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Small and medium-sized enterprises (SMEs) may now be required to carry out energy audits or implement an energy management system (EMS).
The Act of April 30, 2025 on various provisions for adapting to European Union law in the fields of economics, finance, the environment, energy, transport, health and the movement of persons (DDADUE) notably transposes the Directive of September 13, 2023 on energy efficiency by modifying the criteria for companies to be subject to obligations to carry out energy audits or implement an EMS.
The new criteria are based on energy consumption rather than company size, sales or balance sheet.
New liability criteria
Energy audits
Companies whose average annual final energy consumption is equal to or greater than 2.75 GWh and which have not implemented an EMS are subject to energy audits.
This means that companies that have already implemented a certified EMS are exempt from the obligation to carry out an energy audit.
Energy audits are carried out every 4 years. For newly-qualified companies, the first energy audit must take place no later than October 11, 2026.
Energy management system
Companies whose average annual final energy consumption is equal to or greater than 23.6 GWh are required to set up an EMS.
The companies concerned are not obliged to carry out an energy audit.
This EMS is certified by an accredited certification body no later than October 11, 2027.
Drawing up an action plan
In both cases, companies are required to draw up an action plan based on the recommendations of the energy audit or the EMS. This action plan includes
- measures identified to comply with the recommendations ;
- justification for not implementing an action with a payback period of less than 5 years.
This action plan must then be validated, published in the company's annual report and made available to the public, while respecting the confidentiality protected by law.
Transmission of the energy audit or EMS
Within 2 months of EMS certification or completion of the energy audit, the companies concerned must transmit to the administrative authority the information relating to the implementation of their obligation(a decree, not yet published, determines the data to be transmitted, as well as the access restrictions required to protect data confidentiality).
To date, energy audits are submitted via the ADEME website: Plateforme de recueil des audits énergétiques - https://audit-energie.ademe.fr/.
In addition, as of October1, 2025, the companies concerned must declare their annual final energy consumption.
In a nutshell,
To find out if you are newly required to implement a certified EMS or carry out energy audits:
Determine your average annual final energy consumption:
If your average annual final energy consumption is greater than or equal to 23.6 GWh:
- implement an energy management system (EMS) certified by an accredited certification body no later than October 11, 2027 ;
- on the basis of the EMS, draw up a validated action plan and include it in the company's annual report. Then make the defined information available to the public;
- transmit, within 2 months of the certification audit, information relating to the implementation of this obligation by electronic means;
- declare the company's annual final energy consumption.
If your average annual final energy consumption is greater than or equal to 2.75 GWh and you have not implemented an EMS:
- Carry out an energy audit by a qualified auditor no later than October 11, 2026, and every 4 years thereafter;
- Based on the audit recommendations, draw up a validated action plan and include it in the company's annual report. Then make the defined information available to the public;
- within 2 months of the energy audit, send information on the implementation of this obligation electronically;
- declare the company's annual final energy consumption.