Amendments to emergency legislation
- 2022 changes
- air conditioning
- amendments to energy efficiency legislation
- deadline extension
- EEA
- electrical equipment measurement
- emergency legislation
- energy efficiency obligation scheme
- energy savings
- heat generating equipment
- MEKH
- obligation of a specialised adviser
- OSAP energy savings
- Price market
- small business universal service
- submeter regulation
- VET amendment
Energy Efficiency Legislative Changes in the Emergency (2022)
The emergency legislative amendments that came into force at the beginning of 2022 have brought significant changes to the energy efficiency sector, in particular as regards the obligations of companies. These measures were intended to provide flexibility in a challenging period. Our article details the affected points of the Electricity Energy Act (EIA) and the Energy Efficiency Act, highlighting the most important changes to the Energy Efficiency Obligation (EO) and the Submetering Regulation.
General Changes to the Emergency Regulations
The amendments to the emergency legislation affected two main areas in the energy sector:
- Price market: under the amendment to the VET, small businesses with fewer than 10 employees are allowed to enter the universal service if they meet certain conditions. This was an important relief for them.
- Energy obligations: the Energy Efficiency Act was amended to affect traders participating in the Energy Efficiency Obligation (EEO) scheme and the provisions of the sub-metering regulation.
Below we present in more detail the legislative changes related to the Energy Efficiency Act, which were in force from the entry into force of the Decree on 7 December until the expiry of Act I of 2021 on the control of the coronavirus pandemic, i.e. until 1 June 2022.

Amendments to the Energy Efficiency Act
The amendments to the Energy Efficiency Act (Ehat. tv.) mainly concerned the energy saving tasks of the obligated parties and the use of the energy consultant.
Deadline for meeting EDF Commitments
The deadline for ERA obligated parties to meet their energy saving obligations for 2019 has been modified:
- Original deadline: 31 March 2022.
- Amended deadline: 31 December 2022 (or until the end of the emergency regulation, i.e. 1 June 2022).
What does this mean in practice?
- More time has been allowed for the 2021 projects to be re-audited and the savings certified.
- This relief applied only to 2019 obligations and did not include a reduction for subsequent years.
Impose a fine:
- The Hungarian Energy and Public Utility Regulatory Office (MEKH) could impose fines for the first time on 31 March 2023 for failure to meet energy saving obligations.
Obligation to engage the services of an Energy Specialist
The period of application of the obligation to use an energy adviser has also been amended:
- Applicable from 15 November 2022.
- Impact: companies that did not already have a live contract with an energy specialist will have time to sign one in the second half of 2022. Those who already had such a contract will not be bound by the sub-metering regulation.
Amendment of the Submeasurement Regulation
The amendment to the sub-metering regulation postponed the next step of the installation obligation, which affected companies obliged to use an energy efficiency adviser.
- Deferral: the obligation has been deferred for one year.
- Impact: the 2021 obligations remain in force, but the obligation to measure with sub-meters is replaced by 2022 2023. from 1 January has become due in respect of:
- stand-alone electrical installations with a rated output of over 50 kW (over 1000 operating hours per year).
- Heating and air conditioning systems with a rated electrical output of over 70 kW (over 1000 operating hours per year).
- Installations fed through a single entry point and in technological queuing, where the maximum simultaneous power demand exceeds 100 kW. An important change is that the limit on the number of hours of operation has been abolished for production lines.
The 2022 emergency legislative changes introduced significant, albeit temporary, relaxations and time-limits in the field of energy efficiency. The postponement of the deadlines for the EQS obligations, the later start of the obligation to use an energy advisor and the amendment of the sub-metering regulation have all helped companies to adapt. However, it is important to note that these benefits were linked to the validity of the emergency legislation, so that the long-term energy efficiency targets and obligations remained relevant.
Do you have further questions on the energy efficiency legislative changes?
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