In the language of Italian law, the energy manager is the «technical officer responsible for the conservation and rational use of energy»: the person an organisation names each year as the reference for its consumption. The law assigns three tasks: identifying actions and measures to use energy better, ensuring energy balances are prepared also in relation to economic parameters, and preparing the energy data requested by the Ministry.
When the appointment is mandatory
Article 19 of Law no. 10 of 9 January 1991 requires the appointment for entities that exceeded a consumption threshold in the previous year, expressed in tonnes of oil equivalent (toe).
The ministerial circular of 18 December 2014 clarifies that entities with an ATECO 2007 code in sections B, C, D, E and F are «industrial»; for all others the 1,000 toe threshold applies. The obligation concerns the individual legal entity, not the corporate group. Consumption is counted in primary sources and includes everything, also the fuel feeding a cogeneration plant and the energy included in service contracts.
| Carrier | Conversion factor | 10,000 toe is about | 1,000 toe is about |
|---|---|---|---|
| Electricity drawn from the grid | 0.187 toe per MWh | 53.5 GWh | 5.3 GWh |
| Natural gas | 0.836 toe per 1,000 Sm³ | 12 million Sm³ | 1.2 million Sm³ |
The factors are those of the circular and of the FIRE guidelines. Carriers add up: a company using electricity and gas exceeds the threshold before reaching the values in the table.
How and to whom it is filed
The law speaks of a communication to the Ministry; in practice appointments are collected by FIRE, the Italian Federation for the Rational Use of Energy, which manages the network of energy managers on behalf of the Ministry (now MASE). Filing is online only, on the NEMO platform, and must be repeated every year: the appointment is valid if sent by 23:59 on 30 April. Those appointing on a voluntary basis can do so at any time the first time, then follow the same deadline.
The officer can be an employee or an external professional with adequate experience. In large organisations, according to the circular, it is a management-level function, equivalent to the person responsible for the ISO 50001 management system.
What happens without an appointment
Article 19 excludes those who do not file the appointment from the incentives provided by the same law, and Article 34 provides for an administrative penalty that the text still expresses in lire: from 10 to 100 million, that is about €5,165 to about €51,646 (fixed rate of 1,936.27 lire per euro). There is also a practical effect: for white certificates the decree of 21 July 2025 asks entities obliged to appoint an energy manager to document the appointment for the current year, and FIRE makes the appointment data available to GSE.
Energy manager and EGE are not the same thing
| Aspect | Energy manager | EGE |
|---|---|---|
| What it is | A role assigned by the organisation | A person with certified skills |
| Reference | Law 10/1991, Article 19 | UNI CEI 11339 standard |
| Formal requirements | No mandatory certification | Personal certification issued by an accredited body |
| What it is for | Fulfils the appointment obligation | Can conduct mandatory audits; if appointed by the company, allows it to submit white certificate projects directly |
The two roles can coincide, but one does not replace the other.
For a business: what to look at
- Count your toe at the start of the year. You need the consumption of the year just closed for each carrier: electricity drawn and self-produced, gas, diesel and vehicle fuels, purchased heat. FIRE publishes a spreadsheet to check the thresholds.
- Use the right threshold. Logistics, large retail, private healthcare, data centres and offices fall under 1,000 toe, not 10,000.
- Register on NEMO in good time. Those appointing for the first time must register before the deadline, with the documents signed by the legal representative.
- Typical mistakes. Treating the appointment as valid «until revoked» (it is annual), forgetting self-production in the calculation, appointing a person with no mandate or access to data, confusing the appointment with EGE certification.
Below the threshold the appointment remains possible on a voluntary basis, often together with an energy audit. If you need a check of your consumption in toe or external support for your officer, the energy consulting of IPGS ENERGY starts from there: Request a discussion.
Sources
- Normattiva — Law 9 January 1991, no. 10, Article 19 (accessed 10 October 2026)
- Normattiva — Law 9 January 1991, no. 10, Article 34 (penalties) (accessed 10 October 2026)
- MASE — Energy manager, with the circular of 18 December 2014 (accessed 10 October 2026)
- FIRE — Nomina dell'energy manager (accessed 10 October 2026)
- FIRE — Linee guida per la comunicazione della nomina dell'energy manager (accessed 10 October 2026)
- Normattiva — Legislative Decree 4 July 2014, no. 102, Article 2 (definition of EGE) (accessed 10 October 2026)
- GSE — MASE Decree of 21 July 2025 on white certificates (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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