Does the air conditioning inspection obligation still exist in the Netherlands?

Short answer: no, not anymore. The periodic inspection obligation for air conditioning systems and for heating systems was removed from the Besluit bouwwerken leefomgeving (Bbl) as of 29 May 2026. Anyone who still offers a "mandatory EPBD air conditioning inspection" today is selling an obligation that no longer exists.

This article previously stated the opposite answer here. That was incorrect and has been corrected below.

The old rule: class 1 from 12 kW

Under the first version of the EPBD (Energy Performance of Buildings Directive), as implemented in the Bouwbesluit 2012, air conditioning systems were classified into power classes: class 1 (12-45 kW), class 2 (45-270 kW) and class 3 (>270 kW). Systems from 12 kW nominal power upward were therefore already subject to the inspection obligation. This is the rule that still circulates as "the air conditioning inspection obligation".

The intermediate phase: 70 kW since 2020

Since 10 March 2020 the classification into classes had been dropped and a single threshold applied: inspection was mandatory for air conditioning systems with a nominal power of more than 70 kW, measured per system and not summed across the building. The legal basis was set out in article 6.37 of the Besluit bouwwerken leefomgeving (Bbl), with heating systems in a separate section.

That is the rule that applied until May 2026 — and that you still come across on many websites and in quote templates.

What changed as of 29 May 2026

When implementing EPBD IV, the Netherlands removed the inspection sections instead of tightening them. The Besluit van 21 april 2026 (Stb. 2026, 103) (opent in nieuw tabblad) states literally in article I, part AV:

Paragraaf 6.5.2 en paragraaf 6.5.4 vervallen.

Section 6.5.2 contained the inspection of air conditioning systems (article 6.37), section 6.5.4 that of heating systems (article 6.42). The decree entered into force on 29 May 2026. Both articles have since been marked as lapsed in the consolidated statutory text.

There is therefore no longer any Bbl basis for a periodic EPBD inspection of air conditioning or heating systems, regardless of the power. The 70 kW threshold has not been raised — the obligation that threshold belonged to no longer exists.

What does remain in force

This is the most important nuance, because it's easy to strike out more than you should:

• Inspection of combustion installations remains. Section 6.5.3 of the Bbl has NOT been removed. The SCIOS inspection of combustion installations therefore simply still stands. That is a different track with its own scope.
• The F-gas leak check is entirely separate from this. That follows from the European F-gas Regulation, not from the Bbl, and is unchanged. See F-gas leak checks: how often are they mandatory?.
• Building automation (GACS/BACS) is a separate obligation with its own timeline, and does not disappear along with the inspection obligation.
• Contractual agreements remain in place. If you have agreed a periodic inspection with a customer in a maintenance contract, that agreement still applies — only the legal basis underneath it is gone.

What does this mean for your installation company?

Two things, and they go the opposite direction from most regulatory changes.

Commercially: adjust your quotes and texts. If you offered EPBD air conditioning inspections with "legally mandatory" attached, that has no longer been correct since 29 May 2026. That is not only a factual error but also a misleading statement toward your customer. You can of course keep offering the work itself — as a service that prevents breakdowns and saves energy, not as an obligation.

Administratively: don't let the record-keeping lapse. For installations you already carried out inspections on, the history remains relevant for maintenance advice and for the customer's own file. An installation management module that records inspection data, certificates and expiry dates per installation keeps that together — now as a contractual and commercial agreement instead of a legal obligation.

Disclaimer: this article was updated on 11 August 2026 based on Stb. 2026, 103 and the consolidated text of the Besluit bouwwerken leefomgeving. Regulations can change and the implementation of EPBD IV is in some respects still ongoing. If in doubt about a specific installation, check the current position with RVO or IPLO, or ask for advice.

Further reading

• F-gas leak checks: how often are they mandatory?
• CO inspection: checklist and what needs to be on your work order
• ATP inspection for refrigerated transport: complete checklist 2026