--- title: "EU EED 85 TJ and 10 TJ enterprise thresholds under Article 11" canonical_url: "https://www.sorena.io/artifacts/eu/energy-efficiency-directive/85-tj-and-10-tj-enterprise-thresholds" source_url: "https://www.sorena.io/artifacts/eu/energy-efficiency-directive/85-tj-and-10-tj-enterprise-thresholds" author: "Sorena AI" description: "Article 11 guidance for enterprises checking the EU Energy Efficiency Directive 85 TJ energy-management-system threshold and 10 TJ energy-audit threshold." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Energy Efficiency Directive" - "Article 11" - "85 TJ threshold" - "10 TJ threshold" - "energy audits" - "energy management systems" - "Energy Efficiency Directive" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU EED 85 TJ and 10 TJ enterprise thresholds under Article 11 Article 11 guidance for enterprises checking the EU Energy Efficiency Directive 85 TJ energy-management-system threshold and 10 TJ energy-audit threshold. *EED* *Article 11* *EU* ## EU Energy Efficiency Directive 85 TJ and 10 TJ Enterprise Thresholds Article 11 of Directive (EU) 2023/1791 uses average annual energy consumption over the previous three years, taking all energy carriers together, to decide which enterprises need an energy management system or an energy audit. Use this page to separate the 85 TJ and 10 TJ triggers, capture the evidence behind the calculation, and keep audit action plans and implementation records aligned with the Directive. The 85 TJ and 10 TJ thresholds are not size tests based on headcount or revenue. Article 11 looks at an enterprise's average annual energy consumption over the previous three years, taking all energy carriers together. Above 85 TJ, the enterprise must implement a certified energy management system. Above 10 TJ, an enterprise that does not implement an energy management system is subject to an energy audit. ## What Article 11 requires at 85 TJ and 10 TJ For enterprises with average annual consumption higher than 85 TJ over the previous three years, Article 11 requires an energy management system. The system must be certified by an independent body in line with relevant European or international standards, and Article 11 sets 11 October 2027 as the latest date for having it in place. For enterprises with average annual consumption higher than 10 TJ over the previous three years that do not implement an energy management system, Article 11 requires an energy audit. The first audit is due by 11 October 2026, and subsequent audits must be carried out at least every four years. - Use a three-year average, not a single procurement invoice or one reporting period, when checking the primary threshold trigger. - Count all energy carriers together when testing whether the enterprise is above 85 TJ or 10 TJ. - Treat 85 TJ as the energy-management-system trigger and 10 TJ as the audit trigger when no energy management system is implemented. - Do not rely on a generic large-enterprise or SME label alone; the revised Directive expands audit obligations to companies consuming energy above the relevant threshold. Sources for this answer: - [Directive (EU) 2023/1791 Article 11](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023L1791&ref=sorena.io) - Article 11 states the 85 TJ energy-management-system trigger, the 10 TJ energy-audit trigger, the three-year average, all-energy-carrier scope, and the 2026 and 2027 dates. - [European Commission Energy Efficiency Directive overview](https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-rules/energy-efficiency-directive_en?ref=sorena.io) - The Commission overview explains that the revised Directive ties audit obligations to energy-consumption thresholds rather than company size alone. ## How to document the threshold calculation A threshold file should show the enterprise boundary used, the three years included, the energy carriers counted, the conversion basis used to express consumption in TJ, and the final average. Article 11 itself supports the three-year and all-energy-carrier elements; local transposition may add reporting mechanics, competent authority portals, or national calculation instructions. Article 11 also creates a separate authority-information trigger. Where an enterprise covered by paragraph 1 has annual consumption above 85 TJ in a given year, or an enterprise covered by paragraph 2 has annual consumption above 10 TJ in a given year, Member States must ensure that this information is made available to the national authorities responsible for implementation. - Keep source energy data by site, meter, fuel type, invoice stream, or operational system before converting it into the three-year TJ average. - Record which legal entity or enterprise boundary was used and why that boundary matches the national implementation being applied. - Separate the three-year average used for the Article 11 obligation from the single-year information that may need to be made available to national authorities. - Preserve the calculation workbook, approver, source systems, conversion assumptions, and the date the threshold status was last reviewed. Sources for this answer: - [Directive (EU) 2023/1791 Article 11](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023L1791&ref=sorena.io) - Article 11 supports the three-year average, all-energy-carrier threshold test, and the national-authority information requirement for annual consumption above the relevant threshold. - [Commission Recommendation (EU) 2024/2002 on Article 11](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024H2002&qid=1719245800368&ref=sorena.io) - The Commission identifies Recommendation (EU) 2024/2002 as the guidance for interpreting Article 11 on energy management systems and energy audits. ## Energy management system or energy audit The 85 TJ path is not satisfied by an informal efficiency programme. Article 11 requires an energy management system certified by an independent body according to relevant European or international standards. The 10 TJ path applies when the enterprise is above the 10 TJ threshold and does not implement an energy management system. The audit must be independent and cost-effective through qualified or accredited experts, or implemented and supervised by independent authorities under national law. - For the 85 TJ path, keep the certificate, scope statement, standard reference, independent certification body record, and monitored energy-consumption objectives. - For the 10 TJ audit path, keep the auditor qualification or accreditation evidence, independence check, audit scope, audit date, and next four-year deadline. - If relying on an energy performance contract or certified environmental management system instead, document how the contract