knowledge article/ f-gas
BRL 100 version 3.0: what changes.
BRL 100 is the Dutch certification scheme behind the company certificate you need in the Netherlands to work for customers on refrigeration and air conditioning installations and heat pumps. Rijkswaterstaat, the executive agency of the Dutch Ministry of Infrastructure and Water Management, adopted version 3.0 on 5 December 2025, and it has formally been in force since 31 August 2026.
Below are the dates, what version 3.0 contains and what an auditor looks at during an inspection. Everything comes from the scheme itself and from the explanations by IPLO, the Dutch government's information point for environmental law, and NVKL, the Dutch trade association for refrigeration and air conditioning. The sources are at the bottom.
Do you work outside the Netherlands? The EU F-gas Regulation behind it, Regulation (EU) 2024/573, applies in every member state, but certification is organised per country. This article is about the Dutch scheme.
This is an explanation, not legal advice. What applies to your company is decided by the scheme and your certification body.
what changes/
No longer only F-gases.
Version 2.0 was only about F-gases. Version 3.0 also covers hydrocarbons such as propane, CO2 and ammonia. For that the scheme has three sub-areas: I for F-gases and hydrocarbons, II for CO2 and III for ammonia. Your certificate only lists the sub-areas you actually work in (1.2).
Your technicians
Whoever does the work needs a personal certificate under BRL 200 version 2.0, the Dutch scheme for personal certification (1.3). It has a new structure: A1 and A2 for F-gases and hydrocarbons, B for CO2, C for ammonia, D for recovery only and E for leak checks only without opening the circuit. Your company has an employment contract with at least one certified person (2.1.2). Old certificates remain valid under conditions until 12 March 2029; the new ones are valid for seven years.
Working safely
You make sure your technicians have the right instruments, procedures and protective equipment (2.1.3). Hazardous work on installations with hydrocarbons or flammable F-gases calls for a task risk analysis (3.1). The explosion protection document is drawn up by the owner of the installation. Checking that it exists and reading it is part of your task risk analysis.
Your quality system
Management records its commitment in a policy statement and reviews every year whether the procedures and work instructions work (2.2). The scheme also asks for a fixed way of monitoring your work, including checking work orders for execution and recording, and calibrating your measuring equipment. For every employee it is described which role they have and which certificate goes with it.
the transition/
When does it affect you?
Do you already hold a certificate under 2.0? Then your audit cycle stays as it is and no extra audit is added. Your first regular audit after 31 August 2026 is the transition audit: the certification body then checks whether your processes and your way of working meet version 3.0. If they do, your certificate continues under 3.0, in the same cycle.
NVKL gives an example. If you had your audit in July 2026, it was still done under 2.0, and two years later the next one follows under 3.0. According to NVKL you must already meet 3.0 from 31 August 2026, even if your audit falls later.
Are you applying for a certificate for the first time? Then you go through an initial assessment under 3.0. You get a provisional certificate if you meet the general requirements and your procedures and work instructions are in order. An inspection follows within six months, and after that every 24 months (6.5).
A certification body may only assess under 3.0 once the Dutch Accreditation Council (Raad voor Accreditatie) has accredited it for that (transition arrangement 2.2). Ask your own certification body where it stands.
Are your technicians still in training for the new personal certificate? The transition arrangement recognises that there are few training places. If you can show that you are working on training and exams in a planned way, that does not immediately count as a major nonconformity. If there is too little progress, it can still become a nonconformity (transition arrangement 8.1).
the inspection/
What the auditor wants to see.
The auditor talks to your people and carries out an extensive document review, using recent projects and your records (6.5.2). He asks your technicians how they did the work, and compares that with what is on paper or in your system.
- Work orders and photos
- Using recent projects, the auditor looks at what was done. Is the pressure test on the work order? Did the evacuation have a standing time of at least 30 minutes? And at commissioning, were the readings of the pressure gauge and the thermometer put on the work order?
- BRL 100 v3.0, 6.5.2
- The logbook
- A separate record for each independent circuit, from installation to maintenance. The owner gets a copy in a form that cannot be changed; digital is allowed. You keep the originals for at least five years, and the logbook must be present where the installation is.
