Author: Francesca Ciccolella
Key Points on Mandatory Energy Audits
- The mandatory energy audit continues to apply to large, energy-intensive companies, but new European regulations are broadening the focus to include actual energy consumption.
- The thresholds of 10 TJ/year and 85 TJ/year, which will take effect only following the publication of the national decree, will be key to determining which companies will need to comply between 2026 and 2027.
- The four-year renewal of the mandatory energy audit should not be treated as a mere update of documentation.
- Monitor i energy consumption is essential to determine whether the company is subject to the new European requirements.
- An energy audit based on real data can support technical decisions, investments, and efficiency strategies.
In recent years, the issue ofenergy efficiency has become increasingly important for businesses, industries, and owners of energy-intensive assets. The evolution of the regulatory framework at the European and national levels is, in fact, introducing requirements, thresholds for consumption and compliance requirements that are changing the way energy management of production sites and buildings.
In this context, the mandatory energy audit is taking on an increasingly strategic role. Not only because it represents a requirement as provided for by the regulations for certain categories by entities, but also because it allows you to analyze in a concrete way consumption, inefficiencies and possible presentations by improvement, creating a useful technical foundation for planning investments, reducing waste, and addressing future energy developments with greater awareness.
Table of Contents
- Key Points on Mandatory Energy Audits
- What Is a Mandatory Energy Audit?
- Who is required to conduct the mandatory energy audit today?
- Mandatory Energy Audit 2026: What Will Change with the New Thresholds?
- Mandatory Energy Audit 2027: Renewals and New Requirements
- What are the thresholds and consumption limits for the mandatory energy audit?
- How often should an energy audit be renewed?
- Energy Audit Exemptions: When Might the Requirement Not Apply?
- What happens if you don’t complete the mandatory energy audit?
- Why Take Action Before the Deadline
- How an Energy Audit Becomes a Practical Tool
- Frequently Asked Questions About Mandatory Energy Audits
- From Mandate to Energy Strategy
What Is a Mandatory Energy Audit?
The Mandatory Energy Audit It is asystematic analysis of the energy consumption of a business, a building, a facility, or a production site, request from regulations for certain individuals.
Its goal is to identify how energy is used, where the main areas of consumption are concentrated, and what measures can reduce waste, costs, and inefficiencies. Unlike a general assessment, the Mandatory energy audit must be based on measurable, technical surveys and consistent analyses consistent with the asset’s actual performance.
Compared to a voluntary diagnosis, the mandatory energy audit must comply with regulatory requirements and methodological specific. It must be drafted by qualified entities, and submitted in accordance with the established procedures, for example through the ENEA for the assessments required by Article 8 of the Legislative Decree 102/2014.
Who is required to conduct the mandatory energy audit today?
The mandatory energy audit currently applies primarily to large companies and energy-intensive businesses. The new European framework, however, is introducing criteria that are increasingly linked to Actual energy consumption.
According to the Italian regulatory framework Under current regulations, large enterprises and energy-intensive enterprises are required to conduct energy audits at their facilities. Large enterprises are traditionally identified based on size-related criteria, such as the number of employees, revenue, and total assets; energy-intensive enterprises, on the other hand, are identified based on high energy consumption and inclusion on the relevant lists CSEA.
This distinction remains important, but it is no longer sufficient to understand how the issue has evolved. The EU Directive 2023/1791 is, in fact, introducing an approach in which actual energy consumption of the organization takes on a central role in determining future obligations.
For this reason, many companies that do not view themselves as “large enterprises” may still need to carefully assess their energy profile. The point is not just the size of the organization, but the quantity of energy actually consumed during the year.
Mandatory Energy Audit 2026: What Changes with the New Thresholds?
In 2026 the central theme concerns the new thresholds related to energy consumption. Companies with consumption exceeding 10 TJ/year may be required to conduct a mandatory energy audit in accordance with the new European criteria.
The EU Directive 2023/1791 introduces a very important principle: the criterion of actual energy consumption is becoming increasingly important compared to dimensional parameters alone. According to the Directive, companies with an average annual consumption exceeding than 10 TJ, taking into account all energy sources, must undergo an an energy audit, except under specific conditions related to energy management systems or other equivalent tools.
