Heat pump installer certificate mandatory 2026

A customer asks you to install a heat pump. You know how to do that technically. But do you also have all your paperwork in order? In 2026 there are several certificates that a heat pump installer is required to hold or practically needs — and an inspection by the Inspectie Leefomgeving en Transport (ILT) arrives unannounced. This article sets out what is actually mandatory, what is practically indispensable, and how to set up your records so you get through an inspection without stress.

Why certification for heat pump installers is more complex than for ordinary technicians

A heat pump is not a simple appliance. Air-to-water systems contain refrigerant — in most current models R-32, with a Global Warming Potential (GWP) of 675. A typical split heat pump has a charge of 2 to 6 kg. That looks like little, but: 4 kg R-32 × 675 GWP = 2,700 kg CO₂ equivalent — already more than half of the legal threshold of 5,000 kg (5 tonnes CO₂-eq). At 7 kg (still a normal charge) you're already at 4,725 kg, just under that limit — and with a higher-GWP refrigerant such as R-410A (GWP 2,088), the threshold is reached at around 2.4 kg.

In addition, some heat pumps operate at slightly higher pressures than a classic split air conditioner, and the installation environment (boiler room, outdoor placement, crawl space) requires its own safety protocols. The result: three different certification frameworks overlap, and anyone who thinks a BRL 200 card "covers everything" can be in for surprises at an ILT inspection.

The legally mandatory foundation: F-gas certificates

### Personal certificate — BRL 200 (EU 2024/2215)

This is the hard core: every technician who works on a heat pump with F-gases must hold a valid personal certificate under Implementing Regulation (EU) 2024/2215 — since 29 March 2026 the successor to EU 2015/2067. In the Netherlands this is implemented via the Assessment Guideline 200 (BRL 200), issued by certifying bodies such as Kiwa or Normec.

Since 29 March 2026, BRL 200 has used the new A1/A2/B/C/D/E scheme, replacing the old four categories I/II/III/IV — existing old-scheme certificates remain valid until their own expiry date, with a hard cutoff of 12 March 2029 at the latest. For heat pump installers two categories are relevant:

• Category I / A1: all operations on all installations, regardless of refrigerant charge. Required for commercial heat pumps and larger systems.
• Category II / A2: all operations except leak checking, limited to installations with a charge of <3 kg (or <6 kg for hermetically sealed, labelled systems). This covers most residential heat pumps (a charge of 2–6 kg therefore sometimes already sits just above the A2 limit).

A technician who only mounts a heat pump without any refrigerant operations (pre-charged system, plug-and-play) can argue that he doesn't need a BRL 200 for that specific moment. But for every first top-up, leak check or removal, the certificate is indispensable. Check per installation whether the charge falls within the Category II/A2 limit — if not, Category I/A1 is needed.

Validity: valid indefinitely until 2026; the EU revision introduces a period of validity of 7 years with mandatory recertification, phased in between 2026 and 2029. No renewal = no authorisation. Koldwerk sends reminders 90, 60, 30 and 7 days before the expiry date — but that changes nothing about the legal obligation itself.

### F-gas company certificate (EU 517/2014 / EU 2024/573)

Besides the individual technician's personal certificate, the company needs its own certificate: the F-gas company certificate. This is regulated via the F-gas Regulation (the new version, EU 2024/573, has applied since 11 March 2024) and implemented in the Netherlands via STEK (Stichting Emissiepreventie Koudetechniek).

What does it involve?

• Your company is registered and certified for working with F-gases.
• You can demonstrate that your employees hold the correct BRL 200 certificates.
• You have calibrated tools: leak detector, gauge set, vacuum pump, recovery equipment — calibrated no more than 12 months ago.
• You keep watertight refrigerant administration per cylinder, per installation, per change.

Without this company certificate you are legally not allowed to touch F-gases. That also applies to heat pumps with R-32, R-410A or R-454B. You can read more about exactly what STEK involves in the article STEK quality mark: what it is and how you keep it.

### Logbook obligation for installations above 5 tonnes CO₂ equivalent

If the heat pump is larger — or you have multiple heat pumps at one location — the CO₂-eq thresholds quickly come into play:

• ≥ 5,000 kg CO₂-eq (5 tonnes): annual leak check mandatory, keeping a logbook mandatory.
• ≥ 50,000 kg CO₂-eq (50 tonnes): leak check every six months.

Concrete worked example: a heat pump with 7 kg of R-32 (GWP 675) has a CO₂-eq of 7 × 675 = 4,725 kg. Just under the 5-tonne threshold. But if you use R-410A (GWP 2,088)? Then with the same 7 kg you're already at 14,616 kg CO₂-eq — well above the threshold. Use the logbook-obligation check to check per installation what applies. The GWP values per refrigerant are in the GWP table.

Practically indispensable: BRL 100 process certificate

Legally speaking, BRL 100 is not mandatory — but in 2026 practice it has become a hard requirement for a large proportion of clients. Municipalities, housing associations, owners' associations and project developers are increasingly prescribing BRL 100 in tenders and maintenance contracts for heat pumps.

BRL 100 is the process certificate for installation and maintenance companies, issued by one of six authorised certifying bodies (InstallQ is not among them — see What is BRL 100, and why does it affect your work order?). The certificate doesn't just test whether you are professionally competent, but whether you can also demonstrate that: structured record-keeping per installation, work orders with both signatures, traceability of refrigerant changes, and records that are kept for at least 5 years.

Anyone holding BRL 100 proves to clients that they are ready for the annual audit of their refrigerant administration. For heat pump companies that want to grow into subsidy-bound contracts (Nationaal Isolatieprogramma, SEEH, Warmtefonds projects), BRL 100 is the entry ticket. See also What is BRL 100, and why does it affect your work order? for the full explanation.

