EnEfG and EDL-G: audit, plans and management system

Germany’s Energy Efficiency Act, the EnEfG (Energieeffizienzgesetz), has applied since 18 November 2023. It ties its own duties to actual energy consumption rather than company size: a management system above 7.5 GWh and published implementation plans above 2.5 GWh. The energy-audit duty for non-SMEs under the EDL-G continues alongside it. For a company that does not know its consumption, or is only now approaching the thresholds, the question is which duty applies when, and what a storage system has to do with it.

Two thresholds, two duties

The EnEfG sets two thresholds for the average annual total final energy consumption over the last three completed calendar years. Companies above 7.5 GWh must set up and run an energy or environmental management system under §8 EnEfG, for example to ISO 50001 or EMAS. Companies above 2.5 GWh must draw up and publish concrete, implementable action plans for all economically viable final-energy-saving measures under §9 EnEfG, whether or not they also fall under the management-system duty above 7.5 GWh. A company can therefore be required to act purely because of the action-plan duty, without running a full management system.

Deadlines

For companies that had already exceeded the 7.5 GWh threshold when the law took effect on 18 November 2023, the deadline to set up a management system ran to 18 July 2025. Companies that reach the threshold later have 20 months from that point. The action plans under §9 EnEfG must be published within three years of completing certification or re-certification of the management system, or of completing the energy audit, and a certifier, environmental verifier or energy auditor must first confirm their completeness and accuracy.

Where the EDL-G still applies

Below the 7.5 GWh threshold, the duty to run an energy audit under §8 EDL-G (Energiedienstleistungsgesetz, Energy Services Act) still applies to companies that are not SMEs. The EnEfG has not replaced the EDL-G; the two laws apply side by side, depending on consumption. An energy audit under the EDL-G follows the methodology of DIN EN 16247-1, which sets requirements, a common methodology and result formats for energy audits, and applies to businesses of every kind, with the exception of individual private residential buildings. For companies with total energy consumption across all energy sources of 500,000 kWh a year or less, §8 EDL-G itself provides a simplified procedure in place of the full audit; what counts is the company’s total consumption, not the consumption of a single connection point.

ISO 50001, ISO 50002 and DIN EN 16247-1 compared

ISO 50001 is a management-system standard with annual surveillance audits and re-certification every three years, built for continual improvement of energy efficiency. DIN EN 16247-1 and ISO 50002, by contrast, are not management-system standards; they describe the methodology of a single energy audit without providing for certification of the company itself. The four-year cycle for an energy audit is set not by the standard but by §8 EDL-G. A company below the management duty can choose an energy audit under DIN EN 16247-1, or build a management system voluntarily if the ongoing improvement process offers more value than the recurring single audit.

Where storage and solar PV appear among the measures

Both an energy audit under DIN EN 16247-1 and an energy management system under ISO 50001 identify measures to cut final energy consumption or improve energy efficiency. A battery storage system primarily changes when and how power is drawn from the grid, less the total consumption itself. It typically appears as a complementary measure alongside efficiency measures in the narrower sense, for instance where peak shaving or a higher self-consumption share from an existing PV system becomes part of the action plans. The assessment needs solid consumption data, not estimates.

Spot checks and the duty to document

§10 EnEfG provides for spot checks by which the responsible authority verifies whether companies actually meet their §8 and §9 duties, both setting up an energy or environmental management system and publishing the action plans on time. A company should therefore document not only the measures themselves but also the evidence for them from the start, so it is complete if a check occurs rather than needing to be reconstructed afterwards.

A company approaching the thresholds for the first time benefits from clarifying its average consumption over the last three completed calendar years early, because that average, not the consumption of a single year, decides the duty. A one-off spike, say from a particularly energy-intensive project, can trigger a duty that lapses again only once the three-year average falls back below the threshold.

A company under neither threshold can still choose an energy audit or an energy management system voluntarily, for instance to build a solid basis for future investment decisions before any duty arises. Whether and when the EnEfG thresholds apply to a business, and which measures follow from that, is what an energy audit that systematically evaluates its own consumption data establishes. As of September 2026.

Sources

1. §8 EnEfG, gesetze-im-internet.de
2. §9 EnEfG, gesetze-im-internet.de
3. §8 EDL-G, gesetze-im-internet.de
4. BAFA, energy audits under EDL-G and energy/environmental management systems under EnEfG (in German)
5. DIN EN 16247-1, DIN Media
6. ISO 50001:2018, iso.org