EU · Directive (EU) 2023/1791, Article 11
The EED energy audit: your portfolio is probably in scope now.
The 2023 recast of the Energy Efficiency Directive stopped measuring company size and started measuring energy. Any enterprise above 10 terajoules a year owes a completed energy audit by 11 October 2026. Three or four mid-size offices clear that threshold without trying.
What the EED is
The Energy Efficiency Directive is the EU law that sets the bloc's energy efficiency targets and the obligations behind them. The 2023 recast, Directive (EU) 2023/1791, replaced the 2012 and 2018 versions. Member states had until 11 October 2025 to write it into national law, so what you actually file is set by your national scheme. See EPBD for the buildings-specific directive.
Scope and thresholds
Who is in scope, and why real estate is unusually exposed.
The trigger changed from headcount to energy use. Real estate runs high consumption on small teams, which is exactly the profile the old test let through.
The two thresholds
10 TJ
2,778 MWh a year, averaged over the previous three years. Above this, you owe an energy audit by 11 October 2026, repeated at least every four years.
85 TJ
23,611 MWh a year. Above this, an audit is not enough. You must run a certified energy management system, typically ISO 50001, by 11 October 2027.
4 yr
The audit cycle. The action plan you publish in 2026 is what you get measured against in 2030.
The size test is gone
The previous directive caught "large enterprises": 250 or more employees, or turnover above 50 million euros with a balance sheet total above 43 million. Small and medium-sized enterprises were exempt no matter how much energy they used. The recast dropped that test entirely.
All energy carriers count together
Electricity, gas, district heat, and fuel are added up, not assessed separately. Vehicle fleets count too. Portfolios that check only their electricity bills routinely underestimate their position.
It applies at enterprise level, not per building
Consumption is aggregated across every site the enterprise operates. A portfolio where no single asset looks significant can still cross the line comfortably in aggregate.
10 TJ is smaller than it sounds
At 150 kWh per square meter per year, a common European office benchmark, 2,778 MWh is roughly 18,500 square meters of floor area. Logistics and retail sit lower per square meter, hospitality and data-heavy assets sit much higher.
Not sure where your portfolio sits?
Most companies estimate their position because they cannot add up all utilities across every site. Rhino gives you the actual number.
What the audit demands
An Article 11 audit runs on operating data, not invoices.
The audit has to be proportionate, representative, and built on real consumption. Four requirements do most of the damage to unprepared portfolios.
Cover the majority of your energy
The audit must cover a substantial majority of total final energy consumption, commonly set at 80% in national implementations and higher in some. You cannot audit your three best buildings and call it done.
See the platformMeasured data, not estimates
Auditors work from actual consumption profiles. Annual invoice totals technically satisfy some national schemes, but they cannot support the load profile analysis that produces credible savings recommendations.
Why interval data mattersAn action plan you publish
The recast added teeth. After the audit you must produce a concrete plan for implementing the recommendations, and publish information on that implementation. The audit no longer goes in a drawer.
See ESG & ComplianceEvidence within weeks, on request
National authorities sample and request proof. In Germany the window is typically four weeks from the letter. That is not enough time if the data for 40 buildings still sits with eight managers, three suppliers, and a folder of PDF invoices.
See the Utility Data APIThe second cycle is where a paper audit fails
If you have a small portfolio, a competent facilities team, and clean annual invoices, you can get through a first audit without changing anything. Plenty of companies will. What that approach does not survive is 2030: you cannot demonstrate that a measure delivered savings without consumption data from before and after it. Portfolios that treat 2026 as a document exercise tend to discover a few years later that they committed in public to savings they have no way to evidence.
See how savings get measured
The landlord question
Whose energy counts as yours?
This is the question that decides whether a portfolio is in scope, and the one most landlords answer with an assumption.
Shared parts are yours, without argument
Lighting, lifts, ventilation, car parks, outdoor areas, heating and cooling for common spaces, your own offices and operational buildings, and the vehicle fleet. Heating a lobby is your activity, not your tenant's.
