EU Energy Efficiency Directive (EED): what it means for companies and buildings

The EU Energy Efficiency Directive (EED, Directive (EU) 2023/1791) no longer places obligations on companies according to their size but according to their energy consumption: companies consuming more than 85 TJ on a three-year average need an energy management system, and those consuming more than 10 TJ that do not introduce one need an energy audit with an action plan. Public bodies are additionally subject to savings targets and a renovation rate. In Germany, the directive is transposed through the Energy Efficiency Act (Energieeffizienzgesetz, EnEfG), which is currently being amended. This guide explains what the EED requires, which parts are already in the EnEfG and what role lighting and lighting control play.

What is the EED?

Alongside the EU Energy Performance of Buildings Directive (EPBD), the Energy Efficiency Directive is the EU's second major set of efficiency rules. The recast (EU) 2023/1791 was published in the Official Journal on 20 September 2023. According to the European Commission, member states had until October 2025 to transpose most of its provisions.

At its core is a binding EU target: final energy consumption is to fall by at least 11.7 % by 2030 compared with the 2020 projections. In addition, member states have annual energy savings obligations which, according to the Commission, rise in stages, to 1.5 % for 2026 and 2027 and 1.9 % from 2028.

While the EPBD targets buildings and their technical systems (in Germany via the GModG, see German energy laws and lighting control), the EED is aimed primarily at companies and public bodies and their total energy consumption.

Article 11: energy management and energy audits based on consumption

The most important change for companies is in Article 11. Previously, the audit obligation depended on whether a company was an SME. Now consumption is what counts:

Commission Recommendation (EU) 2024/2002 on the interpretation of Article 11 makes clear that the action plan must be presented to the company's management, should contain all technically or economically feasible recommendations and must be published in the annual report together with the implementation rate. All energy carriers and all uses count towards the thresholds; the recommendation explicitly mentions ventilation, lighting, heating, cooling, transport, data storage and production.

How Germany transposes the EED: the EnEfG

In Germany, company obligations are set out in the Energy Efficiency Act. The text currently in force already contains consumption-based thresholds:

• § 8 EnEfG: companies with an average annual total final energy consumption of more than 7.5 GWh must set up an energy or environmental management system. Among other things, it must identify technically feasible savings measures and assess them in accordance with DIN EN 17463.
• § 9 EnEfG: companies with more than 2.5 GWh must draw up concrete, feasible implementation plans for all measures classified as economic, have them confirmed and publish them. A measure is economic if it achieves a positive net present value after no more than 50 % of its service life.

The government draft amendment is intended to transpose the EED in full. According to the Bundestag, energy or environmental management systems are in future to be mandatory only from a consumption of 23.6 GWh instead of 7.5 GWh, which corresponds to the EU threshold of 85 TJ. How the audit obligation and the implementation plans will be regulated in detail will only be clear once the law has been passed. You can read more about today's obligations in the guide German energy laws and lighting control.

Public sector: leading by example with fixed targets

For public bodies, the EED is particularly specific. The Commission summarises it as follows: the public sector as a whole is to reduce its energy consumption by 1.9 % per year, and the annual renovation rate of 3 % for public buildings will in future apply to all levels of public administration.

Germany has transposed this in § 6 EnEfG:

• Public bodies with a total final energy consumption of at least 1 GWh per year must reduce their final energy consumption by 2 % annually, up to and including 2045.
• From 3 GWh, an energy or environmental management system had to be set up by 30 June 2026; between 1 and 3 GWh, a simplified energy management system.
• Missed savings must be made up in the following two years.

For municipalities with schools, sports halls and administrative buildings in particular, lighting is a lever that can be implemented quickly and measurably.

What the EED means for lighting

The EED does not prescribe any particular technology. It requires consumption to be recorded, savings measures to be identified and economic measures to be implemented. Lighting is an obvious candidate for three reasons:

• It counts: lighting is part of the energy consumption that determines whether the thresholds are exceeded.
• The savings are easy to document: presence and daylight control reduce operating hours and power, and energy monitoring makes the effect visible for each zone.
• It fits into the action plan: lighting control is a clearly defined measure with a clear cost-effectiveness calculation that can be assessed in accordance with DIN EN 17463.

Without dedicated metering, lighting is often only estimated in audits. A networked lighting control system, by contrast, provides consumption and occupancy data for each zone, as described in the guide Energy monitoring and occupancy data. You can estimate the savings that are realistic for your building with the savings calculator.

Relationship to the GModG and reporting obligations

The EED, EnEfG and GModG interlock without replacing one another:

The Commission also encourages member states to avoid duplicate reporting: companies that report under the CSRD should be able to integrate the action plan into their sustainability reporting. More on this in the guide CSRD and ESRS: reporting energy consumption. The requirements arising from the GModG are explained in German energy laws and lighting control.

How we support you

We survey your building on site, plan the sensors and zoning and show you the lighting control in 3D in advance in Sensora. We usually carry out the installation ourselves, or your own electrical contractor can do so if you prefer. We implement every project with the AU-Manager, so occupancy detection, zoning and monitoring are included, and the consumption data for each zone is available for audits, energy management and implementation plans. How the data reaches your building management system is shown in Energy monitoring and BMS. For your project, you can reach us via our contact page.