EU Energy Efficiency Directive Threshold Triage Workflow

Start with energy data, not company size. Article 11 uses average annual consumption over the previous three years and requires the calculation to take all energy carriers together.

Create one file per enterprise boundary and list each carrier separately before converting totals into a common energy unit. Eurostat describes energy balances as accounting for statistically significant energy products and converting commodity balances into a common energy unit such as TJ.

Route the result mechanically. The 85 TJ route requires an energy management system certified by an independent body. The 10 TJ route applies to enterprises above 10 TJ that do not implement an energy management system and makes them subject to an energy audit.

Do not substitute employee count, revenue, sector, or a single electricity meter for the threshold test unless a grounded source in the implementation file supports that narrower boundary.

For the audit route, the working output is not just an audit report. Article 11 requires a concrete and feasible action plan based on audit recommendations, management submission, and public availability of the action plan and implementation rate subject to trade-secret and confidentiality protections.

For the energy-management-system route, keep evidence that the system monitors actual energy consumption, includes actions to increase energy efficiency, measures progress, and is certified by an independent body under relevant European or international standards.

After the enterprise threshold route is assigned, run two narrow branch checks. These checks do not replace the 10 TJ and 85 TJ calculation; they capture separate EED facts that are grounded in the directive and Commission material.

Branch only when the facts are present in the evidence file. Do not infer data-centre status from cloud usage alone, and do not infer public-body status from public-sector customers alone.