Renewable Energy 2025 Comparisons

Last Updated September 25, 2025

Contributed By HabrakenRutten

Law and Practice

Authors



HabrakenRutten is an industry sector boutique law firm focusing on all legal aspects of projects, infrastructure, energy and tech. Its legal services cover the entire energy chain and the full life cycle of activities of both conventional and renewable energy market players. The firm’s expertise includes onshore projects, such as solar PV projects, electricity grids and biogas installations, as well as offshore wind farms, subsea cables and LNG platforms. Widely recognised as a market leader, HabrakenRutten has been involved in most significant (energy) infrastructure and construction projects in the Netherlands in the past decade. The specialists of HabrakenRutten advise stakeholders on projects, transactions, regulation and disputes in all energy and utilities-related areas, including oil and gas, power, renewables, nuclear, heat, water and waste management. The firm’s recent track record includes advising on large renewable hydrogen projects, batteries, smart grids and carbon capture and storage.

The energy mix in the Netherlands consists of crude oil, natural gas, coal, renewable energy and other types of energy such as nuclear and energy from waste. The Netherlands has substantial natural gas reserves, but the government decided in 2018 to phase out the extraction of natural gas (mainly because of earthquake concerns). 

According to the most recent figures for 2024 (published in June 2025), the Netherlands had a 19.8% share of renewables (ie, wind energy, solar energy, geothermal heat, biomass, renewable cold and ambient heat) in its energy mix.

Pursuant to the European Green Deal and the European Climate Law, each EU member state must use 100% renewable energy and thus become climate neutral by (ultimately) 2050. By 2030, the Netherlands aims for a CO₂ reduction of 55% compared to 1990. Furthermore, the Dutch government initiated the Climate Agreement in 2019. This national agreement aligns governments and commercial partners to speed up the transition to a sustainable society.

Because of (societal) issues with renewable energy on land, including “not in my backyard” (NIMBY) sentiments, offshore wind is the main focus of the Dutch government. The market is up and running, and offshore wind energy has proven to be relatively reliable in terms of supply. Nevertheless, in July 2025, the (caretaker) Minister of Climate Policy and Green Growth announced the scaling back of the government’s ambitions for offshore wind farms. The former 2040 goal of 50 gigawatts (GW) of offshore wind generation has been reduced to 30-40 GW.

Green gas installations are emerging and the first (substantial) hydrogen projects have kicked off.

In terms of renewable energy technologies, the Netherlands is currently mostly relying on biomass (including biogas/green gas and bioLNG), wind and solar PV. The largest renewable sources in 2024 were: biomass at 6.69% (120,950 TJ), wind energy at 6.4% (115,668 TJ) and solar energy at 4.3% (77,714 TJ) (source: Statistics Netherlands).

Hydrogen and geothermal heat are still relatively small sectors. Hydrogen only represents a share of 0.02% (300 TJ) in the energy mix, while geothermal heat covers 0.81% (14,572 TJ) of renewable energy usage. Although still small, these sectors are steadily emerging.

Between 2023 and 2024 (the most recent figures), the renewable energy share within the total energy usage mix increased from 17.4% to 19.8%.

The renewable energy market is challenged by congestion on national and regional electricity grids. The capacity of electricity grids has to be increased as soon as possible, but the current speed of grid expansion is insufficient. The Dutch national energy regulator, the ACM (Authority for Consumers and Markets), has taken certain measures to regulate this congestion. For more detail, see 4.2 Intermittency, Grid Congestion and Flexibility

Uncertainty on governmental plans in general has increased since the Dutch government collapsed in June 2025. The cabinet is now in a so-called caretaker capacity. Elections will be held at the end of October 2025. It is expected that forming a (new) government will take considerable time afterwards.

The long-pending legislative proposal for a new Heat Act caused uncertainty in the field of regulation for (collective) heat supply projects (for more detail see 2.1 Governing Law and Upcoming Changes). The uncertainty resulted in projects being paused or terminated. The proposal was adopted by Parliament on 3 July 2025. It remains to be seen how the market will respond.

Preparations for two new nuclear plants are still continuing. The (caretaker) Minister for Climate Policy and Green Growth is targeting a 2035 start date for their operation. The Minister has appointed seven locations in four regions (Sloegebied, Terneuzen, Maasvlakte II and Eemshaven) for the location analysis. In addition to these two plants, Parliament has passed a motion to allow two extra nuclear plants. It remains to be seen, however, whether these two extra plants will be (economically) feasible. The Dutch government will focus on the realisation of the first two nuclear plants. That process is decisive for the feasibility question regarding the two additional ones.

Furthermore, the Dutch government is encouraging the development of large-scale batteries to help stabilise and relieve the strained power grid. Developers of large-scale battery projects are increasingly finding their business cases commercially viable, which resulted in significant investment in the sector during 2024 and the first half of 2025. Nevertheless, the power grid remains congested, and not all developers and producers are able to secure a connection and sufficient transportation capacity. In 2025, the ACM introduced new types of electricity transportation contracts, including time-bound transportation contracts. These contracts should favour flexible users of the grid such as battery storage facilities. The trade organisation Energy Storage NL is unsure about the effectiveness of this measure, particularly in light of increasing grid transportation tariffs.

The Dutch energy market is governed, to a large extent, by the Electricity Act 1998, the Gas Act and the Heat Act, combined with subordinate legislation, such as decrees, regulations and national network codes.

Parliament adopted an overarching new Energy Act, which will, inter alia, replace and update the current Electricity Act and Gas Act (not the Heat Act), aiming to facilitate the “energy system of the future”, including more local renewable energy production, storage and flexibility. The new Energy Act incorporates and unifies parts of the current legislation and includes new legislation on consumer protection, flexible use of the electricity grid and exchange of information between grid operators, energy suppliers and off-takers. The Energy Act enters into force on 1 January 2026.

In July 2025, following the EU Hydrogen and Decarbonised Gas Market Package (including the EU Directive 2024/1788), a draft bill was submitted for public consultation, proposing amendments to the Energy Act to implement the new Gas Directive. The Decarbonisation Package provides the fundamental regulatory framework necessary to initiate the hydrogen value chain. It sets out rules for infrastructure that is critical to the development of the chain: transmission and distribution systems, storage facilities, and terminals. These elements are partly of a monopolistic nature, and companies seeking to invest in hydrogen depend on access to such infrastructure. This draft bill establishes the rules governing market organisation. In combination with assigning a supervisory role to the ACM as the independent regulator of the hydrogen market, it contributes to investment certainty for market participants and system operators. The public consultation procedure will be closed at the end of September 2025. Following this procedure, the draft bill will be discussed in Parliament and the Senate.

