IgeraIndustria Energy Team · Updated 2026-08-06 · 7 min read
Part of the ISO 50001:2018 Step by Step series · Clause 5
ISO 50001:2018 Clause 5 places accountability for the Energy Management System (EnMS) on top management. It has three sub-clauses: 5.1 (leadership and commitment), 5.2 (energy policy), and 5.3 (organisational roles, responsibilities, and authorities). Unlike the 2011 edition, ISO 50001:2018 — aligned with the High Level Structure (Annex SL) — no longer mandates a single "management representative" or a formally constituted "energy management team"; top management can organise the EnMS structure as it sees fit, but cannot delegate accountability for its effectiveness.
In practice, certification auditors treat Clause 5 as a strong predictor of how the rest of the EnMS will perform. An organisation where top management can articulate the energy policy, name the current energy performance indicators (EnPIs), and explain recent energy performance trends is far less likely to have gaps elsewhere in the system than one where the energy manager alone carries the whole conversation.
5.1 Leadership and commitment — 8 evidences auditors look for
Clause 5.1 requires top management to demonstrate leadership and commitment with respect to the EnMS through specific, verifiable actions. Here are the 8 evidences most commonly checked during a certification or surveillance audit:
| # | Requirement (5.1) | Practical evidence |
|---|---|---|
| 1 | Accountability for EnMS effectiveness | MD chairs management review meetings; signed management review minutes on file |
| 2 | Energy objectives and targets aligned with business strategy | Board agenda item showing energy performance reviewed alongside operational KPIs |
| 3 | Resources for the EnMS made available | Budget sign-off for metering, energy audits, training, and efficiency projects |
| 4 | Importance of effective energy management communicated | All-hands briefings or intranet updates referencing energy performance data |
| 5 | Achievement of intended EnMS outcomes ensured | EnPI trend reports reviewed at set intervals with documented corrective actions when off-track |
| 6 | Direction and support for people contributing to EnMS effectiveness | Named process owners with energy responsibilities in their job descriptions |
| 7 | Continual improvement of energy performance promoted | Improvement log with at least one sponsored efficiency project per certification cycle |
| 8 | Active participation in management review | Management review minutes showing top management input, not just sign-off |
Note on the removal of the mandatory management representative: ISO 50001:2011 required organisations to appoint a management representative and constitute an energy management team. The 2018 revision, aligned with Annex SL, removed this specific requirement — top management is now directly and explicitly accountable, and can structure the EnMS team as it judges appropriate, provided the necessary technical competence in energy use, consumption, and efficiency is ensured.
5.2 Writing an energy policy that passes audit
Clause 5.2 requires the energy policy to be appropriate to the purpose of the organisation; include a commitment to continually improve energy performance; include a commitment to ensure the availability of information and of necessary resources to achieve objectives and targets; include a commitment to comply with applicable legal requirements and other requirements related to energy use, consumption, and efficiency; provide the framework for setting and reviewing energy objectives and targets; support the procurement of energy-efficient products and services, and design for energy performance improvement; be documented, communicated within the organisation, and available to relevant interested parties; and be reviewed and updated as appropriate.
A generic policy that never mentions the organisation's actual energy uses is a common audit finding. Compare these two examples:
"We are committed to reducing our energy consumption and complying with all applicable requirements. We continually improve our energy management system."
This could apply to any site in any sector — it says nothing about which processes consume the most energy or what "improvement" actually means for this organisation.
"A metal processing plant is committed to reducing the specific energy consumption of its melting and forming processes, which account for the majority of site energy use. We commit to complying with applicable UK energy efficiency legislation, including ESOS obligations, ensuring adequate resources for metering and energy audits, prioritising energy-efficient equipment in capital procurement decisions, and reviewing energy objectives annually alongside operational KPIs. Our Managing Director is personally accountable for EnMS effectiveness and reviews energy performance indicators quarterly."
Communication requirement: the energy policy must be communicated within the organisation and made available to relevant interested parties on request. It does not need to be published publicly, but it must genuinely reach the people whose work affects significant energy uses — production supervisors, facilities management, and procurement — not just sit in a policy binder.
