Energy audits and energy management systems are recognized as important instruments to improve energy efficiency. By introducing Article 8 of its Energy Efficiency Directive (EED) the European Commission has made regular energy audits an obligation for large companies. Its transposition into national legislation by the EU-28 Member States (MS) results in different national implementations. The aim of this paper is to analyze differences and communalities in the national requirements and to derive good practice for policy makers from these. We structure the implementation process according to the theoretical concept of Policy Cycle Analysis and apply it as a heuristics from a multi-level governance perspective. The empirical analysis is based on a review of national implementation documents and 30 semi-structured interviews with stakeholders involved in the process of Article 8 EED. The transposition was delayed in more than half of the 28-EU MS. Our findings suggest that the interlinkages of the policy cycles are particularly important for a smooth policy process as MS partly interpreted the requirements differently. Further research on an updated, in-depth analysis of the correctness of the transposition as well as research on the impact of energy audits and energy management systems induced by the regulation is needed.