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Whitepaper 9 min read

EU RfG & Dutch PGMD: A Compliance Guide for New Power Plants

Miss the PGMD submission deadline by a day, and your commissioning date slips by months — costing far more than anyone budgeted for. The EU Requirements for Generators (RfG) framework sounds straightforward on paper, but the Dutch implementation has enough specific thresholds, procedural stages, and documentation layers to catch even experienced project teams off guard. This guide walks you through exactly what you need to know before you plug a new power plant into the Dutch grid.

Why the RfG Exists — and Why You Can't Ignore It

Before 2016, every EU member state essentially wrote its own rules for connecting generators to the grid. If you were developing projects across borders, you were dealing with a patchwork of national codes that rarely spoke to each other. EU Regulation 2016/631 — the Requirements for Generators (RfG) — changed that by establishing a single European network code that harmonises grid connection rules for power-generating modules across all EU member states.

The goal is grid stability. As more distributed generation, renewables, and storage come online, transmission and distribution operators need confidence that every connected asset will behave predictably during faults, frequency deviations, and voltage events. The RfG sets the technical floor for that behaviour.

In the Netherlands, the RfG has been incorporated into the Netcode elektriciteit, which is the domestic regulatory instrument that gives the regulation its legal teeth at a national level. So when your Dutch system operator talks about compliance, they're drawing on both the EU regulation and the Netcode simultaneously.

Watch out: The Netcode elektriciteit doesn't just re-state the RfG — it adapts and extends it with Dutch-specific thresholds and procedures. Always check both documents, not just the EU-level text.

The Four Generator Types: Where Does Your Project Land?

The RfG classifies power-generating modules into four types — A, B, C, and D — based on maximum capacity and the voltage level at the connection point. Getting your classification right from day one determines which compliance pathway you follow, which documents you submit, and how much testing you need to budget for.

Here's how the Dutch thresholds break down under the Netcode elektriciteit:

Picture a 4 MW solar park connecting to a regional distribution network. That's solidly Type B territory, which means a PGMD submission is in your future. Now picture a 65 MW gas peaker plant — that jumps straight to Type D, with TenneT likely involved as the relevant system operator rather than a regional DSO.

The classification drives everything downstream, from documentation to testing obligations to who you're actually talking to on the operator side. Get it wrong early and you'll be backtracking through design decisions that are expensive to unwind.

Type A: The Lighter-Touch Path

For smaller generators in the 0.8 kW to 1 MW range, the compliance procedure is comparatively streamlined. You register the installation data via energieleveren.nl using the RfG installation document. This is the route most rooftop solar, small CHP, and micro-wind installations will take. It's not zero-effort — the data registration still needs to be accurate and complete — but it doesn't involve the full PGMD process.

Types B and C: Enter the PGMD

This is where the compliance workload steps up noticeably. The Power Generating Module Document (PGMD) is the core compliance form for Type B and C installations in the Netherlands, submitted to the relevant system operator. Think of it as the formal record of your installation's technical characteristics, proving that it meets the requirements set out in the RfG and Netcode elektriciteit.

Pro tip: The PGMD must be submitted at least 3 months before your desired commissioning date. This isn't a soft guideline — it's a hard procedural requirement. Build this lead time into your project programme from the very first schedule draft.

What Goes Into a PGMD Submission?

The PGMD is a technical document, not an administrative form you can knock together in an afternoon. It needs to accurately describe your installation's characteristics in a way that the system operator can use to assess grid impact and verify compliance.

A critical point here: inverters and generators must be of a make and type that has been tested and accepted by Dutch grid operators for RfG and Netcode elektriciteit compliance. This means your equipment selection decisions — made months before the PGMD lands on a desk — directly affect whether your submission will pass muster. If you're specifying equipment for a Type B project, verify operator acceptance early, not after you've signed procurement contracts.

The relevant technical standard underpinning the design of your generating plant is EN 50549-1:2019, which specifies technical requirements for generating plants connected in parallel with distribution networks. This standard provides the engineering framework that sits beneath the regulatory requirements — your protection settings, ride-through capabilities, and reactive power behaviour all connect back to it.

Testing Requirements for Larger Type B Installations

For Type B installations of 5 MVA or larger, the compliance process goes a step further. Site tests described in the RfG Compliance Verification Document must be performed. This document is published by Netbeheer Nederland and defines the specific testing and documentation requirements your installation needs to satisfy.

These tests are not optional extras — they're a formal part of demonstrating compliance before you can move to full operational status. Factor testing time and any remediation work into your commissioning plan.

The Three Notification Stages: EON, ION, and FON

Even after the PGMD is submitted and accepted, the compliance process isn't over. The Dutch RfG framework operates through three sequential notification stages that govern how your installation progresses from first energisation to full operational status.

Stage 1 — EON (Energisation Operation Notification)

This is the notification that allows you to energise the installation for the first time. You're connecting to the grid, but you're not yet in commercial operation. Think of it as the point where the physical connection is made and initial electrical tests can begin.

Stage 2 — ION (Initial Operation Notification)

The ION allows the installation to operate initially — but with a maximum duration of 24 months. This window exists to give project teams time to complete any outstanding commissioning activities, address findings from site testing, and work through the documentation needed to achieve final compliance. It's a practical allowance, but 24 months can move faster than expected on complex projects.

Watch out: The 24-month ION window is not an indefinite extension. If you're approaching the limit without a clear path to FON, engage your system operator proactively. Waiting until month 23 is not a strategy.

Stage 3 — FON (Final Operation Notification)

The FON is the end goal — confirmation that your installation is fully compliant and cleared for normal, ongoing operation. Reaching FON means all testing is complete, documentation is accepted, and the system operator is satisfied that your plant meets its obligations under the RfG and Netcode elektriciteit.

These three stages are sequential and non-negotiable. Understanding where you are in the process at any given moment, and what's required to advance to the next stage, is one of the most practical things you can do to keep your project timeline on track.

Common Pitfalls That Delay Commissioning

Based on the structure of the process itself, there are a few patterns worth flagging that consistently cause problems:

Practical Next Steps for Your Project

The RfG and Dutch PGMD process is manageable if you approach it methodically and early. Here's a practical checklist to take away:

  1. Confirm your Type classification (A, B, C, or D) based on maximum capacity and connection voltage — check the Dutch thresholds in the Netcode elektriciteit specifically.
  2. Identify your system operator — for most Type B and C projects this will be a regional DSO; Type D projects may involve TenneT.
  3. Verify equipment acceptance — confirm that your specified inverters and generators are accepted by Dutch operators before finalising procurement.
  4. Map the PGMD submission deadline back from your target commissioning date — minimum 3 months prior, ideally more.
  5. Plan for site testing if your Type B installation is 5 MVA or larger — review the Netbeheer Nederland RfG Compliance Verification Document early.
  6. Track your ION start date and build a realistic programme to reach FON within 24 months.

If you're working across multiple EU markets, the underlying RfG framework is consistent, but every member state has its own national implementation with specific thresholds and procedures. The Dutch approach described here won't map directly onto, say, a Belgian or German project — always verify the local code.

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