Energy saving obligation and reporting duty (and how ISO 50001 helps)

The energy saving obligation (energiebesparingsplicht) requires companies and institutions that use 50,000 kWh of electricity or 25,000 m³ of natural gas (equivalent) or more per year at one location to carry out all energy-saving measures with a payback period of five years or less. Under the reporting duty (informatieplicht), you report once every four years which measures you have taken. The RVO (Netherlands Enterprise Agency) gives 1 December 2027 as the next final deadline. ISO 50001 does not replace these duties, but it makes them much easier to meet. It is separate from the EED audit obligation, which applies from 10 TJ.

Short answer: does your use at one location reach 50,000 kWh or 25,000 m³ of natural gas (equivalent) per year or more? Then you must take recognised measures and report them by 1 December 2027 at the latest, through RVO’s eLoket. From 1 July 2027, the payback period is expected to change from five to seven years.

Who is covered by the energy saving obligation?

Since 1 January 2024, the obligation falls under the Environment and Planning Act (Omgevingswet). For activities, it is set out in the Environmental Activities Decree (Besluit activiteiten leefomgeving, Bal, article 5.15). For buildings, it is set out in the Buildings Decree (Besluit bouwwerken leefomgeving, Bbl, article 3.84). You look at use per location over a recent, representative year. Energy you generate yourself counts. Energy you resell does not.

Situation	What applies
Under 50,000 kWh and under 25,000 m³ of natural gas (equivalent) per location	No energy saving obligation
From 50,000 kWh or 25,000 m³ of natural gas (equivalent)	Energy saving obligation and reporting duty
From 10 million kWh or 170,000 m³ of natural gas (equivalent), in sectors with national rules	Investigation duty instead of the list of recognised measures (EML, Dutch list of recognised energy-saving measures)
Building with energy label A++ or A+++ (depending on building use)	Most building measures count as implemented, energy monitoring does not

A few groups are exempt, such as homes, buildings smaller than 50 m² and buildings that use only their own renewable energy without a grid connection. Not sure? Use RVO’s Energy Saving Law Checker (Wetchecker energiebesparing) .

Who is responsible? For building measures, such as insulation, this is usually the building owner. For measures on your business activities, such as cooling or compressed air systems, it is the organisation that carries out the activity. Supervision lies with the municipality or province, carried out by the regional environmental service (omgevingsdienst).

Energy saving reporting duty: what and when do you report?

The reporting duty shows which measures you have taken. You report once every four years through RVO’s eLoket, with eHerkenning level 2+ or higher (the Dutch digital identity for businesses). The previous deadline was 1 December 2023. According to RVO , the next final deadline is 1 December 2027.

You report using the list of recognised measures (EML) . For each measure, you choose: implemented, not implemented, or an alternative measure implemented.

Example: reporting for an office with a workshop

A fictional installation company uses 85,000 kWh and 18,000 m³ of gas per year at one location. It therefore falls under the obligation. An extract of the preparation:

Measure (from EML)	Status	Evidence	Comment
LED lighting in office and workshop	Implemented	Invoice 2025
Presence detection lighting in toilets and corridors	Implemented	Photos, invoice
Insulation of central heating pipes	Implemented	Maintenance report
Hydraulic balancing of central heating system	Not implemented		Scheduled for Q1 2027, payback period under 5 years
Monthly energy monitoring	Alternative	Smart meter and dashboard	Discussed monthly in team meeting
Cavity wall insulation	Not applicable		Building has no cavity, recorded in a note

Entering “not implemented” is not a free pass. If a measure on the EML applies to you and falls within the payback period, you must carry it out. The regional environmental service can request reports from RVO and enforce compliance.

If you do not want to report using the EML, you must show with your own investigation that you have carried out all measures with a payback period of five years or less.

Investigation duty for large energy users

Locations in sectors with national rules that use 10 million kWh or 170,000 m³ of natural gas (equivalent) or more must meet the investigation duty . You then have an investigation carried out into which measures are cost-effective for your business processes, including measures that reduce CO2, and you draw up an implementation plan. You also report this once every four years. The EML does not apply to these locations.

What changes in 2027 for the energy saving obligation?

The government is updating the energy saving obligation. According to IPLO (Dutch Information Platform for the Physical Living Environment), the updated obligation is expected to take effect on 1 July 2027. At the time of writing, the decree has not yet been published in final form.

Component	Now	Planned from 2027
Payback period	5 years	7 years, so more mandatory measures
Threshold	50,000 kWh or 25,000 m³	Stays the same (the earlier proposed increase to 100,000 kWh will not go ahead)
Reporting duty	Building owner or user, depending on transitional rules	Always with the party that must carry out the measure
Investigation duty	For various sectors	Some sectors move to the reporting duty
Transitional rules for the old Activiteitenbesluit (Dutch Activities Decree)	Still running	Expires on 1 December 2027

Before you report, check which version of the rules and which EML apply. You can already list measures with a payback period between five and seven years.

How does ISO 50001 help with the energy saving obligation?

ISO 50001 does not exempt you from the energy saving obligation or the reporting duty. It does provide almost everything you need to comply with them.

What the obligation requires	What ISO 50001 already provides
Knowing use per location	Energy review and measurement plan
Knowing which measures are cost-effective	Action plans for your significant energy aspects
Proving that measures have been implemented	Records and progress in the management system
Reporting every four years	Annual cycle with internal audit and management review
For the investigation duty: basic energy check	Exemption from the basic check and a more limited investigation report (current rules)

The last point comes from RVO’s investigation duty page: with ISO 50001, the investigation report only needs to include the measures taken, the inventory of cost-effective measures and the implementation plan. IPLO reports that this changes with the 2027 amendment: the report must then be complete, including parts you were previously allowed to skip based on a certificate.

For companies above 10 TJ, the biggest gain lies elsewhere. There, ISO 50001 does give an exemption, namely from the EED audit obligation. Above 85 TJ, an energy management system even becomes mandatory from 2027. See EED obligation 2027.

What does the ISO 50001 auditor check for these legal duties?

ISO 50001 requires you to determine and comply with legal requirements on energy. The auditor therefore wants to see the energy saving obligation in your legal register, with the latest report to RVO, the status of open measures and the next deadline. A missing report about 2023 is a clear finding.

Next step

Check your use per location in the energy baseline and determine whether you fall under the reporting duty or the investigation duty. Look at subsidies and tax benefits to see which schemes make measures cheaper. Do you also have ISO 14001? Then record the obligation in your legal register.

Sources

RVO: Energy saving obligation
RVO: About the energy saving obligation : threshold values, payback period, Bal and Bbl
RVO: Reporting duty for energy saving
RVO: Investigation duty
IPLO: Developments in the 2027 energy saving obligation