The EED Amendment: An Opportunity for More Energy Saving Measures in Industry?

• The analysis of audit systems in six EU member states provides detailed insights into the similarities, differences, strengths, and weaknesses of national systems. Recently, a concise overview of the audit systems for all 27 EU member states has been created in the form of fact sheets. Since 2014, member states have required large companies to conduct energy audits in line with the EU Energy Efficiency Directive. However, political analysis reveals significant differences in target groups and ambition levels among countries. Many have included energy intensity criteria in their audit requirements. Germany, Italy, and the Netherlands have gone further by mandating the implementation of specific energy-saving measures, although in Germany, this is intended only as a temporary response to the energy crisis. The criteria for evaluating these measures also vary, leading to different perceptions of risk regarding efficiency investments.

• The report on implementing energy efficiency measures and the related decision-making processes is based on a qualitative evaluation of company surveys. It confirms that most companies focus on "low hanging fruits," meaning measures with quick payback times and low investment costs. Management is typically responsible for final investment decisions but often needs greater awareness of energy efficiency. Few companies currently have a supportive energy management system. Although auditors play a crucial role, over a third do not emphasise the non-energy benefits in their evaluations and fail to provide implementation guidance, such as investment and monitoring plans.

• The analysis of the drivers and barriers to implementing energy-saving measures in European industrial companies is based on a comprehensive literature review and survey results. It confirms that the main obstacles to enhancing energy efficiency are primarily economic and organisational. High investment costs, long payback periods, competing priorities, lack of time, and difficulties in changing routines are the key challenges. Information and competence barriers, like lack of expertise and inaccurate recommendations, are less significant but more pronounced in smaller companies. Besides financial support, raising awareness and providing training can boost ambition and build internal expertise, while an energy management system can help close information gaps. 

Policy Recommendations for Effective Implementation of New EED Requirements

The revised EU regulations present new challenges for both member states and European companies. Member states must incorporate the changes of the EED amendment into national law, requiring company compliance from 2026. Governments can choose to meet only the minimum requirements or set more ambitious targets. In light of European climate goals, member states should aim for an ambitious, action-oriented implementation that supports companies with incentives and funding for energy efficiency measures. A first step would be to define the requirements for the content of action plans. 

The authors have published a report with policy recommendations as part of this national legislative process. They gathered key findings from the Audit2Measure consortium and consulted national energy agencies and ministries of the partner countries on their adaptation process. The main recommendations are summarised here:

• Incentives, awareness-raising, and binding targets for measure implementation: To overcome financial barriers, the authors propose more targeted financial support for efficiency measures with high energy-saving potential that are often not implemented due to high costs or technical complexity. They recommend that EU states introduce content and qualitative minimum requirements for action plans to ensure they are binding and feasible. Additionally, efforts should be made to raise awareness of climate protection and energy efficiency among companies, emphasising their importance so that long-term strategies for reducing energy consumption and CO2 emissions are adopted.
• Increased quality requirements and controls for audits and energy consultants: To encourage a more holistic approach to environmental and climate protection, it is suggested to enhance the promotion of environmental management systems. Many companies criticise the quality of energy audits and the lack of information for implementing measures. Therefore, it is recommended that energy auditors undergo regular training and that the requirements for energy audits be standardised to improve quality. This would provide companies with a better foundation for evaluating the implementation of efficiency measures. Regular evaluations of national audit systems are essential to identify gaps and areas for improvement, and member states should continue to receive support from the EU in this regard.
• Harmonisation and transparency of European requirements: At the EU level, the authors recommend harmonising the minimum requirements for auditors, along with additional requirements for energy audits. They also propose creating synergies between the EED and other EU legislation, such as CSRD, IED, and E-PRTR, by referencing already collected data.

Next steps in the Audit2Measure project

Audit2Measure will continue until 2025. The nine project partners from Greece, Italy, the Netherlands, Spain, and the Czech Republic work closely with companies to identify and overcome operational barriers, advise on energy efficiency issues, and assist in implementing energy efficiency measures. They document, evaluate, and consolidate these processes. The experiences and results are included in the policy recommendations report, with a second version planned for the project's conclusion. adelphi research will organise a final conference with relevant European stakeholders in the last quarter of 2025 to share the results and encourage discussion on implementing Article 11 of the EED in EU member states.