Energy Audit (EnMS)

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🔎 Key takeaways

Here are the key points of the new energy obligations:

Calculating whether you are subject: based on the average final energy consumption over the last 3 years, including self-consumed renewable energy.
Mandatory Energy Management System (≥ 23.6 GWh): implementation of an ISO 50001-certified system by 11 October 2027 for the largest consumers.
Mandatory audit (≥ 2.75 GWh): carrying out an energy audit every 4 years for companies below the Energy Management System threshold.

Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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As a reminder, an energy management system (EnMS) must be implemented and certified in companies whose average annual final energy consumption is equal to or greater than 23.6 GWh. An energy audit must be carried out, by a competent auditor, every 4 years in companies whose average annual final energy consumption is equal to or greater than 2.75 GWh and which have not implemented an EnMS.

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

Issued under the law of 30 April 2025 (DDADUE) and transposing the European “Energy Efficiency” directive, Decree No. 2025-1382 of 29 December 2025 sets out the procedures for carrying out energy audits and Energy Management Systems (EnMS). Calculating whether you are subject, exemptions, scope and declaration: here are the key points to remember.

Calculating whether you are subject

First of all, the company's average annual final energy consumption (at SIREN level) must be calculated to determine the applicable obligations.

The decree now specifies that average annual final energy consumption:

Corresponds to the average of the previous 3 calendar years.
Includes energy consumption linked to all of the company's activities
Now includes renewable energy produced and self-consumed on-site.

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

An order sets out the procedures for calculating this energy consumption.

Obligations according to thresholds

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

Consumption ≥ 23.6 GWh

If the company's average annual final energy consumption is equal to or greater than 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 incorporating an energy audit equivalent to the one required by the regulations:

Implement an EnMS that covers at least 80% of the company's final energy consumption and is certified, under standard NF EN ISO 50001:2018/Amd.1:2024 or any other equivalent standard, by an accredited certification body by 11 October 2027 at the latest;
Based on the EnMS, draw up a validated action plan and include it in the company's annual report. Then make the defined information available to the public;
Submit, within 2 months of the certification audit, the information relating to the implementation of this obligation on the ADEME platform;
Declare the company's annual final energy consumption on the ADEME platform at the same time.

Consumption ≥ 2.75 GWh (and < 23.6 GWh)

If the company's average annual final energy consumption is equal to or greater than 2.75 GWh and you have not implemented an EnMS 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 the one required by the regulations:

Carry out an energy audit that covers at least 80% of the company's final energy consumption. This audit must be carried out by an auditor recognised as competent by 11 October 2026 at the latest, then every 4 years (the order of 10 July 2025 sets out the procedures for carrying out the audit and the arrangements for recognising auditors' competence);

https://www.tennaxia.com/en/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 defined information available to the public;
Submit, within 2 months of the energy audit, the information relating to the implementation of this obligation on the ADEME platform;
Declare the company's annual final energy consumption on the ADEME platform at the same time.

Additional exemption

In addition to the exemption linked to implementing an ISO 14001 environmental management system (2015 version/Amd 1:2024) issued by an accredited body, incorporating an energy audit compliant with the regulations, the decree introduces the Energy Performance Contract (EPC) as a condition allowing exemption from the audit or the EnMS. The conditions will be set out in an order not yet published at the time of writing.

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