This article focuses on the Dutch implementation of the revised Energy Efficiency Directive (EED). The EED is a European directive that each EU Member State translates into national legislation and regulations. As a result, obligations, thresholds, and enforcement may differ from one country to another.
In the Netherlands, the implementation, supervision, and enforcement of the revised EED are supported by the Netherlands Enterprise Agency (RVO), part of the Ministry of Economic Affairs and Climate Policy. Within this context, the CO₂ Performance Ladder can help organisations fulfil EED obligations in a practical and structured way.
This article provides an overview of the Dutch situation and how the CO₂ Performance Ladder plays a role in meeting EED requirements. The CO₂ Performance Ladder is well positioned to also serve as an (alternative) approach for meeting these obligations in other EU countries. We welcome discussions with relevant stakeholders on this topic. Please get in touch to start the conversation.
If your energy consumption is 10 terajoules per year or more, your company must comply with the requirements of the European Energy Efficiency Directive (EED). Due to the 2023 revision of the EED, a larger proportion of Ladder certificate holders are now subject to the EED. In this blog we explain which requirements apply to your company and how you can use a CO₂ Performance Ladder or ISO 50001 certificate as an alternative to an EED audit obligation (in the Netherlands) and as an energy management system.
The Energy Efficiency Directive (EED) is a European directive for reducing organisations’ energy consumption. EU member states translate the EED into national legislation. In the Netherlands, the Netherlands Enterprise Agency (RVO) is responsible for implementing and supervising the EED.
As part of the Fit for 55 package, the EED was revised in 2023. The main change for companies is that the EED no longer looks at turnover but at energy consumption. Before the revision, your company was subject to the EED from 250 FTE or an annual turnover of more than €50 million and a balance-sheet total of €43 million. In the revised version, the obligation applies from an energy consumption of 10 terajoules (TJ) per year.
Due to the revision, more companies with a Ladder certificate are affected by the EED. In concrete terms, after the revision the EED relates to three groups of certificate holders:
Before you know whether your organisation is subject to the EED and which obligations then apply, you must first determine your energy consumption. You do this by mapping all your organisation’s energy flows, such as the consumption of electricity, gas and fuels. Together these form your organisation’s energy footprint.
Read more here about calculating your energy use.
For the EED you focus on:
The EED makes no distinction between green and grey energy. Switching from grey to green electricity, or from diesel to HVO, is certainly important for your emissions reduction, but not for your energy reduction. Having solar panels does, however, play a role in the EED, because using and feeding back self-generated energy results in lower energy consumption.
Do you have an energy consumption of between 10 and 85 TJ? Then the EED audit obligation applies to you. This means you must report your energy consumption in the Netherlands to the RVO every four years. This concerns the average consumption over the past three years. In addition, you submit an action plan and a list of cost-effective energy-saving measures.
You are permitted to draw up an EED audit report yourself, as long as it is done by an expert. Most companies choose to have an external party draw up the audit report.
NB: for companies that were already subject to the EED before the revised version, the audit obligation applies from mid-2026. For companies that only become subject to the audit obligation after the revision, a transition year applies until mid-2027.
For the EED audit obligation, since 2016 you have been able to use a CO₂ Performance Ladder certificate as an alternative in the Netherlands. This means you do not have to carry out a separate audit carried out and submit an audit report and action plan. Instead, you simply send your Ladder certificate to the RVO. You do still have to additionally report your energy consumption and a list of cost-effective measures. The alternative applies to Ladder version 3.1 from Level 3 and to 4.0 from Step 1.
Besides a Ladder certificate, an ISO 50001 certificate, among others, is also valid in the Netherlands as an alternative way of meeting the EED audit obligation. ISO 50001 is an internationally recognised energy management system aimed at reducing and greening organisations’ energy consumption.
Is your annual energy consumption higher than 85 TJ? Then you are obliged to implement and use a certified energy management system, such as the CO₂ Performance Ladder or ISO 50001. With such a management system you show that your organisation works structurally to reduce energy use. Here too, you make your energy consumption transparent every four years, based on an average of the past three years.
NB: The deadline for organisations in this category is 11 October 2027. By that date you must have introduced an energy management system and had it certified under accreditation.
As an organisation, you are free to choose between the Ladder or ISO 50001 as an alternative to the audit obligation or the energy management system. You can base this choice on, for example, customer or contract requirements, or on the focus of the management system. Here we set out several similarities and differences between the two systems.
The main similarities are that they:
The main differences are that:
Finally, two tips for organisations:
Do not wait too long to choose and implement an energy or CO₂ management system. Collecting and structuring all the data takes time. Moreover, you must request an audit in good time, as certification bodies have limited capacity. A pre-audit by a consultant can help to determine whether you are ready for the official audit.
Make sure you look carefully at the organisational boundary you use when drawing up your energy footprint. The CO₂ Performance Ladder allows scope for this with two methods, but when making your choice, check carefully that everything is in line with the RVO’s requirements. If it turns out that the boundaries do not match, you may have extra work later.
It is not only companies that face new obligations under the revised EED. Government bodies must also make their energy use transparent and take measures to reduce it.
By 1 December 2026 at the latest, government bodies in the EU must report how much energy they use and which energy-saving measures they are taking. This obligation applies to national, regional and local governments and to organisations that are directly financed and managed by these governments, provided they have no industrial or commercial character.
With the reporting obligation, government bodies map their energy use and energy-saving measures. The collected data helps to provide insight into the Netherlands’ progress on energy saving and on making buildings more sustainable.
In the first report, government bodies provide insight into:
After this first report, an annual update on energy use and the progress of the energy-saving measures follows. In addition, every four years government bodies report which new measures they will implement for buildings, processes and transport.
They must also register the most recent version of the energy label in EP-online – the national energy-label database maintained by RVO – after major sustainability measures or a comprehensive renovation.
You can find more information about the reporting obligation and the requirements for government bodies in the Netherlands on the RVO website: Energy-efficient government | RVO.nl.
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