Revision of the European Energy Efficiency Directive (EED): how to prepare your company

The European directive and its transposition in France

In practical terms, the EED calls for a further 11.7 % reduction in primary and final energy consumption across the EU by 2030 [4]. For member states this translates into a cumulative energy savings obligation whose pace rises in steps: 1.3 % per year over 2024 and 2025, 1.5 % per year over 2026 and 2027, then 1.9 % per year from 2028 to 2030 [5].

France is taking on this challenge through its energy and climate strategy (SFEC) and its three planning documents, all of which have now been adopted:

• ●
  the multiannual energy programme (PPE), set by the decree of 12 February 2026 for the 2026-2035 period [6];
• ●
  the national low carbon strategy (SNBC), adopted by the decree of 16 July 2026, which caps emissions at 342 Mt CO2e per year over 2024-2028, 262 Mt over 2029-2033 and 194 Mt over 2034-2038 [7];
• ●
  the national climate change adaptation plan (PNACC), published on 10 March 2025, with 85 % of its actions under way one year after launch [8].

To reach carbon neutrality by 2050, the national low carbon strategy identifies four main levers for industry [9]:

• ●
  changing material inputs;
• ●
  improving energy sufficiency and energy efficiency;
• ●
  replacing carbon based energy with decarbonised energy;
• ●
  carbon capture and storage.

Energy management in the industrial sector is clearly a central question. Industry consumed 285 TWh in 2024, or 18 % of the country's final energy consumption, a share that has fallen since 1990 when it stood at 24 % [10].

The European directive and industry: what changes in 2026

The timetable has tightened and the obligations are now expressed as figures in the French energy code. Two areas concern industrial sites directly: the overhaul of the regulatory energy audit, whose first deadline falls on 11 October 2026, and the carbon allowance reform, which has entered its concrete phase with the carbon border adjustment mechanism.

Overhaul of the mandatory regulatory energy audit

The trigger criterion changed in nature on 1 October 2025. The content of the audit itself was redefined by an order issued in July 2025.

The previous rules

From 2012 to 30 September 2025, companies with more than 250 employees, or with turnover above 50 million euros and a balance sheet total above 43 million euros, had to carry out an energy audit and update it every four years. The obligation was triggered by the size of the company.

What changes

Since 1 October 2025, liability rests on final energy consumption, calculated as the average of the three preceding calendar years [11]. Two thresholds structure the scheme:

• ●
  above 2.75 GWh per year, or 10 terajoules, an energy audit is required every four years, the first one by 11 October 2026 [12];
• ●
  above 23.6 GWh per year, or 85 terajoules, a certified ISO 50001 energy management system becomes mandatory on 11 October 2027 [13].

The scope is the legal entity registered with the trade and companies register, which aggregates every site belonging to that entity [14]. Annual final energy consumption is declared on ADEME's collection platform, which also receives audit reports and ISO 50001 certificates [15].

The order of 10 July 2025 sets out the content of the industrial energy audit [16]. It must:

• ●
  follow the NF EN 16247 standards, the general standard and its sector specific parts;
• ●
  cover the energy uses representing more than 10 % of consumption at each audited site, with a minimum of three uses;
• ●
  assess renewable energy and heat recovery opportunities against their profitability;
• ●
  sort the action plan into four payback categories: one year or less, one to three years, three to five years, more than five years.

The audit, like the management system that can replace it, must cover at least 80 % of final energy consumption [17]. Failing these obligations carries an administrative fine of up to 2 % of the last financial year's turnover excluding tax, raised to 4 % for a repeat breach [18].

Please note: this revision does not concern companies operating an energy performance contract (EPC) covering at least 80 % of final energy consumption, nor those holding an ISO 14001 certified environmental management system that includes a compliant energy audit [19].

Carbon allowance reform (EU ETS)

The second area concerns the price of carbon. The reform adopted in May 2023 produces its most visible effects in 2026, the year the carbon border adjustment mechanism entered its definitive phase.

Introduced in 2005 as part of the ratification of the Kyoto protocol, the European Union emissions trading system (EU ETS) aims to reduce greenhouse gas emissions from energy intensive industrial sectors, electricity producers and airlines, by lowering over time the cap on emission allowances set by the EU.

