---
title: "EN 16247-1 audit structure under the EU Energy Efficiency Directive"
canonical_url: "https://www.sorena.io/artifacts/eu/energy-efficiency-directive/en-16247-audit-structure"
source_url: "https://www.sorena.io/artifacts/eu/energy-efficiency-directive/en-16247-audit-structure"
author: "Sorena AI"
description: "How to structure an EN 16247-1 energy audit for EED Article 11 and Annex VI: scope, data, site work, analysis, report outputs, recommendations, and evidence."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EN 16247-1"
  - "Energy Efficiency Directive Article 11"
  - "EED Annex VI"
  - "energy audit structure"
  - "energy audit report"
  - "energy audit evidence"
  - "Energy Efficiency Directive"
  - "Directive (EU) 2023/1791"
  - "Article 11"
  - "Annex VI"
  - "energy audits"
  - "energy management systems"
---
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# EN 16247-1 audit structure under the EU Energy Efficiency Directive

How to structure an EN 16247-1 energy audit for EED Article 11 and Annex VI: scope, data, site work, analysis, report outputs, recommendations, and evidence.

*EED* *EN 16247-1* *Audit structure*

## EN 16247-1 audit structure for EED Article 11 and Annex VI

Build an energy audit file that follows EN 16247-1's general audit methodology and the EU Energy Efficiency Directive's minimum criteria.

Use this page to organize scope, measured data, site work, calculations, report outputs, recommendations, and management evidence.

EN 16247-1:2022 is the general energy-audit standard covering requirements, common methodology, and deliverables for energy audits across establishments, organizations, energy forms, and energy uses. Under Directive (EU) 2023/1791, Article 11 makes energy audits and energy management systems part of the Energy Efficiency Directive framework, while Annex VI sets the minimum criteria that an audit must satisfy.

## Start with the Article 11 audit trigger and audit boundary

Article 11 separates enterprises that must implement a certified energy management system from enterprises that must undergo an energy audit when they do not implement such a system. The audit file should therefore start with the enterprise boundary, the three-year average energy-consumption basis, the energy carriers counted, and the reason an audit rather than a certified management system is being used.

EN 16247-1 should then be used as the structure for the audit method and deliverables. The standard is described as applying to all forms of establishments and organizations, all forms of energy, and all energy uses, with sector-specific parts adding detail for buildings, industrial processes, and transport.

- Record whether the enterprise is in the Article 11 energy-audit population or the energy-management-system population.
- Define the audit boundary before data collection: buildings or groups of buildings, industrial operations or installations, transport, and relevant energy carriers.
- Name the audit route: independent qualified or accredited expert, independent authority-supervised audit, in-house audit under a national quality scheme, voluntary agreement, environmental-management-system audit, or energy-performance-contract route where applicable.
- Keep a short boundary register showing included sites, excluded sites, included meters, energy carriers, operating periods, and the rationale for any sampling.

Sources for this answer:

- [Directive (EU) 2023/1791 on energy efficiency](https://eur-lex.europa.eu/eli/dir/2023/1791/oj?ref=sorena.io) - Article 11 provides the EED trigger for energy management systems and energy audits, including consumption thresholds, audit timing, independence routes, and action-plan follow-up.
- [EN 16247-1:2022 catalog entry](https://standards.iteh.ai/catalog/standards/cen/3fbb3fd5-0106-42d0-8b9f-cb546db8465a/en-16247-1-2022?ref=sorena.io) - Standards catalog source for EN 16247-1:2022 as the general energy-audit standard covering requirements, common methodology, deliverables, and broad audit applicability.

*Recommended next step*

*Placement: after evidence section*

## Structure an EED-ready energy audit evidence file

Use the EN 16247-1 audit structure to connect Article 11 scope, Annex VI data, site evidence, validated savings calculations, and management action-plan follow-up.

- [Open Research Copilot](/solutions/research-copilot.md): Check EED audit questions against cited directive and standards sources.
- [Discuss EED audit evidence](/contact.md): Review audit boundaries, source evidence, and action-plan records with Sorena.

## Build the data pack around Annex VI minimum criteria

Annex VI is the practical minimum-content test for an EED audit. It requires up-to-date, measured, traceable operational data on energy consumption and electricity load profiles, a detailed review of the energy-consumption profile, identification of energy-efficiency measures, and identification of cost-effective renewable-energy use or production potential.

The data pack should be audit-ready before site work starts. If a figure is estimated, normalized, allocated, or excluded, the audit evidence should show why the treatment is reasonable and how it affects the reliability of the overall energy-performance picture.