This aspect is particularly relevant for many industrial and manufacturing companies. A company may not fit the traditional definition of a large enterprise, but it may still have significant energy consumption due to its processes, facilities, production cycles, or heating needs.
For businesses, therefore, the first operational step is reconstruction of total annual energy consumption, taking into account:
- electricity;
- gas;
- fuels;
- heat;
- steam;
- other carriers used.
Without this database, it is difficult to determine whether the company is already subject to these requirements or whether it will need to prepare to comply in the coming months.
Mandatory Energy Audit 2027: Renewals and New Requirements
With regard to the mandatory energy audit in the 2027 It is relevant both for the renewal of the diagnosis already carried out, as well as for the obligations related to the companies with very high consumption.
The topic concerns companies that are already subject to Legislative Decree 102/2014. In fact, the mandatory energy audit ensures a every four years: following the cycles in 2015, 2019, and 2023, the 2027 marks the new timeline for the renewal of energy audits that have already been submitted.
Therefore, 2027 should not be viewed as a distant deadline. A energy audit requires:
- data;
- audits;
- site inspections;
- technical analyses;
- consumption modeling;
- In more complex cases, a more structured monitoring system may also be required.
For this reason, preparing in advance helps reduce the risk of reaching the deadline without the necessary information.
What are the thresholds and consumption limits for the mandatory energy audit?
The most significant thresholds introduced by the EU Directive 2023/1791 are 10 TJ/year and 85 TJ/year.
- The first concerns the requirement to energy audit
- Second, the adoption of an energy management system.
One of the topics most frequently searched for by companies is precisely the issue of energy thresholds, since compliance with these thresholds determines whether a company can qualify or not requirements. The new European approach considers the The company’s average annual energy consumption, taking into account all the energy sources used.
| Average Annual Energy Consumption | Required |
| Greater than 10 TJ/year | Energy audit or energy assessment in accordance with the applicable requirements |
| Greater than 85 TJ/year | Energy management system, such as ISO 50001 |
These thresholds mark a significant shift in approach. The energy consumption becomes the key metric for understanding a company’s exposure to these obligations, gradually moving beyond an interpretation based solely on economic size or organizational.
How often should an energy audit be conducted?
For businesses subject to the requirement under the Legislative Decree 102/2014, the mandatory energy audit must be renewed every four years.
As mentioned earlier, the four-year term will end on 2027.
The renewal, however, should not be treated as a simple documentary repetition. In four years, they can change:
- the company’s consumption;
- production lines;
- the facilities;
- hours of operation;
- energy carriers;
- energy costs;
- sustainability goals;
- incentive opportunities.
An up-to-date diagnosis must therefore provide a snapshot of the actual energy consumptionthe company’s conditions at the time the work is performed. Simply replicating previous assessments would diminish the technical value of the tool and risk no longer accurately representing the site’s operating conditions.
Energy Audit Exemptions: When Might the Requirement Not Apply?
This requirement may not apply under certain conditions, such as theadoption of a certified energy management system, but each case must be carefully reviewed.
The issue of exemptions must be handled with caution because it depends on the applicable regulatory framework and the specific circumstances of the company. In general, the implementation of a certified energy management system ISO 50001 can be a significant factor with regard to energy audit requirements, provided that the system includes anenergy analysis that complies the specified requirements.
The EU Directive 2023/1791 in fact establishes obligations related to both energy audits and energy management systems, with thresholds that vary based on consumption. However, for certain categories, such as the energy-intensive businesses that qualify for specific incentives may be subject to additional obligations to submit an energy audit or implement energy-saving measures.
Before considering themselves exempt, it is therefore necessary to verify the following carefully:
- the company’s status;
- annual consumption;
- any CSEA registration;
- the existence of ISO 50001;
- the requested energy incentives;
- the specific obligations related to the sector or applicable regulations.
What happens if you don’t conduct the mandatory energy audit?
Failure to comply with this requirement may result in administrative penalties and does not, in any case, eliminate the need to conduct an energy audit.
The penalties provided for by the Legislative Decree 102/2014 They are generally listed in a range from 4,000 to 40,000 euros for failure to conduct the mandatory energy audit and from 2,000 to 20,000 euros for an audit that does not comply with the requirements.
This point is important because thefailure to is not is not merely economic. An Energy Audit absent or non-compliant can result in critical issues in the checks, delays in theaccess to benefits and reduced ability to plan interventions energy efficiency.