Government is aiming for a substantial boost of the geothermal heat sector through the implementation of a new Heat Act, called the Collective Heat Act (Wet collectieve warmte). This ambitious legislative proposal, which aims at increasing public control over the realisation and operation of collective heat projects, developing collective heat with zero greenhouse gas emissions by 2050, tightening consumer protection and better guaranteeing security of supply of collective heat, as well as introducing transparent and cost-based tariff regulation for captive consumers of collective heat, was adopted on 3 July 2025. The (caretaker) Minister of Climate Policy and Green Growth has requested that the Senate promptly consider the Act, with the aim of bringing it into force swiftly, ideally by 1 January 2026.

There is no general separate legal framework for renewable energy. Provisions for renewable energy are incorporated in both the Electricity Act 1998 and the Gas Act (soon to be the Energy Act), as well as in the Heat Act. There is some specific legislation for special types of renewable energy, such as the Offshore Wind Energy Act (Wet windenergie op zee), together with subordinate legislation, and legislation on subsidies for renewable energy (the Renewable Energy Production Incentive Scheme). Furthermore, since 1 February 2022, implementing the EU Directive on Renewable Energy (REDII), the Structures (Living Environment) Decree (Besluit bouwwerken leefomgeving) includes requirements for a minimum renewable energy usage in major renovations of buildings, including a heating or cooling installation.

There are specific provisions for renewable energy in place focusing on sound certification of renewable energy products and protection against greenwashing. The Gas Act, the Electricity Act (as of 2026: the Energy Act) and the Heat Act include sections on “guarantees of origin” (GoOs), which certify the renewable origin of energy.

ACM

The Authority for Consumers and Markets (ACM) is the Dutch national regulating authority for the energy market and a member of the European Agency for the Cooperation of Energy Regulators (ACER). The ACM ensures fair competition between businesses, and protects consumer interests. This includes energy markets, and protection of consumers in those markets. The ACM is responsible for, inter alia, translating EU electricity and gas codes into national codes for the electricity and gas markets and for monitoring compliance with energy regulation. The ACM also determines the regulated tariffs for energy grid operators and heat supply companies.

The ACM has various powers and tools, following from its Establishing Act and Division 5.2 of the General Administrative Law Act (GALA). These include rights to information, whereby the ACM is able to request information from companies in the energy sector to monitor compliance, and a right to enter every place (except private homes) without the occupant’s permission. The ACM can also conduct inspections and audits of energy companies, issue binding decisions and instructions to enforce compliance with laws and regulations, and impose fines and penalties for non-compliance. Persons and companies are to co-operate fully with requests from the ACM. Finally, the ACM is the authority in charge of granting (and, if necessary, revoking) licences required for the supply of electricity, gas and heat to small consumers. The ACM is also the supervisory authority for monitoring unfair trade practices and wilful deception of consumers.

SSM

The State Supervision of Mines (SSM) is the independent regulator of mineral and energy extraction in the Netherlands. The SSM oversees safety and environmental protection in mining activities, the gas grid and offshore wind energy. It performs its supervision from a technical perspective, taking social interests into account as well. Most of the SSM’s tasks are laid down in the Mining Act and the Gas Act.

Minister

The primary policymaker for energy activities, more specifically renewable energy activities, is the Minister of Climate Policy and Green Growth (the Minister). The Minister creates the legal and regulatory framework for the energy sector and is leading in terms of promoting new energy projects by, for example, managing subsidy and incentive schemes.

RVO

The Netherlands Enterprise Agency (RVO) is part of the Ministry of Economic Affairs and Climate Policy. RVO was established in order to facilitate sustainable prosperity in the Netherlands, and therefore facilitate sustainable and innovative projects, including renewable energy projects. RVO administers subsidies and financial incentives for renewable energy projects, and monitors the progress and compliance of these subsidised projects. If necessary, RVO is equipped to reclaim subsidies in case of non-compliance with the relevant terms and conditions.

Renewable energy activities are regulated to ensure compliance with national and European laws and regulations, environmental standards, and market rules.

Wind Energy

Wind energy can be divided into offshore and onshore wind activities. The basic regulation of wind energy production and supply does not fundamentally differ from conventional electricity production (from fossil fuel).

Offshore wind has specific legislation: the Offshore Wind Energy Act (the OWE Act), which governs the planning, tendering and permitting of offshore wind farms. This act also contains the (legal) concept of the so-called wind farm site decision (kavelbesluit) in which the Minister of Climate Policy and Green Growth (the “Minister”) (in co-ordination with the Minister of Infrastructure and Water Works) designates a plot for the development of an offshore wind farm (if it is part of the areas designated for offshore wind in the National Water Plan). A developing party also needs a permit in order to construct an offshore wind farm, to be obtained in a tender process (see 6.2 Offshore Project Development).

For onshore wind, the provincial governments, local governments (municipalities) and the RVO are the key authorities involved. Provincial governments and municipalities should co-ordinate their spatial planning in terms of onshore wind energy. Where needed, provincial and municipal zoning plans are (re)drafted in order to facilitate onshore wind farms. There are regulations on noise and shadow flickering, as well as on the proximity to residential areas.

Solar Photovoltaic (PV)

Key regulatory authorities are quite similar to onshore wind: provincial and municipal governments as well as the RVO. The Environmental Act (in force since 1 January 2024) states that, in principle, rooftop solar installations can be built without the need to request a permit.

Biogas, Green Gas

Several permits and registrations are required for building and operating a biogas installation. An environmental permit is key. In addition, an installation may require an accreditation from the Netherlands Food and Consumer Product Safety Authority, a Fertilisers Act registration and a registration on the list of transporters, collectors, dealers and brokers of waste substances.

Hydrogen

As mentioned in 2.1 Governing Law and Upcoming Changes, the Minister has drafted a bill amending the (new) Energy Act, with the aim of laying the foundations of the regulatory framework for hydrogen. Nevertheless, the legislative procedure is still in its early stages.

At the national level, the Minister will also be responsible for defining access and tariff conditions, after which a consultation will take place on the standard contract terms and conditions to be applied by the grid operator. Ultimately, in 2031, the Dutch government aims to have a full hydrogen legal framework in place, including rules on balancing, capacity allocation and congestion management.

In the meantime, the (usual) spatial planning legislation applies to the construction of hydrogen plants and storage plants, as well as pipelines. Therefore, spatial and environmental permit procedures must be followed in order to be able to construct the required installations and buildings.

Geothermal Energy

The authorities involved in geothermal energy are the Minister and the SSM. Geothermal energy is governed by the Mining Act and underlying regulation, regulating the exploration and extraction of geothermal heat resources.

