Energy-saving obligation — mandatory measures for businesses (art. 2.15 Environmental Management Act)
Statutory duty for businesses > 50,000 kWh or > 25,000 m³ gas/year: implement all energy-saving measures with payback < 5 years. Plus reporting duty.
Under Environmental Management Act art. 2.15 + Activities Decree art. 2.14 jo. 2.15, businesses above the threshold (50,000 kWh electricity OR 25,000 m³ gas equivalent per year per site) must implement ALL energy-saving measures with payback < 5 years. RVO publishes sector Recognised Measures Lists (EML) — businesses doing all EML measures automatically comply. Reporting duty (since 2019): every 4 years via Mijn RVO eLoket on which measures were taken or why not. Municipality or environmental agency enforces with penalty payments (typically €1,500 — €15,000). For SMEs: EIA + MIA + ISDE substantially reduce net cost — often payback < 3 years after subsidy.