Under Italian Legislative Decree 102/2014, an energy audit (diagnosi energetica) is a systematic procedure used to understand the energy consumption profile of a site, to identify and quantify cost-effective savings opportunities, and to report the findings. For some companies it is an obligation that recurs every four years; for all of them it is the document from which investments, incentives and energy management systems start.
Who is obliged today
As of 10 October 2026 the rule is Article 8 of Legislative Decree 102/2014, in the text in force since 29 July 2020. The obligation covers the production sites in Italy of two categories of companies.
| Who | Criterion | What they must do |
|---|---|---|
| Large enterprises | More than 250 employees together with annual turnover above €50 million or a balance sheet total above €43 million, for two consecutive financial years | Audit every 4 years |
| Energy-intensive companies | Listed in the CSEA registers, whatever their size | Audit every 4 years and, between one audit and the next, at least one of the measures identified or an ISO 50001 system |
| Excluded | Large enterprises below 50 toe per year; companies with ISO 50001 that includes an audit compliant with Annex 2 | Documentation to ENEA instead of the audit |
Employees, turnover and balance sheet are calculated including linked and partner enterprises (ministerial clarifications of 2016): a small subsidiary may turn out to be «large» because of its group. And the exemption for management systems now concerns ISO 50001 only: EMAS and ISO 14001 no longer appear in the text in force.
Deadlines, checks and penalties
Companies that complied in December 2023 have their next deadline in December 2027, but calendars vary: at the 5 December 2025 deadline ENEA received 671 audits from 438 obliged entities. Each year ENEA checks a sample of companies, equal to at least 3%, and all audits carried out by in-house auditors.
An audit not carried out costs from €4,000 to €40,000, a non-compliant one from €2,000 to €20,000; paying does not remove the duty to do it. For energy-intensive companies that neither implement the measures nor adopt ISO 50001 the penalty ranges from €1,000 to €10,000. The effect on relief schemes weighs more: since 28 April 2026 ENEA has been checking all companies, and the audit must be valid and uploaded to Audit102 on the date of the application to CSEA.
How it is carried out
The audit is conducted by energy service companies (ESCOs) or energy management experts (EGE), certified by accredited bodies under the UNI CEI 11352 and UNI CEI 11339 standards. The minimum criteria are in Annex 2 of the decree and in the UNI CEI EN 16247 standards.
Companies with several sites must list them all with their consumption and audit a proportionate and representative number of sites, also using the «clustering» method proposed by ENEA.
The European thresholds on the way
Directive (EU) 2023/1791 replaces the size criterion with average annual consumption over the previous three years, adding up all energy carriers.
| Average annual consumption | Obligation | Deadline in the directive |
|---|---|---|
| Above 10 TJ (about 2.8 GWh) | Energy audit at least every 4 years and an action plan submitted to the directors | First audit by 11 October 2026 |
| Above 85 TJ (about 23.6 GWh) | Certified energy management system | By 11 October 2027 |
Transposition was due by 11 October 2025 and Italy has not completed it: on 1 October 2026 the European Commission sent it a reasoned opinion (case INFR(2025)0334), with two months to reply. Until the national rule exists, the operative obligation remains the one in Article 8; the thresholds do show, however, who will be involved, including SMEs with high consumption that are excluded today.
For a business: what to look at
- Check your status every year. Size is read at group level and over two financial years; being listed in the CSEA registers obliges even an SME.
- Work out your TJ now. The sum of electricity, gas and other fuels over the last three years tells you whether you will exceed 10 or 85 TJ.
- Prepare the data before appointing the auditor. Bills and load curves, readings from internal meters, list of sites with their consumption, production volumes.
- Typical mistakes. Forgetting linked companies, excluding sites without giving reasons, assuming an exemption with EMAS or ISO 14001, leaving the identified measures in a drawer.
The measures that emerge can access white certificates, if the project is submitted before works start. To apply these rules to your sites there is the energy audit and efficiency service of IPGS ENERGY: Request a discussion.
Sources
- Normattiva — Legislative Decree 102/2014, Article 8 (energy audits) (accessed 10 October 2026)
- Normattiva — Legislative Decree 102/2014, Article 16 (penalties) (accessed 10 October 2026)
- MASE — Diagnosi energetiche, with the ministerial clarifications (accessed 10 October 2026)
- ENEA — Portale Audit102 (accessed 10 October 2026)
- ENEA — Diagnosi energetiche: online il Rapporto ENEA sui risultati al 2025 (accessed 10 October 2026)
- ENEA — Comunicazione inizio controlli delle imprese energivore, annualità di agevolazione 2026 (accessed 10 October 2026)
- EUR-Lex — Directive (EU) 2023/1791 on energy efficiency, Article 11 (accessed 10 October 2026)
- European Commission — October infringements package: key decisions on energy (accessed 10 October 2026)
Informational content by IPGS ENERGY. Information is reviewed as of the stated update date and does not replace a contractual, tax or regulatory assessment specific to an individual business.
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