Company energy audit – new audit obligations

Company energy audit – new audit obligations

A company energy audit is a detailed analysis of a company’s energy consumption, aimed at identifying areas where savings can be made and energy efficiency improved. It is not only a legal requirement, but also a strategic tool that enables the optimization of various energy sources. During the audit, processes, technologies, and areas where energy efficiency measures can be implemented are examined. Conducting the audit is a fundamental element of the strategy for companies striving to reduce greenhouse gas emissions and achieve sustainable development.

Until now, the obligation to conduct a company energy audit applied mainly to large enterprises that met certain criteria, such as the number of employees or turnover. However, due to regulatory changes, starting from 2026, this obligation will be extended to smaller companies. According to the new regulations, companies consuming from 10 TJ (approximately 2,778 MWh) of energy annually will be required to conduct a company energy audit every four years. Companies consuming more than 85 TJ of energy annually will be required to implement an energy management system compliant with ISO 50001 by October 2027.

Extension of the obligation to conduct a company energy audit

Currently, the obligation to conduct a company energy audit applies to companies that in the last two financial years met one of the following criteria:

  • Employed at least 250 employees on average annually,
  • Had a net turnover exceeding 50 million euros and their balance sheet total exceeded 43 million euros.

Starting from 2026, the size criteria will be replaced by annual final energy consumption. The introduction of this new approach aims to increase energy efficiency across a broader range of enterprises, regardless of their size or turnover.

Guidelines for conducting a company energy audit

A company energy audit should include:

  • an analysis of energy consumption in buildings, industrial installations, and transport, accounting for at least 90% of the company's total energy consumption,
  • identification of areas for improvement, including assessment of heating, cooling, lighting systems, and other energy devices,
  • proposals for actions to reduce energy consumption and lower operating costs,
  • life cycle cost analysis of buildings and installations, taking into account long-term energy savings,
  • ensuring a comprehensive assessment of the company’s energy efficiency and indicating specific improvement actions.

What are the benefits of a company energy audit?

The company energy audit is primarily an effective tool supporting strategic energy management. Its implementation allows the identification of key energy consumption areas and highlights the most profitable modernization directions, resulting in real savings and improved efficiency of production processes. By implementing audit recommendations, companies can significantly reduce energy intensity and thus lower operating costs, improving profitability and competitiveness.

The energy audit also plays an important role in building a company's resilience to energy price fluctuations and regulatory changes. It enables better investment planning and facilitates access to external financing – both from public sources (e.g., White Certificates, EU funds) and more favorable loan conditions for companies positively assessed in ESG terms. Improving energy efficiency supports environmental goals, increasing the chances of securing contracts, especially in international markets where low emissions and sustainable development are key.

What are the requirements for an auditor conducting a company energy audit?

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Currently, Polish legislation does not contain precise requirements regarding the qualifications of energy auditors conducting company energy audits. In practice, auditors are usually individuals with technical education in fields such as energy, environmental engineering, or construction, who have completed relevant courses or postgraduate studies. However, the lack of formal regulations results in inconsistent audit quality.

Recently, the energy industry has been emphasizing the need to introduce uniform qualification standards for auditors. Companies point out that these requirements should go beyond those applicable to individuals issuing energy performance certificates, as audits require deeper expertise.

In the context of future regulations, it is worth noting that the government is planning an amendment to the Energy Efficiency Act to implement necessary changes. Although details are not yet known, it is likely that the new provisions will include requirements for energy auditor qualifications, which will contribute to raising standards and improving audit quality.

Maciej Stępień Attorney

Summary

Starting from 2026, a significant change will occur in Poland regarding company energy audit obligations. The current criteria based on company size will be replaced by an analysis of annual final energy consumption. Companies consuming more than 2,778 MWh of energy annually will be required to conduct a company energy audit every four years. Companies with consumption exceeding 23,611 MWh annually will need to implement an energy management system compliant with ISO 50001 by October 2027. These changes aim to increase energy efficiency across a broader range of companies, regardless of their size or turnover. The introduction of these obligations marks a step toward more sustainable and conscious energy resource management while boosting companies' competitiveness in the European market.

Knowledge base

Is a company energy audit mandatory?

A company energy audit is a specialized set of analyses that identifies areas where energy consumption in a company can be reduced. For some businesses, it is a mandatory audit that must be carried out every four years. This audit involves a range of calculations and the development of the most promising and cost-effective energy efficiency measures that can be implemented in the company. It is a fundamental step and the most important pillar of a zero-emission strategy.

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Energy efficiency audit and enterprise energy audit

Energy audits play a significant role in the strategies of companies striving to increase energy efficiency, particularly in sectors with high energy consumption. For industrial companies that use significant amounts of energy, these audits not only enable savings but also serve as a tool for obtaining various forms of financial support, such as energy efficiency certificates, known as white certificates. In this article, we will compare energy efficiency audits and energy audits in the context of businesses, highlighting their key differences and importance.

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The green transformation, which forms the foundation of the EU’s climate strategies, is not just a buzzword – it is a broad set of regulations and initiatives that will strongly influence both Polish and foreign companies in the coming years. Regulations such as the European Green Deal, Fit for 55, and the EU ETS system require businesses to implement solutions that reduce CO₂ emissions, improve energy efficiency, and increase the share of renewable energy sources.

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