Efficient implementation plan
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For groups of companies: Yes, it is possible to create implementation plans for subsidiaries/companies in the same group.

For consultants: It is not possible to create implementation plans for different, independent companies with one license. In this case, one license is required for each company/group of companies.

BAFA currently sets the following requirements: “The implementation plans to be prepared and published in accordance with Section 9 EnEFG must be publicly available. In particular, this can be done as part of a public company report or as a separate document on the company's website. Provided that the implementation plans meet all of the above requirements, they can also be published as part of the company's sustainability report.” Source: Information sheet for the Energy Efficiency Act (EnEFG) - Status: 12.02.2025

The current Energy Efficiency Act (13.11.2023) requires “companies [...] to have the completeness and accuracy of the implementation plans prepared in accordance with sentence 1 confirmed by certifiers, environmental verifiers or energy auditors before publication.” This requirement is likely to be waived/possibly a future amendment to the Act. However, external confirmation is currently still required.

No, according to §9 EnEFG, the obligation relates exclusively to “final energy saving measures”. Accordingly, measures such as reducing toxins do not have to be considered.

Answer: No, external verification is not required. However, the assumptions presented during the external verification process must withstand plausibility checks. For non-standard measures, proof of costs could therefore be helpful. This can also be provided upon request as part of the external verification process.

At least every 3-4 years, depending on the management system, "The published implementation plans must remain publicly accessible for a period of at least three or four years (depending on the method of verification – management system or energy audit). They can then be replaced by the updated implementation plans prepared during the next recertification audit or energy audit."

Source: Fact sheet for the Energy Efficiency Act (EnEfG) – Status: October 1, 2025

Implemented Measures – “In the case of an early update, implementation plans for measures that have already been fully implemented do not need to be considered further.”

Re-audit – “A re-audit by an external third party is only required as part of the next certification audit or energy audit.”

Source: Information Sheet for the Energy Efficiency Act (EnEfG) – Status: October 1, 2025