Stricter GACS Rules in 2026: What Changed in the Netherlands

In February we published our BACS Compliance Guide 2026, just after the Dutch obligation took effect and while EU countries were working toward the 29 May deadline to transpose the revised EPBD. That deadline has now passed. The Netherlands met it, and building owners face a stricter and far more detailed set of rules than the one they started the year with.

In Dutch law, BACS is called GACS (gebouwautomatiserings- en controlesysteem), so this follow-up uses that term. It focuses on the Netherlands and covers the requirements that took effect on 29 May 2026 and the practical guidance RVO and IPLO have published since, before looking at the dates still ahead.

Key facts: GACS in the Netherlands in 2026

• Since 1 January 2026, existing non-residential buildings with heating or air conditioning of 290 kW or more must have a GACS (BACS).
• Since 29 May 2026, EPBD IV rules apply: detailed technical requirements, indoor air quality monitoring and new-build rules for major renovations.
• Existing buildings need at least Class C overall and Class B for management and analysis functions under NEN-EN-ISO 52120-1.
• New buildings need at least Class B overall and Class A for management and analysis functions.
• Periodic inspections of heating and air conditioning systems were scrapped on 29 May 2026.
• Automatic lighting control becomes mandatory on 1 January 2028.
• From 1 January 2030, the threshold drops to 70 kW.
• The building owner is responsible, and municipalities or omgevingsdiensten enforce the rules.

What is the GACS obligation in the Netherlands?

Since 1 January 2026, existing non-residential buildings in the Netherlands with heating or air conditioning of 290 kW or more must have a GACS. Our February guide explained why an existing building management system (BMS, or GBS in Dutch) usually falls short: the law asks for continuous energy analysis and benchmarking, not control alone. It also showed why Class C overall is not enough when the energy management functions must reach Class B.

What has changed since then is the level of detail. In February, much of the technical substance still had to be written into Dutch regulation. That work is now done, and municipalities and omgevingsdiensten can use IPLO's Handreiking toezicht en handhaving GACS to set up supervision.

What changed for GACS on 29 May 2026?

On 29 May 2026, the transposition deadline we flagged in February, the Netherlands implemented the first tranche of EPBD IV. For GACS, it brought detailed technical requirements, indoor air quality monitoring, rules for major renovations and the end of periodic heating and air conditioning inspections. The ministerie van Binnenlandse Zaken en Koninkrijksrelaties (BZK) describes the result as a broader and more clearly defined set of GACS requirements for buildings above 290 kW. Several changes stand out.

The technical requirements are now written down. Until May, critics argued that Dutch law never defined clearly what a GACS had to be. The Omgevingsregeling now contains a technical elaboration of the requirements, with separate rules for new and existing buildings and for different building sizes. It also lists exceptions and acceptable alternatives.

Indoor air quality is now part of the system. Article 4.160d of the Bbl, which governs GACS, now requires the system to be able to monitor indoor air quality. BZK adds that both large and mid-size buildings get obligations for monitoring and controlling indoor environmental quality, such as temperature and ventilation. This moves GACS beyond pure energy management toward comfort and health.

Major renovations trigger the new-build rules. When a building undergoes an ingrijpende renovatie (major renovation), the new-build requirements for GACS now apply. Owners planning large refurbishments should factor this into the design stage rather than retrofit later.

Mandatory inspections of heating and air conditioning were scrapped. In February we noted that a compliant BACS could replace mandatory inspections. The Netherlands has now gone further and removed the periodic inspection rules from the Bbl and Omgevingsregeling altogether. The government chose instead to steer on actual energy use, based on a standard approach to building management. In effect, continuous monitoring through automation replaces the occasional site visit.

GACS now counts in the energy performance calculation. From 29 May, NTA 8800:2025 became the method for calculating a building's energy performance. For non-residential buildings, it now takes GACS into account, which means automation can affect a building's energy label.

