BRL 9500 inspections: internal and external checks

Under BRL 9500, energy labels are checked in two ways. The company carries out internal checks itself, and a certification body (CB) carries out external checks and audits. Whoever finds a deviation determines what happens next: a short period to put it right, a suspension or, in the worst case, withdrawal of the certificate.

The requirements are set out in chapters 6 and 7 of the assessment guideline BRL 9500-W from InstallQ (the Dutch certification body). These checks only work if the registration in EP-Online is correct, because the CB takes its sample from there. You can read how a company gets certified on company certification.

The difference between internal and external checks

The company carries out internal checks itself, using its own auditor. That auditor must be independent of the work they check. External checks are carried out by the CB. It checks whether the company continues to meet the requirements, and whether the energy labels are correct.

	Internal check	External check
Who	The company itself	The certification body
What	The quality system and a share of the reports	The organisation and a sample of the reports
How often	At least one internal audit per year	One organisation audit per year, and project checks
Result	Recorded in a register, with the deviations found	Recorded in a report, with the sanction that follows

Internal checks: what the company does itself

The company carries out internal audits every year. The audit checks whether the quality system works as described in the manual. The first audit must take place within the first six months after admission.

The company also checks a share of the reports that each advisor registers. That share is at least 2% per advisor, per subarea, per year. Half of it is checked on file. The other half is checked on site, at the location. This applies to existing dwellings or handover. Reports for a check against the Building Work and Living Environment Decree (Bbl) are only checked on file. The checks preferably take place within three months of registration.

An example makes this concrete. Advisor Sanne de Vries of the fictional company Haagsma Energieadvies BV registered 100 reports for existing dwellings last year. The company then checks at least 2 of her reports. One on file and one on site. The company records the result in the register.

If the company registers more than 1,000 reports per year, it carries out file checks every quarter. For a new advisor, the company also checks extra reports straight after registration.

External checks: what the certification body does

The CB checks two things. First the organisation, then the projects. The organisation audit takes place every year. The CB calls this the annual follow-up. See also the Kiwa overview of the follow-up .

For the project checks, the CB selects a sample. Six months after admission, and then every year, the CB checks at least 0.5% of the reports per advisor. That is never fewer than two reports per advisor. Of the first two reports, one is checked on site afterwards and one on file.

Advisors who register fewer than 50 reports per year receive one check per year. This alternates between a check on site and a check on file.

The CB can also carry out targeted checks, for example after a complaint. Ask your CB how it handles that.

What happens when there is a deviation?

Not every deviation is equally serious. The guideline distinguishes between non-critical and critical deviations. A critical deviation directly affects the quality of the work. The table shows what follows.

Situation	What the CB requires	Deadline
Non-critical deviation in the organisation	Written corrective measures	Within three months
Critical deviation in the organisation	Corrective measures, and an extra check if these are not sufficient	Measures within one month, extra check within three months
Critical deviation in a project	Re-registering the report after correction	After the deviation has been resolved
Suspension	A plan of action, and the certificate may not be used	Up to six months
Suspension not lifted	Withdrawal of the certificate	After six months

A project deviation has a tolerance. The margin depends on the primary fossil energy use (EP2) of the dwelling. Up to and including 125 kWh/m² per year, the margin is 10 kWh/m² per year. Between 125 and 435 kWh/m² per year, the margin is 8%. Above 435 kWh/m² per year, the margin is 35 kWh/m² per year. If the deviation exceeds that margin, it is a critical deviation (section 7.2.6.2).

Withdrawal of the company certificate does not automatically affect all labels. Only the reports from the period covered by the decision disappear from EP-Online, and only if the sample check has not yet taken place or the suspension results from poor project checks. Read more about the consequences on EP-Online registration.

What happens to the advisor?

The individual advisor can also face consequences. After one critical deviation, the CB can give the advisor a yellow flag. This is visible in the Centraal Register Techniek (Central Register for Technical Professionals), for the advisor, the company and the CB.

The yellow flag is removed after two years without new critical deviations, and as soon as the advisor fully cooperates with the checks again. If the advisor receives a second yellow flag, InstallQ withdraws their professional competence. InstallQ can also withdraw competence in cases of fraud, or after critical deviations in two consecutive years. An example is registering a basic assessment when a detailed assessment was required. See basic or detailed assessment.

Without professional competence, the advisor may no longer prepare reports. They then have to retake the full exam. You can read how the exam works on the EP advisor exam page.

Frequently asked questions

Can a company refuse a check?

No. The company must cooperate with the organisation-focused and project-focused checks. If it refuses, the CB withdraws the certificate. This also applies after the certificate has ended: anyone who stops certification must still cooperate with checks on the reports already issued.

What exactly is a critical deviation?

A critical deviation directly affects the quality of the work. Think of a missing mandatory element in the manual, or a report whose outcome is too far from the check. Not every mistake is critical. For the organisation, it concerns a missing mandatory element in the manual or delegation to non-certified parties. For projects, it concerns a deviation that exceeds the permitted margin.

How often are checks carried out for a new company?

The first external project check takes place six months after admission. After that, a new check follows every year. The company itself checks reports from the first months onwards. See BRL 9500 company certification for the admission assessment.