To check whether a business exceeds 10 or 85 terajoules, do not rely on a single electricity bill. The threshold is based on average annual energy consumption over the previous three years and includes all relevant energy carriers.
What the EED thresholds require
Article 11 of Directive (EU) 2023/1791 sets two bands. Businesses averaging more than 10 TJ must carry out an energy audit at least every four years, unless they meet the applicable energy-management-system requirements. Above 85 TJ, a certified energy management system is required.
The calculation covers total consumption across relevant carriers, including electricity, gas and fuels. 10 TJ is about 2.78 GWh; 85 TJ is about 23.61 GWh.
- Use the three-year annual average, not one month or one supplier.
- Convert all carriers to a consistent unit before adding them.
European dates under Article 11
The directive’s transposition deadline was 11 October 2025. European Commission guidance interprets 11 October 2026 as the first audit deadline for businesses above 10 TJ, and 11 October 2027 as the deadline to establish an energy management system above 85 TJ.
For businesses in Italy, also check current national legislation and implementing provisions. A general EU timeline or infringement procedure is not a substitute for verifying the national requirements that apply to a specific company.
How to estimate whether the business exceeds 10 TJ
Collect at least three years of consistent consumption data, covering all energy carriers and using comparable units and periods. Define which company sites and activities belong in the calculation under the applicable rules.
After calculating the average, check which band applies and whether an exemption is available. Businesses close to a threshold should verify conversions, missing data and the reporting perimeter with a qualified professional.
From the threshold to an improvement plan
An audit should do more than confirm an obligation: break down consumption by site and process, identify waste, rank measures and estimate savings. An ISO 50001 system can put monitoring, targets and continual improvement into an ongoing management cycle.
Check national requirements and involve a qualified professional before setting the timetable.
Worked example using three years
Assume annual consumption of 2.60 GWh, 2.90 GWh and 3.10 GWh. The average is 2.87 GWh. Since 1 TJ is about 277.78 MWh, that average is approximately 10.32 TJ, above the 10 TJ threshold.
This example is illustrative. Use complete data, the correct perimeter and applicable conversion factors; check carefully when the result is close to a threshold.
- Average the three annual values; do not add the three-year total.
- Convert every carrier before summing.
- The directive refers to consumption “above” the stated threshold.
Data to gather before deciding
Prepare an annual table for electricity, gas, fuels and other carriers. Record each unit, coverage period, source, site and conversion factor; invoices are a starting point and may need internal meter or production data.
An audit and a certified energy management system are not interchangeable in every case. The right route depends on the consumption band, applicable exemptions and current national rules.