- Collect energy invoices, meter exports, sub-meter data, fuel records, electricity load profiles, production or occupancy data, operating schedules, weather or process drivers, and asset lists.
- Tie each dataset to a source, owner, period covered, unit, conversion factor if used, and validation status.
- Separate measured values from estimates and explain any missing meters, abnormal periods, shutdowns, acquisitions, disposals, or outsourcing changes.
- Keep data in a form that can be stored for historical analysis and later performance tracking.

Sources for this answer:

- [Directive (EU) 2023/1791 on energy efficiency](https://eur-lex.europa.eu/eli/dir/2023/1791/oj?ref=sorena.io) - Annex VI sets the minimum criteria for EED energy audits, including measured operational data, detailed consumption review, measures, renewables potential, life-cycle cost analysis, representative coverage, validated calculations, and storable data.
- [Commission study on minimum criteria for energy audits and energy management systems](https://energy.ec.europa.eu/publications/study-guidance-member-states-minimum-criteria-energy-audits-and-energy-management-systems_en?ref=sorena.io) - Commission publication describing guidance for Member State authorities on Article 8 and Annex VI minimum criteria under the earlier EED framework.

## Use site visits and measurements to validate the energy profile

EN 16247-1 gives the general audit methodology, while Annex VI requires the audit to be sufficiently representative to identify the most significant improvement opportunities. In practice, the audit plan should show where desktop data is enough and where site inspection, interviews, temporary metering, controls review, or load-profile checks are needed.

The evidence should make the auditor's judgement visible. A reviewer should be able to see which sites, assets, operating modes, and energy uses were observed; which readings or measurements were taken; and how those observations changed the consumption profile or recommendation list.

- Plan site work against the largest energy uses first, then cover material buildings, processes, utilities, transport activities, and control systems.
- Use interviews and walkthroughs to validate operating hours, setpoints, maintenance condition, control logic, occupancy, production intensity, and transport patterns.
- Use temporary measurement or load-profile analysis where invoices and annual meter totals are not enough to identify peak demand, standby losses, compressed-air losses, heating and cooling overlap, or process variability.
- Store site notes, photos where appropriate, meter screenshots, measurement periods, instrument identifiers, and assumptions with the audit file.

Sources for this answer:

- [Directive (EU) 2023/1791 on energy efficiency](https://eur-lex.europa.eu/eli/dir/2023/1791/oj?ref=sorena.io) - Annex VI requires a detailed review of the energy-consumption profile and representative audit coverage sufficient to identify significant opportunities for improvement.
- [BS EN 16247-1:2022 Energy audits - General requirements](https://www.en-standard.eu/bs-en-16247-1-2022-energy-audits-general-requirements/?ref=sorena.io) - Standards listing describing EN 16247-1 as covering audit stages from planning to reporting and the general requirements common to energy audits.

## Turn analysis into validated savings, not a loose opportunity list

Annex VI requires audits to allow detailed and validated calculations for proposed measures so they provide clear information on potential savings. The analysis section should therefore connect each recommendation to a baseline, method, assumptions, investment logic, expected energy savings, and non-energy constraints.

Where possible, Annex VI points teams toward life-cycle cost analysis rather than simple payback, so the audit structure should capture long-term savings, residual values, and discount-rate assumptions when those inputs are available. If simple payback is used because national practice or available data requires it, the audit should say so plainly.

- For each measure, record the affected energy use, current baseline, proposed change, calculation method, expected energy saving, cost inputs, dependencies, and uncertainty.
- Identify measures to decrease energy consumption and separately record cost-effective use or production of renewable energy where found.
- Flag recommendations that require shutdown windows, landlord approval, capital planning, safety review, production validation, district-heating or cooling feasibility checks, or procurement work.
- Keep rejected or deferred measures with the reason, because Article 11 action planning depends on assessing whether recommendations are technically or economically feasible.

Sources for this answer:

- [Directive (EU) 2023/1791 on energy efficiency](https://eur-lex.europa.eu/eli/dir/2023/1791/oj?ref=sorena.io) - Annex VI supports the need for validated savings calculations, life-cycle cost analysis where possible, renewable-energy potential, and representative identification of improvement opportunities.

## Make the report and action plan usable for Article 11 follow-up

The audit report should not stop at findings. Article 11 requires the concerned enterprise to draw up a concrete and feasible action plan based on audit recommendations, identify measures to implement each recommendation where technically or economically feasible, and submit that action plan to enterprise management.

For EED evidence, the report package should therefore include the audit scope, data register, audit method, site-work record, consumption profile, baseline, calculations, recommendation register, feasibility screening, action plan, management submission evidence, and implementation-rate tracking.