New homes get their own version. New dwellings must offer more insight into energy use, for example through smart meter data. They must also be prepared for smart control of installations, so residents can later respond to signals from the electricity grid.

Which GACS class do Dutch buildings need?

Existing non-residential buildings in the Netherlands need a GACS of at least Class C overall and Class B for management and analysis functions, as covered in our February guide. Since 29 May 2026, new non-residential buildings face a higher bar: at least Class B overall and Class A for those functions.

The required performance level depends on the building. According to RVO, the Omgevingsregeling scores a system with the NEN-EN-ISO 52120-1 method, on a scale from Class A (very efficient control) to Class D (inefficient). The functions for technical building management and analysis, in chapter 7 of that standard, have a stricter target than the rest of the system.

• Existing non-residential buildings: at least Class C overall, and Class B for management and analysis functions.
• New non-residential buildings (from 29 May 2026): at least Class B overall, and Class A for management and analysis functions.

IPLO words the new-build rule more narrowly. Where the permit was issued after 29 May 2026, the installation functions in table 6 of the standard must reach at least Class B, and the energy analysis function (7.4) at least Class A. Either way, new projects now need analysis capabilities at the top of the scale from day one.

What does RVO say about GACS compliance?

Rijksdienst voor Ondernemend Nederland (RVO) publishes the main public guidance on GACS for Dutch building owners. It sets out four required functions, clarifies which buildings are in scope and confirms that the owner, not the tenant, is responsible. Its content was last checked on 25 September 2026, and it answers several practical questions the law itself leaves open.

The four functions a GACS must have. Our February post described three mandatory functions. RVO now lists four, based on Bbl articles 3.145, 3.146, 4.160d and 4.160e. A compliant system must be able to:

• monitor, log and analyze energy use continuously, and adjust it;
• benchmark the building's energy efficiency, detect efficiency losses in technical systems and tell the facility manager where improvements are possible;
• communicate with connected technical systems and other devices in the building;
• work with other systems that change the building's energy use, such as storage, solar panels and EV chargers.

The fourth is the new one, and it matters more than it first appears. It ties GACS to the wider energy system, and RVO explicitly links it to easing netcongestie (grid congestion).

The brand does not matter. A GACS can be one vendor's complete package or a mix of components from different manufacturers. What counts is that together they deliver the required functions.

Who is in scope, in more detail. Buildings that contain any homes are exempt. Factory halls, workshops and laboratories are included when their climate installation heats or cools spaces where people work. Spaces that people only visit occasionally do not count toward the 290 kW, and neither do spaces kept below 15 °C or only frost-free. For heat pumps, owners use the nominal capacity under EN 14511-4:2013.

Data centers depend on the layout. A closed server room that staff only enter for maintenance does not count. If an office section above 290 kW shares one climate installation with a server room, the capacity is split pro rata. If the data center is really one large open space, the whole building counts.

The owner is responsible, not the tenant. Municipalities and omgevingsdiensten will approach the building owner first. They may look at the lease and at who owns the climate installation to decide where obligations sit.

A Class D score does not automatically force an upgrade to C. RVO stresses that the NEN-EN-ISO 52120 score has no legal status; it is a method, and an equivalent approach such as an assessment by a GACS adviser is allowed. Its example: manual sun shading scores D, but an owner does not have to install automatic shading if they can show the manual setup achieves good control. Measures also have to be technically and financially feasible.

All improvement options must be carried out. The exception is when an exemption in the Omgevingsregeling applies. RVO's suggested process is to inventory which buildings qualify, assess each one with the Checklist technische eisen GACS, record the result in a report and write an improvement plan if the system falls short. The inspector will likely discuss that report during a visit. Note that the checklist file dates from January 2024, before the EPBD IV changes.

