Environmental permit (omgevingsvergunning milieu) and ISO 14001

Since 1 January 2024, the environmental permit has been called an environmental permit for an environmentally impacting activity. The rules are set out in the Environment and Planning Act (Omgevingswet) , mainly in the Dutch Living Environment Activities Decree (Besluit activiteiten leefomgeving, Bal). For each activity, the Bal determines whether you need a permit, must submit a notification, must supply information or only follow general rules. For ISO 14001, all these duties are compliance obligations (clause 6.1.3) that belong in your legal register. Below you can read how to determine what applies to you, with a sample register.

Short answer: check in the Omgevingsloket (online permit portal) whether your activity is listed in chapter 3 of the Bal. If it is, that section tells you whether you need a permit, notification or information duty, and which rules apply. If your activity is not listed, the environmental rules in your municipality’s environment plan (omgevingsplan) apply. If you already held a Wabo environmental permit, it automatically counts as an environmental permit for an environmentally impacting activity.

What changed with the Environment and Planning Act for the environmental permit?

Under the old Environmental Management Act (Wet milieubeheer), the authorities looked at an “installation”: your whole business location. The Environment and Planning Act looks at separate environmentally impacting activities. A company can therefore have several activities, such as a boiler installation, a storage tank and a workshop, each with its own rules.

Under the old law	Under the Environment and Planning Act (since 1 January 2024)
Installation	Environmentally impacting activity
Environmental Management Activities Decree (Activiteitenbesluit milieubeheer)	Dutch Living Environment Activities Decree (Besluit activiteiten leefomgeving, Bal)
Environmental permit under the Wabo	Environmental permit for an environmentally impacting activity
Notification under the Activities Decree	Notification or information duty under the Bal
Rules in the Activities Decree for shops and hospitality, for example	Rules in the municipal environment plan

Existing permits have not lapsed. An irrevocable Wabo environmental permit applies by law as an environmental permit for the environmentally impacting activities of the former installation. The conditions remain in force. This is set out in the transitional law of IPLO (Information Point for the Living Environment) .

Your old permit number and conditions therefore remain valid, but the rules around them have moved. References in your register to the Activities Decree or the Environmental Management Act are out of date. An ISO 14001 auditor sees that as a register that is not up to date.

Permit, notification or information duty?

The IPLO step-by-step plan helps you determine, for each activity, what applies. In summary:

Step	Question	Where you find it
1	Is my activity listed as an environmentally impacting activity in chapter 3 of the Bal?	Bal chapter 3, or the Omgevingsloket
2	Which substantive rules apply?	Bal chapters 4 and 5, via the signpost article (“richtingaanwijzer”) in chapter 3
3	Do I need a permit?	The article on the “designation of cases requiring a permit” in the section
4	Must I submit a notification?	Bal chapter 4, at least 4 weeks before the start
5	Which other information must I supply?	Information duties in chapters 2 to 5
6	Are there rules from the municipality, province or water board?	Municipal environment plan, provincial environment regulation, water board regulation
7	Has the competent authority (bevoegd gezag) deviated from the rules?	Tailored conditions (maatwerkvoorschriften), permit conditions, equivalent measures

Two details are often forgotten. For every environmentally impacting activity under the Bal, a specific general duty of care applies: you prevent or limit adverse effects on the environment, even where there is no specific rule. And a notification lapses if the activity already requires a permit, because you then supply the information with the application.

Who is the competent authority? Usually the municipality. For complex companies, often the province. In practice, supervision and enforcement is carried out by the environmental service agency (omgevingsdienst).

What does an environmental permit for an environmentally impacting activity contain?

A permit contains conditions that are specific to your location. They are added to the general rules in the Bal. Typical conditions concern:

noise and vibration at the boundary of your site;
emissions to air, with measurement obligations;
discharges of wastewater;
storage of dangerous substances;
records and reports to the competent authority.

Every condition with a measurement, recording or reporting obligation becomes a rule in your register. This is exactly the kind of evidence that an ISO 14001 auditor asks for during the compliance evaluation.

Example: the environmental permit in your ISO 14001 register

Below is an extract from the compliance register of a fictional metal processing company. The company has a transferred Wabo permit and a few activities that require notification. The “Source” column shows where each obligation comes from.

Environmental aspect	Activity	Source	Type of duty	What is required	Evidence	Check frequency	Owner
Emissions to air	Paint line	Environmental permit, condition 4.2	Permit	Solvent emission measurement, report to the competent authority	Measurement report	Annually	KAM coordinator
Wastewater	Degreasing parts	Environmental permit, condition 6.1	Permit	Discharge via oil separator, separator maintenance	Maintenance report, emptying receipts	Every six months	Technical department
Energy use	Whole site	Bal, energy saving obligation	General rule and information duty	Take recognised measures and report	RVO report (Netherlands Enterprise Agency), see energy saving obligation	Once every 4 years	Facilities
Storage of dangerous substances	Storage of spray cans and paint	Bal, general rules for storage in packaging	General rule	Storage according to the prescribed PGS guideline (Publication Series on Dangerous Substances)	Storage inspection report	Annually	Warehouse
Refrigerants	Office cooling installation	EU F-gas Regulation (F-gassenverordening)	General rule	Leak check by a certified company (BRL 100)	Installation log	According to the log	Facilities
New activity	Installation of a second boiler	Bal, boiler installation	Notification	Notification at least 4 weeks before start	Acknowledgement from the Omgevingsloket	One-off, on change	Technical department

Also store the permit itself in your document register: decision date, reference number, any amendments and tailored conditions. That way you can see at a glance which version applies.

What does the ISO 14001 auditor want to see for the environmental permit?

The auditor does not check whether your permit is legally correct. The auditor checks whether you know what it says and whether you can show that you comply with it.

Clause	What the auditor asks	Evidence
6.1.3	Which permits, notifications and general rules apply?	Register with current sources, copy of the permit
6.1.2	Are the permitted activities linked to your environmental aspects?	Link between the aspects register and the legal register
6.3	How do you ensure that a change is notified or applied for in time?	Change procedure with a check on the permit and notification
7.4	Do you communicate with the competent authority as required?	Submitted reports, correspondence with the environmental service agency
9.1.2	Do you comply with every condition?	Compliance evaluation with measurement data and conclusion

A common finding is a new installation that has been put in place without the notification having been submitted. Clause 6.3 of ISO 14001:2026 (planning of changes) is specifically intended to prevent this.

Do you need ISO 14001 for an environmental permit?

No. The Environment and Planning Act does not require ISO 14001, and a certificate does not replace a permit or notification. The other way round, ISO 14001 does help: the system obliges you to keep track of obligations, assess changes and check compliance every year. That makes an inspection by the environmental service agency a lot more predictable.

Next step

Update your register with the sources on this page and link each rule to your environmental aspects. Then plan a compliance evaluation and use the ISO 14001 checklist to check whether clauses 6 and 9 are complete. Work in manufacturing? Also read ISO 14001 for manufacturing companies.