The Energy Efficiency Act sets a deadline for the energy audit and also governs what happens if the audit is not carried out. The Finnish Energy Authority supervises compliance and may order a company by decision to fulfil its obligation; the decision may be reinforced with a conditional fine or with a threat of enforced performance or suspension. The same legislation also sets out the company’s rights: a hearing, consideration of the deadline, and appeal. Below is what the law says and how the situation is put right.

Who supervises compliance with the audit obligation?

Under section 30 of the Energy Efficiency Act (1429/2014, as amended by 1382/2025), the Ministry of Economic Affairs and Employment is responsible for the general steering and monitoring of the Act’s implementation. The Energy Authority is responsible for supervising compliance with the Act and with the provisions and official regulations issued under it.

Supervision of the audit obligation is governed separately by section 30 a: the Energy Authority supervises that companies introduce certified energy management systems and carry out the mandatory enterprise energy audits. Under the same section, a set proportion of the enterprise energy audits drawn up each year is inspected. More detailed provisions on how many audits are inspected and how the inspection is carried out may be issued by decree of the Ministry of Economic Affairs and Employment.

The Act also governs where the Authority obtains the information it needs for supervision. Under section 30 a, the Finnish Patent and Registration Office must, at the Energy Authority’s request, provide company data from the Trade Register so that supervision can be organised, without delay and free of charge. In addition, under section 30 b the Authority has the right, notwithstanding secrecy provisions, to obtain the information necessary for supervision from the company and from any other party subject to an obligation under the Act, and under section 30 c the right to access the premises and areas of the supervised operator, carry out inspections there, and take documents into its possession where necessary to achieve the objectives of the inspection.

What can the Energy Authority require from a company?

Audit reports do not reach the authority by themselves. Under section 30 a, the Energy Authority has the right to obtain for inspection the reports on the mandatory enterprise energy audit and on the site audit included in it, along with other information needed for supervision. The material must be submitted within one month of the Authority’s request, and audit reports may not be more than four years old.

If a company considers itself exempt from the audit obligation, the grounds for the exemption must also be shown. Under section 7, the obligation is met by a certified environmental management system, by a voluntary energy efficiency agreement signed with a state authority, or by an energy service contract, where these include an energy audit meeting the minimum requirements of the Act or the components of an energy management system.

One submission goes without a separate request. Under section 11, a company must submit the key data from all site audit reports included in its energy audit to a register maintained or designated by the Energy Authority within three months of the completion of each site audit report. If a site audit report is completed on 20 August 2026, the data must be submitted by 20 November 2026. The obligation concerns site audits included in the enterprise energy audit, so it does not apply to a company that has a certified energy management system under section 3 g and therefore no audit obligation under section 6.

Exceeding the consumption threshold must be notified separately. Under section 6, a company must notify the Energy Authority if its final energy consumption during a calendar year exceeds 2,700 megawatt hours, and under section 3 g a corresponding notification is made when the 23,600 megawatt-hour threshold is exceeded. Under section 31 a, the Energy Authority is entitled to charge a fee for processing a notification and other matters.

What can failing to carry out an energy audit lead to?

The sanctions are based on section 31 of the Energy Efficiency Act and on the Act on Conditional Fines (1113/1990). The chain runs as follows:

  1. Decision to fulfil the obligation. The Energy Authority may order a party that breaches or neglects the Act, or a provision issued under it, to fulfil its obligation. The decision may specify how the breach or neglect is to be corrected (section 31(1)).
  2. Reinforcing the decision. The Energy Authority may reinforce a prohibition or order issued under the Act with a conditional fine or with a threat of enforced performance or suspension (section 31(2)).
  3. Imposing the threat. A conditional fine is imposed by ordering the principal obligation to be complied with under threat of a fine. The imposing decision must clearly state what the company is obliged to do and by when the principal obligation must be complied with. When considering the length of the deadline, account is taken of the nature and extent of the principal obligation, the party’s ability to comply with it, and other relevant circumstances (section 6 of the Act on Conditional Fines). A conditional fine may be directed only at a party that has the legal and factual ability to comply with the principal obligation (section 7).
  4. Hearing. The party must be given an opportunity to submit an explanation before a conditional fine is imposed and ordered to be paid, and before a threat of enforced performance or suspension is imposed and ordered to be enforced, as provided in section 34 of the Administrative Procedure Act (434/2003) (section 22 of the Act on Conditional Fines).
  5. The amount of the fine. There is no tariff. When considering the amount, account is taken of the nature and extent of the principal obligation, the party’s ability to pay, and other relevant circumstances (section 8 of the Act on Conditional Fines).
  6. Ordering payment. The authority that imposed the conditional fine may order it to be paid if the principal obligation has not been complied with and there is no valid reason for the non-compliance. A precondition is that the decision imposing the fine has become final, unless the decision has been laid down or ordered to be complied with notwithstanding appeal (section 10 of the Act on Conditional Fines). A new conditional fine may not be imposed until the question of ordering payment of the earlier one has been dealt with (section 12).

