumption related to all company activities
  • Now includes renewable energy produced and consumed on site.

https://www.tennaxia.com/blog/lautoconsommation-electrique

A decree specifies the methods for calculating this energy consumption.

Obligations according to thresholds

Once the average annual final energy consumption has been established, two scenarios arise:

Consumption ≥ 23.6 GWh

If the company's average annual final energy consumption is greater than or equal to 23.6 GWh and you have not implemented an environmental management system compliant with ISO 14001:2015 / Amd. 1: 2024 (or any other equivalent standard) certified by an accredited body and including an energy audit equivalent to that required by the regulations:

  • Implement an energy management system (EMS) that covers at least 80% of the company's final energy consumption and is certified, in accordance with standard NF EN ISO 50001:2018/Amd.1:2024 or any other equivalent standard, by an accredited certification body by October 11, 2027 at the latest.
  • Based on the SMé, establish a validated action plan and include it in the company's annual report. Then make the defined information available to the public.
  • Submit information regarding the implementation of this obligation to the ADEME platform within two months of the certification audit.
  • At the same time, declare the company's annual final energy consumption on the ADEME platform.

Consommation ≥ 2,75 GWh (et < 23,6 GWh)

If the company's average annual final energy consumption is greater than or equal to 2.75 GWh and you have not implemented an EMS or an environmental management system compliant with ISO 14001:2015 / Amd. 1: 2024 (or any other equivalent standard) certified by an accredited body and incorporating an energy audit equivalent to that required by the regulations:

  • Conduct an energy audit covering at least 80% of the company's final energy consumption. This audit must be carried out by a recognized competent auditor no later than October 11, 2026, and then every four years (the decree of July 10, 2025 specifies the procedures for conducting the audit and the procedures for recognizing the competence of auditors).

https://www.tennaxia.com/blog/veille-reglementaire-hse-et-energie-de-juillet-et-aout-2025

  • Based on the recommendations arising from the audit, draw up a validated action plan and include it in the company's annual report. Then make the information available to the public.
  • Submit information relating to the implementation of this obligation to the ADEME platform within two months of the energy audit.
  • At the same time, declare the company's annual final energy consumption on the ADEME platform.

Additional exemption

In addition to the exemption linked to the implementation of an ISO 14001 environmental management system (version 2015 / Amd 1:2024) management system issued by an accredited body, including an energy audit in accordance with regulations, the decree introduces the Energy Performance Contract (EPC) as a condition for exemption from the audit or EMS. The conditions are specified in a decree that has not yet been published.

Implementing regulations are expected shortly to specify the exact content of the action plans and the technical details of the Energy Performance Contracts (EPCs).