Energy audits 2027: why many companies face a new audit cycle

Since 2015, companies that are not small or medium-sized enterprises have had to carry out an energy audit according to DIN EN 16247-1 at regular intervals. The obligation follows a four-year cycle. For many companies that have been involved since the first obligation period, the next date falls in 2027. At the same time, on 24 September 2026 the Bundestag debated in first reading a draft law intended to redefine who is obliged. Both together argue for early planning.

The four-year cycle under Section 8 EDL-G

Under the current Section 8 EDL-G, the first energy audit had to be carried out by 5 December 2015. After that, a further audit is due at least every four years, calculated from completion of the previous audit. BAFA explains this in its fact sheet on energy audits with an example: anyone who completed their first audit in December 2015 had to carry out the repeat audit by December 2019. Continuing this chain, 2023 and then 2027 follow.

Companies that completed their audits towards the end of 2015, 2019 and 2023 will therefore be required to do so again in 2027. However, the individual completion date of the last audit is always decisive. Anyone who audited at a different time has their own date.

Reference date and data basis

For repeat audits, the BAFA fact sheet specifies a reference date: 31 December of the year that follows three years after the year in which the previous audit was completed. For an audit from 2023, this is 31 December 2026. On this reference date it is determined whether the company is still obliged as a non-SME. The consumption data for the audit must cover a period of twelve consecutive months that includes this reference date. For many companies, 2026 will therefore become the data basis for the next audit.

After the audit has been completed, the online energy audit declaration must be submitted to BAFA no later than two months after completion. Companies with a certified system according to ISO 50001 or with EMAS are exempt. The declaration does not replace the provision of evidence in the event of a spot check.

What the planned amendment would change

The draft act to accelerate the implementation of the Energy Efficiency Directive (Bundestag printed paper 21/8027) links the audit obligation to energy consumption rather than company size. Anyone who consumes more than 2.77 GWh of total final energy per year on average over the last three completed calendar years would be obliged. The de minimis rule for companies up to 500,000 kWh would be abolished. According to the explanatory memorandum, the number of obliged companies would fall from around 38,300 to around 22,800.

According to the explanatory memorandum, companies that were already subject to the audit obligation remain on the four-year cycle from completion of the last audit. Companies that fall under the obligation for the first time, such as energy-intensive SMEs, would have to have carried out their first audit no later than twelve months after acquiring that status, but no earlier than twelve months after entry into force. Companies with an energy management system or EMAS would be exempt, as would, under certain conditions, companies with an energy performance contract.

At the same time, the requirements for the audit are increasing: DIN EN 16247-1 in the November 2022 edition, measured and verifiable operating data including load profiles, examination of at least 90 per cent of total final energy consumption, identification of renewable energy potential and an assessment using the net present value method. The draft has not yet been adopted. Until it enters into force, the existing rules apply.

Why 2027 requires early planning

An audit that meets these requirements needs lead time. Measurements on significant energy consumers cannot be made up at short notice, and meaningful load profiles only arise if metering starts in good time. In addition, there are the implementation plans under Section 9 EnEfG. Under current law, for audits completed after 18 November 2023 they must be prepared within three years, confirmed by independent third parties and published. The draft provides for three months after completion of the audit instead. Anyone auditing in 2027 should therefore set up the assessment of measures from the outset so that the implementation plan can be derived directly from it.

Scheduling also plays a role. If due dates cluster in one year, it makes sense to coordinate the auditor, internal contacts and site inspection dates at an early stage.

What companies should do now

• Check the completion date of the last energy audit and derive your own due date from it.
• Clarify your status on the relevant reference date: non-SME under current law and three-year average consumption with regard to the planned threshold of 2.77 GWh.
• Secure complete and verifiable consumption data for 2026, including bills and meter readings.
• Set up a metering concept for the significant energy consumers so that reliable measurement data and load profiles are available.
• Check the implementation status of measures from the last audit and plan for the implementation plans.
• Prepare the online energy audit declaration and documents for a possible BAFA spot check.

How LUNEXS supports you

With the Energy audit obligation check you can clarify whether and when an audit is due for your company. As a BAFA energy auditor, LUNEXS carries out the Energy audit according to DIN EN 16247-1 , with a metering concept, cost-effectiveness assessment and a report that serves as the basis for implementation plans. To arrange an appointment, please use our contact page.

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.