AUDIT2MEASURE Policy Recommendations Report - 1st Edition

With the new Energy Efficiency Directive (EED) in place, EU Member States are required to transpose the provisions of the new Article 11 of the revised EED (formerly Article 8) into national law by October 2025. The implementation of the Audit2Measure project provides insights and guidance on how national policymakers can enhance the impact of their current national audit systems on energy saving measures (ESM), exceed European minimum requirements, and how the European Commission could further support efforts to reduce energy consumption and greenhouse gas emissions in the industry.

This report presents an initial set of policy recommendations developed at the mid-term of the AUDIT2MEASURE project, to be updated at the end of the implementation phase. It focuses on policy recommendations to support EU Member States in implementing Article 11, "Energy Management Systems and Energy Audits," of the recast EED of 2023 into national legislation to increase the uptake of energy efficiency measures in industrial companies. The deliverable first identifies the differences between Article 8 of the previous EED and Article 11 of the recast EED, and highlights synergies with other EU policies such as the IED, E-PRTR, and CSRD. It compiles key findings from the first component (WP2) of the AUDIT2MEASURE project on the current status of national energy audit legislations in all 27 EU Member States, the decision-making process of companies on energy efficiency, and the main barriers to ESM implementation. The results of the AUDIT2MEASURE "Laboratory of Ideas" (WP4), which involved industrial companies and energy experts across five project countries, consolidate those findings. The main reason for implementing ESM is to reduce energy costs, while most of the measures implemented are those with short payback periods. The main perceived barriers to ESM implementation are long payback periods and financial constraints. It also shows that national evaluations of audit systems do have an impact on the introduction of support measures.

Through expert interviews with national energy agencies and relevant ministries of the project countries, policy measures and supporting instruments for the uptake of ESM implementation were collected, such as financial incentives in Greece, implementation obligations like in the Netherlands, or setting more ambitious energy thresholds for the audit obligation as in Germany. The recommended policy measures and tools at the national level address incentives, regulation, support, audit quality and control, monitoring, and evaluation measures. Additionally, the report formulates recommendations on how the European Commission could assist Member States in improving the effectiveness of Article 11 of the Directive, for example by supporting national control and monitoring systems, harmonising audit and auditor quality standards, and seeking better integration between EU regulations. The final version of this deliverable will be presented at the AUDIT2MEASURE final conference planned for the second half of 2025.