Dutch businesses using 50,000 kWh of electricity or 25,000 m³ of natural gas equivalent or more per year at a location must take every energy saving measure that pays back within five years, usually by following the recognised measures list. Every four years they report the measures taken in the RVO eLoket; the next deadline is 1 December 2027. The largest users must also do an energy saving investigation. Revised rules, with a seven-year payback, are expected from mid-2027.
The energy saving obligation
Under the Environment and Planning Act, businesses and institutions in the Netherlands that use 50,000 kWh of electricity or more, or 25,000 m³ of natural gas equivalent or more, per year at a location must take every energy saving measure that pays for itself within five years. The obligation applies per location and is enforced by the municipality or the regional environmental service.
The recognised measures list
To make the obligation workable, the government publishes recognised measures lists (Erkende Maatregelenlijsten, EML) for sectors and for common building and process measures, such as LED lighting, insulation, heat pump controls and frequency drives. A business that takes the measures on the list that apply to it is considered to meet the obligation. Measures not on the list still count if they pay back within five years.
The information obligation
Businesses under the energy saving obligation must report every four years which measures they have taken, in the eLoket of the Netherlands Enterprise Agency (RVO). The last deadline was 1 December 2023; the next is 1 December 2027. You tick the recognised measures you have taken and explain any you have not. Not reporting is a breach in itself.
The investigation obligation
The largest users, with 10 million kWh of electricity or 170,000 m³ of natural gas equivalent or more per year, must also carry out an energy saving investigation every four years. It looks at their specific processes and installations and lists the measures that pay back within five years, which they then have to carry out.
What changes in 2027
The government is revising the rules. The changes announced include a longer payback period of seven years, updated recognised measures lists, updated energy prices for the calculations and better alignment with who carries out the measures, for example tenant or owner. The consumption thresholds of 50,000 kWh and 25,000 m³ stay. The revised rules are expected to apply from mid-2027, so check the current text before the December 2027 report.
Doing it in Greener Ahead
Greener Ahead does not file the information obligation report. Carbon accounting in Greener Ahead records your electricity, gas and other energy use per location from invoices and meter readings, so you can see whether you pass the thresholds, turns it into Scope 1 and 2 emissions and shows year on year what your measures saved. It costs €1,495 per year with unlimited users, and you can try it free for 14 days without a card. Check the pricing page for current details.
Which obligation applies
The thresholds are per location and per year.
| Annual consumption at a location | Obligation | How often |
|---|---|---|
| 50,000 kWh electricity or 25,000 m³ natural gas equivalent or more | Take all measures with a payback of five years or less | Ongoing |
| The same thresholds | Report the measures taken in the RVO eLoket | Every four years; next by 1 December 2027 |
| 10 million kWh or 170,000 m³ natural gas equivalent or more | Energy saving investigation of processes and installations | Every four years |
Preparing the 2027 report
Start well before December.
- Collect a full year of electricity and gas use per location.
- Find the recognised measures list for your sector and building type.
- Go through each measure: done, not applicable, or planned, with evidence.
- Check whether the revised rules apply to your report.
- Agree with the building owner or tenant who carries out which measures.
Sources and scope
These resources explain a preparation workflow. Check your selected standard and recipient requirements before sharing your report.
Joost ThissenFounder
