Lower Boundaries of the Energy Efficiency Obligation: Towards Effective and Future-Proof Implementation

The current threshold values of the energy-saving obligation date back to 2008. These thresholds determine the level of annual energy consumption above which companies and institutions are subject to the energy-saving obligation. However, it is unclear on what basis these thresholds were established, and they have never been evaluated. For this reason, the Ministry of Climate and Green Growth (KGG) has asked CE Delft to investigate and provide advice on new thresholds that are up to date and effective.

The objective of this study is to provide a more detailed justification for whether, and if so how, the thresholds of the energy-saving obligation should be adjusted. To this end, we address the following three research questions:

1. What are the current thresholds of the energy-saving obligation?
2. Which alternative threshold variants could be applied?
3. How future-proof, effective and efficient are the current and these alternative threshold variants in achieving the objectives of the energy-saving obligation?

This report forms part of the parliamentary letter State of Play of the Energy-Saving Obligation (only available in Dutch), which was sent to the House of Representatives on 18 December 2025.

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