Existing systems rarely qualify as they are. RVO is blunt about common setups:

• Building management system (GBS): automates the climate installation but does little to show efficiency or losses; probably does not meet GACS requirements.
• GBS combined with an energy management system (EMS): usually shows simple feedback but rarely analyzes or talks to other brands; small chance of meeting requirements.
• Energy registration and monitoring system (EBS): can meet only a limited number of the requirements.
• EMS with functions comparable to GACS: no extra investment needed, provided the functions are actually used.

For owners comparing suppliers, RVO points to hulpmiddelen from Techniek Nederland and to the EMS-vergelijker of TKI Urban Energy, which lists GACS providers.

Which RVO documents cover GACS?

RVO's GACS guidance is spread across one web page and several PDFs. The most practical document is the seven-page Checklist technische eisen GACS, but it dates from January 2024 and does not yet reflect the EPBD IV changes of May 2026.

• Maatregelenlijst MKB-Energiebesparingslening (August 2026): measures eligible for this loan for small and medium-sized businesses. Using an energieregistratie- en bewakingssysteem (ERBS) or a GACS is listed as measure 21. Current.
• EPBD IV handreiking laadinfrastructuur (June 2026): EV charging requirements under EPBD IV. Not about GACS; no GACS equivalent exists yet.
• Checklist technische eisen GACS, version 3 (January 2024): function-by-function check against NEN-EN-ISO 52120. Predates EPBD IV but is still linked from RVO's GACS page.
• EPBD: eisen aan gebouwen and related EPBD III infographics (2021): overview of EPBD III obligations, including the GACS exemption from inspections. Outdated, because periodic inspections were scrapped on 29 May 2026.

What the checklist checks. The checklist follows table 5 of NEN-EN-ISO 52120 and covers seven groups of functions: heating, domestic hot water, air conditioning, ventilation, lighting, sun shading and technical building management. For each function it lists which control types are not allowed and which are. A heating system with no automatic temperature control fails, for example, while central automatic control passes.

The reporting function is the strictest item. Function 7.4, reporting on energy use and indoor climate, must reach Class B or better. A system that only displays measured values, such as temperatures or meter readings, does not pass. It must at least report trends in measured values and energy use, or analyze them and benchmark the building's energy performance.

It is a quick test, not a full assessment. RVO designed the checklist mainly for inspectors, for cases where no supplier statement or installer assessment is available. It is meant to show whether a system probably complies. A full assessment needs a detailed analysis of the system, and owners may also prove compliance in other ways.

It carries some legacy references. The checklist still refers to the Bouwbesluit and to NEN-EN 15232, which have been replaced by the Bbl and NEN-EN-ISO 52120. It also notes that the standard is only available in English, so its Dutch descriptions are informal translations. It contains no check for indoor air quality monitoring, which became part of the GACS requirements on 29 May 2026.

GACS also appears in RVO's pages on the energiebesparingsplicht. On its page Softwaresystemen voor energiemanagement, RVO links GACS to the erkende maatregel (recognized measure) for an energieregistratie- en bewakingssysteem. Its page Europese Richtlijn energieprestatie van gebouwen EPBD IV confirms that GACS and energy storage now count in the calculation of a building's energy performance.

Until RVO publishes an updated checklist, owners should use version 3 together with the Omgevingsregeling and IPLO's page GACS-verplichting voor bestaande bouw, especially for indoor air quality and new-build requirements. Our BACS Compliance Guide explains the classification levels and includes a step-by-step assessment framework.

What GACS deadlines come after 2026?

After 2026, two GACS dates matter most in the Netherlands. Automatic lighting control becomes mandatory on 1 January 2028, and the GACS threshold drops from 290 kW to 70 kW on 1 January 2030.

From 1 January 2028, an automatic lighting control system becomes mandatory for various existing and new buildings, zoned per area and able to detect occupancy.

The bigger change lands on 1 January 2030, when the Dutch threshold drops from 290 kW to 70 kW. This matches the EPBD IV deadline of 31 December 2029 for buildings above 70 kW. For mid-size buildings this is an entirely new obligation. IPLO estimates that installations from 70 kW are often found in buildings of about 400 to 1,400 m², depending on the energy label. That brings in many smaller offices, schools and shops.

