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Small and medium-sized enterprises (SMEs) may now be required to conduct energy audits or implement an energy management system (EMS).
The Act of April 30, 2025, containing various provisions for adapting to European Union law in economic, financial, environmental, energy, transport, health, and mobility matters (DDADUE), transposes the Energy Efficiency Directive of September 13, 2023, by modifying the criteria for companies subject to the obligation to conduct energy audits or implement an EMS.
New criteria are based on energy consumption rather than company size, turnover, or balance sheet.
New compliance criteria
Energy audits
Companies with an average annual final energy consumption greater than or equal to 2.75 GWh and that have not implemented an EMS are required to conduct energy audits.
Consequently, affected companies that have already implemented a certified EMS are exempt from the requirement to conduct an energy audit.
Energy audits must be conducted every 4 years. For newly affected companies, the first energy audit must be completed no later than October 11, 2026.
Energy management system
Companies with an average annual final energy consumption are required to implement an EMS if it is greater than or equal to 23.6 GWh.
The companies concerned are not required to carry out an energy audit.
This EMS must be certified by an accredited certification body no later than October 11, 2027.
Developing an action plan
In both cases, subject companies must develop an action plan based on the recommendations resulting from the energy audit or the EMS. This action plan must include:
- the measures identified to comply with the recommendations;
- the justification for not implementing an action with a return on investment period of less than 5 years.
This action plan must subsequently be validated, published in the company's annual report, and made available to the public in compliance with legally protected secrets.
Submission of the energy audit or EMS
Within 2 months of the EMS certification or the completion of the energy audit, the companies concerned must submit information regarding the fulfillment of their obligation to the administrative authority (a decree, not yet published, will determine the data to be submitted, as well as the access restrictions necessary to protect data confidentiality).
To date, energy audits are submitted via the ADEME website: Energy Audit Collection Platform - https://audit-energie.ademe.fr/.
Furthermore, as of the 1st October 2025, affected companies must declare their annual final energy consumption.
In summary,
To determine if you are newly subject to implementing a certified EnMS or conducting energy audits:
Determine your average annual final energy consumption:
If your average annual final energy consumption is 23.6 GWh or more :
- implement an energy management system (EnMS) certified by an accredited certification body no later than October 11, 2027;
- based on the EnMS, 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 electronically within 2 months of the certification audit;
- declare the company's annual final energy consumption.
If your average annual final energy consumption is 2.75 GWh or more and you have not implemented an EnMS :
- conduct an energy audit by a recognized competent auditor no later than October 11, 2026, and every 4 years thereafter;
- based on the recommendations from the audit, 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 electronically within 2 months of the energy audit;
- declare the company's annual final energy consumption.