A geothermal project requires a “start-up permit” before exploration activities begin. According to Section 24t of the Mining Act, this permit shall be rejected in whole or in part if:

  • the exploration or extraction of geothermal heat in the geological strata indicated in the application and their delimitation are not permitted by or pursuant to law;
  • an allocation search area for geothermal heat has been granted to someone other than the applicant for the ground layers and their boundaries indicated in the application, or an initial permit for geothermal heat or a follow-up permit for geothermal heat has been granted;
  • the exploration and extraction described in the application will entail unacceptable risks for the safety of local residents or may cause unacceptable damage to buildings or infrastructure works or their functionality; and/or
  • if the ground layers specified in the application are located wholly or partially under an area designated for the extraction of drinking water from groundwater, and no financial security can be provided to cover liability for damage due to contamination of groundwater or soil in connection with the exploration and extraction.

Subsequently, a “follow-up permit” is needed for the extraction of the geothermal heat. According to Section 24aj of the Mining Act, this permit shall be rejected in whole or in part if there are material or financial risks as laid out in the last two bullet points above. The decommissioning is regulated (see 6.5 Decommissioning Requirements). In addition, an environmental permit may be required for geothermal activities.

Conclusion

The regulatory framework for renewable energy in the Netherlands is comprehensive and varies across different types of renewable energy. Each type of renewable energy activity is subject to specific rules and restrictions aimed at ensuring environmental protection, safety, and compliance with national and European policies. The regulatory authorities, including the Minister, the ACM, the SSM and the RVO, play a critical role in enforcing these regulations to facilitate a sustainable energy transition.

There are no general restrictions on the ownership and transfer of (renewable) energy assets in the Netherlands, except for a privatisation ban regarding the transmission system operators and distribution system operators and their assets. Other (renewable) energy assets are generally open to both domestic and international private ownership. The strategic importance of certain assets may add scrutiny and restrictions on ownership and transfer: ownership transfer of offshore wind assets requires governmental approval, which is also required for the transfer of geothermal energy assets.

Section 86f of the Electricity Act and Section 66e of the Gas Act (as per 1 January 2026: Section 6.3 Energy Act) contain a notification requirement. Any change of control in respect of an electricity production facility with a nominal capacity in excess of 250 MW (under the Energy Act: 100 MW) or in respect of an LNG installation or company must be reported to the relevant minister by one of the parties involved in such transaction. On grounds of public safety, security of supply or security of delivery, the relevant minister may attach certain conditions to the transaction or prohibit the change of control altogether (“control” being defined as “the possibility of exercising decisive influence over a company’s activities on the basis of factual or legal circumstances”).

On 1 June 2023, the Investment, Mergers and Acquisitions Screening Act (Wet Veiligheidstoets investeringen, fusies en overnames) entered into force. This Act introduced a general FDI screening mechanism. Transactions involving targets operating, managing or providing a service which can be deemed of vital importance to Dutch society may need approval from the Minister of Economic Affairs. A proposal on the expansion of the scope of this Act – including areas such as artificial intelligence, biotechnology and nanotechnology – was released for public consultation in December 2024 and January 2025. The (caretaker) Minister of Economic Affairs is aiming to submit a legislative proposal to Parliament before the end of 2025.

Furthermore, the above-mentioned proposed new Heat Act will introduce public ownership. An appointed heat company (warmtebedrijf) or heat community (warmtegemeenschap) will have exclusivity within a so-called heat plot (warmtekavel) and at least 50% of the shares (+1) in such heat company/community must be held, directly or indirectly, by (local) government.

Energie Beheer Nederland (EBN) invests in energy projects on behalf of the Dutch state. In the past, EBN’s focus was on oil and gas projects. Now, its activities focus on the gas transition, the heat transition and CO₂ storage and transport systems. As of 1 July 2023, EBN is a mandatory participant in new geothermal heat projects. This entails that EBN participates financially and with a risk-bearing stance in these projects as non-executive partner. EBN’s stake is between 20% and 40% and EBN’s participation commences as soon as a permit holder is granted an exploration area. This mandatory EBN participation will be evaluated in 2028.

Some permits may be person-related, such as nuclear energy permits and Mining Act permits. This may have an impact on ownership or transfer of control. Certain permits and subsidy decisions may also stipulate that transfer is not allowed (without prior consent), or is not allowed within a specified timeframe.

In addition to what is stated in 2.4 Ownership and Transfer of Control, investments in the Dutch energy market have always been open to both national and foreign investments. Foreign investors have a relatively substantial presence in the Dutch energy market. The foreign share in the Dutch gas market is quite large and major international players, including Vattenfall (owned by the Swedish state), Eneco (owned by Japanese shareholders) and German energy company E.ON, are active in the Dutch energy sector, both in production and supply.

The main sources of renewable energy in the Netherlands are biomass, wind and solar energy. The (net) electricity production from renewable sources increased from 53.6 billion kWh in 2023 to 59.9 billion kWh in 2024. As a result, the share of renewable electricity production is 50.4% of the total electricity usage.

There are currently ten active offshore wind farms. Additional offshore projects are to be constructed in the coming years, following the roadmap as set by the Minister of Climate Policy and Green Growth. The current wind farms are owned and/or built by international parties such as Shell, Eneco, Mitsubishi Corporation and Ørsted.

According to the most recent figures (as of October 2024), 40.5% of onshore wind farms are owned by purely local partnerships (local community initiatives with their local partners) and the majority by non-local parties, such as Eneco, Pure Energie and Innogy.

Solar energy is the second-most important renewable source in the energy mix. According to the latest figures provided by Statistics Netherlands, a total of 986 solar parks have been constructed in the Netherlands (in a field or floating). The vast majority of the projects are owned by non-local partnerships/companies. A key player in the solar market is the company Sunrock, of the well-known Brenninkmeijer family. Some other major players are GroenLeven, Blue Elephant Energy, Solarfields, HVC and Powerfield. The only traditional energy firm in the top ten of solar park owners is Eneco.

In addition to professional large-scale solar projects, there is a substantial number of small-scale rooftop solar PV panel systems. Rooftop solar energy has been quite heavily subsidised in recent years and, consequently, a substantial number of households have had solar panels installed on their rooftops. However, subsidy schemes are now to be reduced. In 2024, regional grid operators reported that just under three million (residential) properties were fitted with (rooftop) solar panels.

Gas from renewable sources is still relatively uncommon in the Dutch gas market. Biogas makes up only 0.45% of the total energy mix. In 2024, green gas production (an upgraded version of biogas) increased to 294 million m3, which is only a 5% increase compared to 2023 and far less than the average increase of 21% in the last five years (up until 2023).

In May 2025, only five energy suppliers supplied 100% green gas (thus excluding CO₂-compensated gas). The (Dutch) Climate Agreement aims for two billion m³ of green gas in 2030, both in the existing gas system, and for automotive use (fuels). This means the green gas production has to achieve an annual increase of 37%.

