Sustainability & compliance

Energy legislation

Energy legislation changes fast: taxes, saving obligations, reporting duties, grid rules. We tell you which rules apply to you now, which are coming, and what you have to do about them, and we help you do it.

What applies, and to whom

Different rules run on different clocks.

Obligations around energy do not share a single deadline. One follows company size, one follows what a site consumes, one arrives through a customer. The register below separates them.

The situation

Picture five rules tracked in five places, or in none, until one of them arrives as a letter. The first question is not when something is due, but whether it reaches you at all.

ObligationApplies toRhythmWhat you must be able to show

EED energy audit

Applies toTotal energy use, not headcount or turnover. The recast directive sets an audit duty from 10 TJ per year and an energy management system from 85 TJ. Dutch implementation is expected from late 2026; confirm the timing with RVO.

RhythmRecurring, on a four-year cycle. Newly in scope, one year to complete the first audit.

What you must be able to showAn audit report covering consumption and the measures it identifies.

Energy saving obligation and the reporting duty

Applies toSites consuming above a threshold, assessed per site rather than per company. Confirm the current threshold with RVO.

RhythmThe obligation runs continuously; the report goes in on a four-year cycle.

What you must be able to showWhich recognised measures were taken per site, and for each one not taken, why it does not apply.

Sustainability reporting (CSRD)

Applies toSince the Omnibus revision of February 2026, a direct duty only above 1,000 employees and EUR 450 million turnover, from financial years starting in 2027. Below that it reaches you through a reporting customer instead.

RhythmAnnually, alongside the management report.

What you must be able to showEnergy consumption and emissions by scope, with the method and the factors used.

Carbon pricing on fuels (ETS2)

Applies toReaches buildings, transport and smaller industry through the fuel supplier rather than through you directly. The timetable has been politically contested.

RhythmNo filing of your own. It arrives as a cost component.

What you must be able to showNothing to submit. It shows up in the gas price, which makes it a budget question rather than a compliance one.

A customer's data request

Applies toNo obligation of your own. It is triggered by your customer's reporting, not by your size or consumption.

RhythmWhenever your customer asks, usually annually.

What you must be able to showConsumption per site, and the evidence behind any green claim you pass on.

What this asks of you: establish per site which rows reach you, and name who inside the organisation owns each one. The rows above are started by different things, so one owner rarely covers them all.

As at September 2026

Size, consumption and a customer are three separate triggers.

A company can fall under the saving obligation at one site without being large enough for the audit duty, and be asked for data while under neither. Checking only one of the three is the common gap.

One of these obliges an action, not a report.

The saving obligation requires measures to be taken, not merely described. That is a different kind of duty from the reporting ones, and it is the one most often treated as paperwork.

This is the fastest-moving area we work in.

Thresholds, scope and timetables have all been revised in recent years, several of them in 2026. That is why this register carries a date and names the authority to confirm with, so a figure that moves can be checked rather than trusted.

A general register of how these obligations are structured, dated at the time of writing. It is not legal advice and not a client's situation. Confirm thresholds, scope and deadlines with RVO or the competent authority before acting.

How we approach it

From question to execution

01
We map which rules apply to your organisation and sites.
02
We show what is coming and when.
03
We translate the rules into actions with deadlines.
04
We support the execution where needed.

What it yields

This is what changes for you

No surprises from rules you did not see coming
Obligations translated into actions
Support in meeting them

One partner for everything around your energy

We calculate, arrange and execute: procurement on the exchanges, steering of your assets, grid capacity, sustainability and subsidies. Independent, not a supplier, not a comparison site. A conversation is free of obligation.

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