To complete an EIA, you need to identify which type applies to your situation, gather the required documentation, follow the relevant procedural steps, and submit your application within the required timeframe. In the Netherlands, EIA most commonly refers to the Energie-investeringsaftrek (Energy Investment Allowance), a tax scheme that lets entrepreneurs deduct 40% of qualifying energy investment costs from their taxable profit. This article walks through the most important questions surrounding the EIA process, from preparation to submission.
What documents and information do you need to start an EIA?
To start an EIA application in the Netherlands, you need proof that the investment qualifies under the Energy List 2026 (Energielijst 2026), details of the business asset being purchased, the order confirmation or commission date, and your tax registration details. The investment must be unused, and it must meet the specific requirements defined on the Energy List.
Before you submit anything, it helps to have the following in order:
- The specific code from the Energy List that corresponds to your investment
- The date the order was placed, since the 3-month submission window starts from that moment
- The invoice or order confirmation showing the investment value
- Your company’s tax identification details (income tax or corporate tax registration)
- Technical specifications of the asset, particularly if applying under a generic code
If your investment does not appear on the Energy List under a clearly defined code, you can check whether it qualifies under a generic (tailor-made) code. Generic investments must demonstrate substantial energy savings and meet the applicable savings standard. In that case, additional technical documentation showing the energy performance of the investment will be required.
What are the main steps in the EIA process?
The main steps in the EIA process are: verify that your investment qualifies under the Energy List, place the order, report the investment to the Netherlands Enterprise Agency (RVO) within 3 months, and then claim the deduction when filing your tax return. The process is digital from start to finish.
Here is a step-by-step breakdown of how the process typically works:
- Check eligibility: Confirm that your investment appears on the Energy List 2026 under a specific code, or that it qualifies under a generic code based on energy savings performance.
- Place the order: Commission the purchase of the qualifying business asset. This is the moment that starts the clock on your 3-month reporting window.
- Submit your application digitally: Report the investment to RVO within 3 months of placing the order. Applications must be submitted online through the RVO portal.
- Receive confirmation: RVO processes your application and confirms whether the investment qualifies.
- Claim the deduction on your tax return: Deduct 40% of the investment costs from your taxable profit. This deduction applies on top of standard depreciation and can be spread across multiple years if needed.
One important note: if your investment is not yet on the Energy List and you want it included for the following year, you can submit a Leveranciersvoorstel voor Energielijst. For 2026, that proposal must be submitted before 1 September 2026, and the procedure is conducted in Dutch.
How long does an EIA typically take to complete?
The EIA application itself is relatively quick to complete once you have your documentation in order. The key constraint is not the processing time but the 3-month deadline: you must submit your application within 3 months of placing the order. Missing this window means losing eligibility for that investment.
RVO processes applications on a rolling basis, and most straightforward applications are handled within a few weeks. More complex cases, particularly those involving generic codes or investments that require technical review, may take longer. If you are planning a larger capital investment, it is worth initiating the eligibility check before placing the order so that you are ready to submit promptly after commissioning.
The actual tax benefit is realised when you file your annual tax return, which means the financial impact may not be felt until the following financial year, depending on your reporting cycle.
Who is responsible for carrying out an EIA?
The entrepreneur making the qualifying investment is responsible for carrying out the EIA process. This means the business owner or the person with tax liability within the company must submit the application and claim the deduction. The EIA is not available to private individuals, associations, or foundations.
In practice, the responsibility is often shared between the finance or tax team, who handle the submission and tax return, and the sustainability or operations team, who identify qualifying investments and gather the technical documentation. For larger organisations, an external tax adviser may manage the process, but the legal obligation rests with the entrepreneur as the taxpayer.
It is also worth noting that the EIA applies to entrepreneurs who pay income tax or corporate tax in the Netherlands, as well as in Aruba, Curaçao, Sint Maarten, and the BES Islands. If your entity structure does not fit these criteria, you will not qualify regardless of the investment type.
What are the most common reasons an EIA gets rejected or delayed?
The most common reasons an EIA application is rejected or delayed are: missing the 3-month submission deadline, investing in an asset that does not appear on the Energy List or does not qualify under a generic code, the asset having been used previously, or submitting incomplete documentation. Each of these is avoidable with proper preparation.
Here are the pitfalls to watch out for:
- Late submission: The 3-month window runs from the date the order is placed, not from delivery or installation. Many applicants miss this because they wait until the asset is operational.
- Asset not on the Energy List: If the investment does not have a specific code and does not meet the savings standard for a generic code, it will not qualify.
- Previously used assets: The EIA only applies to unused business assets. Second-hand equipment is not eligible.
- Incorrect or missing technical data: Generic code applications require evidence of energy savings performance, and incomplete technical documentation is a frequent cause of delays.
- Wrong entity type: Applications submitted by private individuals, associations, or foundations are automatically ineligible.
If you are unsure whether your investment qualifies, contacting RVO before placing the order is the safest approach. They can advise on eligibility without committing you to a submission.
How does introducing new clean energy technology affect an EIA?
Introducing new clean energy technology can strengthen your EIA position significantly, provided the technology appears on the Energy List or qualifies under a generic code. Investments in innovative energy systems that deliver substantial energy savings are precisely what the EIA scheme is designed to incentivise, and the 2026 budget of €460 million reflects the scale of that ambition.
For industrial companies investing in emerging technologies, such as advanced industrial boiler systems that replace fossil fuel heat generation, the EIA can provide a meaningful financial offset. The 40% deduction on top of standard depreciation reduces the effective upfront cost, which is particularly relevant given that new clean energy systems often carry higher initial investment costs than conventional alternatives.
