Article 11 of the Energy Efficiency Directive (EED) sets requirements on enterprises to implement energy management systems or conduct energy audits based on their energy consumption.
Within DEESME 2050 project, a study has been carried out to assess the practical and economic implications of Article 11 of the EED for SMEs across different industrial sectors. Beyond quantifying the number and size of affected enterprises, the study also examines the cost-effectiveness of energy audits in relation to consumption levels and enterprise size.
Analysis across all EU Member States shows that most SMEs consume between 0.1 and 2 TJ annually. Only around 5-10% exceed the 10 TJ threshold that triggers mandatory energy audits. For the majority of SMEs, full compliance with audit or EMS obligations would not be economically justified. Instead, proportionate approaches such as simplified audits, as developed under DEESME 2050, can achieve similar energy savings at significantly lower cost and limited administrative burdens. For energy-intensive SMEs, however, full energy audits and comprehensive EMS remain appropriate and cost-effective. Energy audits and management systems enable firms to reduce operating costs, improve process efficiency, and shield themselves from energy price volatility. When evaluated through the Multiple Benefits approach, the economic returns of energy efficiency investments increase substantially. In many cases, payback periods are reduced by nearly half.
Overall, a proportionate implementation of Article 11, combined with MB-based evaluation, offers the most cost-effective and competitive pathway for SMEs. In this way, energy efficiency becomes not just a regulatory requirement, but a strategic driver of resilience and competitiveness for Europe’s SMEs.
The full article is available for download at this link.




