EED audit obligation: when do you need an energy audit?

The EED audit obligation requires companies with high energy use to have a periodic energy audit carried out. Whether you are obliged depends on your average energy use in terajoules (TJ). This obligation comes from the revised Energy Efficiency Directive (EED) . In the Netherlands, it is enforced by the Rijksdienst voor Ondernemend Nederland (RVO, Netherlands Enterprise Agency) . Do you have a certified energy management system such as ISO 50001? Then you are exempt from the audit obligation.

Short answer: do you use an average of 10 TJ or more of energy per year (over the past 3 years)? Then you fall under the EED audit obligation. From 85 TJ, a stricter obligation to have an energy management system applies.

What is the EED audit obligation?

An EED audit is a mandatory study of your energy use. A certified energy auditor maps out where your energy goes and which savings are possible. You submit the report plus an action plan to the RVO. The audit follows the EN 16247 standard.

Since the EED was revised, the threshold has changed. Previously, the law looked at company size: more than 250 employees or a turnover above €50 million. Now only your energy use counts. A small company with high energy use can therefore be obliged, while a large office with low use is not. If you use less than 10 TJ, you may still fall under the Dutch energy saving obligation and information obligation (energiebesparingsplicht en informatieplicht), which already applies from 50,000 kWh per location.

Which EED threshold applies to you?

Your obligation depends on your average annual energy use over the past 3 years. The total includes all your energy: electricity, gas and fuel for your vehicle fleet.

Average energy use	Obligation	Deadline
Under 10 TJ	No EED audit obligation	None
10 to 85 TJ	Energy audit (every 4 years) or ISO 50001	About 1 year after the Dutch law takes effect (expected end 2026)
More than 85 TJ	Energy management system (ISO 50001 or EMAS)	11 October 2027

The Dutch law that implements the revised EED is expected to take effect at the end of 2026. The exact deadline for the 10 to 85 TJ group follows from that. Check the current dates with the RVO .

Not sure which category you fall into? Convert your consumption to TJ. For reference, 10 TJ roughly equals 2.8 million kWh of electricity. A medium-sized manufacturing company often exceeds this quickly.

What must an EED audit include?

The audit follows EN 16247. A certified auditor delivers at least these parts:

Scope: which buildings, processes and energy flows are covered by the audit?
Data: historical consumption (at least 12 months), invoices and measurements
Inspection: the auditor visits your site and reviews the installations
Analysis: where does the energy go? Which consumers are the largest?
List of measures: concrete savings with costs and payback period
Action plan: which measures you will take, with a schedule

New since the revision: you submit not only a report but also an action plan. In follow-up reports, you show the progress of those actions. You are not obliged to carry out all measures, but you must submit a substantiated plan.

EED audit obligation versus the 2027 obligation

This is a common source of confusion. There are two different EED obligations, depending on your energy use:

	Energy audit obligation	Energy management system
Applies from	10 TJ	85 TJ
What	Periodic energy audit (EN 16247)	Certified system (ISO 50001 or EMAS)
Frequency	Every 4 years	Ongoing, with annual checks
Deadline	About 1 year after the Dutch law (expected end 2026)	11 October 2027

This page covers the audit obligation (10 to 85 TJ), which already applies today. We discuss the stricter obligation to have an energy management system above 85 TJ on the page about the EED obligation 2027.

ISO 50001 gives exemption from the audit obligation

Do you have a certified energy management system under ISO 50001? Then you are fully exempt from the separate energy audit obligation. You do not need to have a separate audit carried out every 4 years, because ISO 50001 provides the same insights on an ongoing basis.

This is an important trade-off. If you are close to 85 TJ or expect your energy use to grow, ISO 50001 is often smarter than repeated separate audits. You can find a full comparison of both routes on ISO 50001 vs energy audit.

With ISO 50001, you kill two birds with one stone: you meet the EED requirements, and you have a system that saves energy on an ongoing basis. Companies save 10 to 20% on their energy costs on average.

What does an EED audit cost?

The costs depend on your company size and complexity. As an indication:

Company size	Indicative audit cost
Small (10 to 30 TJ)	€5,000 to €15,000
Medium-sized (30 to 85 TJ)	€15,000 to €35,000

This is a snapshot per audit. If you choose ISO 50001 instead of separate audits, the costs and benefits look different. A full overview is on costs and timeline.

Frequently asked questions about the EED audit obligation

Q: Does the old threshold of 250 employees still apply? A: No. Since the revision, only your energy use in TJ counts, not your number of employees or your turnover.

Q: How often do I need to carry out an EED audit? A: In the 10 to 85 TJ category, at least every 4 years. With ISO 50001, this obligation no longer applies.

Q: Who may carry out the audit? A: Only a certified energy auditor. The RVO keeps a list of them.

Q: Do multiple sites count together? A: You look at the total energy use of your organisation. Check the scope with the RVO.

Working on it in practice

Are you ready to write the report itself? The guide to EED reporting helps with the report sections, site details and use of the RVO templates. The page distinguishes the current way of working from announced changes.