Preparing and publishing implementation plans under the EnEfG correctly: with cost-effectiveness assessment according to DIN EN 17463

BAFA amended its fact sheet on the Energy Efficiency Act again on 16 September 2026. The change concerns the content of implementation plans under Section 9 EnEfG. The timing is no coincidence: for energy audits completed shortly after the EnEfG entered into force on 18 November 2023, the first three-year deadlines for preparation and publication expire from mid-November 2026. This article shows what an implementation plan must contain under current law and how the cost-effectiveness assessment according to DIN EN 17463 helps.

Who must prepare implementation plans

Companies with an average total final energy consumption of more than 2.5 GWh per year over the last three completed calendar years are obliged. The obligation concerns measures from energy audits under Section 8 EDL-G completed after 18 November 2023, and from action plans of energy or environmental management systems drawn up after that date. The deadline is three years after completion of the energy audit, after certification or recertification according to ISO 50001, or after registration or renewal in the EMAS register. Anyone who permanently reduces their consumption below 2.5 GWh is no longer obliged.

Cost-effectiveness according to DIN EN 17463 (VALERI)

All measures assessed as cost-effective must be included. A measure is cost-effective if, when assessed according to DIN EN 17463, December 2021 edition, it results in a positive net present value after no more than 50 per cent of its useful life. The most likely scenario according to the standard is to be used. The useful life is based on the depreciation tables of the Federal Ministry of Finance. If no suitable value is given there, the technical useful life must be estimated realistically, for example using manufacturer information. Measures with a useful life of more than 15 years are not covered by the obligation.

An example: for a measure with a useful life of ten years, the net present value must be positive after five years at the latest. The standard, known by the abbreviation VALERI, provides a traceable scheme for this: investment, energy and operating cost savings, price trends, discount rate and assessment period are transparently documented. It is precisely these assumptions that the independent third party later checks for plausibility.

Measures with a net investment volume of up to €2,000, measures whose implementation has already been decided and which are included directly in the plan, and measures required by law or regulation can be excluded from the assessment according to DIN EN 17463.

Mandatory information in the implementation plan

According to the BAFA fact sheet, the implementation plan must contain the following information, while protecting trade and business secrets:

• Priority: consecutive numbering or priority classes, for example A, B and C.
• Name of the measure: taken unchanged from the audit report or action plan.
• Calculated investment volume: per measure, also rounded or as a range.
• Time frame: completion of planning and implementation, with month and year.
• Implementation status: open, in progress or completed.

In terms of content, the plan follows the requirements of the standards: clause 5.8.2 of DIN EN 16247-1:2022 for the audit report, clause 6.2.3 of ISO 50001:2018 for action plans, and the action plans under EMAS. Anyone who keeps these documents properly can largely derive the implementation plan from them.

Confirmation by independent third parties

Before publication, the plan must be confirmed as complete and correct. EMAS environmental verifiers, certifiers from an accredited certification body for ISO 50001 and energy auditors approved by BAFA are authorised to do so. Anyone who identified and assessed the measures may not confirm the plan themselves.

The application of DIN EN 17463, the plausibility of the cost-effectiveness assessment with regard to methodology, planning horizon, term and price increase rates, and completeness are checked. Of the measures not included, at least 40 per cent must be checked, but at least five. If there are fewer than five, all are checked. Measures showing final energy savings of more than 5 per cent of total final energy consumption must always be checked. On request, the company provides evidence of the confirmation using an electronic BAFA template.

Publish actively

The plans must be publicly accessible, for example in the annual financial statements in the company register, as a separate document on the website of the company or group, or in the sustainability report if all information is included. Making them available only on request is not sufficient. The publication remains in place for three or four years and is then replaced by the updated plan from the next audit or recertification. Measures not implemented are carried over. Infringements can be punished as an administrative offence under Section 19 EnEfG; the BAFA fact sheet mentions fines of up to €50,000 for implementation plans.

Outlook on the planned amendment

The government draft to accelerate the implementation of the Energy Efficiency Directive, adopted by the Federal Cabinet on 24 June 2026, provides for a new Section 9 EnEfG: obligation only for companies between 2.77 and 23.6 GWh with an energy audit, preparation and publication within three months of the audit, abolition of external confirmation, annual updating and acknowledgement by management. Companies with an energy or environmental management system would be exempt. The assessment according to DIN EN 17463 would remain the benchmark. The draft has not yet been adopted; until it enters into force, the existing law applies.

What companies should do now

• Record all audits completed and action plans drawn up after 18 November 2023 and calculate the respective three-year deadline.
• Assess each identified measure according to DIN EN 17463 and document assumptions such as useful life, energy prices and interest rate.
• Build the implementation plan with all five mandatory items and take over the names of the measures unchanged.
• Commission an independent reviewer in good time who was not involved in assessing the measures.
• Determine the publication channel and ensure permanent availability.
• Set up processes so that they would also work with the shorter deadlines of the draft.

How LUNEXS supports you

In our resources you will find a template for the implementation plan under the EnEfG as an Excel file and a VALERI tool for the cost-effectiveness assessment according to DIN EN 17463. With the EnEfG check you can clarify whether and from when the obligation applies to your company. LUNEXS carries out the Energy audit according to DIN EN 16247-1 with an integrated cost-effectiveness assessment and, as a BAFA energy auditor, can confirm implementation plans, provided LUNEXS has not itself identified or assessed the measures.

Technical information. No legal or tax advice and no guarantee or commitment. For a binding assessment of your individual case, please consult a specialist lawyer or tax adviser.