or system covers the required Article 11 elements and Annex VI audit criteria. - If audits are carried out by in-house experts, verify the national quality-assurance scheme and keep evidence that the expert is not directly engaged in the activity audited. Sources for this answer: - [Directive (EU) 2023/1791 Article 11](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023L1791&ref=sorena.io) - Article 11 distinguishes certified energy management systems from independent energy audits and identifies exemptions for qualifying energy performance contracts and environmental management systems. - [European Commission Energy Efficiency Directive overview](https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-rules/energy-efficiency-directive_en?ref=sorena.io) - The Commission overview links Article 11 to audit obligations, technical competence requirements, and mandatory energy management systems for large industrial energy consumers. *Recommended next step* *Placement: after audit evidence section* ## Turn Article 11 thresholds into an audit-ready evidence file Use the 85 TJ and 10 TJ threshold check to maintain the three-year energy-consumption calculation, management-system or audit evidence, action-plan status, and annual-report publication support. - [Open Research Copilot](/solutions/research-copilot.md): Check Article 11 threshold questions against cited EED source material. - [Discuss EED implementation](/contact.md): Review threshold calculations, audit cadence, action plans, and publication evidence with Sorena. ## Audit outputs and implementation records Article 11 requires the enterprise concerned to draw up a concrete and feasible action plan from the energy audit recommendations. The action plan must identify measures to implement each audit recommendation where technically or economically feasible and must be submitted to enterprise management. Member States must ensure that the action plans and the recommendation implementation rate are published in the enterprise's annual report and made publicly available, subject to Union and national rules protecting trade secrets, business secrets, and confidentiality. - Turn each audit recommendation into a measure, feasibility note, owner, implementation status, expected savings record, and management-submission evidence. - Maintain an implementation-rate register that can be reconciled to the annual report or other public availability route required by national law. - Mark confidential or trade-secret material before publication, but keep an internal version that shows how the public implementation rate was derived. - Use the four-year audit cadence to refresh the action plan rather than treating the audit as a one-off report. Sources for this answer: - [Directive (EU) 2023/1791 Article 11](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023L1791&ref=sorena.io) - Article 11 requires action plans from audit recommendations, management submission, and publication of action plans and recommendation implementation rates. - [Commission Recommendation (EU) 2024/2002 on Article 11](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024H2002&qid=1719245800368&ref=sorena.io) - The Commission Article 11 recommendation is the official interpretive guidance source for energy management systems and energy audits. ## Minimum audit evidence under Annex VI Annex VI sets the minimum criteria for energy audits, including audits carried out as part of energy management systems. Those criteria are the practical checklist for whether an audit record is strong enough to support the Article 11 threshold path. The audit should be based on up-to-date, measured, traceable operational data; review the energy-consumption profile of buildings, industrial or commercial operations or installations, and transport; identify energy-efficiency measures; identify cost-effective renewable-energy use or production potential; and provide detailed validated calculations for proposed measures. - Store measured consumption data and electricity load profiles so they remain available for historical analysis and performance tracking. - Show that the audit scope is sufficiently representative of overall energy performance and the most significant improvement opportunities. - Keep lifecycle-cost analysis where possible, not only simple payback, so longer-term savings and residual values are visible. - Retain validated calculations behind proposed measures, including assumptions, baselines, expected savings, and data sources. Sources for this answer: - [Directive (EU) 2023/1791 Annex VI](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023L1791&ref=sorena.io) - Annex VI lists the minimum criteria for Article 11 energy audits, including traceable operational data, representative scope, proposed measures, validated calculations, and storable audit data. - [European Commission Energy Efficiency Directive overview](https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-rules/energy-efficiency-directive_en?ref=sorena.io) - The Commission overview confirms that EU countries must ensure appropriate competence for energy auditors, energy managers, and related professionals. ## Primary sources - [Directive (EU) 2023/1791 Article 11 and Annex VI](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023L1791&ref=sorena.io) - Primary legal source for the 85 TJ and 10 TJ Article 11 thresholds, energy management system and audit obligations, action-plan publication rule, authority-information rule, and Annex VI audit criteria. - Quote: "higher than 10 TJ of energy" - [European Commission Energy Efficiency Directive overview](https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-rules/energy-efficiency-directive_en?ref=sorena.io) - Commission overview supporting the revised Directive context, the Article 11 guidance reference, and the shift from company-size-only audit obligations to energy-consumption thresholds. - Quote: "energy management systems and energy audits" - [Commission Recommendation (EU) 2024/2002 on Article 11](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024H2002&qid=1719245800368&ref=sorena.io) - Official Commission recommendation identified in the grounding material as the Article 11 interpretive guidance for energy management systems and energy audits. - Quote: "interpretation of Article 11" ## Related Topic Guides - [Annex VI energy audit criteria under the EU Energy Efficiency Directive](/artifacts/eu/energy-efficiency-directive/annex-vi-audits.md): A grounded guide to the Annex VI minimum criteria for EU Energy Efficiency Directive energy audits: data quality, representative scope, LCCA, calculations, recommendations, and evidence. - 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