Energy audits from 10 TJ, energy management systems from 85 TJ
The landscape of energy regulation has changed. Under the recast European Energy Efficiency Directive (EED, 2023/1791), compliance is no longer determined by the size of your company, but by how much energy you actually consume. The "large enterprise" criterion disappears.
For sites in Flanders, it is not the Directive itself that binds you, but the Flemish transposition of it. That sits in the decree the Flemish Government approved in principle on 17 July 2026. It sets different dates and different thresholds from the Directive — and that is precisely where organisations that rely on the European texts get it wrong.
Status. The Flemish decree is still a draft. It has yet to go for advice to the Flemish Utility Regulator, the Flemish Supervisory Commission and the Council of State, and must then be definitively approved and published in the Belgian Official Gazette. Thresholds, dates and percentages may still change. We track the file and keep this page current.
What applies to your site?
All obligations apply per site, on the basis of the average annual final energy consumption over the previous three years. That three-year average is new — today a single consumption year is used. If you fluctuate around a threshold, you may land differently than you expect.
| Consumption | Obligation | Deadline |
|---|---|---|
| Under 10 TJ ± 2.8 GWh |
None | — |
| 10 – 50 TJ ± 2.8 – 13.9 GWh |
Enterprise energy audit | 1 July 2027 |
| 50 – 85 TJ ± 13.9 – 23.6 GWh |
Enterprise energy audit | 1 July 2027 |
| 85 – 100 TJ ± 23.6 – 27.8 GWh |
Energy audit plus energy management system | 1 July 2027 11 October 2027 |
| From 100 TJ ± 27.8 GWh |
Compliance-approved energy plan plus energy management system | 1 October 2027 11 October 2027 |
Four things that are regularly overlooked.
The audit obligation in Flanders runs to 100 TJ, not to 85 TJ. Above 100 TJ there is no audit but a compliance-approved energy plan — a heavier instrument, declared compliant by the Flemish Energy and Climate Agency (VEKA).
Between 85 and 100 TJ, two obligations run in parallel, with different deadlines. Note that the Flemish draft does not treat a certified energy management system as an exemption from the audit. Under the Directive, the audit obligation applies to enterprises above 10 TJ that do not implement an energy management system; the Flemish text lists different exemption routes, so an ISO 50001 certificate on its own does not remove the audit requirement here.
The Flemish deadline for the audit is 1 July 2027, not the European date of October 2026. If you cross a threshold later, you have until the first six months of the following calendar year — nine months for the energy plan.
Already hold a valid energy audit or enterprise energy balance? It remains valid for the remainder of its term. At the next update, the new rules apply. Note also that the enterprise energy balance is abolished and absorbed into the energy audit.
It is about the measures, not the report
This is where most organisations misjudge the regime. In Flanders an energy audit is not a report you file away. Within three years of submission you must implement:
10 – 50 TJ: all measures with a payback period shorter than three years;
50 – 100 TJ: all measures with an internal rate of return of at least 13% after tax.
New is that renewable energy measures that produce an energy saving also enter that mandatory list — heat pumps drawing on ambient or waste heat, electric rather than thermal motors, mechanical vapour recompression.
There is flexibility. A measure with an internal rate of return of at least 13% and a payback period longer than three years can, on reasoned request to the VEKA, be substituted by a less profitable measure delivering an equivalent saving, by the export of waste heat beyond the site boundary with equivalent energy content, or by a substitute measure approved under an energy policy agreement.
What you allow into the audit therefore determines what you must invest over the next three years. That makes the quality of the profitability calculation anything but a formality.
Energy management system from 85 TJ: four routes
Above 85 TJ you must have an energy management system implemented by 11 October 2027, certified by an independent body in accordance with the relevant European or international standards. But certification is not the only route.
1. ISO 50001 certification. Certification to NBN EN ISO 50001 is deemed to satisfy the requirement. The most direct path, and the one with the longest lead time.
2. Accession to EBO3. Energy management measures approved under an energy policy agreement (Energiebeleidsovereenkomst) count as an energy management system. The draft text attaches no further condition to this route. That makes EBO3 the most accessible way out — and it is no coincidence that the 85 TJ threshold coincides with the target group proposed for EBO3.
3. Environmental management system. A certified ISO 14001 system or an EMAS registration exempts you, but only in so far as it includes an energy plan (above 100 TJ) or an enterprise energy audit (between 85 and 100 TJ).
4. Energy performance contract. Exempts you provided the contract meets the thirteen substantive conditions of Annex XV to the EED — guaranteed savings, measurement and verification provisions, baseline data, penalties for non-performance — and itself includes an energy management system or an environmental management system.
How We Help You Comply
Consumption analysis. We calculate your three-year average per site and establish your exact obligation — including the industrial or agricultural parts outside your non-residential EPC, which count towards the threshold and are often forgotten.Route selection. The assessment between ISO 50001, accession to EBO3, your existing environmental management system or an energy performance contract, with the conditions attached to each route.
Baseline review. We map your existing ISO 9001 or 14001 processes against the ISO 50001 requirements and against what the VEKA expects.
Metering infrastructure. Establishing whether your data passes the "current, measured and traceable" test, and what is missing if it doesn't.
Audit and energy plan. Preparation, profitability calculation on a life-cycle cost basis, and submission in the VEKA web application.
Implementation and follow-up. The chronological action plan, the grid connection application within the deadline, and the transparency reporting in your annual report.
Leverage Your Existing ISO Standards
Already certified to ISO 14001 or ISO 9001? Then you have more than a head start: under the Flemish draft decree, ISO 14001 or EMAS can exempt you entirely from the energy management system — provided the system includes an energy plan or energy audit. That proviso is exactly the work we do.
All modern ISO standards share the harmonised structure: the same core terms, the same document control systems, the same management review processes. We specialise in integrated management systems, which lets you:
avoid redundancy — we don't build a second system, we add an energy layer to the one you have;
streamline your audits — combined internal audits for quality, environment and energy in a single cycle;
certify faster — reusing an existing framework is substantially quicker than starting over.
Certification
We have been and are involved in the certification of multiple ISO50001 certification assignments. As a partner for major certification organisations.