Industrial Energy Compliance: How Energy Savings Certificates Turn a Constraint into a Competitive Advantage

METADATA — PARTNER PUBLICATION
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Excerpt above title (EN):
EED Directive, ISO 50001, CSRD: how to fund your compliance through Energy Savings Certificates

Title (EN):
Industrial Energy Compliance: How Energy Savings Certificates Turn a Constraint into a Competitive Advantage

Short description (EN):
Three regulatory obligations converge in 2027 for French industrial operators: EED audit, ISO 50001 and carbon reporting. Discover how the CEE IND-UT-134 scheme can fund up to 90% of your energy metering equipment — while simultaneously covering your compliance requirements.
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ARTICLE — FULL ENGLISH VERSION
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France's industrial energy bills have risen by more than 50% since 2019 — while actual consumption has fallen by 16%. This paradox alone captures the pressure now bearing down on plant managers, technical directors and senior executives at French SMEs and mid-sized industrial companies.

On top of this economic strain, regulatory pressure is mounting: the revised EED Directive, ISO 50001, CSRD, and mandatory quadrennial energy audits. The timeline is tight. The penalties are real. And yet, most industrial operators are unaware that a public funding mechanism — the CEE IND-UT-134 scheme — can cover a significant share of the investments required for compliance.

This article explains, concretely, how to turn that constraint into a competitive advantage.

Contents:

1. The regulatory stack: what changes before 2027
2. The CEE IND-UT-134 scheme: the mechanism most industrials overlook
3. The strategic link between IND-UT-134 and ISO 50001
4. The CEE landscape in 2026: why act now
5. The reality on the ground: what still holds companies back
6. The hidden opportunity in utility systems
7. FAQ — Your questions answered

1. The regulatory stack: what changes before 2027

The EED Directive transposed into French law

The revised European Energy Efficiency Directive (EED 2023/1791) was transposed into French law by the DDADUE Act of 30 April 2025. It introduces two structural obligations for industrial operators:

The quadrennial energy audit is now mandatory for any site consuming more than 2.75 GWh/year. Typical costs range from €10,000 to €100,000 depending on site size and complexity.

ISO 50001 certification becomes mandatory before 11 October 2027 for sites consuming more than 23.6 GWh/year (85 TJ). This certification replaces the quadrennial audit obligation for companies that implement it.

The penalties for non-compliance are significant: up to 2% of annual turnover, rising to 4% for repeat offences. Loss of eligibility for public funding schemes is also provided for.

ISO 50001: a compliance obligation with an embedded savings opportunity

ISO 50001 is not merely an administrative requirement. Available studies — including an AFNOR study covering 486 certified organisations — show that companies deploying an Energy Management System (EnMS) compliant with this standard achieve average energy savings of 20%, with a 94% satisfaction rate.

Implementation typically takes 6 to 18 months. Initial costs range from €20,000 to €100,000 depending on company size. Average ROI is reached within 3 to 4 years — before accounting for available funding mechanisms.

CSRD: indirect pressure that remains real

The December 2025 Omnibus package raised the CSRD obligation threshold to 1,000 employees, exempting a large portion of mid-sized industrial companies. However, trickle-down effects remain strong: large buyers are progressively integrating carbon requirements into their procurement processes and supplier audits. SMEs and mid-caps operating as subcontractors to industrial groups or large retailers feel this pressure indirectly, even when not directly subject to the directive.

► Key takeaway: Three obligations converge in 2027 — EED audit, ISO 50001 and carbon reporting. A single instrumentation project, properly structured, can address all three.

2. The CEE IND-UT-134 scheme: the mechanism most industrials overlook

What is the IND-UT-134 scheme?

The IND-UT-134 standardised action sheet, published in January 2019 and revised in October 2020, covers systems for measuring energy performance indicators (EPIs) in industry.

In practice, it enables companies to fund — through Energy Savings Certificates (CEE) — all the equipment needed to establish a compliant industrial metering plan: meters, measuring instruments, data loggers, communication gateways, and energy management software.

Eligible utility systems cover a broad scope:
- Heat production and distribution
- Compressed air
- Industrial refrigeration
- Thermal or electrical processes
- Other motorised systems

The main eligibility conditions are:
- Nominal equipment capacity below 10 MW
- Data collection at a maximum interval of 10 minutes (for standard processes)
- Compliance with standard NF EN 17267 for the metering plan
- Sustained maintenance of the metering plan over time

The supervision software may be purchased outright or leased on a subscription basis — which opens up interesting financial structuring options.

