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EED Audit Obligation

18-04-2023

The European Energy Efficiency Directive (EED) is a European Union directive that obligates large enterprises to perform energy efficiency audits every four years. If the EED Audit Obligation applies to your organisation, you need to report to the Netherlands Enterprise Agency (RVO). The third round of the audit obligation starts on 1 July 2023.

The EED Audit Obligation applies to large enterprises active in The Netherlands. A large enterprise is defined as follows:

  • At least 250 employees (FTE) including those in partner companies and associated companies; or
  • An annual turnover of more than € 50 million and a balance sheet total greater than € 43 million.

If your organisation meets one of these requirements, you are obligated to carry out an energy audit every four years.

How do you meet your EED Audit Obligation?

The EED Audit Obligation is meant to make organisations aware of their energy use and their opportunities to save energy. The audit covers the entire enterprise and reports on the energy use of buildings, installations, industrial processes and business traffic. The report has to be submitted in the online eLoket portal.

What does the report need to contain?

RVO has made a template for the audit report. The report needs to contain at least the following elements:

  • A schematic overview and generic description of the enterprise and the activities
  • A schematic overview of all existing energy flows (including business traffic)
  • A description of important factors that influence the energy usage
  • A quantified overview of the energy saving potential of the enterprise
  • An inventory of all cost effective energy saving measures

You can use the Recognized Energy saving measures list (Erkende Maatregelenlijst, or EML) as part of your audit report. However, this list is not sufficient for the inventory of all cost effective energy saving measures. You will need to elaborate on what other energy saving measures are possible regarding the four audit categories: buildings, installations, processes and business traffic.

Does your business location have a certification or quality label?

Some enterprises do not have to perform an EED audit, because they have a certification or quality label that is considered a sufficient alternative. This is applicable to enterprises with:

  • An ISO 50.001 certification, or an ISO 14.001 certification in combination with ISO 14.051: these enterprises already have to perform an EED audit.;
  • One of the quality labels approved by the Ministry of Economic Affairs and Climate Policy.

Does your enterprise not hold a certification or quality label, but one or more business locations do? Business locations with a certification or quality label do not have to be audited. You can name these locations and their certification or quality label in the audit report. The enterprise as a whole nevertheless needs to be audited.

Do you also have an Energy Saving Investigation Obligation?

Does your enterprise have to conduct an energy audit under the EED and do you have one or more business locations that have an Energy Saving Investigation Obligation? The report for the Energy Saving Investigation Obligation has a lot of similarities with the EED location report. There are also certain differences.

These are:

  • The EED Audit Obligation has a broader scope. The EED audit report is about the buildings, activities and commercial transport. The Energy Saving Investigation Obligation only regards activities.
  • The Energy Saving Investigation Obligation asks that you note your unused heat flows. This is not necessary for the EED audit report.
  • The Energy Saving Investigation Obligation adds three elements to the inventory of cost effective measures: the scan of the technical insulation; the analysis of the electrical drive systems; and the reflection on the base list of energy saving measures.
  • The calculations of the payback period of potential measures are different.
  • The Energy Saving Investigation Obligation requires you to add an implementation plan for measures with a payback period of five years or less. This is not required for the EED audit report.

RVO has made a template which allows you to combine the Energy Saving Investigation Obligation report with the location report for the EED Audit Obligation.

Who enforces the EED audit obligation?

RVO is the competent authority for the EED audit obligation. RVO will assess your EED audit report. If your report raises questions or is insufficient, you will be contacted by RVO.

If you do not report on time, RVO may take enforcement measures. This may have financial consequences in the form of a non-compliance penalty.

More information?

Contact us for more information or read our Dutch information page. There are several Dutch tools available (introductory videos, step-by-step plan and EML list) to aid you with the EED Audit Obligation.

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