The energy saving obligation and the information obligation: what does your company need to know?
The energy saving obligation is not a one-off action but an ongoing obligation. What differs per company is how you demonstrate that you comply with it. Energy use per site determines whether you fall under the information obligation, under the heavier investigation obligation, or in addition under the European EED audit obligation. Each of those three routes asks something different of you, and the threshold you sit just above or just below determines which one.
Information obligation
- Threshold
- 50,000 kWh or 25,000 m³of electricity or natural gas (equivalent) or more, per site per year.
- What you have to do
- You report via Mijn RVO which energy saving measures you have taken. The basis for that report is the Recognised Measures List (EML): according to the RVO, more than a hundred proven measures, divided over buildings, facilities and processes. A separate EML exists for greenhouse horticulture.
- Reporting
- Once every four years. The next final date is 1 December 2027.
- Note
- The threshold applies per site and not per company: a chain with ten locations above the limit has ten separate reports.
Investigation obligation
- Threshold
- 10 million kWh or 170,000 m³of electricity or natural gas (equivalent) or more, per site per year.
- What you have to do
- You map out yourself where savings are possible in your energy-intensive processes and which measures pay back within five years. You may not use the EML approach to demonstrate compliance.
- Reporting
- Once every four years. The next final date is 1 December 2027.
- Note
- The RVO prescribes what the investigation report has to contain. With an ISO 50001 certification or an equivalent energy management system you can submit a shortened report.
EED audit obligation
- Threshold
- 250 FTE or moreincluding participating interests and affiliated companies, or an annual turnover of more than € 50 million together with a balance sheet total of more than € 43 million.
- What you have to do
- The obligation comes from European legislation and looks not at a single site but at the entire group. The audit assesses the buildings and processes of the whole company.
- Reporting
- The final date of 1 December 2027 applies to the information obligation and the investigation obligation.
- Note
- With chains it regularly happens that no individual location falls under the investigation obligation, while the company as a whole is subject to the audit obligation. In the recast EED (2023/1791) the audit obligation is linked to an annual energy use of 10 TJ instead of to company size; the RVO reports that the Dutch legislation for this is still being finalised.
What this asks of you: place your annual consumption per site alongside the two thresholds before you look at the list of measures. Without that picture you do not know which of the three routes applies to you, and therefore not which report you have to prepare.
The next reporting date: 1 December 2027.
Reporting takes place once every four years. The previous round closed on 1 December 2023. For all establishments that had an information obligation or investigation obligation on that date, the next final date is 1 December 2027. Anyone who missed the 2023 round can, according to the RVO, still submit that report; waiting until 2027 is therefore not a route. Under the transitional rules of the Environment and Planning Act (Omgevingswet), the operator of the establishment formally remains responsible for submitting the report up to the 2027 deadline.
What this asks of you: 2027 seems a long way off, but the measures you report then have to have been carried out or demonstrably planned. A measure with a lead time of a year and an investment decision that needs a budget round is therefore on the agenda in 2026. Also check whether your consumption has crossed a threshold since the previous round. A site that has grown or been electrified may have shifted from the information obligation to the investigation obligation.
What COMCAM does for you.
On the basis of your metering data we assess which of the three obligations applies to your sites, and we take on the work that follows from it.
- We determine the actual annual consumption in kWh and m³ per site and which obligation follows from it.
- We go through the Recognised Measures List with you and assess which measures suit your installations and processes.
- We calculate what a measure means for your consumption and for your energy costs.
- We take care of the report to the RVO where that is required.
- For COMCAM energy clients this service is free of charge for the information obligation and the investigation obligation.
What still needs to be checked in your situation: which measures pay back within five years depends on your consumption profile, your installations and the tariffs at which you purchase. That is not a list you copy from a website, but a calculation on your own quarter-hour values. Contact us if you would like to know which obligation your sites fall under and what has to be ready before 1 December 2027.
Does this apply to your business?
Our energy specialists are happy to look at what this means for your connections, your contract and your purchasing situation. Without obligation.
