Energy management system, energy audit and climate audit in certain enterprises

Companies or groups with an average annual energy consumption of:

Over 10 TJ in the previous three years must report energy and climate audits every 4 years. Energy and climate audits must be conducted by an approved energy and climate audit-performing company (link).
Over 85 TJ in the previous three years must implement and maintain certified energy management and a climate audit every 4 years. Energy management must be certified by an approved certification body, and climate audits must be conducted by an approved energy and climate audit-performing company.

You can read more about the new rules in the guidance (only available in Danish) and in the current applicable regulation.

Companies that were not previously subject to energy audit requirements

A company with an annual energy consumption of over 85 TJ in the previous three years that was not subject to energy audit requirements must implement energy management and conduct a climate audit by August 1, 2026.

A company with an annual energy consumption between 10-85 TJ in the previous three years that was not subject to energy audit requirements must conduct an energy audit by August 1, 2025, and conduct a climate audit by August 1, 2026.

Companies that were previously subject to energy audit requirements

A company with an annual energy consumption of over 10 TJ in the previous three years that was subject to energy audit requirements must report documentation for the completed energy audit four years after the last reported energy audit, or for energy management or environmental management systems when the validity period of the existing certificate expires. Regardless of their deadlines due to previous reporting, companies must still conduct a climate audit by August 1, 2026.

The Danish Energy Agency has prepared a guide and a series of templates to be used for execution and reporting.

Guidance to energy management system, energy audits and climate audits

Reporting Excel sheet

Checklist for energy audits and climate audits (will be available later)

Companies must report their energy management system, energy audit, or climate audit through Virk.dk. Depending on what needs to be reported, the submission must include:

Reporting form (current energy consumption, CO2 emissions, savings projects, and action plan, applicable to all types).

Energy audit report.

Climate audit report.

Checklist.

Valid certificate for energy management or environmental management supplemented with an energy review.

Documentation of the energy review in connection with the implementation of environmental management.

To log in to Virk.dk, employee MitID must be used.

See the specific reporting requirements in the guide (only available in Danish).

Companies that, by agreement with the Danish Energy Agency, can report energy audits (including energy and environmental management) according to the rules in Executive Order 624 of 30/05/2023 must report the energy audit here: www.ens.dk/Energisyn - BEK 624 of 30-05-2023.

For the execution of energy or climate audits, an approved energy and climate audit-performing company must be used.
Administration of energy and climate audit-performing companies is handled by the Technological Institute (TI).

Administration of energy and climate audit-performing companies is managed by the Technological Institute (TI). The process and criteria for obtaining approval are available on TI's website.

The rules on energy audits stem from Directive (EU) 2023/1791 of the European Parliament and of the Council of 13 September 2023 on energy efficiency and amending Regulation (EU) 2023/955 (recast), while climate audits are established by the Agreement on Green Tax Reform for Industry, etc. of June 2022.

Energy and climate audits are being implemented into Danish legislation through both an act and an executive order to be published in week 24, including:

• Executive Order No. 761 of 18 June 2024 on mandatory energy management systems, energy audits, and climate audits in certain enterprises
• Executive Order on Promotion of Efficient Energy Use and Greenhouse Gas Reduction, LBK No. 296 of 17/03/2023
• Act amending the Act on Promotion of Efficient Energy Use and Greenhouse Gas Reduction, Act No. 669 of 11/06/2024
• EU's Energy Efficiency Directive of 2023 (Article 11 on energy management system and energy audits)
• Political agreement on the Green Tax Reform for industry, etc.