Geothermal heat has been produced in the Netherlands since 2007, but is still a relatively small sector within the Dutch energy landscape, making up 0.81% (14.572 TJ) of renewable energy usage.

Geothermal heat is governed by the Mining Act and the regulating authority is the Ministry of Climate Policy and Green Growth. The State Supervision of Mines (SSM) is the supervising authority.

In 2024, 23 operational installations collectively produced 7.49 PJ of geothermal energy, representing an increase of over 10% compared to 2023. The government aims to increase geothermal heat production to 15 petajoules (PJ) by 2030 (the equivalent of the average electricity and gas consumption of 2.2 million households). To achieve this goal, a Geothermal Heat Action Plan was published in 2022.

A permit is required for geothermal heat exploration and production at depths of 500 metres or more. As of 1 July 2023, there is a separate regime applicable to geothermal permits, taking into account practical and safety aspects.

As mentioned in 2.1 Governing Law and Upcoming Changes, Parliament adopted a legislative proposal for a new Heat Act in July 2025. The Minister of Climate Policy and Green Growth is aiming for the new Heat Act to enter into force on 1 January 2026; however, the Senate still has to consider the bill.

Despite criticism of commercial heat companies on the mandatory publicly owned majority of shares of collective heat projects, it is still a key element of this new Heat Act. It remains to be seen how the market will respond to the new Act.

In July 2025, the Minister of Climate Policy and Green Growth announced that – in consultation with Geothermie Nederland and EBN – efforts are being made to establish a framework agreement between the national government, regional authorities, and the geothermal sector, with the aim of further stimulating the development of geothermal energy.

Significant project risks, driven by high capital expenditures and suboptimal support schemes, remain a key obstacle to the development of new projects with uncertain returns. The SDE++ scheme (see 6.4 Subsidies and Incentive Schemes) still plays a crucial role in the development of new projects.

Hydrogen has a modest share of 0.02% (300 TJ) in the current Dutch energy mix. However, the sector is growing. The Netherlands aims for a national network of 50 hydrogen filling stations and electrolyser capacity of 8 GW by 2032, including sufficient storage locations and infrastructure. To achieve these goals, various subsidy schemes are in place.

In July 2025, eleven Dutch sustainable hydrogen production projects were granted approximately EUR700 million in subsidies, with the aim to realise 602 MW of electrolyser capacity.

An onshore hydrogen network is being developed by Hynetwork.

Specific rules and regulations for hydrogen are still in the early stages of legislative procedures, but safety guidelines do apply. The first version of the Safety Guideline for Hydrogen Carriers addresses both existing activities (such as ammonia storage and transhipment) and new activities, such as storage and transhipment of liquid hydrogen and liquid organic hydrogen carriers, as well as converting hydrogen carriers.

As indicated in 3.1 Electricity, small-scale generation of renewable energy by way of rooftop solar PV for domestic use is very common in the Netherlands. This is a relatively mature market, which has been pushed by a governmental renewable energy netting scheme. Generally, no permit is required for small-scale rooftop solar PV.

The netting scheme, under which households and small enterprises generating their own electricity (mainly via solar PV) can offset their annual electricity consumption against their production, will be terminated in 2027. Previously, the plan was to gradually phase out the scheme starting in 2025. However, the government has decided to discontinue the scheme entirely in 2027, without a prior phase-out period.

Another downside for households and small enterprises generating and feeding in electricity is that energy suppliers charge feed-in costs. Previously, this could only be avoided via a dynamic contract (ie, a contract in which the energy pricing directly relates to the market pricing). Recent research has shown that an increasing number of energy suppliers implemented feed-in costs in dynamic contracts as well.

In addition to solar energy for private use, more heat pumps are being installed in households nationwide, even though sales of new pumps are decreasing. In May 2022, the government announced the introduction of a hybrid heat pump obligation from 2026 onwards. In 2024, the current (now caretaker) government abandoned this plan.

In principle, no permit is required for the installation of a heat pump on a rooftop or outside a home, but local exceptions apply. Since 2021, regulation has been in place regarding noise emission standards. Noise produced by a heat pump should be limited to 40 dB. Subsidies can be applied for when installing a heat pump.

An increasing number of Dutch households are storing solar power in home batteries for personal use. Suppliers and industry associations report a growing demand for home battery systems, now that the netting scheme for feeding electricity back into the grid is coming to an end. In 2024, approximately 40,000 households had a home battery system. That number is expected to rise to 50,000 in 2025.

The anticipated termination of the netting scheme in 2027 is likely the primary driver of this increase. After the scheme ends, the feed-in compensation is expected to be significantly lower, making self-consumption more attractive and helping households avoid feed-in charges.

Transmission and storage of electricity from renewable sources is similar to that for non-renewable electricity. The national transmission system operator TenneT operates the national high-voltage power grid in the Netherlands, ensuring the delivery of electricity to regional grid operators and connected parties. Distribution system operators operate the regional grids. The system operators are supervised and regulated by the ACM.

TenneT expects 4 GW of battery storage capacity in its system by 2030. In August 2024, TenneT and Giga Storage announced a 300 MW battery storage in Delfzijl (GIGA Leopard), that has access to TenneT’s system through a flexible transmission contract. In June 2025, Giga Storage announced it has secured financing, and the project is expected to become operational in the second half of 2027. In March 2025, RWE put a 35 MW battery storage into use in the Eemshaven.

General rules on electricity transportation and storage are incorporated in the Electricity Act 1998, which will be replaced by the new Energy Act. Chapter 5 of the Electricity Act is dedicated to electricity supply from renewable sources. Section 68.1 of this Act states that electricity suppliers (and producers) have the task of promoting the efficient and environmentally sound use of electricity by themselves and customers.

In the new Energy Act, the government focuses on replacing existing fossil sources with renewable sources of electricity and developing a carbon-free electricity system. The new Energy Act also contains clauses on energy storage.

The ACM is developing a new regulatory method, which it will use to determine transmission and distribution system operator tariffs (both electricity and gas) starting in 2027. The ACM expects to adopt draft decisions on the new method by late Q3 2025 and will then be able to provide more detailed information on its design. The final decisions are scheduled to be adopted in 2026, enabling the ACM to determine tariffs in accordance with the new method from 2027 onwards.

Grid congestion is a hot topic in the electricity sector. The current peak electricity demand in the Netherlands stands at approximately 19 gigawatts and is expected to rise to around 27 gigawatts by 2030.

The ACM draws up energy codes that include rules on grid congestion. Chapter 9 of the Net Code Electricity contains terms and conditions for congestion management, including responsibilities for both network operators as well as anyone having a connection to the electricity grid.