Concrete funding levels

The grant calculation formula depends on the capacity of covered equipment, the site's operating hours, and the duration of commitment. Coefficients are favourable for sites operating on two- or three-shift schedules.

On correctly structured multi-site instrumentation projects, IND-UT-134 grants covering between 70% and 90% of total investment have been achieved. The residual cost to the company can thus fall to just a few percent of the initial project value.

This level of coverage is not automatic: it results from a well-framed application, with compliant equipment and a metering plan that is correctly structured from the outset. You can estimate your potential using our online CEE calculator.

Why is this scheme so rarely used?

Paradoxically, the IND-UT-134 sheet is rarely among the first mentioned by industrial operators when the topic of CEE comes up. Several structural reasons explain this.

The perceived complexity is real: the NF EN 17267 standard requires a six-step process, sustained maintenance of the metering plan over time, and rigorous documentation. For an SME without dedicated resources, this can seem out of reach.

The indirect nature of the savings is less intuitive than for material-based schemes (variable speed drives, insulation, heat exchangers): the IND-UT-134 scheme does not directly reduce consumption — it creates the conditions to detect and correct energy drift. The savings are real, but they require expert support to be quantified and captured.

Lack of awareness of available schemes is widespread. According to data compiled by MEDEF and parliamentary reports, 84% of industrial companies say they do not understand the available support, and 50% give up on it — despite the significant funding potential.

Exclusion of EU-ETS sites means the scheme does not reach the largest industrial energy consumers, who would arguably benefit most from a structured metering system.

3. The strategic link between IND-UT-134 and ISO 50001

This is where the most important — and least understood — angle of this scheme lies.

One metering plan, two obligations covered

The NF EN 17267 standard, required by the CEE IND-UT-134 scheme, is directly compatible with the monitoring and measurement requirements of section 4.6.1 of ISO 50001. Both frameworks share the same logic of structured metering plans: measurement scope, granularity, data collection frequency, and performance indicators.

In other words: an industrial operator who deploys a metering plan compliant with the IND-UT-134 scheme simultaneously lays the technical foundation for ISO 50001 certification. The two are not identical in the strict sense — certification requires broader governance and a continuous improvement process — but the instrumentation and measurement plan are shared.

This virtuous cycle can be structured as follows:

1. CEE IND-UT-134 funding covers instrumentation and supervision software
2. The resulting NF EN 17267 metering plan is ISO 50001-compliant
3. ISO 50001 certification replaces the quadrennial energy audit (saving €10,000 to €100,000)
4. Collected data enables detection of energy drift and development of a savings action plan
5. Resulting savings (20% on average, per AFNOR) recover the residual investment within 3 to 4 years
6. Automated energy reporting supports CSRD compliance for companies in scope

One project, properly planned, can cover this entire trajectory.

► Is your site eligible? OXA Groupe offers a free 15–30 minute assessment to evaluate your IND-UT-134 eligibility and ISO 50001 roadmap.

The PRO-SMEn programme as a complement

For companies seeking ISO 50001 certification, the ADEME's PRO-SMEn programme offers a supplementary grant covering 20% of support costs, capped at €40,000. This programme has a budget of €11.2 million for the 2023–2026 period.

The combination of CEE IND-UT-134 + PRO-SMEn can therefore cover a very significant share of total compliance costs.

4. The CEE landscape in 2026: why act now

The 6th obligation period has launched with a sharp increase in targets

The decree of 30 October 2025 launched the 6th CEE obligation period (2026–2030). Energy supplier obligations increase by 35% compared to the 5th period, to 1,050 TWh cumac/year.

This increase in obligations creates mechanical upward pressure on CEE prices, which traded between €8 and €9/MWh cumac at end 2024–2025. Industrial operators who commit their projects now will benefit from favourable pricing conditions, in a market where demand for certificates is set to intensify.

New schemes and enhanced bonuses

The 6th period introduces several innovations favourable to industry: a ×2 bonus multiplier for waste heat recovery and conversion schemes, new action sheets IND-UT-137, 138 and 139 (effective 1 January 2025), and the 2026–2035 PPE energy planning framework confirming the central role of CEE in French energy policy.

