EED obligation 2027 and ISO 50001
From 11 October 2027, companies with high energy use in the Netherlands must have an energy management system. This comes from the revised Energy Efficiency Directive (EED) of the European Union. The Netherlands Enterprise Agency (Rijksdienst voor Ondernemend Nederland, RVO) implements it. Since the revision, whether you are obliged no longer depends on your number of employees, but on your energy use in terajoules (TJ). This article explains which threshold applies to you and what your options are.
From 85 TJ: energy management system mandatory. Do you use more than 85 terajoules of energy per year on average? Then you must have introduced and certified an energy management system (such as ISO 50001) before 11 October 2027. Do you use between 10 and 85 TJ? Then the energy audit obligation applies.
What is the EED and what does it mean for ISO 50001?
The Energy Efficiency Directive is a European directive that requires member states to take measures to save energy. The directive has been revised and tightened. The aim: make Europe considerably more energy efficient by 2030.
The big change: previously the law looked at company size (more than 250 employees, turnover above €50 million). Since the revision, only your energy use counts. If you use a lot of energy, you fall under the rules, regardless of how large or small your company is.
Which EED threshold applies to you?
Your obligation depends on your average annual energy use over the past 3 years. Your use includes all of your energy: electricity, gas, fuel for your vehicle fleet, everything combined. The RVO converts this into terajoules (TJ).
| Average energy use | What you must do | Deadline |
|---|---|---|
| Below 10 TJ | Nothing under the EED | None |
| 10 to 85 TJ | Energy audit (every 4 years) or ISO 50001 | About 1 year after the Dutch law takes effect (expected end of 2026) |
| More than 85 TJ | Energy management system (ISO 50001 or EMAS), certified and mandatory | 11 October 2027 |
For reference, 10 TJ roughly corresponds to about 2.8 million kWh of electricity, or the gas use of a medium-sized manufacturing company. Not sure? Convert your use or ask the RVO .
We explain the difference between the two obligations on the page EED audit obligation. That page explains what the audit obligation (already current for 10-85 TJ) involves, while this page focuses on the more demanding obligation to have an energy management system from 85 TJ in 2027.
ISO 50001 exempts you from the audit obligation
Do you have a certified energy management system such as ISO 50001? Then you are fully exempt from the separate energy audit obligation. You do not have to commission a separate audit every 4 years. This avoids duplicate work and is an important reason why many companies choose ISO 50001.
Two options: ISO 50001 or energy audit
If you are subject to the EED, you have two ways to comply.
Option 1: ISO 50001 certification
You implement an energy management system according to ISO 50001 and have it certified by an accredited body.
Advantages:
- One-off certification (valid for 3 years, then recertification)
- Ongoing system: You keep improving structurally, not only during audits
- Certificate: Marketing, client requirements, tenders
- Higher savings: On average 15-20% energy savings within 3 years
- Subsidy benefits: Helps with EIA and SDE++ applications
Disadvantages:
- Higher initial costs: €40k-€120k to implement (depending on size)
- More work: You build a complete management system
- Annual audits: A surveillance audit every year (€5k-€20k)
Suitable for: Companies that want to take energy savings seriously, already hold ISO 14001 (70% overlap), or need a certificate for clients or tenders.
Option 2: energy audit every 4 years
You have an energy audit carried out every 4 years by a recognised firm, in line with EN 16247.
Advantages:
- Lower costs: €15k-€35k per audit
- Less internal effort: The auditor does the work, you supply the data
- Meets the law: You are compliant
Disadvantages:
- Recurring: Repeated every 4 years (in 2027, 2031, 2035, and so on)
- No system: After the audit, you forget about it until the next one
- Lower savings: On average 5-8% (ad hoc measures without structure)
- No certificate: You cannot show clients that you are actively working on energy
Suitable for: Companies that only want to comply with the law, have no ambition for structured energy management, or for whom energy is not a major cost.
Comparison: ISO 50001 vs energy audit
| Aspect | ISO 50001 | Energy audit |
|---|---|---|
| Frequency | One-off (plus annual check) | Repeated every 4 years |
| Initial costs | €40k-€120k | €15k-€35k |
| Annual costs | €25k-€50k (audit + system) | €0 (until the next audit) |
| Total costs (12 years) | €200k-€400k | €45k-€105k (3 audits) |
| Energy savings | 15-20% (structural) | 5-8% (ad hoc) |
| Payback period | 1-3 years | Depends on the measures |
| System/structure | Yes, ongoing PDCA | No, a snapshot |
| Certificate | Yes, valid for 3 years | No, audit report only |
| Combination with ISO 14001 | Possible (60-70% overlap) | Not relevant |
| Client value | High (marketing, supply chain) | Low |
| Subsidy value | Helps with EIA, SDE++ | Neutral |
Advice on choosing:
- Choose ISO 50001 if: You are energy-intensive (energy above 10% of costs), already hold ISO 14001, clients ask for it, or you really want to improve.
- Choose an energy audit if: You want to do the minimum, energy is a small cost item (below 5%), or you have no resources for a system.
What must an energy audit (EN 16247) contain?
If you choose the energy audit route, the audit must comply with EN 16247.
Required components:
- Scope: Which buildings, processes and energy flows are covered by the audit?