Solar PV causes more congestion than wind power. The Minister of Climate Policy and Green Growth has put a “National Grid Congestion Action Programme” in place, trying to accelerate the expansion of the grid, focusing on better use of the grid, as well as expanding flexible capacity. Since net congestion is a quite common problem in the Netherlands, and there are – in terms of construction materials, but also zoning regulation – obstacles to accelerating grid expansion, market players regularly have to resort to curtailment actions.

In April 2024, the ACM issued eight decisions on measures against grid congestion to be taken by grid operators and off-takers. Sometimes a distinction is made between the national high-voltage grid and regional distribution grids. For instance, it is possible that parties conclude a joint connection and transmission agreement with a system operator, in order to arrange between themselves a smaller and better capacity of the grid. Large off-takers on the national high-voltage grid can gain financial benefits by shifting (part of) their consumption out of peak hours. In addition, it will be possible for large off-takers on the high-voltage grid to receive a discount if they are willing to use less or no electricity at peak times in the grid (up to 15% of the time). The same applies to business off-takers on the distribution grids, though they need to agree on usage time periods in advance with the system operator. These measures help to free up capacity during peak hours and make better use of capacity that already exists outside peak hours. Furthermore, the ACM offers companies more clarity on connection deadlines that the grid operators must apply and the rules on having to return contracted but unused transportation capacity are being tightened (“use it or lose it”).

Also, the ACM issued a decision on a prioritisation framework for requests for grid transmission capacity. With this decision, the ACM tried to limit the societal consequences of grid congestion, and to offer a framework on prioritising projects contributing to the social good. The Trade and Industries Tribunal (CBb) has annulled this decision. On 26 June 2025, the ACM published a draft version of an amended decision on the prioritisation framework. The (draft) decision implements the ruling of the CBb, in which the CBb instructs the ACM to ensure that an independently reasoned assessment of all relevant interests is made when establishing the prioritisation framework. The ACM has done so by defining evaluation criteria to determine whether an activity or function should be included in the prioritisation framework. The period for lodging an objection to the draft decision ended in early August 2025.

In April 2025, the ACM updated its overview of congestion measures, already implemented or to be implemented in the (near) future. The ACM congestion measures can be divided into four categories:

  • offering flexible contract structures (individually or as a group);
  • differentiated tariffs to discourage consumption during peak hours and incentivise use during off-peak periods;
  • regulations to manage scarcity of transmission capacity; and
  • measures enabling national and regional grid operators to effectively apply (physical) congestion management.

Some recent developments on grid congestion from grid operators:

  • In December 2024, TenneT (the national transmission system operator) and Stedin (a regional grid operator) announced that the high-voltage grid in the province of Zuid-Holland has reached its maximum capacity for large-scale electricity consumers. In February 2025, both parties published a similar message for the province of Utrecht.
  • In March 2025, Stedin announced congestion on its own (regional) power grid in (the surroundings of) The Hague (part of Zuid-Holland). Taking into account the aforementioned congestion at the TenneT grid in Zuid-Holland, Stedin refers to “stacked congestion”. Stedin expects the (necessary) expansions around The Hague to be completed in 2035/2036.
  • In April 2025, TenneT announced a new type of flexible contract, introducing time-bound transmission rights (TBTR) on TenneT’s high-voltage grid. New analyses show that as much as 9.1 gigawatts of capacity is available outside of peak hours on the high-voltage grid, which can be (additionally) contracted with this new contract form.

In terms of off-grid solutions for transportation and supply of renewable energy for end users (consumers), there is the possibility to “go off grid” and privately generate energy with solar PV panels and heat pumps. Companies may also decide to join a closed distribution system or a direct connection. An example of a large closed distribution system is Smart Grid Flevoland, a system in which solar, wind and storage are combined.

Transportation and storage of gas from renewable sources is similar to transportation and storage of non-renewable gas. Gasunie Transport Services B.V. (GTS) is the owner and operator of the national gas transmission system (similar to TenneT for the electricity system). In addition, distribution system operators operate the regional grids. The system operators are supervised and regulated by the ACM.

Gas regulation is fairly similar to electricity regulation in the Netherlands. The Gas Act contains the most important general rules concerning gas transportation and storage. The new Energy Act will replace the Gas Act. The definition of “gas” in the Gas Act is twofold, namely natural gas as well as gas from renewable sources (Section 1.1.b). In the Gas Act, although very similar to the Electricity Act in most parts, there is no specific chapter dedicated to gas from renewable sources.

Compared to renewable electricity, there is less focus on renewable gas in the new Energy Act. Nevertheless, producers of renewable gas that apply for grid connection and transportation are granted certain advantages compared to producers of natural gas (see Sections 3.40 and 3.47). The Energy Act also contains rules regulating the intake and seizure of GoOs regarding gas from renewable sources (see also paragraph 2.6.1).

A proposal to supplement the Environmental Management Act with a green gas blending obligation has been in the legislative loop since 2023. It is anticipated that this obligation will enter into force as of 2027. The obligation entails that energy suppliers will be required to add a certain percentage of green gas to the natural gas they deliver to residential and business customers.

In 2025 and 2026, the transmission tariffs of the national grid are subject to a significant increase. The main causes are a decline in the gas network usage and an accelerated depreciation of the grid infrastructure. As fossil gas is used less, the transmission costs are distributed over a smaller number of grid users. In addition, the network is being depreciated more rapidly to prevent the last remaining fossil gas users from facing disproportionately high tariffs as the energy transition progresses further.

The ACM is developing a new regulatory method, which it will use to determine network operator tariffs (both electricity and gas) starting in 2027. See 4.1 Electricity for more detailed information.

The heat supply systems in the Netherlands are local and mostly small scale – eg, per district, city, region or building. There is no national heat grid (transportation system), like there is for gas and electricity. A regional system in the province of South Holland is being developed by WarmtelinQ, part of the Gasunie group. This regional system is a main underground pipeline that allows residual heat from the Port of Rotterdam to be used to heat homes and businesses in the province of South Holland.

One of the goals of the Climate Agreement is that 1.5 million households will stop using gas by 2030. 50% of these households should then be heated via a heat network.

The degree of renewable energy used in heat supply systems differs per system. Which source or sources are used depends on local availability of heat sources. Over time, the source used for a system may change. Existing systems mostly use heat from power plants and waste incinerators. Renewable sources, such as bio energy and geothermal heat, are used more and more to replace fossil sources. Heat systems may be combined with cold systems. This is especially interesting when it is possible to combine the installation of both systems.

The ACM sets maximum tariffs for the supply of heat to households and small businesses (with heat connections up to 100 kW). A licence to supply heat is required in case of supply to more than ten users and 10,000 GJ per year. Some major heat suppliers are Eneco, Engie, Essent, HVC and Vattenfall.

