Mandatory Submetering – Information for Businesses
Companies that are required to use an energy efficiency specialist under Hungarian legislation are also subject to mandatory electricity submetering requirements from 1 January 2022 in specified cases.
This may apply to companies whose average annual energy consumption over the previous three years exceeds any of the following thresholds:
400,000 kWh of electricity;
100,000 m³ of natural gas;
3,400 GJ of heat.
The minimum technical requirements and installation points for mandatory electricity submeters are defined by MEKH Decree No. 1/2020 (I. 16.), issued by the Hungarian Energy and Public Utility Regulatory Authority.
The key principles of the submetering regulation
The regulation defines minimum requirements for both the measuring equipment and the points where separate measurement is required.
1. Requirements for the submetering solution
The submetering solution must include an electricity meter that:
meets at least accuracy class B;
is capable of measurement at intervals of at least 15 minutes;
is capable of storing and/or transmitting measurement data;
and is capable of measuring electricity consumption.
2. Where is submetering required?
Submetering may be required for electrical equipment whose electricity consumption cannot be reliably determined solely from installed capacity and operating hours.
This is particularly relevant where equipment can regulate its power demand through control systems — for example variable-speed or inverter-controlled equipment — or where equipment can switch on and off automatically without its operating time being recorded by an hour meter.
The applicable thresholds from 1 January 2022 are:
| Rated Power Threshold | |
|---|---|
| Individual electrical equipment such as compressors, motors, pumps, drives and process equipment | over 50 kW |
| Electrical heat-generating and air-conditioning equipment | over 70 kW |
| Equipment connected through a common supply point and operated as part of a technological system, such as a production line, industrial hall or building | over 100 kW |
3. Where may submetering not be required?
Equipment exceeding the power thresholds above may be exempt where its average operating time during the previous three years did not exceed 1,000 hours per year.
Separate submetering may also not be required where electricity consumption can be determined from installed power and accurately recorded operating time.
An example may be a fixed-speed compressor equipped with a reliable operating-hour meter.
4. What happens if the requirements are not met?
Compliance with the applicable energy-efficiency and metering requirements may be reviewed by the Hungarian Energy and Public Utility Regulatory Authority (MEKH).
Where a company is subject to mandatory requirements, non-compliance may result in regulatory action under the applicable legislation.
Because regulatory requirements and enforcement procedures may change, the current legislation and MEKH guidance should always be reviewed when determining compliance obligations.
Submetering for energy-efficiency investments supported by a corporate income tax incentive
Where a company claims a Hungarian corporate income tax (TAO) incentive for an energy-efficiency investment, submetering may also be required irrespective of the equipment power rating if the energy saving achieved by the investment cannot be determined reliably by calculation.
For example, if a fixed-speed compressor is replaced with a variable-speed compressor, the resulting energy saving may need to be determined using measured consumption data.
Not sure whether your company is affected?
The requirement depends not only on the size of your company or its total energy consumption, but also on the type, power and operating characteristics of the equipment installed at the site.
OMS24 Zrt. can help assess which equipment may be subject to mandatory submetering requirements and design a measurement system that meets both regulatory and operational needs.
Contact us to discuss whether mandatory submetering requirements apply to your sites.
This information is provided for general guidance and does not constitute legal advice. Applicable requirements should always be determined based on current legislation and the technical characteristics of the individual site.