Do you own or use a building that consumes more than 50,000 kWh of electricity or 25,000 m³ of natural gas? If so, you will most likely have to deal with the energy efficiency disclosure requirement. 1 December 2023 is the next deadline for this purpose. You will then be asked to report on the energy savings made in your buildings and what is still planned. In this article, we will explain the ins and outs of the disclosure requirement and the deadline of 1 December 2023.
The energy efficiency disclosure requirement, what does that involve? The energy efficiency requirement was created to reduce energy consumption in the Netherlands. The built environment is one of the major consumers of electricity and so requirements have been imposed to save energy in buildings.
If a property has an energy efficiency requirement, energy saving measures must be implemented. This applies to companies and institutions that use more than 50,000 kWh of electricity or 25,000 m³ of natural gas (equivalent). Since 1 July 2023, more properties are covered by the energy efficiency requirement, such as greenhouse horticulture, waste processing plants and heavy industrial plants.
To be clear: the energy efficiency requirement is about implementing measures, the disclosure requirement refers to reporting on them. The disclose requirement distinguishes between the property itself, which is managed by the owner, and the activities that lessees carry out on the site. So you can have a disclosure requirement for two things: for the activities carried out on the site and for the properties themselves.
If you are curious to know if the energy efficiency disclosure requirement applies to you, go through the checklist of the Netherlands Enterprise Agency (RVO) [in Dutch only].
The disclosure requirement is relevant now as the deadline of the current round is 1 December 2023. Every four years, you have to report on the energy savings achieved on site. The previous disclosure requirement round was in 2019, so there is another deadline this year. The deadline for the next disclosure requirement round will again be in four years, i.e. on 1 December 2027.
To comply with the disclosure requirement, you need the Recognised Measures List (RML). The specific measures for buildings, facilities and processes make it easier to submit the report. You can therefore use the RML as a guide and compare your site with it. It is advisable to go through the RML before reporting.
How does the reporting work in practice? In short, for each recognised measure, you have to indicate whether it (a) has been implemented or not, and (b) whether an alternative measure has been taken. So for that, you will have to gather information or investigate matters.
Energy efficiency measures also affect a building’s energy performance certificate. If your building has a relatively good energy performance certificate, you will be able to indicate that many recognised measures have been implemented when reporting for the disclosure requirement.
“To save work, the government has commissioned a study to determine at which energy performance certificate level it can be assumed that all recognised energy saving measures have been implemented. The result? If your building meets the renovation standard, you can state that all building-related measures have been implemented when reporting for the disclosure requirement. For most building types, the renovation standard is set at energy label A++ or A+++.”–Youp van der Zande, Consultant at CFP Green Buildings
Legislation relating to sustainability in the built environment is amended regularly. For instance, changes are imminent in the legislation on energy performance certificates. Find out what the Energy performance of buildings directive (EPBD) changes mean for you. Amendments are also going to be made to the renovation standard.
Do you want to get started with the disclosure requirement? Using our Green Buildings Tool, complying with legislation such as the disclosure requirement becomes much easier. This is because you benefit from up-to-date data at portfolio level, giving you easy insight into the energy performance of your buildings. For example, you can see at a glance which buildings fall under the disclosure requirement and you can easily report on the energy saving measures. Want to know more? Contact us for customised advice.