Netherlands · Policy assessment 16 Sep 2026 · Bill 36.947 · Before the Tweede Kamer

Netherlands’ green-gas obligation: the proposed market, pending amendments and investment implications

The Netherlands’ proposed green-gas obligation would create a market for certified lifecycle emissions savings—not impose a fixed physical biomethane percentage at consumers’ meters. Gas suppliers would meet annual obligations through tradable certificates or a government-priced buy-out.

The proposed trajectory reaches 2.85 million tonnes of CO₂-equivalent savings annually from 2031, with green-gas volumes depending on the emissions performance of the supply used. The central policy question is whether this demand obligation will finance additional production—or primarily increase the value of existing supply—while keeping costs acceptable for gas consumers.

2.85MtCO₂e

Certified lifecycle savings each year from 2031, held flat through 2035.

840mln m³

Estimate only. Not a production quota, and not a guarantee of Dutch supply.

€450/tCO₂e

€0.45 per GGE. An authorised alternative to certificates, not a fine.

Bill 36.947 remains before the Tweede Kamer and has not been adopted. Following the first legislative committee discussion on 7 September, the second round is scheduled for 21 September. The government’s intended 1 January 2027 launch remains conditional on parliamentary approval and completion of the implementing rules.
One groengaseenheid (GGE) represents one kilogram of certified lifecycle CO₂-equivalent reduction, so equal energy volumes can earn different quantities of certificates. Two approval tracks must converge: the amendments and bill in both chambers, and the implementing decree and ministerial regulation with their EU standstill period. Suppliers could buy out up to 100% of their obligation. The price constrains what they will pay for GGEs but sets neither a minimum certificate price nor a guaranteed producer revenue. Eligible EU production may compete for the obligation after the European Commission objected to a Dutch-only restriction. A functioning certificate market does not automatically create a financeable construction pipeline.

Bill 36.947 would amend the Environmental Management Act and Economic Offences Act, creating a new Title 9.9 covering supplier obligations, the certificate registry, supervision and enforcement. The numerical targets and detailed operating rules sit below the Act: the draft implementing decree, or AMvB, sets the annual trajectory and banking arrangements; the draft ministerial regulation sets buy-out prices and detailed certification and registry requirements. Both implementing instruments completed public consultation during July–August 2026.

The obligation would cover suppliers serving network-connected gas consumption within the Dutch ETS2 sectoral scope, including households, commercial buildings, smaller industry, horticulture and CNG filling stations. It is not a blanket obligation across all Dutch gas consumption, particularly consumption already within ETS1. Liability would rest with suppliers, not directly with consumers or biomethane producers.

Compliance would be measured in carbon savings

1 GGE = 1 kg certified lifecycle CO₂e reduction
fossil comparator = 80 gCO₂e/MJ
2027 buy-out = €450/tCO₂e = €0.45 per GGE

Eligible suppliers would book qualifying renewable-gas deliveries into the Netherlands Emissions Authority’s register, receive GGEs and trade or surrender them. Each supplier’s obligation would reflect its share of covered gas deliveries. Manure-digestion pathways can receive particularly favourable treatment where the applicable methodology recognises avoided methane emissions. The incentive rewards certified abatement across the supply chain, rather than gas volume alone.

Proposed annual trajectory

Hover or tap a delivery year. Figures are annual, not cumulative.

{{ metricAxis }}
{{ metricFootnote }}
Savings, MtCO₂e {{ activeRow.mt }}
Volume, mln m³ {{ activeRow.vol }}
Buy-out, €/tCO₂e {{ activeRow.price }}

{{ activeRow.note }}

Delivery year Savings, MtCO₂e Volume, mln m³ Buy-out, €/tCO₂e
{{ row.year }} {{ row.mt }} {{ row.vol }} {{ row.price }}

THESE ARE PROPOSED ANNUAL—NOT CUMULATIVE—FIGURES. THE BUY-OUT SCHEDULE INCORPORATES APPROXIMATELY 2% ANNUAL INDEXATION.

The 840 million m³ estimate depends on the assumed feedstock and emissions-performance mix, and does not guarantee that this volume will be supplied or produced additionally in the Netherlands.

Qualifying gas would require both a guarantee of origin and a corresponding proof of sustainability, supported by the relevant supply-chain accounting. An unrelated origin certificate would not establish compliance eligibility.

Eligible production from other EU countries would be permitted; the government removed an earlier Dutch-only restriction following European Commission objections concerning free movement of goods. Dutch projects would therefore compete with eligible imports, rather than receive an exclusive domestic market.

Eligible producers could switch monthly between SDE++ operating support and the quota route. The same output cannot receive both forms of support, although qualifying investment assistance can remain compatible. Nor can the same batch generate both GGEs and transport-fuel compliance units.

The buy-out limits compliance costs—not investment risk

Suppliers could buy out up to 100% of their obligation. The proposed 2027 price is €450/tCO₂e, equivalent to €0.45 per GGE. This is an authorised alternative to surrendering certificates, not a non-compliance fine. The buy-out should constrain suppliers’ willingness to pay for GGEs, but it provides neither a minimum certificate price nor a guaranteed producer revenue. Receipts would enter the Treasury; payment would not itself purchase replacement green gas or represent delivered emissions savings. Legal compliance could consequently fall short of the policy’s intended physical and climate outcomes.

Suppliers could bank surplus GGEs up to 10% of their annual obligation, but not in a year when they use the buy-out. Excess units would expire. Settlement follows the delivery year: obligations arising from 2027 deliveries would be settled on 1 August 2028.

The current package is less ambitious than the earlier 1.6 bcm quota proposal. The government reduced the intended requirement in response to concerns over achievable supply, feedstock availability and consumer costs, moving to the present carbon-based target and indicative 0.84 bcm volume for 2031.