Unmetered tenant supply usually counts as yours too
Where you supply energy to a tenant and the amount is not separately measured and known to that tenant, national implementations generally require you to count it as your own. The UK's ESOS states this explicitly, and the same logic runs through most member state guidance.
Read backwards, that is a lever
Every tenant supply you cannot measure inflates your own assessed consumption and can push you over a threshold you would otherwise sit under. Submetering does not just settle arguments with tenants. It narrows your own regulatory scope.
Corporate structure decides the test, not the energy
Where a national scheme still applies a group test, an SPV with two staff and one building can be pulled in by the fund or holding company above it. Status is assessed on the group. Energy consumption is assessed per legal entity. Confusing the two produces the wrong answer in both directions.
Get the boundary agreed early
Heat supply arrangements, tenant electricity models, and mixed-use assets stay open to interpretation. Settle the boundary with your auditor at the start. If it moves later, your coverage base moves with it and the audit has to be reworked.
The other EED obligation: Article 21
Billing on actual consumption. Article 21 requires that tenants are billed on what they actually used, not on an allocation key, with the supporting data available to them. For multi-tenant buildings in scope, this applies from 1 January 2027.
Same data, two obligations. The submeter reads that move tenant energy out of your audit scope are the same reads that make an Article 21 recharge defensible. You install once and satisfy both.
Frequency matters. Readable, regular consumption information is part of the requirement. An annual settlement statement built from one meter read a year does not meet it.
Where Rhino fits. Per-tenant, per-meter consumption at 15-minute granularity, tied to a billing period, feeding your billing workflow or your tenant app. See Tenant Billing & Engagement.
National implementation
The directive sets the rule. Your country sets the paperwork.
You do not file with Brussels. You file with a national authority, under a national scheme, against national thresholds. Here is where the main Rhino markets stand.
Netherlands
EED-auditplicht
- Authority
- RVO, reporting via eLoket
- Current test
- Large enterprise: 250+ FTE, or turnover above 50 million euros with a balance sheet above 43 million
- After transposition
- 10 TJ and 85 TJ thresholds. Dutch legislation is expected to apply from late 2026, with a one-year window for companies newly in scope
- Exemption
- ISO 50001, or ISO 14001 combined with ISO 14051, and approved quality labels
Germany
EDL-G, section 8
- Authority
- BAFA. Audit declaration within two months, plus sampled evidence checks
- Standard
- DIN EN 16247-1, with 90% coverage of total energy use, assessed per legal entity
- Changing in 2026
- The June 2026 cabinet draft moves the trigger to 2.77 GWh averaged over three years and lifts the energy management threshold from 7.5 to 23.6 GWh
- Penalties
- Up to 50,000 euros under EDL-G, up to 100,000 euros under EnEfG
Poland
Audyt energetyczny przedsiębiorstwa
- Authority
- President of URE, the Energy Regulatory Office
- Trigger
- The amended Energy Efficiency Act adopts the 10 TJ and 85 TJ thresholds, bringing thousands of SMEs into scope for the first time
- Notification
- Within 30 days of completing the audit, and no later than 31 December of the audit year
- Penalties
- Up to 5% of the previous financial year's revenue
United Kingdom
ESOS, Phase 4
- Authority
- Environment Agency, notification via the MESOS portal
- Status
- A separate UK scheme. It descends from the EED but no longer tracks it, so the 10 TJ trigger does not apply
- Qualification
- 250+ employees, or turnover of at least 44 million pounds with a balance sheet of at least 38 million. Qualification date 31 December 2026
- Deadline
- 5 December 2027, covering at least 95% of total energy use, signed off at board level
National schemes are still moving as member states finish transposing the recast. Confirm your obligation with your energy advisor or national authority before you plan resourcing. What does not change in any of them is the requirement to produce measured consumption data across your portfolio.
Rhino's role
Rhino does not run the audit. It feeds the people who do.
Rhino is the data layer between your meters and whoever needs the numbers: your auditor, your authority, your investors. Here is what that covers.
Know your actual position against the threshold
Rhino collects electricity, gas, water, and heat across every site, including submeters. That gives you a real total across all utilities instead of an estimate built from whichever invoices you could find, so you know which side of 10 TJ you are on before an auditor tells you.