Rules for heat production and supply are about to change with the (adopted) new Heat Act (see 2.1 Governing Law and Upcoming Changes).

An onshore hydrogen network is being developed by Hynetwork. The hydrogen network aims at connecting industrial clusters to each other, to other countries and to hydrogen storage and import locations. The hydrogen network will repurpose existing natural gas pipelines (85%) and will include new pipelines (15%) as well. Hydrogen storage is planned in caverns, similar to gas storage. Gasunie is also preparing for an offshore hydrogen network.

By the end of 2024, the Dutch government had completed its decision-making on the Delta Rhine Corridor, which had caused previous delays, providing clarity on the modalities, the approach, and the intended completion date of the hydrogen pipeline within the DRC. In December 2024, Hynetwork published a new proposal to amend an earlier published “roll-out plan”. Stakeholders were able to respond to this proposal until the end of January 2025. Hynetwork finalised the proposal, taking into account the responses, and submitted this proposal to the Ministry of Climate and Energy Policy (KGG). The roll-out plan is subject to formal adoption by the Minister, for which there is no fixed time frame.

There is no specific regulation for hydrogen yet. By 2031 (at the latest), there should be a full legal framework within the Dutch jurisdiction, based on new EU regulation on hydrogen. In November 2022, the Minister of Climate Policy and Green Growth published a Hydrogen Roadmap (Routekaart Waterstof), confirming the Dutch government’s approach to provide certainty on, in particular, hydrogen infrastructure, regulation and certification by 2025. It is unsure if this deadline will be met, but the government recently reconfirmed its commitment to (green) hydrogen.

In July 2025, the Minister of Climate Policy and Green Growth released the draft bill implementing the European Hydrogen and Gas Decarbonisation Package into the Energy Act for public consultation. The (caretaker) government is currently responding to Parliament’s request to maintain momentum in the market of hydrogen development. With policy measures targeting infrastructure, supply, and demand, the government aims to break the deadlock situation and to stimulate investment.

Renewable electricity trade and supply to end users constitutes a fair share of the electricity market. Energy companies such as Vattenfall, Essent, Enenco, Budget Energie, Energiedirecti.nl and GreenChoice have a significant market position in the renewable electricity supply sector, and smaller suppliers include All in Power, DELTA Energie, Powerpeers, Pure Energie and Vrijopnaam.

The EU has set rules on consumer protection concerning electricity trade and supply that also apply to renewable electricity. This has been implemented in the Dutch legislation. A key obligation in terms of electricity supply is the requirement that suppliers obtain a permit from the ACM to be able to supply. Being granted a permit means a supplier needs to supply electricity in a reliable way as well as against reasonable tariffs, and compliance is monitored by the ACM.

An explicit obligation for suppliers of renewable electricity is being able to prove the renewable source of their electricity. The ACM is in charge of the verification of the accuracy of sustainability claims by market parties.

The market for gas from renewable sources is still small in the Netherlands. Some suppliers offer supply contracts for green gas, but most consumers choose a gas product combined with a form of CO₂ compensation.

A supplier of renewable gas is obliged to prove the renewable origin of its product. The ACM is in charge of the verification of the accuracy of sustainability claims.

Consumers with a connection to a heat supply system cannot freely choose their supplier, as there is only one supplier per heat supply system. The ACM sets maximum tariffs for the supply of heat to these captive consumers.

There is no substantial hydrogen trade and supply market yet. However, the hydrogen sector is growing and several projects are in the early stages of development.

The Dutch market for renewable energy certificates – ie, guarantees of origin (GoOs), is mature, but there is an imbalance between supply and demand. The substantial demand for GoOs is pushing GoO prices, as supply is lagging behind.

The government appointed VertiCer as the party responsible for the issue and registration of GoOs. VertiCer is 50% owned by the Gasunie group and 50% by the TenneT group.

Despite the prior enthusiasm regarding the increasing popularity of long-term (corporate) PPAs in the Dutch renewable energy market, and an increase in cumulative contracted volumes in the Netherlands to 2.9 GW, the PPA progress has slowed down. Market players seem to be too accustomed to subsidy schemes and hesitant regarding long-term fixed contracts.

Wind

The production of onshore wind energy totalled 21.2 TWh in 2024, with 1,305 MW of additional capacity in the pipeline. Several projects are well underway; irrevocable subsidy decisions have been granted to projects with a total of 540 MW capacity, of which 57 MW also have an irrevocable permit. The already realised capacity combined with the total potential in the pipeline would amount to an expected annual production of 25.65 TWh. A substantial number of projects are still in an early phase. The actual realisation and its production level are therefore uncertain. It is hence unlikely that the full production potential currently in the pipeline will be realised.

Solar

In 2024, after a record growth in 2023, the increase has slowed down. At the end of 2024, there were almost three million households with solar PV – 10% more than in 2023. The forecast for the coming three years shows no scenario in which there will be a further decrease of yearly added capacity. Although the Dutch focus is shifting from rapid expansion towards optimisation and innovation, the Netherlands is still the global leader in installed solar panel capacity per capita.

As discussed in 4.2 Intermittency, Grid Congestion and Flexibility, grid congestion is a significant problem in renewable energy project development. The netting scheme (salderingsregeling) for solar PV is also a much debated topic. The netting scheme for households (which provides for a set-off of electricity produced and electricity consumed) will be terminated as of 2027. This is expected to have a significant impact on the solar PV market.

Biogas

The former government announced the ambition to produce two billion cubic metres of green gas by 2030. The current (caretaker) government did not explicitly confirm this green gas ambition, but the Green Gas Programme (Programma Groen Gas) has not yet been withdrawn. It remains to be seen what the new, still-to-be-elected government will pursue.

Heat

The legislative proposal for the new Heat Act (introducing public ownership) caused quite some commotion. Energy companies like Eneco and Vattenfall cancelled new heat projects because of insecurity around the transitory law, particularly with regard to the potential expropriation of current private heat companies.

According to the Climate Agreement, by 2040 there should be 1.3 million heating grid connections. However, in February 2025, the Netherlands Court of Audit concluded that it was time to adjust the heat transition. At the end of 2024, there were 500 (smaller) heating grids, totalling 515,000 connections. The popularity of heat pumps has reduced the financial feasibility of heating grids. An important cause of the underperformance of heating grids is the inconsistent, incoherent policy-making on the heat transition, which leads to insecurity.

Nevertheless, in anticipation of the new Heat Act, municipalities are increasingly taking the initiative to establish public heat companies or to bring existing ones largely into public ownership. Several municipalities are currently working on the realisation of a public heat company and a small number of municipalities have already established such a public heat company (warmtebedrijf) – eg, Eindhoven, Tilburg and Groningen.

