EED reporting: how to build the report, action plan and progress

EED reporting is the online submission through which a company subject to the audit obligation sends its energy audit to RVO. The current RVO page on the EED audit obligation describes, among other things, group and site reports, templates and submission via eHerkenning. Also read the explanation of the EED audit obligation and the choice between ISO 50001 and an energy audit.

The status needs attention. On 5 September 2026, the current Dutch regulation applies. RVO also describes announced changes from the revised European directive, but notes that the Netherlands still has to transpose them into national law. Keep these two situations in separate workstreams.

The revised thresholds, the annual progress report and the date of 11 October 2027 do not automatically apply as the current Dutch deadline. Check the RVO website again before you include an obligation or date in a decision.

Current reporting: work from the organisation

According to RVO, the current EED audit obligation is linked to the status of a large enterprise: at least 250 FTE (full-time equivalent) including linked or partner enterprises, or a turnover above €50 million and a balance sheet total above €43 million, also including relevant participations. An enterprise subject to the obligation reports to RVO once every four years. Check whether this applies to you with the current Wetchecker (Dutch legislation checker).

First create a group overview, then a report for each site. Collect energy use from buildings, installations, processes and transport that belongs to the company assets or operations. Describe energy flows and savings measures so that a reader can trace where the data comes from. RVO lets you merge the site reports and the group report into one enterprise report.

Practical reporting workflow

Phase	What do you record?	Check before the next phase
1. Applicability	Enterprise structure, FTE, turnover, balance sheet total and sites	Is the scope of participations justified?
2. Collect data	Invoices, meters, energy carriers, processes and transport	Are units, periods and missing data explained?
3. Site reports	Energy profile, energy flows and measures per location	Does each location match the group list?
4. Group report	Summary, method and overall picture	Have double counts been removed?
5. Submit	RVO templates, eHerkenning and authorisation	Can one authorised person submit on behalf of the enterprise?
6. Store and follow up	Confirmation of receipt, reference number and questions from RVO	Is the next four-yearly cycle scheduled?

RVO provides templates for a group report, site report and combinations with the research obligation (onderzoeksplicht, Dutch energy research obligation). Download the current versions directly from RVO. Also keep your source files. A report without traceable figures is hard to check and difficult to update later.

Manage the announced revised rules separately

The revised directive makes energy use decisive for the route. For enterprises that fall under the audit route, RVO describes an action plan and an annual progress report. An energy management system route is also planned. Use the current RVO explanation of the revised obligation to determine your route. The expected Dutch implementation from the end of 2026 remains subject to final regulation.

For the future energy management system obligation, RVO states that evidence must be submitted by 11 October 2027. Treat this as a conditional rule from the revised directive for as long as the Dutch implementation is not final. Do plan for your data structure to track action plans and measures.

Fictional example: Zonneveld group

This is a fictional example. Zonneveld has three sites. For the current report, it creates an energy profile for each location, adds a group summary and submits one enterprise report. In the future action plan, it records for heat recovery and leak detection the measure, expected saving, planned implementation year and reason for that timing. Annual progress only becomes a mandatory process once Dutch rules require it.

Frequently asked questions about EED reporting

Do I submit separately for each site?

RVO describes an enterprise report that combines site reports and a group report. Check the current templates and submission instructions for your structure.

Is ISO 50001 the same as EED reporting?

No. ISO 50001 is a management system. The EED audit is a reporting and audit route with its own conditions. Under certain conditions, a certified system can offer an alternative; ask RVO or your adviser to confirm the current conditions.

Do I have to report annual progress now?

Not automatically. The annual progress report is described on the RVO page about the revised audit obligation. Check which Dutch regulation applies on the date you submit.

EED audit obligation: current applicability.
EED obligation 2027: status of the announced changes.
ISO 50001 versus energy audit: compare the routes.