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Billing submeter falls within the scope of the Measuring Instruments Directive

In most cases, a meter that determines how much someone has to pay must comply with European requirements for measuring instruments. These requirements are set out in the Measuring Instruments Directive (2014/32/EU) and apply specifically to electricity meters that convert consumption into monetary amounts. A meter that merely shows consumption information for informational purposes, without being directly linked to a bill, generally does not fall within the scope of these requirements. However, as soon as a meter forms the basis for how much a guest has to pay — for example, by converting electricity used in a holiday home to an amount due — there is a strong likelihood that this meter must comply with the legal requirements for measuring instruments.

For those billing guests for electricity, in practice this means that the chosen submeter must be equipped with the correct certification and markings, as described in the electricity meter directive. This is not a question of whether "you can or cannot" — it is a given circumstance that must be taken into account when selecting equipment: a meter without this certification is not automatically suitable for converting consumption into money, even if payment takes place via an app or separate system, rather than through a conventional energy supply company.

What the directive and RDI say about this

This conclusion derives from the Measuring Instruments Directive (2014/32/EU) Annex V, which sets out specific requirements for electricity meters used to determine amounts payable. In the Netherlands, the Rijksinspectie Digitale Infrastructuur (RDI) is the supervisory authority for electricity, gas and heat meters, and describes on its website which meters must comply with these requirements and why this is important for billing applications. For precise requirements and current information, the RDI points to its information pages on this subject.