VCA: when does it apply?

VCA (Safety Checklist Contractors) is a safety quality mark for companies that work on site for clients. There are two levels:

• **VCA Basis (VCA*)**: for companies that second or post out operational employees. Requires its own safety exam per employee and a company inspection.
• VCA VOL (VCA)**: for companies that also have executive and supervisory roles in the safety chain. Mandatory for larger projects and government tenders.

For heat pump installers this applies: VCA is not a legal requirement for standard residential work. But does your company work at industrial sites, in utility construction, or on projects where you act as a subcontractor for larger parties? Then those main contractors typically require VCA as a tender requirement. In the certificates module of Koldwerk you can register and track VCA Basis and VCA VOL per technician.

What are the consequences of working without a valid certificate?

This is not a theoretical risk. The Inspectie Leefomgeving en Transport (ILT) carries out targeted inspections in the installation sector, including at heat pump companies. The fines are categorised:

• Working without a BRL 200 personal certificate: administrative fine, amount depending on repeat offences and scale. For companies this can run up to several thousand euros per offence.
• Company without an F-gas company certificate: a serious offence. The ILT can halt operations, reports the offence to the Autoriteit Consument en Markt, and can impose an order subject to a penalty payment for repeat offences.
• No logbook for an installation subject to the logbook obligation: violation of the F-gas Regulation. Besides the fine, STEK recognition can be put at risk.

Outside the ILT route: if an installation leaks and the installer did not have a valid certificate, the client can pursue liability. Insurers as a rule do not cover damage caused by uncertified work.

Overview: certificates for heat pump installers in 2026

| Certificate | Type | Mandatory? | Valid for | |---|---|---|---| | BRL 200 Category A1 or A2 | Personal certificate | Yes, legally | Technician who touches F-gases | | F-gas company certificate (STEK) | Company certificate | Yes, legally | Every company that handles F-gases | | BRL 100 | Process certificate | No (often required in practice) | Installation + maintenance of heat pumps/refrigeration | | VCA Basis or VOL | Safety certificate | No (requirements per client) | Work at companies / projects | | Logbook (not a certificate, but an obligation) | Records | Yes, at ≥ 5 tonnes CO₂-eq | Per installation above the threshold |

Practical tips for your certificate administration

1. Register expiry dates per technician in a system. An expired BRL 200 means a work order is no longer valid for F-gas operations. The technicians module in Koldwerk shows per technician which certificates they hold, when they expire, and whether action is needed. Automatic reminders prevent you from missing this.

2. Keep a calibration log of your measuring equipment. STEK and BRL 100 auditors check whether your leak detector, gauge set and scales were calibrated no more than 12 months ago. Attach the calibration reports to the tool profile — that way you're not rummaging through a drawer when the auditor asks.

3. Make sure every refrigerant change is traceable to a work order. A BRL 200-certified technician who tops up refrigerant but doesn't link the change to an installation and a work order effectively makes his own certificate worthless at an audit. The refrigerant module enforces this link on every change.

4. Schedule re-assessments at least 3 months before expiry. Popular assessment dates (April and October) fill up. A technician who wants to schedule their re-assessment in the last week before the expiry date risks not finding a spot — and is then temporarily without authorisation. This is regularly a practical problem, one that can be prevented with an alert early enough.

5. Check the scope of your company certificate. The F-gas company certificate states which activities you are certified for (installation, maintenance, leak checking, recovery). Some companies that traditionally only did air conditioning had a limited scope — and find, when switching to heat pumps, that they need to extend their scope. Check this with STEK or your certifying body.

Certificates and the new F-gas Regulation EU 2024/573

The new European F-gas Regulation (EU 2024/573) has applied since 11 March 2024, as the successor to EU 517/2014. For certificates little changes in the short term — the BRL 200 categories and the company-certificate structure remain in place. What does change:

• New split heat pumps up to 12 kW must have a refrigerant with a GWP below 150 from 2027. R-32 (GWP 675) falls outside that. That means a shift towards R-290 (propane, GWP 3) or other low-GWP alternatives will take place over the coming years.
• R-290 (propane) is class A3: flammable and explosive at certain concentrations. Working with A3 refrigerants places additional requirements on training and tools — this falls outside the standard BRL 200 scope and requires specific further training.
• The BRL 200 re-assessment from 2026 includes additional modules on A2L refrigerants (such as R-32 and R-454B). Technicians who already have a BRL 200 don't need to certify again — but the content of the re-assessment has been tightened.

More on what EU 2024/573 concretely means for installers: New F-gas Regulation: what's changing for you?.

Conclusion: start with what's legally required, then build on it

The order is clear:

1. First make sure the legal foundation is right. Everyone who touches refrigerant has a valid BRL 200 personal certificate. The company has a valid F-gas company certificate (STEK). This is not negotiable.

2. Add BRL 100 if you seriously want to grow. Clients in subsidy-bound projects, housing associations and municipalities set this as a requirement. The process requires preparation but is achievable for any company with its administration in order.

3. Set up your administration so that certificates and installations are always up to date. An expired certificate or an unrecorded change costs you more than preventing it. With Koldwerk's certificates module and refrigerant module this is tracked automatically — create an account via /aanmelden.

Disclaimer: this article is an informative summary based on EU Regulations 2015/2067 and 2024/573, the BRL 200 assessment guideline and the BRL 100 guideline. The official texts are always leading. Consult Kiwa (opent in nieuw tabblad), STEK (opent in nieuw tabblad) or the ILT (opent in nieuw tabblad) for current requirements and fine categories.