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Green Deal Duurzame Zorg deadlines: dates in a document that cannot be enforced

The deal expired 31 October 2026, not 31 December. Every date in it, including the deal itself, was already behind us before it was ever enforceable. The Green Deal expired on 31 October 2026.

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In short

  • The Green Deal expired on 31 October 2026. By the time this page publishes, that date and every other dated commitment in the text are already behind us.
  • The expiry date is widely misquoted as 31 December. Article 16a says 31 October, twelve days before this page's own publish date.
  • None of these dates is enforceable. Article 14a rules that out, so they are commitments a sector made to itself.

The Green Deal Duurzame Zorg expired on 31 October 2026, and it is routinely misquoted as having run to the end of December. Every other dated commitment in the text passed well before that: mapping staff travel from 2023, a board-adopted portefeuilleroutekaart by 1 July 2023, a reporting guideline developed during 2023. And none of these dates was ever enforceable, because article 14a says the parties agreed the commitments cannot be enforced in court. This was always a calendar of intentions, not of obligations, and now it is a closed one.

The instrument is the Green Deal Samen werken aan duurzame zorg, reference C-238, signed in The Hague on 4 November 2022. Here is the full calendar and what each row is actually worth.

What is the complete calendar?

DateWhat the text saysWhere
4 November 2022The deal is signed in The Hague. It enters into force the day after signature by the first partiesSigning announcement
From 2023Care providers with more than 100 staff map the CO2 of employee travel movements and draw up a mobiliteitsplanArticle 4.2.e
During 2023Parties develop a format or guideline to help care providers meet forthcoming European reporting obligationsArticle 3.h
1 July 2023Every care provider is to have a board-adopted portefeuilleroutekaart for its real estate portfolioArticle 4.2.b
End of 2026Horizon for the sector-level ambition of an average 30 percent CO2 reduction for real estate and energy against 2018Article 4.2.a
31 October 2026The Green Deal expired. "Loopt tot en met 31 oktober 2026"Article 16a
2030Sector-level ambition of 55 percent less direct CO2 against 2018Article 4.1
2050Sector-level ambition of climate neutralityArticle 4.1

Two of those rows are dates in the ordinary sense, meaning a thing was to be done by then: 1 July 2023 and the start of travel mapping in 2023. The rest are either the life of the document or long-range sector ambitions.

When did it actually expire, and why is the date still worth getting right?

Because plenty of documents drafted while the deal was still running got it wrong, and those documents are still being read.

The Green Deal's own expiry was 31 October 2026. Article 16a puts it plainly, "loopt tot en met 31 oktober 2026", ran up to and including 31 October 2026.

It is commonly described as running to the end of 2026, and the deal is usually summarised as covering 2023 to 2026, which invites people to assume 31 December. Two months of difference does not sound like much until a programme plan, a board commitment or a supplier communication is dated against the wrong one.

The end-of-2026 horizon in article 4.2.a is a separate thing and it is easy to conflate with expiry. That row is the target date for a sector-level ambition of an average 30 percent CO2 reduction for real estate and energy against 2018, monitored through portefeuilleroutekaarten by the Expertisecentrum Verduurzaming Zorg. It is a measurement horizon, not the life of the agreement, and it belongs to the sector rather than to any organisation.

Which dates have already passed?

Three, and they are the ones people still describe as upcoming.

From 2023, staff travel mapping. Article 4.2.e asks care providers with more than 100 staff to map the CO2 emissions of their employees' travel movements from 2023 and draw up a mobiliteitsplan, a mobility plan, with goals and measures. This is not a future commitment for anyone. It began three years before this article was written.

1 July 2023, portefeuilleroutekaart. Article 4.2.b set that date for every care provider to have a board-adopted real estate portfolio roadmap. It is the hardest date in the document and it is well behind us.