- Report outputs: executive summary, audit boundary, data quality statement, energy-consumption profile, significant energy uses, site findings, proposed measures, calculations, cost logic, renewable-potential findings, and limitations.
- Action-plan fields: recommendation ID, measure description, technical feasibility, economic feasibility, implementation owner, target window, dependency, expected savings, status, and management decision.
- Evidence fields: source dataset, meter or record owner, calculation workbook, site-visit note, review date, approver, publication or annual-report location where required, and confidentiality basis for any withheld information.
- Follow-up fields: implementation status, implementation-rate calculation, measured or estimated savings after implementation, variance from expected savings, and reason for deferral.

Sources for this answer:

- [Directive (EU) 2023/1791 on energy efficiency](https://eur-lex.europa.eu/eli/dir/2023/1791/oj?ref=sorena.io) - Article 11 requires a concrete and feasible action plan based on audit recommendations, management submission, publication of action plans and implementation rate subject to confidentiality protections, and audit follow-up at least every four years for covered enterprises.
- [Commission study on Article 8 energy audits and energy management systems](https://energy.ec.europa.eu/publications/study-implementation-energy-efficiency-directive-article-8-energy-audits-and-energy-management_en?ref=sorena.io) - Commission publication giving implementation context for energy-audit and energy-management-system obligations across Member States under the earlier Article 8 framework.

## Primary sources

- [Directive (EU) 2023/1791 on energy efficiency](https://eur-lex.europa.eu/eli/dir/2023/1791/oj?ref=sorena.io) - Primary legal source for EED Article 11 energy-management-system and energy-audit obligations and Annex VI minimum criteria for audit content, calculations, and data retention.
  - Quote: "MINIMUM CRITERIA FOR ENERGY AUDITS INCLUDING THOSE CARRIED OUT AS PART OF ENERGY MANAGEMENT SYSTEMS"
- [EN 16247-1:2022 catalog entry](https://standards.iteh.ai/catalog/standards/cen/3fbb3fd5-0106-42d0-8b9f-cb546db8465a/en-16247-1-2022?ref=sorena.io) - Standards catalog source for EN 16247-1:2022 as the general energy-audit requirements, methodology, and deliverables standard.
  - Quote: "This document specifies the requirements, common methodology and deliverables for energy audits."
- [BS EN 16247-1:2022 Energy audits - General requirements](https://www.en-standard.eu/bs-en-16247-1-2022-energy-audits-general-requirements/?ref=sorena.io) - Additional standards listing supporting the planning-to-reporting structure and general requirements framing for EN 16247-1:2022.
  - Quote: "Energy audits General requirements"
- [Commission study on minimum criteria for energy audits and energy management systems](https://energy.ec.europa.eu/publications/study-guidance-member-states-minimum-criteria-energy-audits-and-energy-management-systems_en?ref=sorena.io) - Commission publication supporting the connection between energy-audit implementation guidance and Annex VI minimum criteria.
  - Quote: "Article 8 and Annex VI requirements"
- [Commission study on Article 8 energy audits and energy management systems](https://energy.ec.europa.eu/publications/study-implementation-energy-efficiency-directive-article-8-energy-audits-and-energy-management_en?ref=sorena.io) - Commission publication giving implementation context for energy-audit and energy-management-system schemes across Member States.
  - Quote: "national implementation of Article 8"

