Example Ltd
Energy management system implementation
ISO 50001 · Industrial plant, Salo
A company consuming over 23,600 MWh a year must have a certified energy management system in place by 11 October 2027. The obligation is determined by the three-year average of final energy consumption, and a system compliant with the act also meets the energy audit obligation.
Management system threshold
23,600 MWh
final energy consumption per year, three-year average
≈ 2.5 million litres of diesel per year
Certified system in place by 11 October 2027
At Iiva we do not issue certificates: a certificate is always issued by an external, accredited certification body. Our role is to compare the routes impartially, build the system ready for certification and support the company through the certification audit.
We sell no equipment and represent no supplier. The client always receives several compared options and makes the decision themselves.
| ISO 50001 | ETJ+ | The ISO 14001 route | |
|---|---|---|---|
| What it is | A certifiable energy management system that the Finnish Energy Efficiency Act accepts as meeting the obligation. | An energy efficiency system linked to the voluntary energy efficiency agreements (the 2026–2035 period). | A certified environmental management system that meets the energy obligations only as part of a combination. |
| Meets the audit obligation (over 2,700 MWh/year) | Yes, when certified; no statutory audit is then carried out at all. | Yes. For a company in the agreement, implementing ETJ+ is enough without certification. | Not on its own, but a certified ISO 14001 together with ETJ+. |
| Meets the energy management obligation (over 23,600 MWh/year) | Yes, when certified. | Yes, when certified. | Yes through two combinations: an audit under the act, or the energy efficiency agreement and ETJ+, alongside a certified ISO 14001. |
| Is certification required | Yes, the energy management obligation requires a certified system. | For the energy management obligation yes, for the audit obligation no through the agreement. | The environmental management system has to be certified. |
| Who the route suits | A company that wants to handle both obligations with a single system. | A company that is party to the energy efficiency agreement or can join it. | A company whose environmental management system is already certified. |
of energy use
Scope and gap analysis: which functions the system covers and what of the standard’s requirements already exists.
Energy review: consumption by energy type, significant energy users and load profiles from measured data.
The potential for savings and renewable energy, with profitability calculations.
Energy policy, targets, indicators and an action plan for the measures.
Documentation, internal audit and management review – plus support in the certification audit.
An energy management system is a documented way of managing energy: the current state against the standard, significant energy uses, and the indicators and targets that are tracked. Here is an excerpt from the start of a sample documentation.
Excerpt from a sample. The figures are fictional – real system documentation is based on the building's and the company's own data.
Example Ltd
ISO 50001 · Industrial plant, Salo
2 · Gap analysis against the standard
| Clause of the standard | Status |
|---|---|
| Leadership and energy policy | Met |
| Energy review | Met |
| Energy baseline and EnPIs | Partly |
| Objectives and action plan | Met |
| Competence and communication | Partly |
| Documentation | Met |
| Monitoring and measurement | Met |
| Internal audit | Missing |
| Management review | Missing |
3 · Significant energy uses and targets
| Indicator (EnPI) | Baseline 2025 | Target 2027 |
|---|---|---|
| kWh / tonne produced | 412 | 370 |
| Compressed air kWh / Nm³ | 0.128 | 0.112 |
| Heating kWh / m², weather-adjusted | 138 | 124 |
A certified ISO 14001 does not meet the energy obligations on its own, but it is part of the combinations accepted by the Finnish Energy Authority. We carry out the missing part – the audit under the act or ETJ+ – within the existing system so that maintenance is not duplicated.
An energy service agreement, that is an EPC or ESCO contract, exempts a company from both the statutory energy management system and the energy audit to the extent the final energy consumption falls within the scope of the agreement.
The condition is that the agreement contains the four elements of an energy management system and that the provider’s remuneration is tied to the improvement in energy efficiency. We go through the agreement and tell you which part of final consumption falls outside the obligation.
