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Written by Jørund Buen
Who is actually covered?
In short: all Norwegian businesses with a total energy consumption of more than 2.5 GWh on average over the last three years. Note the word total: it is not just electricity that counts. District heating, gas, diesel, bioenergy and other energy carriers that the business uses – both in buildings and elsewhere in the business, for example for transport – are counted. This means that more businesses are covered than many people think, not least those with high diesel consumption in transport and low electricity bills otherwise. The survey should also cover at least 90% of the business's total energy use, not just a representative sample.
Three details surprise most people. Firstly, each limited liability company is assessed separately, not the group as a whole; if you have multiple org. numbers in your portfolio, each of them must be checked separately. Secondly, if your company has multiple subunits with a common organizational number but different company numbers, their consumption is counted together. Even if each subunit in isolation is below 2.5 GWh, the main unit is required by law to carry out a survey for all subunits if the total exceeds the threshold. Thirdly, if you are a landlord and invoice electricity to the tenant without specifying the cost (i.e. as part of the common cost), it is you as the owner who is assessed against the threshold, not the tenant. However, if you specify the cost per tenant, it is the tenant himself who must be assessed. It is worth checking the invoice routines for that reason alone.
What happens if you do nothing?
NVE can take businesses out for inspection and ask for documentation. If you cannot provide a survey, you will first receive an order, and ultimately a violation fee that varies depending on how serious the violation is, how long it has lasted, and how large the business is. It can range from a few hundred thousand kroner and up, depending on the scope of the case. It is unlikely to come the day after the deadline, but it can come, and you should be prepared for that. The survey must be available by October 1, 2026 in any case, the measures must be in place no later than one year after the survey, and the survey must be updated at least every four years.
What's actually new (and better) about this round
The previous generation of support schemes for energy mapping did not take climate zone or actual operation into account; you got pretty much the same template regardless of whether the building was located in Kristiansand or Røros, and regardless of how it was operated in practice. The new scheme is more flexible and more realistic: the mapping can be adapted to climate zone and actual operation pattern, and measures can in many cases be combined in packages instead of being assessed individually, as Enova previously required.
It gives a completely different type of report than "here are ten individual measures, good luck": a good mapping today gives you a prioritized action plan, often divided into packages (cheap, medium, expensive), with expected savings in both kWh and kroner, investment cost and payback period for each package. Our experience is that it is more useful for a board that is about to make a decision, than a long list without prioritization.
Save money, not just grade
A common pitfall is chasing energy ratings instead of actual savings. The rating is useful, especially if you have tenants with a specific minimum requirement (public tenants often ask for an energy rating of C as a prerequisite), but a measure that raises the rating from D to C is not automatically the same measure that provides the most cost savings per invested krone. We recommend calculating both: what gives the best rating increase, and what gives the best return, and then choosing based on what you actually need. Sometimes the answer is the same measure; sometimes you have to prioritize.
A couple of practical examples we often encounter with property owners with growing portfolios: electricity and other operating agreements entered into over time and never compiled into a single overview, so that no one really has full control over what is tied up to when, and at what price; buildings with old energy labels that have never been updated, even though operations have changed significantly in the meantime; and meters that no longer follow the correct tenant after renovations, which creates unnecessary arguments about shared costs. None of these are dramatic on their own. If you clean them up at the same time as carrying out the legally required survey, you get two things for the price of one effort: compliance, and a portfolio that is actually tidier to operate.
Enova, applications and a pitfall you should know about
If you are planning measures that qualify for Enova support, the order is critical: the application must be submitted before the measure is initiated, not afterwards. It sounds obvious, but it is the most common mistake we see: someone orders the solar cell system first and discovers the support scheme later. Then the train has left. If you need help applying, contact us!
The link to your bank
This mapping is becoming increasingly relevant even outside the NVE's radar. Banks now view energy documentation as part of the credit assessment (compare the regulations that govern how they must assess climate risk, and how this is related to the capital requirement the bank receives, discussed in more detail in our article on energy labels and loan terms ). A mapping that you are required to carry out anyway can therefore be reused right into the next loan negotiation. If you have decided on measures, it is a good starting point for discussing solutions with the bank that can give you better loan terms; either a loan for renovation, individual measures or transitional financing that takes the upgrade in several stages. If you take the opportunity to create a climate account for the business when the most important measures have been taken, send it to the bank. They need the documentation it provides, and the fact that you as a customer send it to them without them asking will lead to a big plus in the book. It can also help with interest terms if you are lucky. It is rare to get the opportunity to make money on legally required paperwork, so it is worth taking full advantage of it.
The deadline is just around the corner.
A complete energy survey can easily take a few weeks to complete. In other words, you are not early when the deadline is 1.10.26. Good mapping also often requires time for data collection (preferably three months of hourly values ​​and invoices), analysis and anchoring in your own organization. We at Energihuset have done over 500 energy surveys, for customers in various industries and in many parts of Norway, and are happy to help you too. Contact us now!
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