During 2023, the reporting guideline. Article 3.h asks the parties to develop a format or guideline in 2023 to help care providers meet forthcoming European reporting obligations on sustainable care. That is a task for the parties collectively, not for an individual signatory.

If a consultant or a supplier deck presents any of these as a deadline you need to prepare for, it is describing 2023.

What happens if you missed one?

Nothing happens, and that is not a rhetorical answer.

Article 14a: "Partijen komen overeen dat de nakoming van de afspraken van de Green Deal niet in rechte afdwingbaar is." The parties agreed that performance of the commitments is not enforceable at law. There are no sanctions in the text. Any party may withdraw at any time on three months' notice under article 13a. Progress is followed by a Regiegroep, a steering group, through a monitor under article 9, rather than by a regulator.

So a care provider without a portefeuilleroutekaart in July 2023 was not in breach of anything justiciable. It had simply not done a thing it said it would do, which is a governance and reputation question rather than a legal one.

That is worth stating precisely rather than sneering at. Sector covenants work through visibility and peer pressure. What they do not do is create dates you can be penalised against, and pretending otherwise leads organisations to spend compliance money on an ambition and ambition money on nothing.

Which dated obligation should be in your calendar instead?

The statutory one underneath, which the Green Deal itself points at.

WPM, the Dutch reporting duty on work-related personal mobility, binds employers with 100 or more employees whether or not they ever signed the covenant, and the deal's own footnote 39 under article 4.2.e ties the staff travel commitment back to it. For most signatories the Green Deal commitment on mobility is therefore discharged by doing something the law already requires.

That is the date to put in a calendar. A covenant commitment with no enforcement and a statutory filing with a fixed annual deadline should not carry equal weight in a planning conversation, and today they often do.

For a supplier, the equivalent calendar item is not Dutch at all. NHS Evergreen in the United Kingdom is a procurement requirement with a date attached, and our summary of what NHS suppliers must provide from April 2027 sets out what a hard deadline in this space looks like. Where the Dutch questions arriving from care customers exceed what a buyer can reasonably require, the value chain cap on ESG questions is the boundary to hold.

What should you assume about a successor?

Nothing, and this is the point where most planning goes wrong.

As of 28 August 2026 no successor deal had been signed or published. A congress was scheduled for 9 October 2026, and Green Deal parties had written an open letter to ministers on 23 June 2026 asking for government backing for a follow-up, which is a negotiating position rather than an agreement. Names circulating in secondary reporting for a successor are unverified and are not cited here.

The safe planning assumption is that the commercial pressure continues and the document does not. Several hundred care organisations, roughly 650 signatories by December 2025 on the programme site's own count, have built sustainability expectations into how they buy. Those expectations survive the expiry of a covenant.

Where does a platform fit in a calendar like this?

On the recurring work, which is the inventory rather than the covenant.

The Hedgehog platform carries over 20,000 spend-based and activity-based factors you can supplement with your own supplier-specific data, handles entity management across locations and sites, and lets you invite colleagues, consultants and auditors as data owners, auditors or managers. The platform page reports 5,000+ users, and a free account needs no sales call. For an organisation heading toward a proportionate voluntary disclosure, the VSME standard is usually the right destination.

The limitation to state plainly: a mid-market reviewer on G2 in June 2026 said they would like more integrations with other software in the future. If your plan assumed an HR or facilities system would feed travel and energy data across automatically, verify that specific route before you date a milestone against it. Where the work is judgement rather than transfer, scope 3 consulting is the right kind of help.

Sources: Green Deal Samen werken aan duurzame zorg (C-238) full text, in particular articles 3.h, 4.1, 4.2.a, 4.2.b, 4.2.e, 9, 13a, 14a and 16a, the Rijksoverheid signing announcement of 4 November 2022, and greendealduurzamezorg.nl, Hedgehog platform, Hedgehog on G2. Verified 28 August 2026.

Facts on this page were last verified on 2026-09-17.

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This article is written by:
Joost
Joost
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