European Energy Efficiency Directive: Changes Catalan Companies Must Know

The 11th of October 2026 was the date set by the Directive (EU) 2023/1791 for companies with an average consumption exceeding 10 TJ per year to have completed their first energy audit, regardless of their size. In Spain, according to the Ministry for Ecological Transition and the Demographic Challenge (MITECO), the royal decree that must implement this regulation is still being drafted. The obligations currently in force remain those of the Royal Decree 56/2016.

From Company Size to Energy Consumption

Until now, the obligation to audit depended on size. The Royal Decree 56/2016 transposed the previous directive (2012/27/EU) and applies to large companies, meaning those that are not SMEs. The European regulation of 2023 changes this criterion. Its Article 11 considers the average annual energy consumption over the three preceding years, summing all energy vectors.

It sets two thresholds. Above 10 TJ (about 2.78 GWh), the company must undergo an energy audit every four years. Above 85 TJ (about 23.6 GWh), it must also have an energy management system. The guidance note published by the European Commission in the Official Journal of the EU sets the implementation of these systems for October 2027.

For the Catalan business fabric, the change has direct implications. An SME with ovens, cold storage, or energy-intensive machinery can exceed 10 TJ without being a large company. A large company with contained consumption could, however, fall outside the new criteria. Those below the thresholds have no obligation, but the Commission itself recommends that they also undergo audits.

What is Required Today in Spain

MITECO indicates on its website that Royal Decree 56/2016 remains the national reference standard until the transposition becomes effective. Obligated entities must conduct an audit every four years that covers at least 85% of the total energy consumption of their facilities in national territory. They must also submit the results to the energy efficiency body of the autonomous community where the facilities are located, within a maximum period of three months. A certified energy management system can substitute for the audit.

The department opened a prior public consultation between 10th and 28th March 2025 on the draft royal decree for energy audits and energy services. This text will incorporate Article 11, Article 29, and Annex VI of the directive, which outlines the minimum quality criteria for audits.

Meanwhile, Brussels has begun to take action. In November 2025, it opened infringement procedures against several member states for failing to communicate the complete transposition of the directive.

In principle, a directive obliges the state and not directly the company. The threshold of 10 TJ will not be a specific obligation for each company until there is a Spanish regulation that incorporates it. This does not halt the European timeline, and companies arriving without data or audits will find themselves rushed when the text is published.

How to Get Ahead

The first step is simple: calculate the average consumption of the last three years by adding electricity, gas, and fuels, and compare it with the two thresholds. With that number, it can be determined whether the company is on the directive's radar or if, for now, it is not.

The second is to review what has already been done. Those who already audit according to Royal Decree 56/2016 or have a certified system start with an advantage, although they will need to check if their audit meets the criteria of Annex VI. The facilities must be measured in sufficient detail to identify the most significant energy uses.

The third is not to wait for the BOE to know the starting point. An audit conducted now is equally useful for detecting where energy is being lost, and its cost is offset by the savings it helps to identify.

This is the focus of the engineering firm Cavo Energías, with a branch in Barcelona (Calle Bailén, 50). Their team evaluates the energy performance of companies, defines savings measures, and supports implementation. They offer energy audits for companies, as well as related services such as the implementation of management systems according to ISO 50001 or the remote measurement of consumption.

What needs to be monitored now is the publication in the BOE of the royal decree that transposes Article 11. This text will set the national deadlines for the companies that the directive incorporates for the first time.