If the three-year average is higher than 85 TJ, the EU-level answer is the energy management system route. Article 11 requires a certified energy management system, and the system has to be certified by an independent body under relevant European or international standards.
If the three-year average is higher than 10 TJ but not handled through an energy management system, the EU-level answer is the energy audit route. Article 11 requires a first audit by 11 October 2026 and subsequent audits at least every four years. The enterprise must also prepare a concrete and feasible action plan based on audit recommendations, submit it to management, and publish the action plan and recommendation implementation rate in the annual report subject to trade-secret and confidentiality protections.
If neither threshold is met, keep a monitoring file rather than declaring the Directive irrelevant forever. Recalculate the rolling three-year average each year because acquisitions, disposals, new sites, electrification, production changes, outsourced energy services, or renewable self-consumption can change the result. Commission guidance says a later entrant should generally have one year to complete the audit or two years to implement the EMS, but the Directive does not state those later-entrant periods expressly; national law controls the operative deadline.