The MPs’ amendments address four fundamental choices: when the obligation starts, who pays, which supply qualifies and how strongly future demand is protected. None has yet been adopted. Amendment no. 15 replaces no. 13, while no. 18 replaces no. 16.

Filter by choice
{{ a.no }}
{{ a.kind }}
{{ a.title }} {{ a.sponsor }}
{{ a.theme }}

{{ a.text }}

{{ a.source }} →

Two drafting issues remain material

The buy-out brake is not yet an unambiguously defined market-wide trigger. No. 11 refers in its operative wording to more than 10% of a supplier’s annual obligation being bought out, while its explanation discusses a market-wide shortage signal. The final text should clarify how individual supplier outcomes would trigger a change in the national trajectory. The targeted-sector amendment needs its legal scope reconciled with its stated purpose. No. 19’s operative wording refers to electricity-generation installations and CNG filling stations, alongside ceramics and iron/steel. It does not expressly reproduce the explanation’s limitation to peak electricity and district-heating provision. The explanatory ambition should therefore not be reported as an already precise legal sector definition.

The bill was introduced in May 2026, followed by June technical and stakeholder hearings, written scrutiny in July, and the government’s response and revised text on 3 September. The legislative committee debate began on 7 September and is scheduled to continue on 21 September.

Timeline to a conditional 1 January 2027 launch
{{ t.date }}
{{ t.title }}

{{ t.text }}

Parliamentary passage remains outstanding. The Tweede Kamer must decide on the amendments and bill. An approved text then goes to the Eerste Kamer, which may accept or reject it but cannot directly amend it. Enactment, publication and the applicable commencement arrangements follow.

The implementing rules have a separate timetable. In its 3 September reply, the government reported that notification of the framework bill under the EU technical-regulations procedure had concluded, while notification of the lower rules was imminent. Those rules face a three-month standstill. A detailed opinion from the Commission or another member state would extend that period by three months and, according to the government, prevent a January 2027 launch. Ordinary questions would not automatically extend it.

Completion of the decree’s advisory and adoption process is also necessary. Lower-house approval alone would therefore not secure a 2027 start, while adoption of amendment no. 10 would independently rule it out.

September budget update: compensation is separate from quota adoption

Since the original draft, the 15 September budget package has proposed a temporary reduction in horticulture’s reduced energy-tax rates in 2027, intended to compensate for the green-gas obligation’s additional costs. This is a fiscal proposal alongside the quota—not an exemption under Bill 36.947 or evidence that the obligation has been enacted.

The disagreement cuts across the value chain. Infrastructure operators favour durable demand, producers question whether certificate revenues will finance new plants, and consumer-facing organisations challenge the allocation of costs.

{{ s.name }}

{{ s.text }}

{{ s.source }} →
These positions expose the main divide: whether investment is best supported by a broad compliance market or by more targeted, contracted support.

The latter could offer greater price certainty, but requires explicit choices on funding, eligible applications and allocation of risk.

The quota could be met through new installations, greater utilisation of existing plants, imports or redirection from other support markets. These outcomes are not equivalent for Dutch industrial development. VGGP’s warning is therefore significant: a functioning certificate market does not automatically create a financeable construction pipeline. For developers, the decisive questions remain the duration and pricing of offtake contracts, feedstock security and project deliverability. A statutory price ceiling cannot substitute for contracted revenue. Conversely, combining a delayed start, a nominal buy-out cap and an automatic growth brake would protect consumers while making future demand less predictable. Lifecycle-based credits can favour stronger emissions performance, but the 2.85 MtCO₂e target should not be treated as an equivalent reduction in the Dutch territorial emissions inventory. The location and nature of the credited savings matter. The Council of State questioned cross-border verification and the Union Database’s readiness when it reviewed the proposal. The government’s response relies on certification, traceability and cooperation between supervisory authorities. The practical test is whether those arrangements can substantiate the savings for which suppliers and consumers pay. The government’s €450/t buy-out scenario illustrates additional costs of approximately 1.5 euro cents/m³ in 2027 and 9 cents/m³ in 2031, excluding VAT. These are modelled figures—not statutory retail-price caps—and should not be confused with the draft’s indexed buy-out schedule.
{{ c.year }} · {{ c.perYear }} per 1,000 m³ {{ c.cents }}

EURO CENTS PER CUBIC METRE, EXCLUDING VAT. TRACK MAX 10 CENTS.

ACM has stated that suppliers cannot increase agreed fixed supply prices merely because the obligation enters into force. Suppliers may therefore face compliance costs before they can reflect them in new retail contracts.

There is a further distributional effect: with an absolute national target, falling covered gas demand—or exemptions that leave the target unchanged—increases the certificate requirement per remaining cubic metre. Relief for one group can shift costs onto another unless the trajectory or funding arrangements also change.

Policy judgement Conditionally positive

A credible mechanism for creating renewable-gas demand — not yet a guaranteed investment case.

The proposal offers a credible mechanism for creating renewable-gas demand and rewarding lifecycle savings. Its effectiveness will depend on whether that demand becomes additional, verifiable supply supported by durable investment, rather than predominantly higher certificate prices or buy-out payments.

Parliament should therefore assess the amendments together. Changes to coverage, price limits and commencement alter the market’s scale and investment value; they are not independent consumer-protection adjustments.

The appropriate success measures are additional output, commissioned capacity, verified emissions savings and costs borne by consumers—not simply GGEs surrendered. Bill 36.947 could establish a valuable biomethane market, but its final design must connect compliance demand with the conditions needed to build and operate new production.

{{ m.label }}

{{ m.text }}

Sources