## 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.
- [Does ISO 50001 satisfy Article 11 of the EU Energy Efficiency Directive?](/artifacts/eu/energy-efficiency-directive/faq/iso-50001-equivalence.md): FAQ on when ISO 50001 can support the Energy Efficiency Directive Article 11 energy-management-system route, when an energy audit is still needed, and what evidence to keep.
- [EED Article 11 action plans and national planning context](/artifacts/eu/energy-efficiency-directive/action-plans.md): How EU Energy Efficiency Directive action plans work: Article 11 audit-based enterprise plans, management approval, publication evidence, and the difference from national NEEAP and NECP planning.
- [EED Article 11 corporate group and site aggregation FAQ](/artifacts/eu/energy-efficiency-directive/faq/corporate-group-and-site-aggregation.md): How to calculate EU Energy Efficiency Directive Article 11 enterprise thresholds across sites, energy carriers, and national transposition rules.
- [EED Article 11 threshold calculation: 85 TJ and 10 TJ FAQ](/artifacts/eu/energy-efficiency-directive/faq/threshold-calculation.md): How to calculate EU Energy Efficiency Directive Article 11 enterprise thresholds using the previous three-year average, all energy carriers, and auditable evidence records.
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- [EED energy audit report contents: what should be included?](/artifacts/eu/energy-efficiency-directive/faq/audit-report-contents.md): FAQ on EU Energy Efficiency Directive audit report contents, covering Annex VI criteria, EN 16247 context, evidence, recommendations, and action-plan linkage.
- [EED National Transposition Evidence](/artifacts/eu/energy-efficiency-directive/national-transposition-evidence.md): How to evidence national transposition of Directive (EU) 2023/1791 without inventing Member State obligations: EU proof points, national-law checks, retained records, and source limits.
- [EED penalties: what does Directive (EU) 2023/1791 require?](/artifacts/eu/energy-efficiency-directive/faq/penalties.md): FAQ on EU Energy Efficiency Directive penalties, Member State enforcement rules, and the audit, energy-management, action-plan, and reporting evidence that reduces enforcement risk.
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- [EED public body obligations: 1.9% energy reduction and 3% renovation](/artifacts/eu/energy-efficiency-directive/public-body-obligations.md): source-linked guide to EU Energy Efficiency Directive public-body duties: Article 5 final-energy reduction, Article 6 building renovation, inventories, caveats, and evidence.
- [EED reporting and metrics: Article 11 action plans and Article 12 data centres](/artifacts/eu/energy-efficiency-directive/reporting-and-metrics.md): source-linked EU Energy Efficiency Directive reporting guide covering Article 11 audit action-plan records, Article 12 data-centre metrics, and Eurostat consumption indicators.
- [EED threshold triage workflow for 10 TJ and 85 TJ routes](/artifacts/eu/energy-efficiency-directive/threshold-triage-workflow.md): A source-grounded workflow for collecting all energy carriers, calculating the three-year average, and routing EED audit or energy-management-system actions.
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- [EU EED 85 TJ and 10 TJ enterprise thresholds under Article 11](/artifacts/eu/energy-efficiency-directive/85-tj-and-10-tj-enterprise-thresholds.md): Article 11 guidance for enterprises checking the EU Energy Efficiency Directive 85 TJ energy-management-system threshold and 10 TJ energy-audit threshold.
- [EU EED Article 11 Energy Audits: 10 TJ threshold, cadence, and evidence](/artifacts/eu/energy-efficiency-directive/energy-audits.md): Grounded guide to Energy Efficiency Directive Article 11 energy audit obligations, including the 10 TJ trigger, four-year cadence, Annex VI criteria, EN 16247 relation, and action-plan evidence.
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- [EU EED audit frequency: Article 11 cadence and EMS route](/artifacts/eu/energy-efficiency-directive/faq/audit-frequency.md): FAQ on EU Energy Efficiency Directive Article 11 audit frequency: 10 TJ and 85 TJ energy-consumption thresholds, first audit timing, four-year cadence, EMS alternative, and evidence.
- [EU EED Data Centre Reporting Workflow](/artifacts/eu/energy-efficiency-directive/data-centre-reporting-workflow.md): Workflow for identifying in-scope EU data centres, collecting Annex VII energy-performance data, checking evidence, and preparing annual EED reporting.
- [EU EED Implementation Rate Tracking: evidence fields and caveats](/artifacts/eu/energy-efficiency-directive/implementation-rate-tracking.md): Track Energy Efficiency Directive implementation without inventing a headline rate: NECP action status, Eurostat distance-to-target data, audit scheme records, owners, and transposition caveats.
- [EU Energy Efficiency Directive action plan evidence workflow](/artifacts/eu/energy-efficiency-directive/action-plan-evidence-workflow.md): Build an evidence workflow for EU Energy Efficiency Directive energy-audit and energy-management action plans, including records, owners, tracking fields, and review triggers.
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- [EU Energy Efficiency Directive Article 11 energy management systems](/artifacts/eu/energy-efficiency-directive/energy-management-systems.md): Article 11 EMS guide for enterprises above the 85 TJ threshold, covering certified energy management systems, audit links, action plans, energy data, and evidence.
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- [EU Energy Efficiency Directive compliance: audits, EMS, data centres](/artifacts/eu/energy-efficiency-directive/compliance.md): Grounded EU Energy Efficiency Directive compliance guide covering Article 11 energy management and audit thresholds, data-centre reporting, public-body duties, owners, and evidence.
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- [EU Energy Efficiency Directive penalties and enforcement risk](/artifacts/eu/energy-efficiency-directive/penalties-and-fines.md): Article 32 of the EU Energy Efficiency Directive leaves penalties to Member States. Use this page to understand the EU-level rule, the limits of EU-wide fine claims, and the evidence that lowers enforcement risk.
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