Other parts of EPBD IV follow in later tranches, according to the government's Tijdlijn implementatie EPBD IV. They are not GACS rules, but they raise the stakes. Minimum energy performance requirements for existing non-residential buildings are due to apply from 2030, and owners will lean on automation data to show where they stand.

Are Dutch building owners compliant with GACS?

Many Dutch building owners were not ready when the GACS obligation took effect in January 2026. In January 2025, a VV+ article based on conversations with engineering firms concluded it would be nearly impossible to get all qualifying buildings compliant before the deadline. Many owners were unaware the requirement applied to them at all.

Municipalities are still working out how to respond. In Dordrecht, a council member asked the city in October 2025 how many local buildings fell under the rule and how it would be enforced. The answer confirmed the city was aware of the obligation, but the questions themselves show how new this territory is for local government.

Guidance has partly caught up since June. IPLO's page GACS-verplichting voor bestaande bouw now reflects the May changes and spells out the enforcement tools: a last onder dwangsom (an order subject to a penalty), bestuursdwang (administrative enforcement) or a bestuurlijke boete (administrative fine). RVO published an EPBD IV handreiking in June 2026, but it covers charging infrastructure. For GACS, the RVO web page is still the main reference.

For owners, the practical steps are fairly clear:

1. Inventory the installed heating and cooling capacity per building, adding up all generators.
2. Check any existing GBS against the RVO checklist and note where it falls short.
3. Include indoor air quality monitoring and lighting control in any upgrade plan, since both are now part of the requirements.
4. Flag buildings between 70 and 290 kW now, so 2030 does not become another rushed deadline.
5. Treat any ingrijpende renovatie as a trigger for new-build GACS requirements.

What do the 2026 GACS changes mean for building owners?

For Dutch building owners, the thread running through every GACS change in 2026 is a move away from checking buildings once in a while and toward watching them all the time. Dropping the heating and air conditioning inspections makes that explicit: the law now trusts data from automation more than a periodic site visit.

For owners this raises the bar. A system that simply switches installations on and off is no longer enough; it has to analyze, report and increasingly cover comfort and air quality too. For the Dutch building stock, it also means GACS is becoming a basic tool for decarbonization rather than an optional extra.

If you have not yet checked where your buildings stand, our BACS Compliance Guide walks through the classification levels and a step-by-step assessment. Use it alongside the RVO checklist, keeping in mind that the checklist predates the May changes.

How does the Building Intelligence Center support GACS compliance?

The shift the law now asks for, from occasional checks to continuous monitoring and analysis, is also the idea behind our Building Intelligence Center (BIC). The BIC brings the data from a building's meters and systems into one place, down to the room and the hour. AI agents analyze it continuously, and a Building Performance Expert from Next Sense checks every action before it reaches your team.

A roadmap to compliance. For every connected building, the BIC's quick scan estimates the GACS class and explains what is holding it back. Your Building Performance Expert then confirms the definitive class, maps out what is still needed and advises on installation partners, or works with the ones you already have.

Class B energy reporting. Function 7.4 is where many buildings fall short, because control alone is not enough. In the BIC, teams get monthly and annual trend reports for every building, benchmarks of energy use per m² against similar Dutch offices, and analysis that tracks each improvement from opportunity to verified saving. With the Building Agent, they can ask a question such as why energy use went up last month and get an answer based on their own data.

Automated control. Next Sense can also take on control of heating, cooling, ventilation and blinds through setpoint regulation. That goes beyond the GACS minimum and helps a building reach a higher class, while room-level control and the BIC's comfort widgets cover the indoor climate requirements added in May.

To find out where your buildings stand, book a call or take a look at the Building Intelligence Center.

Frequently asked questions about GACS in the Netherlands

What is a GACS?

