Under the revised EU directive, a haulier’s energy audit obligation is settled by a single calculation: the average final energy consumption over the three preceding calendar years is compared with the threshold of 2.78 GWh a year, that is 2,780 megawatt-hours, and vehicle fuel counts towards it. Seven long-haul vehicle combinations can be enough to cross the line, and then the company is covered by the audit requirement under the directive. The Swedish act implementing the requirement is planned to enter into force on 1 January 2027; until then, the Act (2014:266) on energy audits in large companies applies.
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 of those decides the outcome, because the fleet’s fuel is the company’s own energy use just as much as the terminal’s electricity.
The example company’s consumption comes from two sources: diesel accumulating on the fuel cards and electricity from one terminal, where the electricity also covers heating the hall.
Which items are left outside final energy consumption is something we work through against the Swedish Energy Agency’s current guidance before the calculation is locked. When the margin is large the exclusions rarely decide the outcome, but in a borderline case they can turn the result.
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: the default net calorific value 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 328,000 litres in total, that is 328,000 / 7 = about 46,900 litres per combination, which works out at about 39 litres per hundred kilometres. In 2025 the total was 335,000 litres, about 47,900 per combination, and the calculation 47,900 litres × 9.6 kWh/l = 459,840 kWh gives the annual energy of one combination, about 460 MWh. Seven combinations therefore amount to about 3,216 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.
| Year | Diesel (l) | Diesel (MWh) | Terminal electricity (MWh) | Total (MWh) |
|---|---|---|---|---|
| 2023 | 320,000 | 3,072 | 110 | 3,182 |
| 2024 | 328,000 | 3,149 | 117 | 3,266 |
| 2025 | 335,000 | 3,216 | 114 | 3,330 |
| Average 2023–2025 | 327,700 | 3,146 | 114 | 3,259 |
| Fleet only, average | 327,700 | 3,146 | – | 3,146 |
The three-year total is 9,778 MWh, so the average is 9,778 / 3 = 3,259 MWh per year, and that is the figure compared against the threshold, because the obligation is assessed from total final energy consumption. The 2,780 megawatt-hour threshold is exceeded by 479 megawatt-hours, about 17 per cent, so the result does not hinge on rounding. The average for the fleet alone is 9,437 / 3 = 3,146 megawatt-hours, which is 366 megawatt-hours above the threshold: the threshold is exceeded by the fuel alone and the terminal only widens the gap. The directive’s date for a company covered for the first time is 11 October 2026, but in Sweden the requirement applies through the new act, which is planned to enter into force on 1 January 2027. After that the audit is renewed at least every four years.
The upper tier sits at 23.6 GWh a year, that is 23,600 megawatt-hours. A company above that level needs a certified energy management system under the revised directive (the Swedish act is planned from 1 January 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 thresholds and the deadlines come from the EU Energy Efficiency Directive (2023/1791), whose Article 11 sets the thresholds at 10 TJ and 85 TJ a year and gives the deadlines of 11 October 2026 and 11 October 2027. Each member state implements the directive nationally, and an audit always follows the law of the country where the site is located, so the obligation of a subsidiary in another country is checked with the authority in that country.
In the example company the margin is so clear that one tank month booked to the wrong year does not turn the result, but a company close to the threshold should calculate carefully, because a single busy year can push the three-year average over. All three years are therefore calculated from the same data and in the same way. A rough check of your own situation takes a few minutes with the obligation calculator.
What does the fleet mean for the audit?
The fleet is almost all of the example company’s energy use: 3,216 megawatt-hours of diesel out of a total of 3,330 megawatt-hours in 2025, about 97 per cent. The most important figure in the report therefore comes from the fuel cards, not from the terminal.
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. What the Swedish rules require of detailed site-level surveys, and how vehicles are treated in them, we work through against the Swedish Energy Agency’s guidance before the work starts. 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 crossed?
With an average below 2,780 megawatt-hours no audit requirement arises under the directive’s thresholds – until 1 January 2027 the Act (2014:266) applies to large companies regardless of consumption, but the calculation is still worth doing: the same data produces the list of measures with payback times. If there is support available to apply for, we check the current position with the authority before you order anything.
Our example company is 479 megawatt-hours above the threshold. With six combinations the average would be about 2,810 megawatt-hours, still just above the threshold, and only with five combinations, about 2,360 megawatt-hours, does the company fall below it. The average is always calculated over the three preceding calendar years, so two new combinations, about 900 megawatt-hours, are enough to turn an average below the threshold into one above it with a couple of years’ delay. At Iiva we sell neither equipment nor electricity, so the calculation does not lead to a quotation for equipment but to knowing which side of the threshold the company is on.
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.