Mandatory energy audit in France: am I concerned, and what is the deadline?

The thresholds (France)

• ≥ 2.75 GWh/year (average over 3 years, all energy vectors) → mandatory energy audit (NF EN 16247), then every 4 years
• > 23.6 GWh/year (85 TJ) → certified energy management system (ISO 50001) required before 11 October 2027
• Assessed at the legal-entity (SIREN) level — multi-site consumption is aggregated
• Company size (250 employees / €50M) is no longer the trigger
• Deadline for the first audit: 11 October 2026

Exemption: you are exempt from the audit if you hold an ISO 50001 certification (or ISO 14001 integrating an energy audit, or an Energy Performance Contract) covering at least 80% of your final energy consumption.

What it changes for you

• A mid-sized industrial or logistics company of 80–180 employees can now be caught, while a large but low-energy service firm may stay out.
• A holding can cross the threshold by aggregating individually modest sites — the perimeter is the legal entity, not the site.
• The audit must now include a concrete, feasible action plan, made available to the public.
• Non-compliance exposes you to administrative penalties of up to 2% of turnover (higher on repeat).

The timeline

• Directive (EU) 2023/1791 — The recast EED shifts the criterion to real consumption.
• 30 April 2025 — Loi DDADUE n° 2025-391 transposes it into French law.
• 1 January 2026 — Article L.233-1 of the Code de l'énergie enters into force (Décret 2025-1382).
• 11 October 2026 — Deadline for the first audit above 2.75 GWh/year.
• 11 October 2027 — Deadline for a certified EnMS above 23.6 GWh/year.

What to do now

1. Add up all final energy (electricity, gas, fuel oil, vehicle fuel) across your sites over the last three full years and divide by three.
2. If the average reaches 2.75 GWh/year, engage a qualified auditor now — a compliant audit typically takes three to six months.
3. If you already hold ISO 50001 covering ≥80% of consumption, keep the evidence — you are exempt from the audit.
4. Budget realistically (roughly €5,000–€25,000 for a single industrial site) and use the audit as a cost-reduction lever, not just compliance.