A major reform of directive 2003/87, the main legal basis of the EU ETS in European law, was adopted in May 2023. Its provisions are as follows:

• ●
  the emission reduction target for the covered sectors, compared with 2005, moves from 43 % to 62 % in 2030 [20];
• ●
  maritime transport is now covered by the EU ETS;
• ●
  a carbon border adjustment mechanism (CBAM) is introduced.

What it means in practice

These provisions produce four dated effects for industrial operators:

• ●
  the allowance cap falls by 4.3 % per year from 2024 to 2027, then by 4.4 % per year from 2028 [21];
• ●
  shipping companies surrender 40 % of their allowances for 2024 emissions, 70 % for 2025 emissions, then 100 % from 2026 emissions onwards [22];
• ●
  free allowances for aviation ended on 1 January 2026, with the sector's entire allocation now auctioned [23];
• ●
  free allowances for the industrial sectors covered by CBAM are phased out: 97.5 % of the allocation in 2026, 95 % in 2027, 90 % in 2028, 51.5 % in 2030, then zero in 2034 [24].

CBAM itself entered its definitive phase on 1 January 2026. Above a cumulative threshold of 50 tonnes of goods imported per calendar year, authorised CBAM declarant status is required in order to import [25]. Certificate sales open in February 2027 and the first annual declaration, covering 2026 imports, is filed in September 2027 [26].

If your company is subject to the regulatory energy audit

The reform has reversed the link between the audit and free allowances. Article 10a of the ETS directive now provides for a 20 % reduction in free allowances where the recommendations of the audit report or of the certified energy management system are not implemented, unless the payback period of the corresponding investments exceeds three years or their cost is disproportionate [27]. Implementing the recommendations with a payback below three years therefore protects the free allocation.

Compensation for indirect costs, which refunds part of the carbon cost passed through into electricity prices, requires an energy audit or an energy management system covering at least 80 % of the site's energy bills [28].

Anticipating your ISO 50001 certification to move into action

These changes, which call for demanding energy management measures, are naturally shaking up the industrial world. The right course of action? Getting ahead rather than being caught short, by putting a certified ISO 50001 energy management system in place today. Any company engaged in improving its energy management is indeed exempt from the regulatory audit, provided the system covers at least 80 % of the site's energy consumption [29]. Optional until now, certification becomes mandatory on 11 October 2027 for companies consuming more than 23.6 GWh per year [30].

Funding for this work changed shape in 2026. The PRO-SMEn scheme pays a grant equal to 20 % of the annual energy spend of the certified perimeter, capped at 40,000 euros excluding tax [31]. Registrations have been closed since 1 October 2025, the maximum number of fundable applications having been reached on 16 July 2025, with a waiting list taking over [32]. PACTE Industrie, the CEE programme run by ADEME with ATEE to which PRO-SMEn is attached, remains open: it funds up to 40,000 euros towards ISO 50001 implementation, plus 60 to 80 % of the cost of studies and coaching [33]. Its 2026 edition runs from 1 January to 31 December 2026 [34].

Worth knowing: the 2018-2022 PRO-SMEn session supported 306 companies, 69 % of them industrial, for 11.6 million euros distributed [35].

The ISO 50001 standard sets out guidelines for structuring your energy management, and lets you generate savings over the long term. Because it defines requirements in terms of performance and results rather than means, certified industrial operators have to keep improving year on year if they want to retain the benefits of their certification. Adopting ISO 50001 is therefore a significant opportunity to establish effective energy management and measurement practices over time, along with an up to date action plan. As a bonus, it also helps rally your teams around a common goal: real commitment to energy efficiency.

The ISO 50001 approach naturally comes with prerequisites: producing reliable data and indicators, defining an energy policy, structuring the organisation, and committing to monitoring and continuous improvement, the hallmarks of a documented and virtuous management system. Through its dedicated platform, Lemon Energy measures your consumption and qualifies your energy performance at several levels: equipment, workshop, site and group. We produce the technical, quantified basis that will make your exchanges with your certification body easier. Whether you are behind on energy management or newly concerned by the revised EED, our expertise supports you in meeting the challenges of the energy transition.