If a specific clean energy technology is not yet listed on the Energy List, it may still qualify under a generic code if it meets the applicable energy savings standard. Alternatively, suppliers can submit a Leveranciersvoorstel to have the technology added to the following year’s list, with the 2026 deadline set at 1 September. This means that even cutting-edge technologies, which by definition may not yet have a dedicated code, have a formal pathway into the scheme.
For sustainability managers evaluating new industrial heat solutions, understanding how the EIA interacts with the total cost of ownership is an important part of building the internal business case. A 40% deduction on a qualifying investment can shift the financial calculus considerably, particularly when combined with lower energy bills over the asset’s lifetime.
How Iron Fuel Technology can support your EIA strategy
We at RIFT develop and deliver the Iron Fuel Boiler, an industrial heat system designed to replace fossil fuel-fired boilers with a circular, carbon-free alternative. For sustainability managers working through the EIA process, our technology is directly relevant for several reasons:
- High energy efficiency: The Iron Fuel Boiler achieves up to 95% energy efficiency, which supports qualification under energy savings criteria relevant to generic EIA codes.
- Near-zero emissions during combustion: With only 10 kg of CO2 per MWhth (solely from the pilot safety flame) and what RIFT claims are the lowest NOx emissions of any fuel, the environmental profile of the technology aligns with the type of investments the EIA scheme is designed to reward.
- Drop-in compatibility: The Iron Fuel Boiler integrates with existing industrial infrastructure, reducing the complexity and cost of transitioning away from fossil fuels.
- Backed by commercial traction: The first-ever commercial contract for Iron Fuel Technology has been signed with Kingspan Unidek, demonstrating that this is a technology moving from pilot to real-world deployment.
If you are evaluating clean energy investments and want to understand how Iron Fuel Technology fits into your decarbonisation roadmap and financial planning, we would be glad to have that conversation. Get in touch with our team to explore what is possible for your operations.
Frequently Asked Questions
Can I apply for the EIA if I have already placed my order but haven't submitted yet — and the 3-month window is closing soon?
Yes, you can still apply as long as you are within the 3-month window from the order date. Log in to the RVO portal immediately and submit with whatever documentation you have available, then follow up with any supplementary materials if required. Do not wait until your documentation is perfect — a late submission means automatic ineligibility, whereas an incomplete submission can sometimes be resolved through follow-up with RVO.
What is the minimum investment amount required to qualify for the EIA?
For 2026, the minimum investment threshold per business asset is €2,500, and the total qualifying investment in a calendar year must exceed €2,500. There is also an annual cap: the maximum investment amount eligible for the deduction is €136 million per taxpayer per year. For most SMEs and mid-sized industrial companies, the lower threshold is the more relevant figure to keep in mind when evaluating whether smaller ancillary purchases qualify alongside a primary investment.
Can the 40% EIA deduction be combined with other Dutch tax incentives, such as the MIA or VAMIL schemes?
No — the EIA and the MIA (Milieu-investeringsaftrek) cannot be claimed on the same investment. However, if your investment qualifies for both schemes, you can choose whichever provides the greater financial benefit. The VAMIL (Willekeurige afschrijving milieu-investeringen) scheme, which allows accelerated depreciation, can in some cases be combined with the MIA but not with the EIA. Consulting a tax adviser to model the optimal combination for your specific investment is strongly recommended before you decide which scheme to apply under.
What happens if my qualifying investment spans multiple years or is delivered in phases — does the 3-month rule apply to each phase separately?
The 3-month reporting window applies from the moment each order or commission is placed, so phased investments may require multiple separate submissions to RVO. Each phase should be reported individually within 3 months of its respective order date. If you are planning a large capital project delivered in stages, map out the order dates for each phase in advance and set internal reminders to ensure no submission window is missed.
If my investment qualifies under a generic EIA code, what level of technical documentation does RVO typically expect?
For generic (tailor-made) code applications, RVO expects documentation that clearly demonstrates the energy savings performance of the investment relative to a conventional alternative — typically expressed in GJ saved per year or as a percentage improvement against a defined reference technology. This usually includes technical specifications from the manufacturer, independent performance data or test results, and a calculation showing how the investment meets the applicable savings standard. The more clearly and quantifiably you can present the energy savings case, the smoother the review process will be.
Does the EIA apply to leased or financed equipment, or only to assets purchased outright?
The EIA applies to investments made by the entrepreneur who bears the economic risk of the asset, which means it can apply to assets acquired through financial lease arrangements where the lessee effectively owns the asset for tax purposes. Operational lease arrangements, where the lessor retains ownership, generally do not qualify because the investment is made by the leasing company rather than the entrepreneur. If you are financing a qualifying asset, confirm with your tax adviser or leasing provider how the arrangement is classified before assuming EIA eligibility.
How should sustainability managers build the internal business case for a clean energy investment that includes the EIA benefit?
The most effective approach is to model the EIA deduction as a reduction in the effective acquisition cost of the asset rather than as a separate income line. For example, a €1 million qualifying investment with a 40% EIA deduction reduces your taxable profit by €400,000, translating to a direct tax saving based on your applicable corporate or income tax rate. Layer this onto a total cost of ownership model that includes projected energy savings over the asset’s lifetime, and the financial case often becomes significantly stronger than a headline investment figure suggests. Presenting this to internal stakeholders alongside the decarbonisation and compliance benefits typically makes for a compelling combined argument.
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