The regulations framing the compulsory energy audits for large companies evolved significantly from October 1, 2025. A new decree, published on July 10, 2025 in the Official Journal, specifies the requirements of competence, methodology and restitution that the companies concerned will have to respect.
Here is what to remember to anticipate this deadline and remain in conformity.
Reminder: What is a DDADUE energy audit?
The DDADUE energy audit (resulting from the transposition of the European Directive 2012/27/EU) is an obligation for large companies (excluding SMEs) to carry out an energy audit of their activities every 4 years. It is the new European directive relating to energy efficiency (n ° 2023/1791) and which dates from September 2023 which revises the first directive of 2012:
This new legislation currently sets the level of energy savings that the EU must achieve to achieve the agreed objective of an improvement of 32.5% of energy efficiency by 2030.
The new directive has been transcribed in French law through the DDADUE law of April 30, 2025*.
This audit must cover at least 80 % of the total energy bill and include buildings, industrial processes, transport fleets. It aims to identify energy saving deposits and help structure short and medium term action plans.
In France, this obligation is supervised by article L233-1 of the energy code and hitherto concerned around 5,000 companies.
Which changes on October 1, 2025: new thresholds, new requirements
The decree of July 10, 2025 strengthens the eligibility criteria and specifies the terms of execution of DDADUE audits.
3 major developments must be remembered:
Revised thresholds: room for energy consumption
From October 1, 2025, the DDADUE audits subjugation criterion is no longer based on the size of the company (workforce or turnover), but on its annual consumption of final energy.
- Implementation of an Energy Management System (EMS) by 11/10/2027, if the average annual consumption of the company's final energy is greater than or equal to 23.6 GWh
- Creation of a compulsory energy audit every 4 years, now based on energy consumption, if the average annual consumption of final energy is greater than or equal to 2.75 GWh (calculation based on the last 3 years before the year of the audit)
- The implementation of an ISO 50 001 SME exempts companies from the realization of the compulsory energy audit
This means that many companies hitherto not concerned (especially in the tertiary sector, logistics or services) can now be subject as soon as their consumption reaches this threshold.
Strengthening technical requirements
The audit should be more exhaustive and more rigorous on the methodological level, with the mastery by the listeners of dynamic thermal simulation software (STD) capable of modeling energy uses and proposing encrypted scenarios.
The audit report must contain:
- A technical and economic analysis of the proposed actions
- A consumption measurement and monitoring plan
- Energy projection over several years
Communities also affected by the new DDADUE law
From October 1, 2025, the State, state operators and local authorities by more than 50,000 inhabitants will have to reduce their final energy consumption by at least 1.9 % compared to their reference consumption by 2021 each year.
This requirement will be gradually extended to smaller communities:
- from December 31, 2026 for those of less than 50,000 inhabitants
- As of December 31, 2029 for communities of less than 5,000 inhabitants
In parallel, these entities will have to renovate annually at least 3 % of the cumulative surface of their buildings in order to reduce their energy consumption and their greenhouse gas emissions.
These new structuring obligations mark a major acceleration of energy renovation policies in the public sector, now under reinforced and regular control.
New prerequisites on October 1, 2025: Focus on the decree of July 10, 2025 **
The new decree sets the criteria that the energy audits will have to be fulfilled to be admissible, as well as the expected skills of the listeners.
Compulsory certified listeners
The audit must be produced by:
- An internal auditor with training and attested experience.
- Or an external service provider certified according to standard NF in 16247-5,
“ The energy auditor is a thermalian who has carried out at least a mission of dimensioning heating, ventilation, DHW production equipment with cost costing and a mission comprising at least one of the following two actions:
- having carried out or controlled regulatory thermal studies
- Having made digital building models and its systems via dynamic thermal simulation tools (STD) or dynamic energy simulations.
The listeners of Sobre Energy, certified OPQIBI and AFNOR for the realization of the energy audits use the Pléiades d'Izuba software which allows the realization of such a STD.
Dynamic thermal simulation skills (STD)
For audits on buildings, Master of STD is now a requirement, to guarantee the reliability of modeling and recommendations. This type of simulation goes much further and makes it possible to integrate, in addition to energy performance, taking into account the thermal comfort of the occupants. With a detailed statement and an analysis of the building by functional area and according to climatic scenarios, a STD allows you to analyze summer comfort by looking at if the temperature exceeds 28 ° C in an area of the building in this season.
Compulsory realization certificate
A certificate of realization signed by the listener and by the representative of the audited company must be transmitted with the report, indicating compliance with methodological requirements and compliance with the rules set.
This certificate will be controlled by the certification organization to attest to the quality of the listener's work: "The certificate for carrying out energy audit aims to provide proof that the energy audit service has been the subject of a site visit to the audited objects, the delivery of a report of the preliminary contact, the delivery of a report of the start -up meeting and the delivery of a report From the audit provider to the company subject to the regulatory energy audit. »»