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Fatturering submeters fall within the scope of the measuring instruments directive

In most cases, a meter that determines what someone has to pay must meet European requirements for measuring instruments. These requirements are set out in Directive 2014/32/EU on measuring instruments, and they apply in particular to electricity meters that convert consumption into a monetary amount. A meter that only displays consumption for information purposes, without being directly linked to billing, generally falls outside these requirements. But as soon as a meter forms the basis for what a guest has to pay — such as in the case of passing on electricity consumption in a holiday home — there is a strong likelihood that the meter in question must meet the legal requirements for measuring instruments.

For those charging guests for electricity, this means in practice that the chosen submetering device must have appropriate certification and markings, as described in the Directive on electricity meters. This is not a question of "can be or cannot be", but a fact that affects equipment selection: a meter without this certification is not inherently suitable for converting consumption into money, nor is it when payment is processed through an app or separate system rather than through a conventional energy supplier.

What does the Directive and RDI say about this

This conclusion is based on Annex V to Measuring Instruments Directive 2014/32/EU, which sets specific requirements for electricity meters used to determine the amount to be paid. The Rijksinspectie Digitale Infrastructuur (RDI) is the supervisory authority in the Netherlands for electricity, gas and heat meters, and describes on its website which meters must meet these requirements and why this is relevant for billing applications. For precise requirements and the current situation, the RDI refers to its own information pages on the subject.