For an asset or property manager this stopped being a sustainability question some time ago. It is about which objects still let, which of them miss a label date, and how much contracted capacity you pay for every month and cannot prove you need.
COMCAM manages that as one position across the whole portfolio, with the quarter-hour data behind it, so a decision per object stops being a guess.
We see the same pattern in every sector. A market that keeps moving, what your connection and your own profile allow, and where sustainability has to take you. Each on its own is manageable. The bigger problems arise where they overlap, and that is where most of our work is.
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Owner, tenants and grid in one energy plan per property and per portfolio: the only way decarbonisation stays affordable and feasible.
How COMCAM helps
One portfolio, one team: analysis, strategy, trading and risk management across all three forces.
With only a fraction of utility buildings being newly built each year against a standing stock of roughly 1.2 million (CBS), new development will not move the needle. The portfolio you are judged on is the one on your balance sheet today. As grid capacity tightens and municipal enforcement actively scales up in 2026, four mandatory, fast-approaching dates now apply to the buildings you already own:
Offices over 100 m² have needed at least label C since 1 January 2023. At 1 July 2026 the RVO put 84% of office floor area at label C or better, leaving 4% at D or worse and 12% with no label at all. Enforcement can include an order subject to penalty payments. IPLO gives EUR 2,000 a week for up to ten weeks as guidance for an average office building; the authority determines the amount and approach for each case.
Under EPBD IV the worst-performing utility buildings must reach at least label D by 1 January 2030. The thresholds per building function are in consultation now and are legally fixed on 1 July 2027. That label is calculated under NTA 8800: it tells you what a building should use, not what it actually costs you.
Since the ACM's GOTORK decision of 18 April 2024, a grid operator in a congestion area can reduce contracted transport capacity that has gone substantially unused over the previous twelve months and give it to someone else. It is not a fine. You lose capacity that is currently very hard to get back, unless you can show that you need it.
The Dutch energy-saving obligation applies from 50,000 kWh or 25,000 m³ gas equivalent per location, every measure that pays back within five years is mandatory, and the reporting obligation falls due again on 1 December 2027.
A strong energy strategy starts with the actual profile of your portfolio, not with a standard contract offer. In real estate that profile has a split running through it that no portfolio average will show you.
Energy sits at portfolio level, but the split runs through every building: the tenant holds the supply contract and the consumption data, while the owner carries the label obligation and the asset value. Add charging infrastructure arriving over the years, many connections per portfolio, and meter data in as many systems as there are EANs.
Metering, tenant profiles, charging, solar, storage and procurement can be assessed across the full portfolio instead of building by building. Where the owner holds the connection, or the tenant authorises it, COMCAM aggregates the quarter-hour data across every EAN in the portfolio, so the position stops depending on which supplier each tenant happens to use.
Not sure which objects in the portfolio carry the most risk?
Six routes, in the order they usually pay off: see what each connection really does, compare objects instead of averaging them, manage the portfolio as one position, then deal with the capacity and the dates that come with the buildings. COMCAM runs them, so this stays a portfolio decision instead of turning into a technical project.
What each connection actually uses against the GTV you contracted. Usually the first place unused capacity turns up, and the evidence you need in order to keep it.
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Quarter-hour data from every connection in one place, so objects can be compared against each other instead of averaged into a portfolio figure.
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The whole portfolio managed as one position, financial and physical, rather than contract by contract as each one happens to expire.
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Grid operators have had to offer ATR since April 2025: capacity outside peak hours at a lower grid tariff. In practice the regional products are still pilots, so this is worth checking per region rather than assuming. The ACM made binding agreements with all seven operators in June 2026 to speed that up.
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COMCAM is a recognised Congestion Service Provider, so flexibility found in the quarter-hour data can actually be offered and settled: redispatch through GOPACS, or a capacity control contract (CSC), which since May 2026 has largely replaced the older capacity restriction contract (CBC) and allows raising as well as lowering.
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Label C, the step to 2030, the energy-saving obligation and its reporting requirement, tracked against individual objects rather than the portfolio as a whole.
Read moreThree things you can check about COMCAM without taking anyone's word for it.
COMCAM signed the DGBC Paris Proof Commitment, one of around 125 signatories: roughly two thirds less energy use in the built environment by 2040, measured against 2015. It is assessed on WEii, actual metered consumption, rather than on a calculated label, so it can be checked against what a building really used.
TenneT assesses CSP recognition on behalf of all grid operators, after which the party is listed in the Centraal Marktpartijenregister and every individual connection is pre-qualified before it can bid. That chain is what turns flexibility into something that can actually be offered and settled rather than described in a report.
COMCAM is an independent portfolio manager, not an energy supplier and not an installation company. Because we are not tied to one utility, procurement runs across the whole market. We do not sell solar panels, batteries or grid connections, so the advice on capacity is built around what your portfolio needs rather than around something to sell you.
Ask for the reference closest to your own portfolio and we will point you to it, including what it does not prove.
Book an introductory conversation. No obligation and no generic report: we start from the objects, the connections and the labels you actually have.
A selection from our solutions that ties in with the questions on this page. Each one explains what it is, who it is for and how the work runs.
Neighbouring companies pooling connections, generation and flexibility.
What your connection really uses versus what you contracted.
Charging infrastructure that fits your connection, without a heavier one.
All locations bought as one portfolio, with one strategy.
Whether you're navigating market volatility, optimising your portfolio, or exploring sustainable solutions - we're here to help.
In-depth publications on energy procurement, grid congestion and flexibility, written by our specialists. Free to download.
View whitepapersPower, gas, oil, coal, emissions and renewables, regularly analysed by our traders. The same intelligence our portfolio decisions are built on.
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