The most important change is that it is no longer your size that determines whether the audit obligation applies to you, but your energy consumption. As a result, companies in the Netherlands that do not see themselves as 'large consumers' can still fall under it, and vice versa. So it pays to know your consumption in TJ before you assume the obligation does not apply to you.
Old versus new criterion
The old criterion, large enterprise: more than 250 FTE, or more than € 50M turnover, or more than € 43M balance sheet total, is still doing the rounds in a lot of content. The new criterion is the average annual energy consumption over the last three years, with all energy carriers taken together (electricity, gas, heat, fuel).
The national implementation in the Netherlands runs via the revised EED (Directive 2023/1791); transposition is expected around October 2026, with 11 October 2027 as the deadline for the heaviest obligation.
The thresholds, translated into kWh
- 10–85 TJ per year → energy audit obligation plus a concrete action plan with saving measures.
- More than 85 TJ per year → certified energy management system (in practice ISO 50001), implemented and certified before 11 October 2027.
- 10 TJ ≈ 2.78 million kWh of electricity ≈ 316,000 m³ of natural gas, readily reached by a serious factory; this is the realistic anchor.
- 85 TJ ≈ 23.6 million kWh ≈ 2.7 million m³ of gas equivalent, a genuinely energy-intensive site (drying, melting, large-scale chemicals). Most companies of € 15–120M do not come close to this.
For orientation (illustrative). A factory with 3.5 million kWh of electricity and 400,000 m³ of gas per year sits well above 10 TJ and therefore falls under the audit obligation, but is nowhere near the 85 TJ threshold at which ISO 50001 becomes mandatory.
Audit or energy management system?
An energy audit is at heart a periodic review: you map out your energy flows and saving opportunities and draw up an action plan. An energy management system (ISO 50001) is heavier: a continuous, certified system in which measuring, steering and improving are structurally embedded.
Anyone with a certified energy management system is exempt from the separate audit obligation. For most companies in this segment the audit is the relevant obligation, not ISO 50001.
What is overstating it
Presenting ISO 50001 as a generally looming obligation for manufacturers in this band overstates it, the same mistake as citing CSRD: you invoke an obligation that does not affect the reader and lose credibility on precisely the subject where you need it. The audit obligation from 10 TJ, on the other hand, is a legitimate, concrete angle.
What an audit asks of your data
A usable audit and a credible action plan stand or fall on structured, traceable consumption data: per installation, over time, comparable. VDS supplies that measurement layer, so that the audit rests on facts instead of assumptions. The audit itself and the choice of measures stay with you or your adviser.
Sources
Frequently asked questions
Does the EED audit obligation apply to me?
If your average annual consumption over three years lies between 10 and 85 TJ (10 TJ ≈ 2.78 million kWh), then in the Netherlands almost certainly yes. The criterion is consumption, not company size.
Do I have to have ISO 50001?
Mandatory above 85 TJ per year; below that it is voluntary. A certified system does exempt you from the separate audit obligation.
What is the difference between an audit and an energy management system?
An audit is a periodic review with an action plan; an energy management system is a continuous, certified system in which measuring and improving are embedded.
What is the deadline?
11 October 2027 for the heaviest obligation; the national transposition of the revised EED in the Netherlands runs from around October 2026.
How much is 10 TJ?
About 2.78 million kWh of electricity or 316,000 m³ of natural gas per year, a threshold a serious factory can readily reach.
