What you need to know about publishing energy efficiency measures
With the Energy Efficiency Act (EnEfG) coming into force in 2023, many energy-intensive companies will face new legal requirements. One of the key obligations is the creation of so-called implementation plans in accordance with Section 9 EnEfG. These plans should specifically show how identified energy-saving measures can be implemented promptly and economically: an important building block on the path to greater energy efficiency and climate protection.
But what exactly does the law require? Who is affected? And how can an implementation plan be drawn up efficiently and in a practical manner?
This article provides a comprehensive overview of the legal basis, content requirements, and practical implementation – including deadlines, pitfalls, and tips for legally compliant documentation.
What is an implementation plan according to Section 9 of the Energy Efficiency Act (EnEfG)? – Overview and significance
Was die Form der Umsetzungspläne angeht, hat das BAFA ein Merkblatt veröffentlicht (Merkblatt zum Energieeffizienzgesetz), dort sind alle relevanten Informationen enthalten. Wir geben hier noch einen kurzen Überblick, was dort auftauchen muss:
- Prioritisation of measures: Measures must be ranked according to their priority, either by numbering them or by using a separate prioritisation system.
- Name of the identified measure: Please ensure that the name matches the measures calculated in the energy management or audit so that clear allocation is possible.
- Calculated investment volume: Taken from the measure calculation, may be rounded
- Timeframe for implementation: all phases of implementation, starting with planning, should be specified to the month.
- Origin of the measure: Is the source of the measure the energy audit, the company’s energy team, the workforce, etc.?
- Responsibility for implementation: Which department is responsible for implementing the measure?
- Information on implementation progress: Is the measure “open”, “in progress” or already “completed”?
The implementation plans can be published in various ways. There are two main options that are worth highlighting here.
One option is to publish it on the company’s website. Here, a sub-item on the energy management system can be implemented, or the plans can be presented as part of the company’s policy.
There is also the option of publishing the implementation plans as part of the annual financial report.
As a general rule, implementation plans must be publicly accessible.
For whom is an implementation plan mandatory under the Energy Efficiency Act?
Specifically, the obligation to draw up an implementation plan applies to all companies with an annual total final energy consumption of more than 2.5 gigawatt hours (GWh).
It does not matter whether it is electricity, gas, heat, or other energy sources – what matters is the total consumption of all company locations within Germany. Again, caution is advised here: transport or fleet fuels are included here, as is local heating consumed by renting office space.
Environmental heat, such as that used by heat pumps, is not included in the calculation. If you are unsure about how to calculate your energy consumption, please contact the BAFA (https://www.bafa.de/DE/Energie/Energieberatung/Energieaudit/energieaudit_node.html) or contact us directly.
These are the requirements that the EnEfG places on implementation plans
If my company is subject to the obligation to publish implementation plans, certain requirements still apply, first and foremost the measures themselves and then the publication.
Not all measures need to be included in the implementation plans. The EnEfG merely refers to “economic measures” and provides a direct explanation of what makes a measure economic:
A measure is considered economical if, when assessing its economic efficiency in accordance with DIN EN 17463, December 2021 edition, it yields a positive net present value after a maximum of 50 percent of its useful life, but limited to measures with a maximum operating life of 15 years.
This directly leads to two requirements, namely that the measures must be calculated in accordance with DIN 17463 and that the net present value must be positive after no more than half of the useful life. This is somewhat awkwardly worded, but can be reduced to the following context: the dynamic ROI is less than half of the useful life. In the case of 15 years, this means less than 7.5 years. The last sentence of this excerpt from the law means that measures with a useful life of more than 15 years (such as PV systems) generally do not have to be published.
The useful life for a measure can be found in VDI 2067 or the AfA tables. Alternatively, a reasonable estimate based on the current state of the art is also acceptable.
Interaction with energy audits and energy management systems according to ISO 50001
However, this raises the question: Where do the measures that I am required to publish come from, and how should I calculate them in accordance with DIN 17463?
In most cases, there is no problem, as all companies that are required to publish measures must also have carried out at least one energy audit or even maintain an active energy management system. In both cases, the calculation of measures in accordance with DIN 17463 is mandatory.
The obligation to publish only applies to measures in audits and action plans completed after November 19th, 2023. This means that companies that only became subject to energy audits in 2026 will have more than just a few months to publish the measures.
If an energy audit has not been carried out properly and the measures have not been calculated correctly, this should be rectified immediately within this framework.
Caution: At present, the implementation plans still need to be reviewed by energy auditors or energy management system certifiers.
Conclusion: Implementation plan in accordance with Section 9 of the Energy Efficiency Act (EnEfG) – obligation and opportunity for energy-intensive companies
The obligation to draw up an implementation plan in accordance with Section 9 of the Energy Efficiency Act (EnEfG) is more than just a formal requirement – it is an opportunity for companies to systematically identify potential savings and implement targeted, sustainable measures. Those who address the requirements at an early stage will not only benefit from legal certainty, but also from long-term cost reductions and a clear competitive advantage in times of rising energy prices and growing sustainability expectations.
A well-structured and realistic implementation plan lays the foundation for effective energy efficiency measures – and shows that economic efficiency and climate protection can go hand in hand. Companies that take action now will secure a decisive advantage.
Do you require assistance in drawing up a legally compliant implementation plan?
Haven’t you conducted an energy audit yet?
Were your measures not assessed in accordance with DIN 17463?
Our experts will help you to efficiently implement the legal requirements of the EnEfG – in a practical, economical manner tailored to your company’s individual needs.
This blog article was created with the support of generative AI and then carefully supplemented and corrected by us. In addition, comparable tools were used to perform SEO optimisation (this ensures that search engines find and rank this article highly). For this reason, the following keywords were added to the text, which could not be included in the text without compromising readability: end-use energy saving measures, platform for waste heat, EDL-G, environmental auditor, § 8, implementation plans for end-use energy saving measures, create and publish, energy audits according to § 8, Federal Office for Economic Affairs and Export Control, concrete implementation plans, implementation plans prior to publication, certifier, create and publish implementation plans; In addition, the English version of the article was translated using comparable software but carefully revised by a non-native speaker. Please use the contact form in case of serious linguistic mishaps.