A conditional fine is not the only means of enforcement. Under a threat of enforced performance, the principal obligation is ordered to be complied with under threat that the work left undone will be carried out at the defaulting party’s expense, and under a threat of suspension under threat that the work or other activity will be suspended (section 14 of the Act on Conditional Fines).

The sanction may also fall on the person carrying out the audit. Under section 17, the Energy Authority may withdraw the qualification granted to a responsible person if that person repeatedly breaches the minimum requirements for the enterprise energy audit or otherwise shows themselves to be incompetent for the task.

The procedure is not one-sided. The company must be heard before a threat is imposed and before it is ordered to be paid or enforced (section 22 of the Act on Conditional Fines). The deadline must give a genuine opportunity to fulfil the obligation, and the threat may be directed only at a party that has the legal and factual ability to comply with the principal obligation (sections 6 and 7).

The decision can be appealed. Appeals to an administrative court are governed by the Act on Judicial Procedure in Administrative Matters (808/2019); a decision of the Authority to carry out an inspection may not, however, be appealed separately (section 32 of the Energy Efficiency Act). An appeal does not suspend the duty to comply: under section 32 a, a decision of the Energy Authority must be complied with notwithstanding appeal, unless the Energy Authority or an administrative court orders otherwise. A decision ordering a conditional fine to be paid may not, however, be enforced before it has become final.

What has to be done before 11 October 2026?

Take as an example a company whose final energy consumption was 3,100 MWh in 2023, 3,500 MWh in 2024, and 3,600 MWh in 2025. The average for the three preceding calendar years is (3,100 + 3,500 + 3,600) / 3 = 10,200 / 3 = 3,400 MWh. The figure exceeds the 2,700 MWh threshold in section 6 but stays below the 23,600 MWh threshold in section 3 g, so the company falls under the audit obligation and not under the energy management system obligation. Under the entry-into-force provision of 1382/2025, a company falling under the obligation for the first time must have its enterprise energy audit carried out by 11 October 2026 at the latest. Before that, the following has to be done:

  1. Appoint a responsible person for the enterprise energy audit whose qualification has been confirmed and is valid and who is entered in the register of responsible persons for energy audits (section 13). The qualification is valid for seven years from the date of the decision on it (section 16).
  2. Define the scope and the sites to be audited. The audit is carried out for the entire group or company and includes a review of all the company’s operations. Every enterprise energy audit must include at least one site audit, unless the company has no energy use site where carrying out a site audit is appropriate and economically justified (section 8).
  3. Collect the baseline data, make the site visits, and complete the site audits. Site audits are carried out as far as possible on different energy use sites, focusing on those where consumption is highest or where there is most room for improvement (section 9).
  4. Submit the key data from the site audits to the register within three months of the completion of each site audit report, one at a time if necessary (section 11).
  5. Complete the company-level audit report by the deadline (section 10) and draw up an action plan on the basis of its recommendations, specifying the measures by which each recommendation is implemented (section 12).
  6. Include the action plan and information on the degree of implementation of the recommendations in the management report or, if no management report is drawn up, in the notes to the financial statements, and make them publicly available free of charge (section 12).

The deadline is not a one-off. A mandatory enterprise energy audit must be carried out at least every four years, and a site audit included in it may not be more than four years old (section 6); the company must have an audit report that is at most four years old (section 10). In practice the cycle runs from the date of the report: after an audit completed on 11 October 2026, the next must be carried out by 11 October 2030, with site audits in between. A company that was already covered by the obligation before the amendment continues on its existing rhythm, that is, after an audit completed on 22 January 2023 the next is carried out on 22 January 2027. If average consumption over the three preceding calendar years exceeds 23,600 MWh, a certified energy management system must be introduced by 11 October 2027 (entry-into-force provision of 1382/2025).

The obligation is sector-neutral. Under section 3(37) of the Act, a company means a natural or legal person engaged in economic activity, so the obligation may apply to any sector, including a transport company whose energy goes into fuel.

What to do if the deadline is close and the audit has not been started?

It is worth starting the work at the end that is looked at in supervision, that is, with the minimum content of the obligation. One site audit and a company-level audit meeting the minimum requirements of section 8 are the level at which the obligation has been met. The audit must use reliable, up-to-date and, where possible, measured data on energy consumption and load profiles, and the data must be stored for historical analysis and performance monitoring (section 8). Both the company-level audit report and the site audit reports must be retained for at least five years (sections 10 and 11).

If the Energy Authority has already requested material, the timetable is known: the submission time is one month from the request (section 30 a). It is then worth gathering the material that exists and stating what is missing and on what timetable the gap will be closed. If the Authority issues a decision under section 31, it may specify how the neglect is to be corrected, and under section 32 a the decision must be complied with notwithstanding appeal. The further along the work is at that point, the narrower the principal obligation that remains.

At Iiva we sell neither equipment nor electricity, so the content of the audit and the proposed measures are decided on the basis of what makes sense for the company.

We check the deadline and the starting point in a free initial discussion. Read about the energy audit or see the stages and schedule of the audit.