EnEfG Information Sheet April 2026: What Has Changed

EnEfG Information Sheet April 2026: What Has Changed

The Federal Office for Economic Affairs and Export Control (BAFA) has revised its information sheet on the German Energy Efficiency Act (EnEfG) again. The seventh edition dated 30 April 2026 replaces all previous versions and is valid only in this current form. For companies with energy consumption from 2.5 or 7.5 GWh per year, the document remains the central guide to obligations under Sections 8 to 10 EnEfG.

Compared with the October 2025 edition, the substantive updates in the current version are manageable but immediately relevant for affected companies. The focus is on a more precise interpretation of the 90 percent rule for energy and environmental management systems and a streamlining of requirements for published implementation plans under Section 9 EnEfG. Below we explain the changes in the 7th edition and place them in the overall context of the information sheet.

What the EnEfG information sheet provides — and what it does not

The information sheet explains statutory EnEfG obligations for companies that must establish an energy management system (EnMS) according to DIN EN ISO 50001, an environmental management system (EMS) according to EMAS, or — from 2.5 GWh/a — create and publish implementation plans for economically viable final energy saving measures. It does not release companies from their own responsibility to assess whether they fall within scope, and it does not replace binding legal advice. The current version is available on the BAFA website under Energy → Energy consulting & energy audit → Publications.

Since the first edition, the information sheet has evolved considerably: from editorial updates and decision trees to the introduction of the 90 percent rule and detailed audit requirements for implementation plans and sample inspections. Our articles on the BAFA information sheet and changes to implementation plans provide additional background on earlier versions.

Overview of the 7th revision

According to the change log of the current edition, the updates of 30 April 2026 affect two chapters:

1. Chapter 4 – Clarification of site reference under the 90 percent rule

2. Chapter 5 – Reduction and clarification of content in published implementation plans

All other rules — such as thresholds, deadlines, economic assessments according to DIN EN 17463, sample audits, or fine provisions — remain in place from the previous edition. Companies should nevertheless review their existing processes against the current version, as older information sheet editions are no longer valid.

90 percent rule under Section 8 EnEfG: site reference clarified

Companies with average total final energy consumption of more than 7.5 GWh/a over the last three calendar years must establish an EnMS or EMS. The management system must cover at least 90 percent of the company's total final energy consumption — a requirement already introduced in earlier information sheet editions.

The April 2026 edition now clarifies the site reference of this rule. Key points:

The 90 percent rule applies exclusively to the individual obligated company. Cross-company pooling of consumption within a corporate group is not permitted.

All sites covered by the management system must be identifiable in the certificate or its annex. A detailed list of all sites does not necessarily have to be attached to the main certificate — it is sufficient if the main certificate refers to the scope of the management system, for example through an internal site list.

During a BAFA sample inspection, the company must be able to submit this internal site list as evidence of the certification scope.

Certificate and annex together must ensure that the covered sites account for 90 percent of total final energy consumption in aggregate.

For companies with multiple production sites, this means consumption must be assigned to sites without gaps and aligned with the certification body. Companies that previously applied group-wide approaches should review certificate documentation and internal site lists promptly.

The information sheet also continues to require companies with EnMS or EMS under Section 8 EnEfG to record and economically assess waste heat potential. Specific information on identified waste heat potential may need to be submitted to the waste heat platform (Section 17 EnEfG).

Implementation plans under Section 9 EnEfG: leaner publication

From 2.5 GWh/a, companies must create, have confirmed by independent third parties, and publish implementation plans within three years of an energy audit, EnMS certification, or EMAS registration. The 7th information sheet edition reduces and clarifies which information must appear in the public version: a transparent, traceable presentation of planned measures while protecting business and trade secrets — not every detail from the internal audit report.

Mandatory content in the published version

Active publication

Passive provision “on request” does not meet legal requirements. Permitted channels include annual reports, the company register, the company website, or sustainability reports — provided the respective company is clearly identifiable.

External confirmation and audit

These requirements remain unchanged: confirmation before publication is provided by EMAS environmental auditors, ISO 50001 certifiers, or BAFA-approved energy auditors. Audits require sample checks of excluded measures (at least 40 percent, at least five measures) and full review of measures saving more than 5 percent of total final energy consumption. Read more about audit obligations in our article on changes to implementation plans.

eeaser's implementation plan app supports companies in creating, updating, and publishing these plans in a structured way.

What has not changed — but still applies

Despite the focused April update, numerous rules from earlier editions remain relevant:

Thresholds and deadlines: 7.5 GWh/a for EnMS/EMS (20-month establishment period), 2.5 GWh/a for implementation plans (three years after audit or certification)

BAFA sample inspections under Section 10 EnEfG for management systems and implementation plans

Fines of up to EUR 100,000 for violations of Section 8 EnEfG and up to EUR 50,000 for violations of Section 9 EnEfG

Exemptions from economic assessment for measures up to EUR 2,000 net investment, already decided measures, and legally mandated measures

Opportunities and risks for companies

Benefits of the update:

-Clearer guidelines: Precision on sites and publication content reduces interpretation gaps and simplifies alignment with certification bodies.

-Leaner publication: Companies need to disclose fewer sensitive details publicly, as long as minimum content is complete.

-Planning certainty: The information sheet continues to consolidate all central EnEfG requirements in one place.

Risks and challenges:

-Remediation for multi-site companies: Those who previously applied the 90 percent rule at group level must adjust certificate scope and site lists.

-Ongoing update obligation: Older information sheet versions are invalid; compliance processes must reflect the 30 April 2026 status.

-Fine and audit pressure: Sample inspections and publication requirements from previous editions remain fully enforceable.

Conclusion: Small adjustment, significant practical impact

The seventh edition of BAFA's EnEfG information sheet dated 30 April 2026 does not represent a fundamental realignment, but two practically relevant clarifications: the explicit site reference of the 90 percent rule and a clearer boundary for publication content in implementation plans. Companies already working to the October 2025 information sheet should in particular review certificate documentation and public implementation plans against the new edition.

Specialised tools can support EnEfG compliance — from the implementation plan app and VALERI tool to the waste heat platform for Section 17 EnEfG notifications. The current information sheet is available on the BAFA website.

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