Give the auditor load profiles, not invoice totals
Data arrives at 15-minute granularity. That is what lets an auditor see when a building actually runs, find the overnight base load nobody could explain, and produce recommendations worth implementing rather than a generic list.
Draw the landlord and tenant boundary with meters
Submeters are assigned to tenants, zones, and floors in the platform. Tenant consumption becomes separately measured and known, which is exactly the condition that moves it out of your assessed total and into theirs.
Evidence the action plan in the next cycle
Continuous history means you have the before-and-after record for every measure you committed to. When the progress report comes due, the savings claim is a query against your own data, not a modelled estimate.
Answer an evidence request in days, not weeks
Historical data is exportable to CSV and available through the Utility Data API. When a sampling letter arrives with a four-week clock, the numbers are already assembled.
How Rhino connects to your buildings
Software only: where a building has a smart meter, Rhino connects through the meter port or the utility's own data interface. No hardware, active within days.
Own hardware: for gas, water, and heat meters with no digital connection, Rhino installs compact devices alongside the existing meter. No meter replacement.
Existing infrastructure: where a BMS or wireless meter network is already in place, Rhino reads from the existing signal over WMBus, BACnet, or Modbus.
Low CAPEX: in every case Rhino connects to what is already installed. Data collection is the long pole in an audit, and this is the part that shortens it from months to weeks.
Common questions
The EED energy audit, answered.
Any enterprise whose average annual final energy consumption exceeded 10 terajoules over the previous three years, counting all energy carriers together across all sites. Company size no longer matters. Small and medium-sized enterprises that were exempt under the previous directive are in scope if they cross the energy threshold. The exact test you file against is set by your national transposition, so check whether your country has finished writing the recast into law.
10 terajoules equals 2,778 megawatt hours a year, since one terajoule is 277.8 MWh. The upper threshold of 85 TJ equals 23,611 MWh. For a commercial property portfolio at a typical office energy intensity of 150 kWh per square meter per year, 10 TJ is roughly 18,500 square meters of floor area, or three to four mid-size office buildings. The floor area figure is an illustration, not a legal test: your actual energy intensity decides where you land.
Energy you supply to shared parts counts as yours. Energy you supply to a tenant generally counts as yours too, where the amount is not separately measured and known to that tenant. Submetering tenant supplies moves that consumption off your assessment and onto theirs, which can keep a portfolio below a threshold it would otherwise cross. National guidance varies on edge cases such as heat supply and mixed-use assets, so agree the boundary with your auditor early. See Tenant Billing & Engagement for how the same data supports recharge.
Yes, in most national schemes. An enterprise holding ISO 50001 certification is generally exempt from the separate audit obligation, provided the certified system covers enough of its consumption. In the Netherlands, ISO 14001 combined with ISO 14051 is also accepted. Above 85 terajoules a year the choice disappears: a certified energy management system becomes mandatory by 11 October 2027, and going straight to a management system rather than commissioning an audit first is usually the cheaper path. The practical difference is continuity. An audit is a snapshot every four years. A management system requires you to monitor consumption continuously, act on what you find, and measure whether the action worked. You cannot run one on annual meter reads.
Enforcement is national. In Germany, failing to audit or filing false information is an administrative offence carrying fines up to 50,000 euros under the EDL-G, and up to 100,000 euros where the Energy Efficiency Act applies. In Poland the penalty reaches 5% of the previous financial year's revenue. In the Netherlands, RVO can impose a non-compliance penalty. The reputational cost with investors and lenders often outweighs the fine. The practical risk is timing rather than intent: assembling a clean twelve months of consumption data across a portfolio takes months, not weeks, so eight weeks before a deadline is late to start.
Data collection is the long pole. Start there.
Getting meter access agreed, submeters mapped to the right tenants, and a clean twelve months of history assembled across a portfolio takes months. Rhino connects to what is already in your buildings and delivers all utilities, including submeters, at 15-minute granularity.
Further reading
From the Rhino blog.