- Data collection: Historical consumption (at least 12 months), invoices, measurements
- On-site inspection: The auditor visits and reviews the installations
- Analysis: Where does the energy go? Identify the largest consumers
- Saving measures: A list of concrete measures, costs and returns
- Report: A detailed audit report with conclusions and recommendations
Who may carry out the audit: Only recognised energy auditors may do this. The list is on the RVO website (Netherlands Enterprise Agency).
Costs: €15k-€35k depending on company size and complexity
Note: You are not obliged to carry out the recommended measures. You only have to have the audit done. But it would be a waste to spend €20k on an audit and then do nothing with the recommendations.
What happens if you do nothing about the EED obligation?
If you do not comply on time, you break the law. The competent authority (often the environmental service (omgevingsdienst), on behalf of the province or municipality) enforces the rules. Enforcement usually follows these steps:
- Warning and a period to remedy (first offence)
- Penalty payment to force compliance
- Administrative fine for persistent non-compliance
The exact amount of any fine depends on your situation and the competent authority. Check the current enforcement rules with the RVO or your environmental service.
Advice: do not wait. Start preparing in 2026. If everyone calls consultants just before the deadline, the market is overbooked and you pay more.
MJA3 and MEE: what happened to them?
Before 2020, many companies had long-term energy efficiency agreements (Meerjarenafspraken energie-efficiëntie, MJA3) or the MEE agreement (MEE-convenant). These were voluntary agreements between the government and sectors.
Status:
- MJA3 and MEE ended in 2020
- Companies that took part had to switch to ISO 50001 or another form of energy management
- The EED obligation is the successor: no longer voluntary, but legally mandatory for energy-intensive companies
Many former MJA3 companies have implemented ISO 50001. They are ready for 2027.
CSRD and EED: a double obligation for ISO 50001 companies?
Some large companies are also covered by the CSRD (Corporate Sustainability Reporting Directive). They must report on energy, CO2 and sustainability.
Overlap: ISO 50001 helps enormously with CSRD reporting. It provides the data (EnPIs, energy use per process) that you need for the ESRS (European Sustainability Reporting Standards).
If you are subject to both the CSRD and the EED, ISO 50001 is the logical choice: you comply with both through one system.
For more detail, see: CSRD and ISO 50001
How do you start (if you are obliged)?
Timeline: start well in advance
An energy management system must be introduced and certified before 11 October 2027. Implementing ISO 50001 takes 6-12 months, an energy audit 2-4 months. Do not wait until just before the deadline, or the market will be overbooked.
Step 1: Check which threshold applies to you Calculate your average energy use (TJ) over the past 3 years. Below 10 TJ: nothing. 10-85 TJ: audit obligation. Above 85 TJ: energy management system.
Step 2: Make a choice: ISO 50001 or energy audit See the comparison table above. Speak to a consultant or auditor for advice.
Step 3: Arrange the budget ISO 50001: €40k-€120k. Energy audit: €15k-€35k. Arrange approval from the management team (MT) or the board.
Step 4: Request quotes For ISO 50001: a consultancy firm (implementation) plus a certification body (audit). For an energy audit: a recognised audit firm (check the RVO list).
Step 5: Make a plan
- ISO 50001: 6-12 months of implementation, followed by the certification audit
- Energy audit: 2-4 months of data collection, inspection and report
Step 6: Carry out the work Follow the step-by-step plan for ISO 50001, or have an audit firm carry out the energy audit.
Frequently asked questions
Q: Does the company size threshold (250 employees) still apply? A: No. Since the EED revision, only your energy use in TJ counts, not your number of employees or your turnover. A small company with high energy use may be obliged, while a large company with low energy use is not.
Q: Does the EED also apply to non-profits and government? A: Yes. The thresholds apply to every organisation. Municipalities, hospitals and universities with high energy use can therefore be obliged too.
Q: Can I do an energy audit and switch to ISO 50001 later? A: Yes. The audit lets you comply with the law. If you later decide you want more, you can still implement ISO 50001.
Q: What if my energy use is already very low? A: If your average use is below 10 TJ per year, you do not fall under the EED obligations. This applies even if your company is large.
Q: Do I really have to carry out an energy audit every 4 years? A: Yes, if you fall in the 10-85 TJ category and do not have ISO 50001. The law sets a minimum of once every 4 years. More on the audit obligation.
Q: Can I get a subsidy for implementing ISO 50001? A: Not directly for implementation. However, there is the EIA (Energy Investment Allowance, a tax benefit) for investments that result from ISO 50001, and SDE++ (Stimulation of Sustainable Energy Production and Climate Transition) for sustainable energy. See subsidies and benefits.
Checklist: are you ready for 2027?
- Threshold checked: how many TJ do you use on average per year?
- Choice made: ISO 50001 or energy audit?
- Budget approved by the management team (MT) or board
- Quotes received from the consultant or auditor
- Plan made (start date, deadlines)
- Energy manager or project lead appointed
- If ISO 50001: quick scan of the energy situation completed
- If energy audit: data collection started
If you have checked 80% or more, you are on the right track.
More information
- Is ISO 50001 mandatory?: Decision table with TJ calculation and conversion factors per energy type
- EED audit obligation: When you must carry out an energy audit (10-85 TJ)
- What is ISO 50001: Full introduction to energy management
- ISO 50001 vs energy audit: Detailed comparison
- Step-by-step plan: The 8 steps to ISO 50001
- Costs and timeline: What does it really cost?
- RVO: revised EED directive : Official thresholds and deadlines