Conversely, several widely used schemes have been revoked or modified (IND-UT-117 and IND-UT-121 in August 2025). The stability of the IND-UT-134 sheet — unchanged since October 2020 — is therefore a genuine asset for projects to be structured now.

5. The reality on the ground: what still holds companies back

The obstacles industrial operators face in pursuing energy efficiency are well documented. An OpinionWay/Equans survey of industrial decision-makers from April 2025 identifies three main barriers: upfront cost (30%), solution complexity (27%), and the regulatory framework itself, perceived as unstable (25%).

These barriers are real. But they are not insurmountable.

On upfront cost: CEE mechanisms, properly activated, can cover the bulk of instrumentation investment. Self-financing logic is achievable — provided the application is structured correctly from the scoping phase.

On complexity: the IND-UT-134 scheme does require a rigorous approach. But that rigour is precisely what guarantees the durability of savings. Support from experienced field experts — capable of both sizing the metering plan and building the CEE application — turns that complexity into a competitive advantage.

On regulatory instability: it is real (71 amending orders since 2006), but the underlying trajectory is clear. ISO 50001 will be required. Audits will be enforced. Penalties are increasing. Waiting only reduces the available funding window.

6. The hidden opportunity in utility systems

Energy metering systems are often perceived as tools for managing electricity consumption. That is a narrow view.

In industry, utility systems — compressed air, steam, industrial refrigeration, pumping, chilled water — often represent the majority of potential savings, and are frequently the least monitored.

Compressed air, for example, can lose more than 30% of production through leaks on unmonitored networks. Steam, on older installations, can lose 15 to 25% of its energy between production and delivery points. These losses are invisible without targeted metering.

The IND-UT-134 scheme is agnostic as to the utility systems covered: it funds metering for heat, compressed air, refrigeration, electrical and thermal processes. It is precisely this broad coverage — not limited to electricity — that makes it particularly well suited to process-intensive industrial sites.

Want to go further on this topic? See our full guide to industrial energy supervision with IoTMate.

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CTA
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Do you manage energy or utilities at an industrial site?

OXA Groupe offers a free 15–30 minute assessment to evaluate your site's potential: IND-UT-134 eligibility, current instrumentation status, quick wins, and ISO 50001 roadmap.

We also offer an online CEE calculator for a first estimate of your funding potential.

→ Calculate your CEE potential
→ Get in touch with our experts

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AUTHOR
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About the author
Maxime Laffers — Industrial Energy Efficiency Expert, OXA Groupe
A specialist in CEE funding mechanisms and IoT integration for energy management, Maxime has supported French SMEs and mid-sized industrial companies in their energy transition for over 10 years. He has contributed to the deployment of dozens of NF EN 17267-compliant metering plans across industrial sites throughout France.
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OXA Groupe is an independent integrator specialising in industrial energy efficiency. We deploy IoTMate, an all-in-one solution for energy metering, supervision and management, and support industrial operators in structuring and filing their CEE applications. We operate across France.

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FAQ — YOUR QUESTIONS ANSWERED
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Who is affected by the ISO 50001 obligation before 2027?

Any industrial site consuming more than 23.6 GWh/year (85 TJ) must be ISO 50001 certified before 11 October 2027. Below this threshold, the quadrennial energy audit applies from 2.75 GWh/year. ISO 50001 certification replaces the audit obligation for sites that implement it.

What equipment is funded by the IND-UT-134 scheme?

The CEE IND-UT-134 scheme funds meters, measuring instruments, data loggers, communication gateways and supervision software required for the metering plan. It covers utility systems including heat, compressed air, industrial refrigeration, and thermal and electrical processes.

Can the IND-UT-134 scheme be combined with other funding?

Yes. The CEE IND-UT-134 grant can be combined with ADEME's PRO-SMEn programme, which covers 20% of ISO 50001 support costs, up to €40,000. This combination can cover a very significant share of total project costs.

How long does it take to deploy a compliant metering plan?

Depending on site size and complexity, deploying a metering plan compliant with NF EN 17267 takes 3 to 9 months. Full ISO 50001 certification requires a further 6 to 18 months. Given the 2027 deadline, initiating the process without delay is strongly recommended.

Are EU-ETS sites eligible for the IND-UT-134 scheme?

No. Sites subject to the EU Emissions Trading System (EU-ETS) are excluded from the CEE IND-UT-134 scheme. All other industrial sites — including SMEs and mid-caps outside the quota system — are fully eligible, regardless of their sector.