A new legislative framework for energy efficiency will be implemented in our country as a result of the European Directive 2023/1791. This Directive establishes the principle of “energy efficiency first” as a fundamental principle of EU energy policy, giving it legal status for the first time. This means that energy efficiency must be considered in all relevant policies and major investment decisions taken in both the energy and non-energy sectors.
The Implementation of the Directive into national legislation is expected by October 2025, through amendments to the current energy law (Law 4342/2015, 4843/2021). One of the most important changes concerns the way of identifying the companies subject to energy efficiency obligations. From now on, the obligation will not be based on the size of the company, but on the average annual energy consumption in the previous three years.
For 2025, the obligation will be based on the average annual final energy consumption of the company in 2022, 2023 and 2024. This means that companies should already start collecting and preparing data.
The new requirements for businesses are as follows:
- Companies with an average annual energy consumption of more than 85 TJ over the last three years are required to implement a certified Energy Management System (such as ISO 50001) or a certified Environmental Management System (e.g. ISO 14001, EMAS), provided that it includes an energy audit in accordance with the minimum criteria of Annex VI. The deadline for compliance is 11/10/2027.
- Companies with an average annual energy consumption of more than 10 TJ over the last three years are required to implement a certified Energy Management System (ISO 50001) or a certified Environmental Management System (ISO 14001, EMAS), provided that it includes an energy audit in accordance with the minimum criteria of Annex VI. Alternatively, they must undergo an energy audit and the recommendations from the energy audit must result in a concrete and achievable action plan; the action plans, as well as the extent to which the recommendations have been implemented, must be published in the company’s annual report and made public. The energy audit should be repeated every four years. The deadline for compliance is 11/10/2026
The implementation of energy and/or environmental management systems offers significant advantages over simple compliance with the obligation of energy audits, as:
- It ensures continuous improvement of energy efficiency through specific standards, such as ISO 50001.
- It engages senior management and staff in energy management.
- It leads to organised and sustained energy management actions, rather than occasional initiatives.
- It provides a structured basis for making energy saving investment decisions, including economic criteria.
- It sets compliance with legislation as a minimum requirement, allowing for further improvement.
- Ensures the quality of audits through certification by an accredited body.