Energy audit obligation for transport companies

For a haulier, the energy audit obligation comes down to a single calculation: the average final energy consumption of the three previous calendar years is compared with a threshold of 2,700 megawatt-hours, and vehicle fuel counts towards it. Seven long-haul vehicle combinations can be enough to cross the line, and then the first company energy audit has to be completed by 11 October 2026.

Which energy is compared with the threshold?

The threshold applies to final energy consumption, and every energy type counts: electricity, heat and fuels. In transport the last item settles the matter, because the fleet’s fuel is the company’s own energy use just as much as the terminal’s electricity. A benefit car whose fuel the company pays for also belongs in the calculation.

The example company’s consumption comes from two sources: diesel recorded on fuel cards, and electricity from one terminal, which also heats the building.

Less falls outside the calculation than many expect. Ambient energy is excluded, so only the electricity consumption of heat pumps counts, and so are fuels for international maritime transport, deliveries to the transformation and energy sector, and transmission, distribution and power plant losses. Renewable energy the company produces and uses itself, such as solar power from the terminal roof, is counted as own consumption.

The obligation is sector-neutral. Under the old act the audit obligation applied only to large companies, and size was defined by the balance sheet and turnover or by headcount, whereas consumption alone now decides. A small or medium-sized haulier can therefore fall within scope while a large company with low consumption stays outside it.

The calculation is made one company at a time. Ownership relations between companies are not taken into account, but all sites of the same company are added together, so the consumption of three terminals is summed into one figure. A company operating in leased premises counts only the energy it pays for on the basis of metered consumption, and if a tenant’s use is not metered, the property owner counts it as part of its own total energy use.

How are litres converted into megawatt-hours?

The conversion is one multiplication. In our obligation calculator we use a net calorific value of 9.6 kilowatt-hours per litre for diesel, and the figure comes from the Statistics Finland fuel classification 2026: the default net calorific value of diesel (classification code 11.30.30) is 42.8 gigajoules per tonne and the default density 807 kilograms per cubic metre, so one litre is 42.8 × 0.807 = 34.54 megajoules, that is 34.54 / 3.6 = about 9.6 kilowatt-hours. The same calculation gives 8.6 kilowatt-hours per litre for petrol. Litres are multiplied by the calorific value and divided by a thousand, which gives megawatt-hours.

One of the example company’s vehicle combinations runs about 120,000 kilometres a year. In 2024 the seven combinations took on 292,000 litres in total, that is 292,000 / 7 = about 41,700 litres per combination, which works out at about 35 litres per hundred kilometres. In 2025 the total was 298,000 litres, about 42,600 per combination, and the calculation 42,600 litres × 9.6 kWh/l = 408,960 kWh gives the annual energy of one combination, about 409 MWh. Seven combinations therefore amount to about 2,861 megawatt-hours, the same figure as the 2025 row in the table, before anything is counted from the terminal.

Electricity and district heat arrive on the invoices in kilowatt-hours or megawatt-hours, so no conversion is needed. Because every energy type counts, the electricity used by an electrically powered fleet goes into the calculation as well.

Does the energy audit obligation apply to our example company?

The example company is a haulier with seven vehicle combinations and one terminal. The litre figures and the terminal’s electricity consumption are the example’s own input data from fuel and electricity invoices, not industry averages.

The three-year total is 8,703 MWh, so the average is 8,703 / 3 = 2,901 MWh per year, and that is the figure compared against the threshold, because the obligation is assessed from total final energy consumption. The threshold is exceeded by 201 megawatt-hours, about seven per cent, so the result does not hinge on rounding. The average for the fleet alone is 8,400 / 3 = 2,800 megawatt-hours, so the 2,700 MWh threshold is exceeded by the fuel alone and the terminal only widens the gap. The company falls within the audit obligation, and because the obligation arises for it only through the amendment to the act, the first company energy audit must be completed by 11 October 2026. After that the audit is renewed at least every four years.

The upper tier sits at 23,600 megawatt-hours a year. A company above that level needs a certified energy management system by 11 October 2027, and the system also fulfils the audit obligation. A haulier with seven combinations does not reach that figure, but with dozens of vehicles the average is worth recalculating every year.

