Mandatory energy audit: which companies are concerned in France?

For ten years, the statutory energy audit applied to large companies, defined by their workforce or turnover. The DDADUE Act of 30 April 2025, which transposes European Directive 2023/1791, replaced this criterion with a consumption threshold. Industrial SMEs and mid-sized companies are entering the scheme, and the first deadline is approaching.

Current obligations

The criterion applicable since 1 October 2025

Any legal entity whose average annual final energy consumption reaches 2.75 GWh, or 10 TJ, is concerned. The average is calculated over the last three calendar years at SIREN level, combining all energy sources. Until September 2025, the requirement applied to companies with more than 250 employees, or those exceeding €50 million in turnover with a balance sheet total above €43 million. These criteria have been removed.

An energy-intensive industrial SME may now be required to carry out a statutory energy audit, while a company that remains below 2.75 GWh over three years is exempt.

Read also: 5 levers to reduce a factory's energy bill

What the audit requires

The audit must be renewed every four years. It follows the NF EN 16247 standard, covers at least 80% of final energy consumption and results in an action plan. The report is submitted on the ADEME platform. Companies already subject to the requirement before October 2025 continue their four-year cycle.

Exempt companies

An ISO 50001 certification covering all activities within the scope provides an exemption from the audit, provided that the certificate is submitted on the platform. The decree of 29 December 2025 also provides exemptions for a certified environmental management system that includes an equivalent audit, or for an energy performance contract.

Penalties

Failure to comply may result in a fine of up to 2% of turnover excluding tax for the latest closed financial year, and 4% in the event of a repeat offence.

Upcoming obligations

Between 2.75 and 23.6 GWh, a first audit before 11 October 2026

Companies that became subject to the requirement on 1 October 2025 must have completed their first audit and submitted it on the platform before 11 October 2026. This concerns companies consuming between 2.75 and 23.6 GWh per year that do not have a certified energy management system. The deadline is short. They must gather invoices from the last three years, select a certified auditor, and then wait for the report to be prepared.

Read also: European Union: energy management requirements for companies are becoming stricter

From 23.6 GWh, ISO 50001 certification before 11 October 2027

Companies whose average annual consumption reaches 23.6 GWh, or 85 TJ, must have an ISO 50001-certified energy management system by 11 October 2027 at the latest. For them, an audit is no longer sufficient.

The process requires a reliable measurement plan, energy performance indicators monitored over time, continuous improvement, and then a certification audit by a third-party body. Qualisteo estimates that full implementation generally takes between 12 and 24 months.

Read also: Energy sub-metering is essential for ISO 50001 certification

Implementing an energy management system is becoming essential

The quality of consumption data determines the success of an ISO 50001 certification process. In Nice, Qualisteo manufactures the non-intrusive Lynx connected sub-meter, which records consumption by area and use.

Qualisteo also publishes Wattseeker, the energy management software that continuously analyses data.

While these tools are essential for seeking ISO 50001 certification, above all they allow company staff to analyse energy consumption in detail and take appropriate measures to save energy.

Sources

• French Ministry for Ecological Transition, “Energy audits and energy management systems in companies”
• DREAL Grand Est, “Energy audits of large companies”
• DREAL Nouvelle-Aquitaine, “Consequences for energy management systems and statutory energy audits”, December 2025
• Act No. 2025-391 of 30 April 2025 (DDADUE) and Decree No. 2025-1382 of 29 December 2025
• French Energy Code, Articles L233-1 to L233-4