In addition, the payment of the penalty does not discharge the obligation. The company is still required to conduct the energy audit in accordance with the regulations, with the risk of having to take action within a shorter timeframe and under less favorable organizational conditions.
Why Take Action Before the Deadline?
Waiting until the deadline may reduce the time available to collect data, verify consumption, and develop compliant plans.
A thorough energy audit takes time to collect data, analyze energy consumption, conduct site inspections, model the site’s energy behavior, and identify measures that are both technically and economically viable. If a company discovers too late that it falls within the new thresholds, it may not have enough time to develop a compliant plan.
This issue is even more pronounced for companies with energy consumption exceeding 85 TJ/year, for which the transition to an energy management system may require more extensive organizational, technical, and documentation efforts.
Preparing in advance, on the other hand, means turning the diagnosis into a planning tool—not only to comply with regulations, but also to build a reliable database on which to evaluate actions, priorities, investments, and possible strategies for reducing consumption.
How an Energy Audit Becomes a Practical Tool
The collection of actual consumption and construction of an reliable energy baseline become particularly crucial, especially in complex buildings with high operational continuity.
A concrete example involves a project developed by Enertech Solution for two buildings used as nursing homes in the city of Brescia, with a total volume of over 30,100 cubic meters.
The project included technical inspections, definition of the consumption baseline, energy modeling in Edilclima and preparation of pre-renovation energy assessments.
The buildings, which date from before the 1950s and are connected to a district heating system, were analyzed to calculate energy consumption, energy performance indices, and energy efficiency ratings, in order to identify the structures’ main energy-related issues.
Based on the analyses conducted, energy efficiency measures related to power generation, distribution, control, and lighting upgrades were then recommended.
This approach makes it possible to transform the energy audit from a mere regulatory requirement into a useful technical tool for planning actions, investments, and strategies to reduce energy consumption.
Frequently Asked Questions About Mandatory Energy Audits
Is an energy audit mandatory for all companies?
No. The requirement applies to specific categories of companies, including large companies and energy-intensive companies under the current Italian framework. However, under EU Directive 2023/1791, annual energy consumption thresholds—specifically 10 TJ and 85 TJ—also become relevant.
What is the deadline for the mandatory energy audit in 2027?
For companies already subject to this requirement that have followed the four-year cycle, 2027 marks the next deadline following the 2023 cycle. The issue therefore primarily concerns the renewal of assessments that have already been conducted.
What changes will take effect in 2026 regarding mandatory energy audits?
The year 2026 is significant for companies that may be subject to the new requirements under EU Directive 2023/1791, particularly with regard to the consumption threshold of more than 10 TJ per year. However, the final version of the Italian transposition must be reviewed.
What are the thresholds for mandatory energy audits?
The thresholds introduced by EU Directive 2023/1791 are greater than 10 TJ/year for the energy audit and greater than 85 TJ/year for the energy management system.
What happens if I don't complete the mandatory energy audit?
Failure to perform the diagnosis may result in fines ranging from 4,000 to 40,000 euros. An improper diagnosis may result in fines ranging from 2,000 to 20,000 euros. Payment of the fine does not eliminate the obligation to perform the diagnosis.
Who is authorized to prepare a mandatory energy audit?
The diagnosis must be prepared by qualified individuals, such as certified EGE or ESCo professionals, in accordance with applicable regulatory and technical requirements.
From Mandate to Energy Strategy
The mandatory energy audit should not be interpreted solely as a requirement.
If based on real data, accurate measurements, and consistent technical analyses, it can become the foundation for:
- reduce consumption;
- identify waste and inefficiencies;
- plan investments;
- evaluate energy-efficiency measures;
- gain access to incentives or benefits;
- improve energy management in the medium term.
The point is not just to comply with the law, but turning that obligation into a decision-making tool. This is where the energy audit takes on a broader significance: it not only provides a snapshot of the current state, but also makes it possible to develop a technical roadmap and economic aimed at improving energy performance.
Enertech Solution supports businesses, organizations, and asset owners in assessing their energy landscape, verifying applicable obligations, and developing energy audit plans based on real data, sustainable measures, and measurable results.
If you want to find out whether your business is subject to the energy audit requirement or if you need to plan a renovation, please contact the Enertech Solution team for a personalized assessment.