Furthermore, because of this insecurity, in 2024, the sale of heat pumps has also seen a decrease of 14% compared to 2023. This has been a first after years of a growing market. Despite lower sales figures, the total number of heat pumps still increased. By the end of 2024, there were a total of 2.6 million heat pumps in the Netherlands, representing a 17% increase compared to the previous year. This is because more heat pumps were installed in 2024 than were taken out of service.

In Q1 2025, especially in the private (residential) sector, the market is exhibiting signs of a modest recovery after the downturn in 2024, indicating a tentative return to growth.

Hydrogen

The large-scale development of new European and international (sustainable) hydrogen infrastructure remains in its early stages, though some anticipate the market could eventually match the scale and significance of today’s oil and gas sectors.

During the World Hydrogen Summit in Rotterdam in May 2025, the Hydrogen Chemistry Company (HyCC), a producer of green hydrogen, announced that it is developing a large-scale electrolyser in Rotterdam, named H2Next, to support the decarbonisation of industry.

The Port of Rotterdam has entered into an agreement with HyCC regarding a plot for the facility on the Maasvlakte, near the planned landing points of several offshore wind farms.

H2Next should be able to produce approximately 25,000 tonnes of green hydrogen per year. HyCC is currently finalising the study phase of the project and aims to reach a final investment decision no later than 2028, with the objective of commencing hydrogen production around 2030.

Key Parties Involved

Key parties involved in the Dutch onshore renewable projects are:

  • municipalities and provinces, which play a central role in zoning regulations as well as spatial planning in general, while the government is also responsible for granting subsidies;
  • TenneT, GTS and distribution system operators; and
  • parties that develop, construct and operate the renewable energy project, as well as investors; such developers could be local parties, such as farmers (individually or working together), and energy companies, while investors can either be national or international.

Community Participation

The Climate Agreement introduced the aim for 50% local ownership of large-scale renewable energy projects. Such local ownership and financial participation in energy projects is mostly seen in wind and solar projects. The government monitors this participation. The most recent report was published in October 2024 (monitor financiële participatie hernieuwbare energie op land 2023). The general conclusion was that production from wind and solar farms with local ownership and other forms of community participation has increased, both in absolute and relative terms. The report shows that – in absolute terms – the financial participation and ownership in onshore renewable energy is increasing (both wind and solar) especially in projects under 50 MW. These figures are a snapshot because of the large dependency on the completion of (large) projects with or without local ownership in the researched year.

The Minister of Climate Policy and Green Growth expects that the impact of the Climate Agreement’s focus on local ownership and financial participation will become visible in the monitoring of solar projects from 2024 onwards, and in the monitoring of wind projects from 2026/2027 onwards.

In the Netherlands, the main focus for offshore renewable projects is on offshore wind. Offshore wind currently comprises 12.5% of total electricity usage.

The government aims for 21 GW in 2032 and is reserving certain areas for the development of offshore wind farms. These areas are divided into plots, as included in the Offshore Wind Energy Roadmap. Projects Borssele (I-V), Hollandse Kust Zuid (I-IV), Hollandse Kust Noord, Hollandse Kust West and IJmuiden Ver (Alpha and Beta) have already been tendered. The Nederwiek (I) plot is scheduled for 2025, Nederwiek (II-III) for 2026, and Ten noorden van de Waddenweilanden and Doordewind for 2027. These last four plots are still to be permitted and tendered. The planning for plots Ijmuiden Ver (Gamma A and B) will be revised.

Currently, the government is working on the Partial Revision of the North Sea Programme, a policy document exploring whether and where parts of the North Sea can be designated for new offshore wind energy areas. This Partial Revision is expected to be published in 2025. Furthermore, the government is expected to publish an update on the Roadmap Offshore Wind Energy in 2040 (Routekaart windenergie op zee in 2040) in 2025.

Developers of offshore wind projects can participate in the tenders. The winning bidder is granted the permit for the construction and operation of the relevant wind farm plot. The tender criteria may vary per project, but financial aspects will always play a role. For instance, in earlier tenders, the main focus was on the (lowest) subsidy amount required by the developer.

In June 2024, wind farm developers (Noordzeker, a consortium of ABP, APG and SSE Renewables, and Zeevonk II, a joint venture of Vattenfall and Copenhagen Infrastructure Partners) won a tender for two wind plots in the North Sea, where they will build the largest wind farms in the Netherlands so far. In the tenders, the focus was on protecting and strengthening nature in the North Sea (the IJmuiden Ver Alpha wind farm) and on how to better integrate the electricity generated into the Dutch energy system (the IJmuiden Ver Beta wind farm). The latter has resulted in the anticipated construction of a 1 GW electrolyser in the port of Rotterdam to convert electricity generated from the wind farm into green hydrogen, and the largest offshore solar park (50 MWp).

The winning bidder is obliged to contract with TenneT for its connection to the offshore electricity grid. The relevant standard agreements, tailored to the specific conditions of each wind farm, are published during the tender process.

Key parties involved in the offshore renewable (wind) energy sector are:

  • the government, tendering the plots and granting the construction permits (as well as granting subsidies, where applicable);
  • TenneT, being the offshore electricity system operator, taking care of the realisation and operation of the offshore grid; and
  • wind farm developers that develop, construct and operate the wind farms; the Dutch government publishes the names of the developers that have won tendered offshore wind projects (including such parties as Eneco, Vattenfall, Van Oord and several (foreign) parties).

As mentioned in 1.1 Energy Transition, the government’s ambitions regarding offshore wind farms have been scaled back. In July 2025, the previous 2040 goal of 50 gigawatts (GW) of offshore wind generation was reduced to 30-40 GW.

In addition to standard considerations for project-financed assets, relevant topics to take into account in project financing for renewable energy projects in the Netherlands include the following.

  • Grid Connection: Most renewable energy projects require a connection to the grid. Such connections can only be realised by the grid operator. There are long waiting periods mainly caused by congestion (which may be up to even more than a year) when applying for a grid connection, especially on the electricity grid. This may have an impact on the start date of the project.
  • Transmission Capacity: Most renewable energy projects require transmission capacity. There is congestion in many parts of the electricity grids, both in terms of transmission and distribution. This may result in a project having a grid connection, but no transportation capacity, which makes the connection de facto useless. Project developers can wait until capacity becomes available or look for alternative solutions, such as using a joint connection with other parties, requesting temporary capacity, facilitating a direct connection with an installation requiring electricity, or connecting to a closed distribution system.
  • Permits: Most renewable energy projects require permits, and some may require amendments to the zoning plan. It takes time to prepare permit applications and for the competent authority to take decisions. Also, objection and appeal proceedings need to be taken into account, both because of a potential delay, and because of potential changes to the project or the possibility that no irrevocable permits will be obtained.
  • Subsidies: If a renewable energy project requires subsidies, timing of an irrevocable subsidy decision needs to be factored in, as well as the possibility that a subsidy will not be granted, or not be granted in full. When applying for various subsidies or tax schemes, it must be ensured that a project does not receive too much government incentive (state aid risk).
  • Delivery Times of Materials: Some materials, such as rotor blades, may have a long delivery time.
  • Qualified Personnel: Some companies may not have sufficient qualified personnel, which may result in delays in construction.
  • Community Participation: Mandatory or voluntary community participation may take place in various forms, and could include financial participation of the local community.

