EED Audit Obligation

Published on:
18 April 2023
Last checked on:
21 February 2024

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

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The EED Audit Obligation applies to large enterprises that are active in the Netherlands. A large enterprise has:

  • 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 that is over € 43 million.

How do you meet the EED Audit Obligation?

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

Step-by-step plan

  1. Use the step-by-step plan (in Dutch) to check if the energy saving investigation obligation applies to your organisation.
  2. Purchase eHerkenning assurance level 2+ to log into eLoket. Applying for eHerkenning takes five business days. 

Are you a foreign company that is unable to obtain eHerkenning? An intermediary company can submit the report on your behalf.

What does the report need to contain?

The Netherlands Enterprise Agency offers a template for the audit report. The report needs to contain:

  • A general overview and description of the enterprise and its activities
  • A general overview of existing energy flows (including business traffic)
  • A description of important factors that influence the energy use
  • A calculated overview of the energy saving potential 
  • A list of all cost effective energy saving measures

You can use the Recognised Energy saving measures list (in Dutch, Erkende Maatregelenlijst, or EML) as part of your audit report. However, you will need to explain what other energy saving measures you can take within the audit categories of 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 as an alternative. This is the case for enterprises with:

  • An ISO 50.001 certification, or an ISO 14.001 certification in combination with ISO 14.051.
  • Quality labels approved by the Ministry of Economic Affairs and Climate Policy (in Dutch).

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

Does the Energy Saving Investigation Obligation apply to you?

Is your enterprise obligated to do an energy audit under the EED and do you have one or more business locations that fall under the Energy Saving Investigation Obligation? The report for the Energy Saving Investigation Obligation is similar to the EED location report. There are also differences.

These are:

  • The EED Audit Obligation is more extensive. The EED audit report is about buildings, activities and commercial transport. The Energy Saving Investigation Obligation only concerns activities.
  • The Energy Saving Investigation Obligation asks that you list your unused heat flows. This is not necessary for the EED audit report.
  • The Energy Saving Investigation Obligation has three additional cost effective measures: the technical insulation scan, the analysis of 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.

The Netherlands Enterprise Agency has a template in which you can combine the Energy Saving Investigation Obligation report with the location report for the EED Audit Obligation.

Who enforces the EED audit obligation?

The Netherlands Enterprise Agency is the authority for the EED audit obligation. The Netherlands Enterprise Agency evaluates the EED audit report. 

If you do not report on time, the Netherlands Enterprise Agency can take enforcement measures such as 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 help you with the EED Audit Obligation.

Commissioned by:
  • Ministry of Economic Affairs and Climate Policy
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