Energy Act
The Energy Act and the related secondary legislation (the Energy Decree and the Energy Regulation) largely entered into force on 1 January 2026. In addition, several amendments to the Energy Act are currently being prepared. These amendments are required to implement new European Union directives, including provisions on energy sharing under the Electricity Market Design Directive (EMD), the injection of biomethane, and the organisation of the hydrogen market as part of the EU decarbonisation package.
Adapting the codes
To promote the flexible use of the electricity grid, ACM amended several codes in 2025. The regulator has set conditions for the use of the Realtime Interface (RTI), which enables grid operators to manage the capacity of generation and storage facilities connected to the grid. We will install RTI at several companies to help prevent grid overload.
The ACM has also developed a new code for social prioritisation, following the court’s annulment of the previous prioritisation framework. The three existing categories (‘congestion mitigation’, ‘safety’, and ‘basic needs’) remain in place, but additional social functions have been added. These include, among others, the telecommunications, road safety, public transport, waste management, and collective housing sectors. At present, grid operators maintain waiting lists only for high-volume consumers and continue to connect low-volume consumers. From 1 July 2026, this will change, as the prioritisation framework will also apply to low-volume consumers.
In addition, the ACM has published decisions that enable the use of group transmission agreements and capacity control contracts. Finally, the ACM has amended the codes to ensure that the Contracted Transmission Capacity of high-volume consumers in congested areas no longer automatically increases upon an exceedance.
Municipal Instruments Heat Transaction Act
The Municipal Instruments for Heat Transition Act (Wet gemeentelijke instrumenten warmtetransitie, Wgiw) is likely to take effect on 1 July rather than 1 January 2026, to give municipalities more time to adopt their first heat programme by 31 December 2027 at the latest. This law provides municipalities with additional tools to transition to natural-gas-free neighbourhoods by 2050. To achieve this, they will adopt a neighbourhood-based approach to implementing affordable and sustainable alternatives to natural gas in each neighbourhood. The act also stipulates that the obligation to connect to natural gas may be waived.
Collective Heat Supply Act
In December 2025, the House of Representatives approved the Collective Heat Supply Act (Wet collectieve warmtevoorziening, Wcw). The act aims to promote the heat transition while better safeguarding the public interest in terms of sustainability, security of supply, and affordability. The Wcw regulates the transition to a more transparent cost system for heat, providing greater clarity on how costs are structured and passed on to customers. Additionally, the Act ensures that heat networks are transferred to public ownership. This will enable grid operators to take on a role. We are preparing for this transition. The entire Act is expected to come into force on 1 January 2027, but a limited number of articles (including amendments to the permitted ancillary activities in the Energy Act, which provide infrastructure companies with more opportunities in the heating market) will take effect earlier.
Procurement law
The energy transition requires a lot of materials and services. This means that we must purchase on a large scale. The basic principle remains that Enexis complies with the applicable laws and regulations, including procurement law. In practice, there may be a limited number of situations in which there is tension between strict compliance with the law and the desire to accelerate the energy transition. In such cases, we make carefully considered choices, taking various perspectives into account.