The Netherlands has several subsidies and tax benefits in place to incentivise renewable energy projects. There is a tax deduction scheme known as the Energy Investment Allowance. This scheme offers direct financial benefits to entrepreneurs investing in energy-saving assets and renewable energy. In addition to depreciation, investors in renewable energy may deduct an additional amount of these investments from their profits. One of the requirements is that the investment should be at least EUR2,500. In case of investments in environmentally friendly technology, the Environmental Investment Deduction (MIA) and Arbitrary Depreciation of Environmental Investment (Vamil) schemes may apply. MIA allows the deduction of up to 45% of the investment costs for an environmentally friendly investment on top of regular investment tax deductions. Vamil offers advantages in terms of liquidity and interest by letting businesses decide when to write off 75% of the investment costs.

Furthermore, RVO is responsible for the granting of renewable energy subsidies. The three main schemes are:

  • the Renewable Energy Production and Climate Transition Incentive Scheme (SDE++) for large energy projects, including geothermal heat and solar parks, and techniques that reduce CO₂, such as capture and storage of CO₂; despite previous concerns about the government’s ability to make funding available for the SDE++ scheme in 2026, in June 2025, the Minister of Climate Policy and Green Growth announced entrepreneurs will be once again eligible to apply for subsidies under this scheme;
  • the previous subsidy, renewable energy (HER+) for innovative CO₂-reduction projects via renewable energy, has been continued from 2025 onwards under the DEI+ (Demonstration Energy and Climate Innovation) and MOOI (Mission-driven Research, Development and Innovation) scheme, both focused on innovation in the sector; and
  • the investment subsidy renewable energy (ISDE) for smaller projects such as heat pumps and solar water heaters, focused on both the commercial and private sectors.

Government may introduce a Contract for Difference (CfD) system for some projects in the future, instead of the SDE system.

In addition, municipalities and provinces have local and regional subsidy schemes, generally aimed at households or small businesses. Projects may also apply for specific subsidies from RVO and the European Commission.

The cessation of activities, decommissioning, and disposal of renewable energy installations in the Netherlands are governed by a comprehensive regulatory framework aimed at ensuring environmental protection, safety, and site restoration.

Wind Energy

Offshore wind projects are required to submit a decommissioning plan as part of the initial permitting or tender procedure, to be updated during the lifespan of the project. This plan must outline the steps and measures for the safe dismantling and removal of wind turbines, foundations, and associated infrastructure. Project developers must provide financial security (such as a decommissioning bond) to cover the costs of decommissioning. This ensures that funds are available to carry out the decommissioning process. Lastly, the relevant decommissioning activities have to comply with environmental regulations to minimise impact on marine ecosystems. This includes safe removal of underwater structures and proper handling of hazardous materials.

For onshore wind projects, the regulatory authorities, municipalities and provincial governments typically require a decommissioning plan as part of the permitting process. These plans must detail the methods for dismantling and site restoration. A permit is usually granted for 20 years (with potential renewals) and includes a “dismantling obligation”. This obligation entails the responsibility for the project developers to restore the site to its original condition or to a condition agreed upon with the relevant authority (municipality or provincial government). These dismantling/decommissioning activities have to be in line with safety and environmental regulations.

Solar PV

Similar to permits for onshore wind farms, permits for the construction and operation of solar projects usually contain a dismantling obligation after 20 to 25 years. There are programmes and facilities established for recycling solar panels, complying with directive EU/2012/19.

Hydrogen

There is no specific regulation regarding the decommissioning of hydrogen projects yet, but it is expected that this will be included in upcoming hydrogen legislation. For existing and upcoming projects, it is expected that any decommissioning requirements will be included in permits and/or zoning plans.

Geothermal Heat

Decommissioning of a geothermal energy project is governed by the Mining Act. When a geothermal energy project has been terminated, the project owner is responsible for the dismantling and removal of the installation. The operator should also restore the above-ground site to its original state.

Significant future and/or expected developments and points of attention are as follows.

  • New Energy Act: This enters into force as of 1 January 2026.
  • New Heat Act: Following adoption in Parliament in July 2025, the new Heat Act is expected to enter into force on 1 January 2026, though the Senate still has to approve the new act.
  • Hydrogen: Specific national legislation and regulation is being developed following EU legislation. The relatively young hydrogen sector is expected to grow substantially in the coming years.
  • Offshore: More offshore renewable energy projects are in the pipeline. These projects may combine various sources of renewable energy (wind, solar), storage (hydrogen) and/or connections to other projects and offshore hubs.
  • Onshore: Renewable energy producers and off-takers are expected to co-operate more and more, to achieve efficiency benefits and to avoid negative consequences of grid congestion.
  • Storage: More battery and hydrogen storage facilities are expected, both to balance the grid (avoid and mitigate congestion) and work towards a steady, reliable energy supply.
  • Subsidies: The government may introduce a Contracts for Difference (CfD) system in the future (as of 2027) for offshore wind.
  • Furthermore, parliamentary elections will take place in October 2025 and it is expected that establishing a new government will be a challenging and lengthy process, likely extending well into 2026. Although the current caretaker government is still able to make certain policy decisions on the energy sector, it remains to be seen what direction the new government will pursue.
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HabrakenRutten is an industry sector boutique law firm focusing on all legal aspects of projects, infrastructure, energy and tech. Its legal services cover the entire energy chain and the full life cycle of activities of both conventional and renewable energy market players. The firm’s expertise includes onshore projects, such as solar PV projects, electricity grids and biogas installations, as well as offshore wind farms, subsea cables and LNG platforms. Widely recognised as a market leader, HabrakenRutten has been involved in most significant (energy) infrastructure and construction projects in the Netherlands in the past decade. The specialists of HabrakenRutten advise stakeholders on projects, transactions, regulation and disputes in all energy and utilities-related areas, including oil and gas, power, renewables, nuclear, heat, water and waste management. The firm’s recent track record includes advising on large renewable hydrogen projects, batteries, smart grids and carbon capture and storage.