In short
- The Rbsw applies at the level of the tender, not the organisation. No covered tender, no obligation, however large you are.
- It binds the buyer, not the bidder. A supplier meets it as a specification in the tender documents.
- It is a vehicle quota. It asks nobody to hold a carbon footprint, calculate emissions or report anything.
The Rbsw applies to you if two things are true at once: you are an aanbestedende dienst, a contracting authority, and you are running a tender for vehicles or for a covered transport service. The Regeling bevordering schone wegvoertuigen implements the EU Clean Vehicles Directive 2019/1161 and sets minimum shares of clean vehicles in those tenders. It attaches to the procurement, not to the organisation, so an institution that buys no vehicles is untouched by it no matter how many people it employs. And it binds the buyer. If you are a supplier, it reaches you as a specification somebody else wrote.
What is the Rbsw, in one paragraph?
A Dutch ministerial regulation that puts a floor under how clean a public body's vehicle purchasing has to be. It applies to all aanbestedende diensten and PIANOo names hoger onderwijs explicitly in its scope list, alongside the more obvious central and local government buyers.
Its mechanism is a minimum share. Across a reference period, a stated proportion of the vehicles a contracting authority procures in the covered categories must be clean, and for the current period the definition of clean has tightened. That is the whole design. There is no reporting duty attached for the buyer to discharge, no certificate for the supplier to hold and no emissions figure anywhere in it.
What is the test, stated exactly?
Two questions. Both have to be yes.
Question one. Are you an aanbestedende dienst? If your organisation meets the criteria for a publiekrechtelijke instelling, a body governed by public law, you are one. Most Dutch education institutions qualify on that basis, which is why hoger onderwijs appears in PIANOo's list.
Question two. Is this procurement for vehicles or a covered transport service? The rule reaches tenders for the purchase, rental and lease of vehicles, and certain transport services bought in. If the answer is no for every procurement you run, the Rbsw never engages.
That is the entire test, and note what is not in it. There is no turnover threshold, no headcount, no sector carve-out and no obligation that attaches to the organisation as a standing state. It engages when a covered tender is published and it is quiet the rest of the time.
How do the shares work in the current period?
Reference period two runs from 1 January 2026 to 31 December 2030.
| Vehicle category | Reference period two, from 1 January 2026 | Reference period one, to 31 December 2025 |
|---|---|---|
| Cars and light commercial vehicles | 38.5 percent, and only zero-emission vehicles count toward it | 38.5 percent, with low-emission vehicles also counting |
| Heavy vehicles | 15 percent | 10 percent |
| Buses | 65 percent, of which at least half zero-emission | 45 percent |
The change most likely to catch a buyer out is in the first row. The headline percentage did not move, so a policy note written in 2025 still looks current. What moved underneath it is what counts: from 1 January 2026 a low-emission vehicle no longer contributes to the 38.5 percent share, where in the previous period it did. A procurement plan built on the old definition can hit the same number and still miss.
Does it apply to you if you are the supplier?
Not as an obligation. As a specification you either meet or do not.
The Rbsw imposes its duty on the contracting authority. When that authority runs a covered tender, it manages its share by writing requirements into the documents, which is where the rule surfaces for a bidder. What you are answering is a technical specification about the vehicles you are offering, in the same way you would answer any other requirement about the goods.
Two consequences worth planning around. First, the tightening is a supply question for you before it is a compliance question. A buyer that now needs zero-emission vehicles to count is a buyer whose specification you either can or cannot fill from your fleet or your order book. Second, this is one of the rare cases where the requirement is genuinely fixed rather than at the buyer's discretion, so there is little point negotiating it.
What do you do if you are in?
Treat it as a fleet planning exercise and get it out of the sustainability team's inbox.
The work is knowing what you procure in each covered category over the reference period, and specifying accordingly early enough that lead times do not decide the outcome for you. The period runs to 31 December 2030, which sounds generous and is not, because vehicle procurement in a large institution is lumpy and a single big replacement round can dominate the whole period's arithmetic.
The one thing not to do is convert it into a carbon project. The rule counts vehicles.
What do you do if you are out?
Say so, and check the two rules that are genuinely nearby rather than assuming the absence generalises.
An organisation with no vehicle tender has no Rbsw exposure at all. That does not mean it has no dated Dutch obligation. If it employs 100 or more people in the Netherlands, WPM applies, and that is an annual report to RVO on commuting and business travel kilometres rather than anything to do with buying. And the ordinary duty to tender above the EU threshold values applies to any contracting authority, though it attaches no environmental criterion of any kind.
Is the Rbsw a carbon requirement?
No, and this is the misreading it most often attracts.
It is a vehicle procurement quota. It does not ask a buyer or a bidder to hold a greenhouse gas inventory, to calculate emissions, to report a figure or to be certified against anything. Nobody has to produce a tonne of CO2 under it. Presenting it as a general sustainable procurement obligation for the public sector, or as evidence that Dutch public buyers must apply carbon criteria, gets the instrument wrong in a way that a procurement lawyer will notice.
It is worth knowing precisely because it is the exception. In a Dutch market full of policy that looks binding and is not, the Rbsw is the rule that looks narrow and is.
Where does carbon measurement fit around it, if at all?
Alongside it, for different reasons, and usually driven by customers rather than by law.
A fleet transition changes scope 1 emissions and shows up in an inventory as a genuine reduction, which makes the Rbsw one of the few compliance exercises with a visible carbon benefit attached. If you are building or maintaining an inventory around that, the Hedgehog platform reports 5,000+ users and manages multiple entities and sites, which suits an organisation whose fleet, estate and travel data sit with three different teams. The limitation we would flag first for a fleet-heavy user: a mid-market reviewer on G2 in July 2026 noted that applied conversion factors and distance calculations are not exposed in the interface, so you cannot always trace how an input became an entry. If you expect to defend a fuel or distance figure line by line, ask about that before you commit. For a deeper piece of analysis than an annual inventory, that is carbon footprint consulting work, and our guide to choosing carbon accounting software sets out what to ask any vendor first.
Sources: PIANOo, Regeling bevordering schone wegvoertuigen; Rbsw text, BWBR0045768, consolidated version of 1 January 2026; PIANOo, inkopen door onderwijsinstellingen; RVO on the rapportageverplichting werkgebonden personenmobiliteit; Hedgehog platform; Hedgehog on G2. Verified 28 August 2026.
Facts on this page were last verified on 2026-09-17.
