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The Energy Mapping Regulation came into force on 1 October 2024 and implements the EU Energy Efficiency Directive into Norwegian law. It requires large energy users to map their own energy use, find cost-effective measures and report the results to the authorities.
The first deadline is now approaching. Below we will go over who is covered, what the survey should contain, how the reporting is done, and what the consequences are if you miss the deadline.
Who is covered by the regulation?
The requirement applies to businesses that use at least 2.5 GWh of energy per year in Norway, measured as an average over three years. 2.5 GWh corresponds to 2,500,000 kilowatt hours. For the first report, the years 2023, 2024 and 2025 are used as the basis.
All energy use is included
Not just electricity for buildings. District heating, gas, oil, biofuels and fuel for transport count in. Many cross the limit when the transport fleet is taken into account.
The average applies
A single year above the limit does not trigger the requirement. It is the average over three years that is decisive.
Per legal entity
Each company is assessed individually, not the group as a whole. Read more about the group .
If you are unsure whether you pass the threshold, the calculation is the first thing we do. It takes a short time once the energy data is available.
What should the energy assessment contain?
The survey should provide a comprehensive picture of how the business uses energy, and point out what can be done better. Specifically, you should be able to document:
- Total energy use divided by purpose: building, process and transport
- Distribution of energy carriers for the previous calendar year
- Key figures, such as kWh per square meter for buildings
- How heat is distributed in buildings
- Own energy production, if you have it
- Identified profitable energy measures, with estimated savings
- Assessment of connection to district heating or district cooling
- Assessment of renewable energy and utilization of waste heat
The survey should cover at least 90 percent of total energy use. The data should be measured and traceable. Where measurements are not available, calculations according to recognized standards can be used.
It is not enough to carry out the survey internally. The requirement is only fulfilled when the results are reported in Enova's reporting portal, as described below .
How do you report?
Reporting takes place in Enova's reporting portal. This is the step most people underestimate, because it requires access that must be arranged in advance.
Check the Altinn roles
The person who is going to deliver must have the role "Energy, Environment and Climate" or "Completeer/Submitter" for the organization. If no one in your organization has this role, it must be assigned before you can proceed. This takes time in a larger organization, and it is the most common reason why organizations get stuck right before the deadline.
Log in via the ID portal
The portal uses electronic ID: MinID, BankID, Buypass or Commfides.
Fill in the sections
The menu on the left shows how far you have come. Remember to click Next to save. Errors are marked in red and must be corrected. Warnings about unusual values do not stop the submission, but should be checked.
Submit before the deadline
The report can be saved as a draft and edited up until the deadline. It is not submitted until you submit it.
If you have multiple locations, the report must provide sufficient detail for each of them. One of the most common shortcomings is to lump everything into one number.
What happens if you miss the deadline?
NVE supervises the regulations and has several instruments:
Toppings
To rectify the situation within a given deadline
Coercive fine
A running fine that lasts until the requirement is met
Violation fee
A one-off fee for the breach itself
It is also possible to apply for a dispensation. This requires that the application is well-founded and should be submitted in good time.
If you miss the deadline, the advice is to get started anyway and document that the work has started. Doing nothing is the most expensive option.
The mapping is more than a mandatory exercise
The requirement to identify profitable measures is there for a reason. An energy survey usually reveals measures that pay for themselves regardless of the regulations: incorrectly set control systems, ventilation that runs at full power outside working hours, heat recovery that does not work, or power peaks that result in unnecessarily high grid rent.
Enova has its own support schemes for implementing energy measures. Once you have mapped out your options, you will also have the basis you need to apply. Read more about energy analysis .
Checklist before October 1st
Frequently Asked Questions
When is the deadline for energy mapping?
The first report must be submitted by midnight on October 1, 2026. Thereafter, new surveys must be conducted and reported at least every four years.
Who is covered by the Energy Mapping Regulations?
Businesses in Norway with an average annual energy use of at least 2.5 GWh in the previous three years. All energy use is included, including transport and industrial processes. The threshold is assessed per legal entity.
How do we calculate if we pass 2.5 GWh?
Add up all energy use in Norway, regardless of energy carrier, for each of the years 2023, 2024 and 2025. Then calculate the average. If the average is over 2,500,000 kilowatt hours, you are covered.
What must the energy survey contain?
Total energy use divided into buildings, processes and transport, distribution by energy carrier, key figures per building, heat distribution, own production, identified profitable measures with estimated savings, and assessment of district heating, district cooling, waste heat and renewable energy. At least 90 percent of energy use must be covered.
Where do we report the energy survey?
In Enova's reporting portal, with login via the ID portal.
Which Altinn role do we need?
"Energy, environment and climate" or "Completeer/submitter". The role must be assigned before logging in, and this should be arranged well in advance.
Who can carry out the energy audit?
The regulations set qualification requirements for the person carrying out the survey. It can be done internally if the competence requirement is met and can be documented, or outsourced to a qualified advisor.
What happens if we miss the deadline?
NVE can issue orders, impose fines and issue violation fees.
How often must energy audits be carried out?
At least every four years, calculated from the date the previous report was submitted.
Does the requirement apply to the group or each individual company?
The requirement applies to the individual legal entity, not the group as a whole.
Where one legal entity conducts economic activities in several places in the country, it is the legal entity that is considered the "enterprise". This applies even if the enterprise is divided into several sub-enterprises in the business register according to the Standard for Industrial Classification. In such cases, the individual sub-enterprise is not a legal entity.
If, however, the business is divided into several subsidiaries of the same parent company, each company is a separate "enterprise", because a company is a legal entity. Each legal entity in the group must then be considered separately, both when assessing whether it is covered by the regulation and in the energy survey itself.
A parent company is not covered by the regulations unless it itself meets the conditions in Section 2.
Do you need help before the deadline?
Energihuset has conducted energy surveys for around 500 businesses, housing cooperatives and municipalities. We calculate whether you are covered, carry out the survey and help you through the reporting.
Get in touch and we'll find out where you stand.
Sources
- NVE, Guide to the Energy Mapping Regulations
- NVE, § 3 Mandatory energy mapping
- Enova, Guide to reporting energy surveys , version 3, April 13, 2026
- Enova's reporting portal