New legal toolkit for energy hubs with GTO

Energy hubs as a solution to grid congestion

The energy transition calls for a new way of thinking and collaborating. Many entrepreneurs notice that the electricity grid is full; expanding, electrifying, or exporting electricity is often no longer possible. Energy hubs provide a concrete alternative, where companies coordinate their energy consumption and generation.

In December 2025, the Authority for Consumers & Markets (ACM) introduced an additional solution: the group transmission agreement (GTO). With a GTO, multiple companies sign a single agreement for the available grid capacity (the transport capacity). They share a joint transport capacity and decide among themselves how that capacity is used. If one temporarily has an excess, another can use it. With the help of smart software, controllable installations, generation or storage, and clear agreements, companies ensure they utilize the joint transport capacity efficiently. This creates space to invest in growth and sustainability.

Legal toolkit as a practical aid

When companies share transport capacity through a GTO, it is necessary to make mutual arrangements. In practice, this costs a lot of time and incurs high costs. The legal toolkit helps make this step easier. The documents provide a clear foundation to start an energy hub together and to formalize organizational and financial agreements, as well as jointly investing in solutions such as batteries or charging points. This toolkit also helps energy hubs and entrepreneurs attract funding for further sustainability measures.

Astrid Sixma, lawyer-partner at Kennedy Van der Laan: “The GTO is a promising contractual form, which requires the necessary legal arrangements within an energy hub. With this toolkit, we provide a solid foundation for that. By making it publicly available, we contribute to solving the societal problem of grid congestion.”

The toolkit consists of four legal models:

• a deed of incorporation and articles of association for an energy hub cooperative;
• a member agreement, which regulates cooperation between the companies;
• a installation agreement for joint controllable assets, such as batteries or charging infrastructure, contributed by a company;
• a list of subjects for the collective energy management service agreement.

This approach aligns seamlessly with the Wennink Report, which states that economic growth and the energy transition must not be hampered by grid congestion but require smarter organization and standardization.

The practice as a starting point

During the development of the toolkit, collaboration took place with the Kempisch Entrepreneurs Platform (KOP). They work with entrepreneurs at the De Waterlaat industrial area in Bergeijk on an energy hub with a GTO to ensure practical applicability and connection with the actual entrepreneurs in the hubs.

“In our industrial estates, entrepreneurs have pioneered together to show that cooperation on energy is possible, even when the grid is full. The lessons we have learned here are valuable for other industrial estates in the Kempen region and across the Netherlands,” says Jan Rietdijk, Program Manager for Sustainability & Energy at KOP.

Removing barriers in the energy transition

The GTO toolkit builds on previous tools from Invest-NL aimed at removing obstacles in the energy transition. Earlier, Invest-NL, Kennedy Van der Laan, and N/P Notarial Partners developed a legal toolkit for the group capacity restriction contract (group-CBC), and Invest-NL with Ventolines renewed the cable pooling agreement. These instruments help companies reduce the effects of grid congestion more quickly, smarter, and collaboratively, and promote sustainability.

Invest-NL aims to accelerate the energy transition by removing funding bottlenecks. Diederik Apotheker, theme lead Energy at Invest-NL: “To better utilize the electricity grid, many new contractual forms such as the GTO are emerging. By making standards for basic agreements available, we lower the barriers for companies and financiers to invest.”