Both are accepted once certified, so the choice comes down to other factors. ETJ+ is linked to the energy efficiency agreements: for a company in the agreement, implementing ETJ+ is enough without certification, and no company-level audit is then carried out. A certified ISO 50001 removes the statutory audit altogether.
It can, but only in part. Coverage of 90 per cent of energy use is sufficient, but the exemption extends only to the functions within the scope of the certificate: with 60 per cent coverage the audit obligation remains for the 40 per cent left outside. In a group, an ISO 50001 covering at least 90 per cent of the group’s energy use is enough.
No audit under the act is carried out any more, and a certified company needs no designated responsible person for the audit. Data on site audits is not submitted to the Authority, and the certificate is submitted only on request.
No. The audit obligation is met when ETJ+ is implemented alongside the agreement; the system then does not need to be certified. Meeting the energy management obligation requires a certified system, or a certified ISO 14001 together with the agreement and ETJ+.
The obligations can be met at group level, in which case all of the group’s operations are included in the audit or the system. Handling them at group level does not in itself create an energy management obligation: that arises only if a company’s consumption exceeds 23,600 MWh a year. An ISO 50001 certified company can be left outside the audit obligation.
A certified energy management system has to be in use by 11 October 2027. The obligation arises when the average final energy consumption of the three preceding calendar years exceeds 23,600 MWh. Crossing the consumption threshold also has to be reported to the Finnish Energy Authority.
The price of the certification audit is agreed directly with the certification body and is not included in our service.
Coverage of 90 per cent of the company’s energy use is sufficient for certification, and the certificate exempts only the functions within its scope. On the ISO 14001 route the coverage also depends on the other half of the combination: the company-level audit under the act has to cover the company’s energy use as a whole.
A certified ISO 50001 replaces the statutory audit: no designated responsible person is needed and data on site audits is not submitted to the Authority. In the combination of the energy efficiency agreement and ETJ+, no company-level audit is carried out at all; consumption is monitored under the agreement instead. On the ISO 14001 route the audit remains part of the route.
ISO 50001 is continuous system work: monitoring consumption and continual improvement, with no separate four-year audit cycle. On the ETJ+ route consumption is monitored annually under the agreement. On the ISO 14001 route the company-level audit is made at least every four years, and the site audits included may be at most four years old.
Certification is not reported on the company’s own initiative: the certificate is submitted within a month only at the Authority’s request. On the ISO 14001 route the key data on the site audits made alongside is submitted within three months of the audit being completed. A company must notify the Finnish Energy Authority if its final energy consumption exceeds 2,700 MWh or 23,600 MWh during a calendar year. The duty follows from sections 6 and 3 g of the Energy Efficiency Act and is separate from the audit and system obligations.
The energy review is based on measured and traceable data; expert estimates are used only where measurement is not possible or its cost would be unreasonable compared with the accuracy gained. Profitability is calculated primarily as a life-cycle cost analysis. The action plan records, for each recommendation, the measures, the size of the investment (low, medium or high) and whether implementation is decided, under consideration or not going ahead. Documentation is scaled to the size of the organisation, and maintenance means monitoring and continual improvement.
The energy management obligation (over 23,600 MWh/year) is met by a certified ISO 14001 together with a company-level audit carried out in accordance with the minimum requirements of the act, or by a certified ISO 14001 together with the energy efficiency agreement and ETJ+. The audit obligation (over 2,700 MWh/year) is met by a certified ISO 14001 together with ETJ+; the environmental management system alone is not enough for that.
For the audit obligation this is laid down in section 7, subsection 3 of the Finnish Energy Efficiency Act. The agreement has to contain the four elements of an energy management system referred to in section 3, paragraph 31: actual monitoring of consumption, measures implemented to improve energy efficiency, measurement of progress, and compliance with the requirements of Annex XV to Directive (EU) 2023/1791. In addition, the share of guaranteed savings has to be greater than 0 per cent and the financial effects of the project and the division of the savings have to be presented transparently.
In 30 minutes we go through whether the obligation applies to you, which route fits and what the work requires.