EED: new requirements for energy use

The European Energy Efficiency Directive (EED), introduced in 2023, will be revised in mid-2026. That means quite a few things may change for organizations. To look ahead to that revision, we outline the most important expected changes.

The European Energy Efficiency Directive requires member states to promote energy efficiency. Organizations that fall under this regulation must carry out an energy audit every four years. Such an audit maps total energy consumption and identifies cost-effective measures that can help reduce energy use.

Under the current EED, this audit requirement applies only to companies with more than 250 employees, or with annual revenue exceeding €50 million and a balance sheet total of €43 million. With the revision of the directive, that will change.

What will change?

Where the current EED mainly focuses on the size of a company, the new version shifts attention to the energy consumption of organizations. That energy use will determine whether an organization must implement an energy management system – such as ISO 50001 – or carry out an energy audit.

If an organization’s average energy consumption over the past three years falls between 10 and 87 TJ, an EED audit requirement applies. If the average energy consumption exceeds 87 TJ, the organization will be required to implement an energy management system, such as ISO 50001.

When calculating energy consumption under the EED, the assessment does not look at a single company alone. The energy consumption of all affiliated companies and the parent company is added together. This does not apply to independent enterprises.

Who is exempt?

Not every organization is required to carry out an audit. Exemptions apply to:

• organizations with a certified energy management system, such as ISO 50001
• organizations with an energy performance contract (EPC) for the relevant parts
• companies with a certification scheme recognized by the ministry

When must the audit report be submitted?

Organizations that are already subject to the audit requirement must submit a new report within four years of the previous audit. That report must comply with the new requirements and include an action plan.

Organizations that become subject to the audit requirement for the first time under the revised EED will have a different timeline. They will be given up to one year after the introduction of the Dutch legislation to carry out an audit and report on it.

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