Energy audit of a company – new audit obligations

So far, the obligation to conduct an energy audit has mainly applied to large companies that met certain criteria, such as the number of employees or the amount of turnover. However, as a result of changes in regulations, 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 per year will be required to conduct an energy audit every four years. Companies consuming more than 85 TJ of energy per year will have to implement an energy management system compliant with the ISO 50001 standard by October 2027.

Extension of the obligation to conduct an energy audit of a company

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

• They employed an average of at least 250 employees,
• Their net turnover exceeded EUR 50 million, and their balance sheet assets exceeded EUR 43 million.

From 2026, the company size criterion will be replaced by annual final energy consumption. The introduction of this new approach is aimed at increasing energy efficiency in a wider range of companies, regardless of their size or turnover.

Guidelines for conducting an energy audit

An energy audit should include:

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

What does an energy audit of a company provide?

A company energy audit is an effective tool supporting strategic energy management. Its implementation allows the identification of the most important areas of energy consumption and indicates the most profitable directions of modernization, which translates into real savings and increased efficiency of production processes. By implementing audit recommendations, companies can significantly reduce energy intensity and thus reduce operating costs, improving their profitability and competitiveness.

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

What requirements must an auditor performing an energy audit of a company meet?

,,Currently, there are no precise requirements in Polish legislation regarding the qualifications of energy auditors conducting audits of companies. In practice, auditors are usually people with technical education in fields such as energy, environmental engineering, or construction, who have completed courses or postgraduate studies. However, the lack of formal regulations leads to the uneven quality of audits conducted.

Recently, the energy industry has been drawing attention to the need to introduce uniform qualification standards for auditors. Companies emphasize that these requirements should be broader than those for people preparing energy performance certificates, because audits require deeper knowledge.

In the context of future regulations, it is worth considering the fact that the government is planning an amendment to the Energy Efficiency Act, aimed at implementing the necessary changes. Although the details are not yet known, it is likely that the new regulations will take into account the issue of qualifications of energy auditors, which will contribute to improving the standards and quality of audits conducted.” – comments attorney Maciej Stępień.

To sum up, from 2026, Poland will undergo a significant change in the obligations related to energy audits for companies. The previous criteria based on the size of the company will be replaced by an analysis of the annual final energy consumption. Companies consuming more than 2,778 MWh of energy per year will be required to conduct an energy audit every four years. Companies whose consumption exceeds 23,611 MWh per year will have to implement an energy management system compliant with the ISO 50001 standard by October 2027. These changes are intended to increase energy efficiency in a wider range of companies, regardless of their size or turnover. The introduction of these obligations is a step towards more sustainable and conscious management of energy resources, while increasing the competitiveness of companies on the European market.