Energy manager and energy performance certificate: which hotels must have them

In Türkiye a hotel counts as a commercial and service building, so two separate duties apply. The energy manager: an ongoing operational duty at 20,000 m² total construction area or 500 TEP (tonnes of oil equivalent) yearly consumption, under Energy Efficiency Law No. 5627. The energy performance certificate (EKB): a document tied to construction and to property transactions, needed at occupancy permit for new buildings and at sale and rental, valid ten years. If you already own and operate the building, the EKB is not a standing yearly task; the energy manager is.

An owner reads that hotels above 20,000 m² need an energy manager, checks the title deed of the hotel block, and stops there. The regulation measures total construction area across the site, and it offers a second trigger: a yearly consumption figure in tonnes of oil equivalent that most owners have never had to put on one page. After reading this you will know which duties your building owes, how to work out your own consumption figure from bills, and what to ask a firm before signing anything.

What is the difference between the energy manager and the energy performance certificate?#

They are two separate duties from two separate texts. The energy manager is about how the building is run; the energy performance certificate is a document about the building itself.

The energy manager duty comes from the Energy Efficiency Law (No. 5627) and the Regulation on Increasing Efficiency in the Use of Energy Resources and Energy (opens in a new tab) (Resmî Gazete 27 October 2011, No. 28097, Article 9 as amended 6 July 2022 and 21 September 2024). The energy performance certificate, Enerji Kimlik Belgesi or EKB, comes from the Regulation on Energy Performance in Buildings (opens in a new tab) (Resmî Gazete 5 December 2008, No. 27075, amended eight times, most recently 16 May 2026).

The energy manager is a person with a certificate, employed or contracted, who is notified to the Ministry by name. The EKB is a rating of the whole building, produced in the BEP-TR software by an EKB expert, and it stays valid for ten years.

A hotel can owe one and not the other: a small hotel still needs an EKB at sale or rental, and a large hotel may owe both at once. Neither document proves the hotel is efficient. They record who is responsible and what the building is, not what it saves.

Which hotels must appoint an energy manager?#

A commercial or service building with a total construction area of at least 20,000 m², or a yearly total energy consumption of at least 500 TEP, must have an energy manager. A hotel falls in that category.

The two triggers are alternatives: crossing either the area figure or the consumption figure is enough to create the duty. Where a site or campus holds several independent buildings, their construction areas are added together, so a hotel made of a main block, a spa block and a separate annex is measured as one.

The duty is met either by an employee who holds an energy manager certificate, or, where that is not possible, by buying the service under contract from a certified energy manager or an energy services company. The energy manager's identity, CV, address and contact details are notified to the Ministry; for a commercial or service building above 20,000 m² that receives an occupancy permit, the notification is due within one year of the permit (Article 9). Under the Law, owners and managements obliged to employ an energy manager send the requested information to the Directorate General by the end of March each year (Article 7).

Public-sector buildings use lower thresholds, 10,000 m² or 250 TEP. That is where many of the figures circulating in summaries come from, and it is not the hotel threshold.

How do you turn your bills into tonnes of oil equivalent?#

You convert each energy carrier the hotel buys into its oil-equivalent value and add the twelve months together. TEP, tonnes of oil equivalent, is the common unit that lets electricity, natural gas and liquid fuel sit in one figure.

Build a twelve-month register first: every electricity meter, the natural gas meter, fuel oil and LPG deliveries, and diesel used by generators, each with its unit and its annual quantity. Use the current official conversion table, taken from your audit firm or energy manager, and record its source and date. Do not lift a factor from a blog, because a wrong factor moves you across the 500 TEP line.

Use a full calendar year, not the season you remember as busy. A hotel that closes in winter still consumed energy in the months it was open. Read the bills, not the contract: a supplier's estimated invoice can hide a correction that lands in a later period. If part of the building is leased to a third party, such as a shop or a leased spa, ask the audit firm how that consumption is attributed before you submit a figure.

Keep the register after the decision. It is the same data an audit will ask for, and it is the only way to see whether a change did anything. If you already read your meters daily, the same numbers feed this register; see energy and water per occupied room from daily meter readings and, on the electricity side, reactive power charges on a hotel bill.

When is an energy audit required, and where does ISO 50001 fit?#

Above the same threshold, 20,000 m² or 500 TEP, the building must have an energy audit carried out by a company, or by its own staff holding a building audit-project certificate, and the audit is renewed every seven years.

The audit, etüt in the Turkish text, is a study of where the energy goes and which measures are worth taking. It is not the same document as the EKB and it does not replace it. The regulation allows two routes: an outside company, or in-house staff who hold the building audit-project certificate. The second route only works if the hotel actually employs such a person.

Seven years is the renewal interval in Article 10. Put the renewal date in the same calendar as the other periodic obligations, because it is easy to lose after a management change. An audit that lists measures without costs, quantities and a payback period gives the owner nothing to decide with. Ask for those three columns before accepting the report. The audit is also the natural moment to look at room controls and plant scheduling before investing, because that is where the measures usually sit.

What does the energy performance certificate mean for a hotel building?#

The EKB is a document that rates the whole building's energy performance, prepared in BEP-TR by an EKB expert, valid for ten years from issue.

For a new building it is required before the occupancy permit. In sale and rental transactions it is required too, and the owner gives a copy to the buyer or tenant. One copy is kept by the building owner, manager, board or energy manager, and one is displayed where it can easily be seen at the building entrance.

It must be renewed within one year of any work that changes the building's annual primary energy need, so a façade renewal or a new heating plant starts that clock. It covers the whole building, not one wing, and it is prepared in BEP-TR, the national calculation method, by an authorized expert.

Article 2 lists what falls outside the regulation: buildings used for production in industrial areas, buildings planned for less than two years, buildings under 50 m², greenhouses, workshops, and separately built depots, stables and similar buildings that need no climate control for human comfort. Article 25 lists where an EKB is not compulsory: certain state security and defence buildings, buildings built without a permit under zoning law, and buildings outside municipal adjacent areas (mücavir alan) with a construction area under 1,000 m².

The certificate rates the building. It says nothing about how the hotel is operated, so a well-rated building can still waste heat through an unmanaged plant room.

What should you confirm with an authorized firm before you sign?#

Confirm the scope, the authorization, who signs, what is filed with the Ministry and when the next renewal falls. Those five answers decide whether the work is worth its price.

Ask which authorization the firm or expert holds for the specific job. EKB preparation and energy auditing are different authorizations held by different people. Ask whether the audit covers the whole building as defined by the total construction area, or only the part the hotel operates. Ask who prepares the EKB, in which BEP-TR version, and whether the certificate will cover the entire building.

Ask what is notified to the Ministry, by whom, and on what date, including the annual submission due by the end of March. Ask for the seven-year audit renewal date and the ten-year EKB expiry date in writing, and put both in the property's compliance calendar next to the lift, boiler and fire inspections. Do not accept a savings percentage in a proposal as a fact. No figure in a sales document binds the building; only measured consumption after the change does.

What to do next#

Prepare a single page: the site's total construction area, and twelve months of energy quantities converted to TEP with the current official factors. If either figure crosses the line, you owe an energy manager, an audit on a seven-year cycle and a notified contact at the Ministry; if neither does, the EKB duties at occupancy permit, sale and rental still apply. Put the audit renewal and the certificate expiry in the same calendar as your other periodic inspections, and confirm your own case with an authorized firm and your legal adviser, because both texts have been amended recently.