5.3 Roles, responsibilities and authorities — RACI matrix template
Clause 5.3 requires top management to ensure that responsibilities and authorities for relevant EnMS roles are assigned and communicated. There is no mandated job title; what matters is that each critical EnMS function has a clear owner with documented authority to act.
| EnMS function | Accountable (A) | Responsible (R) | Clause ref. |
|---|---|---|---|
| EnMS overall effectiveness | Managing Director | Energy Manager | 5.1 |
| Energy policy maintenance | Managing Director | Energy Manager | 5.2 |
| Energy review and baseline | Energy Manager | Energy Engineer / Consultant | 6.3 |
| EnPI monitoring and reporting | Energy Manager | Facilities / Process engineers | 9.1 |
| Internal EnMS audit | Energy Manager | Lead Internal Auditor | 9.2 |
| Management review | Managing Director | Energy Manager (organises) | 9.3 |
// IgeraIndustria RAG demo — ISO 50001 Clause 5 audit prep query
Energy Manager: What leadership evidence do we have for Clause 5.1 ahead of the surveillance audit?
IgeraIndustria: Your documented evidence for Clause 5.1 includes: (1) Management Review minutes for 2 meetings in 2026 (MR-2026-01, MR-2026-02), both signed by MD James Whitfield, covering EnPI trends, energy objective status, and resource decisions; (2) MD-signed energy policy EP-002 Rev 3, dated 2026-01-15; (3) Capital approval for compressed-air leak survey signed by MD (CAPEX-2026-011); (4) Quarterly EnPI dashboard reviewed by MD, last review 2026-06-30. Gap identified: no documented evidence of MD communicating energy performance to shop-floor staff since Q1 — recommend an all-hands energy briefing before the audit window opens.
Frequently asked questions
Does ISO 50001:2018 still require a management representative or energy team?
No. The 2018 revision, aligned with the High Level Structure, removed the mandatory management representative and formally constituted energy management team required under the 2011 edition. Top management is now directly accountable for EnMS effectiveness and may organise roles as it sees fit, provided technical competence in energy use, consumption, and efficiency is assured somewhere in the organisation.
What is the difference between the energy policy and energy objectives/targets?
The energy policy (Clause 5.2) is the high-level framework — the organisation's overall commitments to improving energy performance and legal compliance. Energy objectives and targets (Clause 6.2) are measurable commitments derived from that policy, such as reducing specific energy consumption of a defined process by a set percentage within a set timeframe. The policy must explicitly provide the framework within which those objectives are set.
Must the energy policy be published publicly?
No, but it must be available to relevant interested parties on request — which can include customers, regulators, or certification auditors. Publication is not mandatory, but the policy must genuinely be communicated within the organisation to the people whose roles affect significant energy uses.
How does Clause 5 relate to ESOS and other mandatory energy audit schemes?
The energy policy required under Clause 5.2 must include a commitment to comply with applicable legal requirements related to energy use, consumption, and efficiency — which, in the UK, includes obligations such as the Energy Savings Opportunity Scheme (ESOS) where applicable. In several jurisdictions, holding a certified ISO 50001 EnMS that covers the relevant energy consumption satisfies mandatory energy audit obligations, avoiding the need for a separate compliance route.
Can top management delegate its EnMS accountability entirely?
Top management can delegate day-to-day operational management of the EnMS to an energy manager or technical team, but cannot delegate accountability for the system's overall effectiveness. Clause 5.1 is explicit on this point. Auditors will typically seek to interview top management directly rather than relying solely on statements from the energy manager.
What should a top management interview cover during an ISO 50001 audit?
Auditors typically ask top management to explain the energy policy in their own words, describe the organisation's most significant energy uses, summarise recent EnPI trends, explain how energy-related risks and opportunities are managed at a strategic level, and confirm what resources have been committed to the EnMS in the current period.
Preparing top management for an ISO 50001 audit interview? IgeraIndustria generates leadership evidence briefings directly from your EnMS records.
See IgeraIndustria in actionArticle reviewed by IgeraIndustria Energy Team, updated 2026-08-06. References: ISO 50001:2018 Clause 5; ISO High Level Structure (Annex SL).