Regulatory energy audit (France)
Quadrennial obligation for large companies and entities consuming more than 2.75 GWh of final energy

The DDADUE energy audit (article L.233-1 of the French Energy Code, transposing EU Directive 2012/27 and the EED 2023/1791) requires large companies to undergo a complete audit every four years. The 2024 regime refocuses the obligation on a consumption threshold of more than 2.75 GWh of final energy averaged over the last three years. The audit, compliant with NF EN 16247:2022, must cover at least 80% of consumption and conclude with a costed action plan. NORMAXIS steers the process in coordination with qualified partner auditors.

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2024 regime shift

The threshold has changed: 2.75 GWh of final consumption replaces the headcount/turnover criterion.

The transposition of the EED 2023/1791 by the French DDADUE law and its implementing decrees has evolved the scope. Since June 2024, any entity, regardless of headcount or turnover, whose annual final-energy consumption exceeds 2.75 GWh (about 236 toe) averaged over the last three years must conduct an audit compliant with NF EN 16247:2022 and submit the report on ADEME's AIDER platform.

Scope threshold

> 2.75 GWh/year averaged over 3 years (final energy)

Periodicity

4 years, rolling cycle since 2015

Filing platform

AIDER, ADEME (aider.ademe.fr)

Scope

Who must conduct a DDADUE audit?

Since 2024, the obligation applies to any company, public body or economic entity consuming more than 2.75 GWh of final energy per year averaged over the last three operating years (article L.233-1 of the French Energy Code as amended by the DDADUE law).

The new criterion replaces the former dual threshold (headcount > 250 OR turnover > €50M with balance sheet > €43M) inherited from Directive 2012/27/EU. Switching to a consumption-based criterion targets high-energy-impact entities regardless of commercial size.

Audit perimeter:

  • The audit must cover at least 80 % of the company's total energy bill (order of 20 May 2015 as amended and order of 24 June 2024).
  • It covers all energy vectors: electricity, gas, district heating networks, fuels, biomass, fuel oil, LPG.
  • It distinguishes buildings (NF EN 16247-2), processes (NF EN 16247-3) and transport (NF EN 16247-4) uses.
  • It is delivered by an external qualified auditor (OPQIBI 18.01 buildings, 18.02 processes, 18.03 transport, or European equivalent qualifications), or by a qualified internal auditor for companies with recognised in-house competence.

ISO 50001 exemption: a company certified ISO 50001 on a scope covering at least 80 % of its consumption is exempted from the DDADUE audit (article L.233-2 of the French Energy Code). The certification must be in force and properly renewed.

Regulatory framework

The texts to know.

  • Directive 2012/27/EU of 25 October 2012, Energy Efficiency Directive (EED), article 8: EU basis of the audit obligation for large companies.
  • EED Directive 2023/1791 of 13 September 2023, recast of the EED, transposition by 11 October 2025. Lowers thresholds and reinforces consistency with the "Fit for 55" package.
  • French Law no. 2013-619 of 16 July 2013, known as "DDADUE" (Provisions adapting to EU law): first transposition of Directive 2012/27/EU.
  • French Law no. 2023-171 of 9 March 2023, DDADUE 2023 law: evolution of the audit regime.
  • Decree no. 2014-1393 of 24 November 2014 and decree no. 2023-444 of 7 June 2023, application terms and shift to the 2.75 GWh threshold.
  • Articles L.233-1 to L.233-5 and R.233-1 to R.233-9 of the French Energy Code, codification of the obligation, auditor competences, report content and sanction regime.
  • Order of 20 May 2015 as amended and order of 24 June 2024, technical application terms: 80 % perimeter, report content, required qualifications.
  • Standard NF EN 16247:2022, energy audit method. Five parts: general requirements (-1), buildings (-2), processes (-3), transport (-4), auditor competences (-5).
  • AIDER platform, ADEME, official report-filing portal (aider.ademe.fr).

Audit content

What a complete NF EN 16247 audit produces.

NF EN 16247:2022 structures the audit into six phases. The final deliverable is an audit report and a costed action plan, usable to arbitrate energy investments and feed a potential ISO 50001 management system.

  1. 1

    Preliminary contact and framing

    Definition of audit perimeter, identification of covered sites and activities, selection of energy vectors and dominant uses, target performance criteria, schedule and expected deliverables.

  2. 2

    Kick-off meeting and data collection

    Collection of energy invoices for the last three fiscal years, plans and technical schematics, equipment inventories, production data, operating hours, usage procedures. Mapping of existing meters.