- BRL 100 v3.0, 2.5.2
- The refrigerant records
- For circuits above 5 tonnes of CO2 equivalent or with more than 1 kg of HFOs: how much and which gas is in it, what you add or recover with the date and the reason, whether the gas was recycled or reclaimed, which company did the work with its certificate number and which technician, and the dates and results of the checks. If the Human Environment and Transport Inspectorate (ILT), the Dutch regulator, asks for it, you must be able to produce an overview of all the installations you maintain.
- BRL 100 v3.0, 3.2
- The F-gas balance
- Per type of F-gas an annual balance over the calendar year, drawn up before 1 March. With the stock on the first and the last day, calculated and weighed, plus what you have bought, sold, recovered and disposed of. In kilograms and in CO2 equivalent. If the calculated stock differs from what you weigh, the auditor wants to see the cause and a plan to prevent it.
- BRL 100 v3.0, 3.3
- Leakage and its cause
- If leakage was the reason for adding refrigerant, the cause must have been found and repaired. And the owner must know that a follow-up check is due within a month of the repair.
- BRL 100 v3.0, 6.5.2
- Your measuring instruments
- Every instrument has a unique identification, and it is on every record of a check. An instrument that does not work properly is clearly marked as unfit for use. The auditor asks for the calibration or verification documents.
- BRL 100 v3.0, 2.5.4
- Labels and nameplates
- You check whether the equipment has a correct label. If it is missing, you point this out to the operator.
- BRL 100 v3.0, 3.4
How much he looks at
It depends on the number of certified technicians you employ, plus the certified self-employed technicians you hired the year before. If you have several branches with their own branch number at the Chamber of Commerce (KvK), the table applies per branch. Which people and projects it will be, the auditor chooses at random.
| certified technicians | interviews | projects |
|---|---|---|
| 1 to 3 | 1 | 2 |
| 4 to 9 | 2 | 4 |
| 10 or more | 3 | 6 |
BRL 100 v3.0, 6.5.2
tools/
Your measuring instruments, with date and name.
Every check needs a record: which instrument, when, the measured values, the deviation and who did it.
- Pressure gauge and vacuum gauge
- Compared with a calibrated reference gauge every 24 months.
- 2.5.5
- Thermometer
- Once a year, in iced water or against a reference meter. At most 1 degree deviation.
- 2.5.6
- Scales for trade use
- Calibration by a calibration body every 24 months, or checking it yourself with a calibrated test weight every 12 months.
- 2.5.7
- Leak detector for F-gases
- Check before use with a test leak to NEN-EN 14624:2020 or ISO 6141, and record that test. The sensitivity is 5 ppm.
- 2.5.4 and 3.5
Scales you use to sell refrigerant must also have the right markings before they are put into use. That follows from the Dutch Metrology Act and is a requirement on the manufacturer (2.5.7).
when it is not right/
Nonconformity or major nonconformity.
A nonconformity is a single deviation, such as a procedure that is missing or incomplete. You let the certification body know within six weeks how you have resolved it. If it can be resolved during the audit, the auditor may close it straight away (6.9.1).
With a major nonconformity you do not meet the requirement at all, and safety or the environment is at stake. Then you have thirty days to analyse the cause, make an improvement plan and send in the evidence. Examples from the scheme: no risk analysis for hazardous work, not having or not checking the required instruments, not following safety procedures, or no root cause analysis after serious leakage (6.9.2 and 6.10).
One case is heavier than the rest. If you have work that requires a certificate done by someone without one, your company certificate is suspended with immediate effect and the Human Environment and Transport Inspectorate is notified (6.10).
and Fikst/
Where Fikst keeps your records.
Fikst is software for air conditioning, heat pump and installation companies. The F-gas records are built in, next to your technician's work order. It helps you keep the records the auditor wants to see. Only your certification body issues the certificate itself, and Fikst is not certified.
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Every handling on the work order
Your technician records on the work order what he did, per handling. For the leak test, the pressure test, the evacuation and the commissioning he picks the measuring instrument. If he adds or recovers refrigerant, he picks the cylinder. If the calibration of the chosen instrument had expired on that day, he cannot complete the work order.
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Task risk analysis and last minute risk analysis as a form
A task risk analysis (TRA) and a last minute risk analysis (LMRA) are ready as a form that you put on the work order. That way the analysis sits with the job it belongs to.
