EU Directive 2023/1791 on Energy Efficiency and ISO 50001

How an energy management system can help ensure compliance

The revised EU Energy Efficiency Directive (EU) 2023/1791 establishes a common framework of measures to ensure the EU meets its energy efficiency targets. Its legislative requirements will soon impact companies  in EU Member States. Being a directive, required measures need to be transposed into Member State legislation for implementation.  Based on national legislation, companies need to move to comply. This is where energy efficiency management system standards like ISO 50001 can help organisations ensure that they meet national legislation within set deadlines driving additional energy efficiency management benefits in the process.
Key aspects of the directive include:

  • Applies to both public and private sectors, pushing efforts at all levels – from EU-wide targets down to individual enterprises.
  • EU countries must collectively achieve an additional 11.7% reduction in energy consumption by 2030 (compared to projected use) – a target that filters down into stricter national policies.
  • Requirements are not directly applicable to companies until each Member State passes corresponding laws. Member States must transpose the directive by October 2025, and they may choose to impose even stricter rules nationally.

How can ISO 50001 help achieve EU Directive 2023/1791 compliance?

ISO 50001 is an internationally recognised best-practice standard for energy management. It sets forth specific requirements for establishing, implementing, maintaining, and continually improving an Energy Management System (EnMS). A key aim of ISO 50001 is to systematically improve energy performance, including energy efficiency, use and consumption.

Implementing an ISO 50001 compliant EnMS and having it certified is a highly effective way to meet national transpositions of the EU Directive 2023/1791 requirements. In fact, the directive explicitly recognises a certified EnMS to standards like ISO 50001 as a valid route to compliance for organisations over the 10 TJ and 85 TJ annual energy-consumption thresholds.

Requirements for companies with large energy consumption

A centrepiece of EU Directive 2023/1791 is Article 11, which mandates implementation of an energy management system or energy audits for energy-intensive enterprises.

Instead of using company size, the obligations are based on a company’s energy consumption. If your organisation’s energy use exceeds certain thresholds, you will be required to take action as outlined below:

Average Annual Energy Consumption (last 3 years) Obligation under EU Directive 2023/1791 (Article 11) *) Compliance Deadline
> 85 TJ (terajoules) Enterprises meeting the threshold shall implement an energy management system and get it certified by an independent body (for example, an ISO 50001-certified EnMS). Oct 11, 2027
> 10 TJ
(terajoules)		 Enterprises meeting the threshold have two options:
Option 1: Implement an EnMS (e.g. ISO 50001)
Option 2: Conduct a qualified energy audit of your operations and develop a structured action plan based on the findings. The first audit must be completed by the deadline, with audits repeated every four years. The resulting energy efficiency Action Plan must be feasible and published in your annual report, along with updates on implementation progress.		 Oct 11, 2026 (first energy audit & action plan due).

*) Valid for both thresholds: Enterprises that implement an environmental management system (EMS) (e.g. such as ISO 14001) certified by an independent body can be exempted from above requirements, provided that the EMS includes an energy audit which meets criteria further specified in the Directive.

In summary, large energy consumers will need either an  energy management system (like ISO 50001) or to regularly execute energy audits and  report on their energy efficiency actions. Even companies below these thresholds are indirectly encouraged to improve energy performance, as Member States aim to achieve overall savings.

How DNV can support

DNV can help you to navigate the complexities of the directive and ensure an effective, certified EnMS is in place. Our teams of auditors globally have deep knowledge and understanding of both regulatory requirements and compliance and ISO 50001 certification, and can offer comprehensive support before, during, and after the certification process.

  • Training & capacity building: We provide targeted public and private training courses focussed on energy management and ISO 50001.
  • Self-Assessment Suite: We offer a set of online tools to evaluate your current management system against ISO standards, including ISO 50001.
  • Gap Analysis & implementation support: Our experts can work with you to conduct gap analyses against the ISO 50001 standard, guide the development of your energy management system, and share best practices from industry.
  • Certification audits: DNV is an accredited certification body for ISO 50001. We can perform independent audits to assess your company’s EnMS against the standard’s criteria.
  • In addition, DNV provides useful resources to help you along the way. For example, you can download our guide “10 Steps to an Efficient Energy Management System” – a practical roadmap to implementing ISO 50001 in your organisation.

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