  3. 3

    Site visit and measurements

    Field observation, instrumented readings (thermography, network analysers, flow meters, wattmeters), check of BMS setpoints and control loops, verification of load factors and efficiencies, interviews with operators.

  4. 4

    Analysis and modelling

    Calculation of energy performance indicators (EnPI) by use, sector benchmarking, identification of gaps, modelling of improvement scenarios, evaluation of expected energy savings and payback times.

  5. 5

    Audit report and action plan

    Structured report compliant with NF EN 16247: executive summary, energy mapping, prioritised action plan (savings, CAPEX, OPEX, payback, CEE energy-saving certificates), recommendations for follow-up and durability.

  6. 6

    AIDER ADEME submission and feedback

    Structured submission of the report and action plan on ADEME's AIDER platform, validation of compliance with the expected format, filing certificate, oral feedback to management and operational teams.

DDADUE audit benchmarks

Key thresholds to remember.

2.75 GWh

Scope threshold

Decree no. 2023-444, final consumption average 3 years

4 years

Audit cycle

Article L.233-1 French Energy Code

80 %

Minimum coverage

Total energy bill, order of 20 May 2015 as amended

2 %

Max fine on excl. VAT turnover

Non-compliance sanction, article L.233-5

DDADUE energy audit FAQ

Frequently asked questions.

Since the 2023 DDADUE law and decree no. 2023-444 of 7 June 2023, any company or economic entity consuming more than 2.75 GWh of final energy per year averaged over the last three years is subject to the audit obligation (article L.233-1 of the French Energy Code). This criterion replaces the former threshold of headcount > 250 or turnover > €50M. The audit is quadrennial.
The report must comply with NF EN 16247:2022 and cover at least 80 % of the total energy bill. It includes: an executive summary, energy mapping by vector and by use, calculated energy performance indicators (EnPI), a prioritised action plan with expected savings, CAPEX, payback and CEE energy-saving certificates, recommendations for follow-up. It is submitted on ADEME's AIDER platform.
The auditor must hold a qualification recognised by the French ministry: OPQIBI 18.01 for buildings, OPQIBI 18.02 for industrial processes, OPQIBI 18.03 for transport. European equivalent qualifications are also accepted (order of 24 November 2014 and order of 24 June 2024). An internal auditor is accepted if duly qualified and independent from the audited services. NORMAXIS steers the process and relies on qualified partner auditors for the production of the legally opposable report.
Yes, under conditions. Article L.233-2 of the French Energy Code exempts companies certified ISO 50001 whose certification scope covers at least 80 % of total energy consumption. The certification must be in force, delivered by an independent third-party body. For partial scope, a complementary audit on the uncovered part is required.
Article L.233-5 of the French Energy Code provides an administrative fine of up to 2 % of excluding-VAT turnover for the last closed financial year, raised to 4 % in case of repeat offence. The DGEC (French Directorate-General for Energy and Climate) controls and may refer the matter to the administrative authority for sanction. Beyond the amount, non-compliance affects ESG ratings and may trigger further audits.
For a single-site company, a complete audit typically takes 2 to 4 months: framing (2 weeks), collection and visit (3-4 weeks), analysis and modelling (3-4 weeks), report and AIDER submission (2 weeks). For a multi-site portfolio or complex industrial site, the delay extends to 4-8 months. Upstream preparation (data reliability, metering) can start a year before the deadline.
Both schemes complement each other but are not the same. The DDADUE audit targets the company (legal entity consuming > 2.75 GWh), the Tertiary Decree targets the building (floor area ≥ 1,000 m²). A single group can be subject to both: the DDADUE audit then directly feeds the actions declared on OPERAT for its Tertiary Decree trajectory. NORMAXIS aligns both processes to avoid duplication.
The recast EED (2023/1791) must be transposed by 11 October 2025. It lowers thresholds (concept of “energy-intensive company”), reinforces audit frequency in some cases, and introduces minimum-implementation obligations for measures stemming from the audit. Companies already subject to the obligation have an interest in anticipating by integrating the recast requirements as early as the 2024-2025 audit, in particular through a gradual ISO 50001 alignment.

Related schemes

Neighbouring obligations to align.

NORMAXIS

French Tertiary Decree

For tertiary buildings ≥ 1,000 m²: the actions identified by the DDADUE audit feed the −40 %/−50 %/−60 % trajectory.

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Arkemep

MEP engineering office

Implementation of audit-driven actions: HVAC optimisation, BMS control, equipment replacement.

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NORMAXIS

CSRD, sustainability reporting

Audit data feed ESRS E1 climate (Scope 1-2 emissions) and CSRD reporting.

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Energy audit

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