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The tool register
Every measuring instrument is in it with its serial number and the calibrations you record, with date and certificate. Which calibration is coming up or has already expired, you see in the list. In the refrigerant records, each entry shows which instrument was used and whether its calibration was valid on that day.
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The logbook per installation
Per installation the refrigerant, the charge, the CO2 equivalent, the leak check obligation with the last and the next check, and everything recorded on it. You put the records per installation in a CSV file, or for the whole year with the columns an inspector looks for.
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The cylinders and the annual balance
Every cylinder has a running series of entries: purchase, use, return, disposal and weighing. You do not change an entry; a correction is a new one. The annual balance per gas puts the calculated stock next to what you have weighed, in kilograms and in CO2 equivalent. If there is a difference, you record the root cause analysis and the improvement plan with it.
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Checks, certificates and leak check certificates
The check schedule lists leak checks and follow-up checks, including the overdue ones, and turns them into a work order with one click. The certificates of your technicians and your company are in it with their validity, and the number of your company certificate goes on every record. Fikst only creates a leak check certificate as a PDF if the personal certificate and the instrument were valid on that day.
What you keep doing yourself
Your quality manual, your procedures and work instructions, the management review and your internal audits. Fikst stores the data you need for it, but does not write procedures for you and does not judge whether you meet the scheme.
The F-gas records are included in your subscription. If you work with refrigerant, we switch them on for you during the setup, together with the handlings on the work order and the tool register. Read what the F-gas records in Fikst do
Questions about BRL 100 version 3.0.
All frequently asked questions about FikstSince when does BRL 100 version 3.0 apply?
Rijkswaterstaat adopted version 3.0 on 5 December 2025. Under the transition arrangement it formally enters into force on 31 August 2026. From 1 September 2026 no more certificates are issued under version 2.0.
Do I need an extra audit right away?
No, not under the transition arrangement. If you hold a valid certificate, your audit cycle simply stays as it is. If your next regular audit falls after 31 August 2026, that is the transition audit to version 3.0. Your quality system and your way of working must already be in line with 3.0 by then.
How long does my certificate under version 2.0 stay valid?
Until 31 August 2028 at the latest. For companies that have their transition audit late in the transition period, there is a remedy period until 30 November 2028. If you do not resolve the nonconformities from that audit in time, the 2.0 certificate lapses.
What is different about version 3.0?
Version 2.0 was only about F-gases. Version 3.0 also covers hydrocarbons such as propane, CO2 and ammonia. For that there are three sub-areas, and your certificate only lists the sub-areas you work in. Your technicians need a personal certificate under BRL 200 version 2.0, with the new structure A1 to E.
What does the auditor look at?
During an inspection the auditor talks to your staff and goes through your documents using recent projects: work orders and photos, the logbook, the refrigerant records, the F-gas balance and the calibration or verification documents of your measuring instruments. How many people and projects he looks at depends on the number of certified technicians.
Can I prepare my BRL 100 audit file in Fikst?
Yes. The F-gas reports have an Audit file tab. You choose a reference date and download one Excel file for the auditor, with your company certificate, your technicians' personal certificates with the check in the Dutch Central Register Techniek, and the inspections of your measuring instruments. The screen shows straight away what has expired or expires within 60 days, your company certificate included, so you can sort it out before the audit. Your quality manual and your procedures are not in it; those remain yours.
Is Fikst certified for BRL 100?
No. BRL 100 is a certificate for your company, and only a certification body issues it. Fikst is a system in which you keep the records the auditor wants to see. Your quality manual, your procedures and your work instructions remain yours.
Sources.
Consulted on 11 October 2026. The numbers in brackets in the text are the sections of BRL 100 version 3.0. The sources are Dutch documents.
- Rijkswaterstaat, BRL 100 version 3.0, adopted on 5 December 2025 (PDF on iplo.nl, in Dutch)
- IPLO, explanation of the transition arrangement for BRL 100 v3.0 (in Dutch)
- IPLO, requirements for companies (installation companies) (in Dutch)
- IPLO, requirements for natural persons (technicians) (in Dutch)
- IPLO, certification (in Dutch)
- NVKL, BRL100 3.0 (in Dutch)
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