A GACS (gebouwautomatiserings- en controlesysteem) is a building automation and control system that continuously monitors, analyzes and adjusts a building's heating, cooling, ventilation and lighting. In EU regulation it is called BACS.

Is BACS the same as GACS?

Yes. BACS (Building Automation and Control System) is the term used in the EU Energy Performance of Buildings Directive. GACS is the term used in Dutch law for the same requirement.

Which buildings need a GACS in the Netherlands?

Since 1 January 2026, non-residential buildings with a heating or air conditioning system of 290 kW or more need a GACS. This includes offices, schools, hotels, shops, factory halls and laboratories. Buildings that contain homes are exempt. From 1 January 2030, the threshold drops to 70 kW.

What changed for GACS on 29 May 2026?

The first tranche of EPBD IV took effect in the Netherlands on 29 May 2026. It added detailed technical requirements in the Omgevingsregeling, made indoor air quality monitoring part of GACS, applied new-build GACS rules to an ingrijpende renovatie and scrapped periodic inspections of heating and air conditioning systems.

Does an existing building management system (BMS) meet the GACS requirements?

Usually not. According to RVO, a gebouwbeheersysteem (GBS) controls the climate installation but probably does not meet the GACS requirements, because it does not analyze efficiency or detect energy losses. A combination of a GBS and an energiemanagementsysteem (EMS) also has only a small chance of meeting them.

Which GACS class is required in the Netherlands?

Existing non-residential buildings need at least Class C overall and Class B for management and analysis functions under NEN-EN-ISO 52120-1. New non-residential buildings need at least Class B overall and Class A for those functions since 29 May 2026.

Who is responsible for GACS compliance: the owner or the tenant?

The building owner. RVO states that municipalities and omgevingsdiensten approach the owner first, and may look at the lease and at who owns the climate installation to decide where obligations sit.

Who enforces the GACS obligation, and what are the penalties?

Municipalities and omgevingsdiensten enforce the GACS obligation. According to IPLO, they can impose a last onder dwangsom, use bestuursdwang or issue a bestuurlijke boete.

Are heating and air conditioning inspections still required?

No. The Netherlands scrapped periodic inspections of heating and air conditioning systems on 29 May 2026. The government now steers on actual energy use, based on a standard approach to building management.

How can I check whether my building complies with GACS?

Start by adding up the nominal heating and cooling capacity of each building. Then assess the system with RVO's Checklist technische eisen GACS, record the result in a report and write an improvement plan if it falls short. Note that the checklist dates from January 2024, before the May 2026 changes. For a fuller walkthrough of the classification levels and an assessment framework, download the Next Sense BACS Compliance Guide.

Sources

• Next Sense: BACS Compliance Guide 2026 (February 2026)
• RVO: Gebouwautomatiserings- en controlesysteem (GACS)
• RVO: Europese Richtlijn energieprestatie van gebouwen EPBD IV
• RVO: Checklist technische eisen GACS, versie 3 (januari 2024)
• RVO: Maatregelenlijst MKB-Energiebesparingslening (augustus 2026)
• RVO: EPBD IV Handreiking eisen laadinfrastructuur (juni 2026)
• RVO: EPBD eisen aan gebouwen (2021)
• RVO: Softwaresystemen voor energiemanagement
• IPLO: GACS-verplichting voor bestaande bouw
• IPLO: Inrichting toezichtproces GACS
• IPLO: Webinar gebouwautomatiserings- en controlesystemen
• Volkshuisvesting Nederland: Technische bouwsystemen en gebouwautomatiseringssystemen (GACS)
• Volkshuisvesting Nederland: Tijdlijn implementatie EPBD IV
• PONT Omgeving / Nieman: Wijzigingen Bbl per 1 juli 2026 en daarna
• Expertisecentrum Verduurzaming Zorg: GACS
• VV+: Reikwijdte en omvang GACS-verplichting nog sterk onderbelicht
• Gemeente Dordrecht: Artikel 40-vragen GACS-verplichting