The calculation above follows Finnish law. The requirement originates in the EU Energy Efficiency Directive (2023/1791), which each member state implements nationally. Article 11 of the directive sets the thresholds at 10 TJ and 85 TJ a year and it sets the deadlines of 11 October 2026 and 11 October 2027; Finnish law expresses the thresholds as 2,700 and 23,600 megawatt-hours a year. An audit always follows the law of the country where the site is located, and Finnish law does not extend to sites outside Finland, so for a subsidiary in another country the requirement is checked with that country’s authority.

In the example company the margin is wide enough that a single month of refuelling booked to the wrong year does not turn the result around, but a company close to the threshold should calculate carefully, because the three-year average can be pushed over the line by a single busy year. All three years are therefore calculated from the same records and in the same way. For a company that has operated for less than three years, consumption for the missing years is counted as zero, which lowers the average.

Crossing the threshold also has to be reported to the Finnish Energy Authority. The reporting duty arises when consumption exceeds 2,700 or 23,600 megawatt-hours in any calendar year. A rough check of your own situation takes a few minutes with the obligation calculator.

What happens to means of transport in the audit?

No site audits are carried out. Means of transport, that is cars, trains, ships and aircraft, are outside the scope of site audits, and their energy is not counted towards the total energy use from which the minimum number of site audits is calculated. The fleet’s fuel still belongs to the company’s total energy use and is reported for one year in the company energy audit.

In the example company this shifts the focus. Once 2,861 megawatt-hours of diesel drop out of the site audit calculation, the terminal is what remains to be audited. Site audits have to cover at least 10 per cent of total energy use, or the minimum number is instead derived from the number of buildings or sites, in which case one site audit is enough when there are between 1 and 15 of them. Buildings or sites whose energy costs are below 15,000 euros a year (VAT 0%) or whose floor area is below 500 square metres can be left out of that calculation.

If the fleet’s share stayed below one per cent of total energy use, its consumption could be left out as marginal, but the number of vehicles would still be stated in the report. In our example company the ratio is the opposite: the fleet accounts for about 97 per cent of the energy, 2,861 megawatt-hours of diesel out of a total of 2,962 megawatt-hours, which makes it the most important figure in the report.

So the fleet does not disappear from the audit even though no site audit is made. At company level the energy use is presented by energy type and across all operations, and the audit identifies cost-effective saving opportunities and estimates the size of the saving. The updated Finnish act also requires the audit to establish the scope for reducing energy consumption and the potential for using or producing renewable energy (section 8, subsection 2 of the Finnish Energy Efficiency Act), and an action plan is drawn up to take the recommendations forward (section 12). On the terminal side the measures are often the same as in other properties, for example demand charge optimisation.

What if the threshold is not exceeded?

With an average below 2,700 megawatt-hours no statutory audit obligation arises, but the audit can be carried out with support. Finland’s Ministry of Economic Affairs and Employment subsidises voluntary energy audits following the Motiva model, and the share depends on the energy efficiency agreement rather than on the form of the organisation: small and medium-sized enterprises, municipalities, parishes and foundations that have joined an energy efficiency agreement receive 50 per cent, other companies 40 per cent. The subsidy is limited to companies whose energy consumption stays below 2,700 megawatt-hours a year as a three-year average, so the same threshold divides companies into those under the obligation and those eligible for support.

The subsidy is applied for from Business Finland, and the applicant is the party ordering the audit. The order is strict: the work begins only after the subsidy decision, so the quotation and the application have to be settled before anyone visits the site. For a haulier that means a few weeks of lead time before the first field visit.

The statutory requirement can also be met another way: taking part in a voluntary energy efficiency agreement signed with a state authority fulfils the audit requirement when the agreement includes an energy audit that meets the minimum requirements.

Below the threshold it is worth looking ahead as well. Our example company crossed the line by 201 megawatt-hours, but with six combinations it would have stayed below the threshold: the three-year average for diesel, 2,800 megawatt-hours, is 400 megawatt-hours per combination, so six combinations plus the terminal’s 101 megawatt-hours add up to about 2,500 megawatt-hours, and instead of the obligation it would have had the option of a subsidised audit. The average is always calculated over the three previous calendar years, so two new combinations, about 800 megawatt-hours, are enough to turn an average below the threshold into one above it with a couple of years’ delay. We at Iiva sell neither equipment nor electricity, so the calculation leads to a clear answer about which side of the line the company is on rather than to a quotation for hardware.

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We work through three years of consumption from your fuel and electricity invoices and tell you whether the obligation arises. Check your situation with the obligation calculator or read about the statutory energy audit.