What do I need to do for the 2027 energy-saving obligation?
Direct answer
To prepare for the Dutch energy saving obligation deadline in 2027, follow four steps: check whether your site falls under the obligation, map your energy consumption, implement every measure with a payback period of five years or less, and report via the RVO portal by 1 December 2027. The obligation applies to sites using at least 50,000 kWh of electricity or 25,000 m³ of natural gas equivalent per year.
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What do I need to do for the 2027 energy-saving obligation: scattered information versus Energy Intelligence
The Netherlands has long required businesses and institutions to actually carry out cost effective energy savings. Since the Environment and Planning Act, the energy saving obligation has become broader and now also counts CO2 reduction alongside savings. Picture a distribution centre reviewing its lighting, compressed air leaks and heating curves, then accounting for the results. Many organisations last reported in 2023 and must demonstrate again in 2027 what has been implemented. Starting now with measurement and planning prevents a backlog of overdue measures just before the deadline.
- The notification duty and the investigation duty run on a four year cycle: the previous round closed on 1 December 2023, and the next final submission date is 1 December 2027.
- The Recognised Measures List (EML) is the basis of the report: for each recognised measure you state whether you have implemented it, have not implemented it, or replaced it with an alternative.
- Large consumers using at least 10 million kWh of electricity or 170,000 m³ of natural gas equivalent per year, in sectors regulated at national level, fall under the investigation duty and submit an investigation report.
Insight
Traditional approach
Information is scattered across portals, documents, invoices or separate spreadsheets.
Modern approach
Data, context and interpretation are brought together into a clear decision picture.
Decision-making
Traditional approach
Choices are made based on averages, assumptions or occasional analyses.
Modern approach
Scenarios, KPIs and current measurement data make the trade-off more concrete and repeatable.
Follow-up
Traditional approach
Actions often stay non-committal or disappear into separate reports.
Modern approach
Follow-up actions, monitoring and reporting are linked to the same energy data.
Does your organisation fall under the obligation?
You fall under the energy saving obligation if your site carries out a relevant environmentally impactful activity and uses at least 50,000 kWh of electricity or 25,000 m³ of natural gas equivalent per year. The obligation is set out in the Living Environment Activities Decree for activities and in the Living Environment Structures Decree for buildings. Two parties can therefore be responsible: the user for the activities and the building owner for the building measures. Since 1 July 2023 the obligation also applies to companies holding an environmental permit. If your site uses at least 10 million kWh or 170,000 m³ of natural gas equivalent per year and your sector is regulated at national level, the investigation duty applies as well. Other energy carriers, such as diesel or heat, are converted into natural gas equivalents.
- Threshold: at least 50,000 kWh of electricity or 25,000 m³ of natural gas equivalent per year
- Legal basis: the Living Environment Activities Decree and the Living Environment Structures Decree
- The user and the building owner can each carry their own obligation
- Investigation duty from 10 million kWh or 170,000 m³ of natural gas equivalent per year
- Permit holding companies have also been covered since 1 July 2023
Which steps should you take towards 1 December 2027?
You must submit the new report via the RVO portal by 1 December 2027. Work towards that date in four steps. First map your energy consumption per site, for example with metering data per building and per installation. Then work through the Recognised Measures List for your situation and determine the status of each measure. Next, implement every measure with a payback period of five years or less, calculated with the statutory method in the Environment and Planning Regulation. Measures that do not save energy but do reduce CO2 emissions are also covered, such as generating renewable energy or switching to an energy carrier with lower emissions. Finally, report for each recognised measure whether you have implemented it or chose an equivalent alternative.
- Step 1: map consumption per site and per installation
- Step 2: work through the Recognised Measures List (EML) for your sector
- Step 3: implement measures with a payback period of five years or less
- Step 4: report via the RVO portal by 1 December 2027
- Building measures are always reported through the notification duty
How do monitoring and data provide the evidence?
Energy monitoring demonstrates that measures have been implemented and are effective. The competent authority, usually the municipality and in practice the regional environment agency, assesses your report and can ask for substantiation. Consumption data per meter and per installation show what a measure delivers compared with the reference situation. That reference also underpins the payback calculation when you deviate from the EML: anyone choosing their own route must prove through an investigation that all measures with a payback period of five years or less have been taken. Start structural monitoring well before the deadline. That way you detect hidden consumption, check that settings remain in place after maintenance, and build a file that withstands an inspection.
- Supervision lies with the municipality or province; regional environment agencies carry it out
- Metering data substantiate the reference situation and the effect of measures
- Deviating from the EML requires your own investigation as evidence
- Structural monitoring detects regression after maintenance or a change of season
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