Serious power disruption is no longer just an engineering risk for Dutch organisations - it is a business continuity and governance issue.
The April 2025 blackout in Spain and Portugal showed how a serious disturbance in one part of an interconnected system can escalate into a wider, cross-border event, affecting everyday life and economic activity. ENTSO-E’s final investigation highlighted how voltage-control and system-stability challenges can contribute to such disturbances. For organisations on the Dutch grid, the practical lesson is to understand critical dependencies and prepare for disruption, without assuming that the same event will occur in the Netherlands.
At the same time, Dutch and EU frameworks on resilience, cybersecurity and energy markets are raising expectations of how organisations plan for and handle serious interruptions. Sector wide initiatives such as the Sectorpact Weerbaar Energiesysteem underline that resilience is now treated as a shared responsibility. Organisations connected to the grid also need to assess and document their own preparedness.
For organisations connected to the grid, resilience starts with practical questions: what needs to keep running if power is interrupted, and for how long? Can you demonstrate that your governance, responsibilities, contracts and continuity arrangements support that plan?
What you need to know now
On the interconnected Dutch grid, a major blackout or a period of curtailment can disrupt operations at your key sites – and put continuity plans, contractual commitments and resilience responsibilities to the test. Questions may continue after power is restored, when regulators, customers, lenders and insurers want to understand what happened and how your organisation responded.
For organisations connected to the Dutch grid, three practical questions are:
1. Do you know what is expected of your business, in the Netherlands and beyond?
Businesses should understand which Dutch resilience and cyber obligations apply to them, how responsibilities sit at board level, and how rules on notification, mitigation and liability differ in the other countries where they operate.
2. Will your contracts work when the power doesn’t?
Review and test your priority agreements, including PPAs, direct lines and private-wire arrangements, EPC and O&M contracts, storage and flexibility agreements, energy-community and heat-network arrangements, and data-centre and telecoms SLAs. A blackout does not automatically amount to force majeure or excuse performance: the position depends on the contract, the circumstances and the applicable law.
3. Will your plan work in practice and can you explain your decisions afterwards?
Who decides which activities continue or shut down safely? How will you contact staff, customers and suppliers if telecoms or IT are disrupted, and manage the restart? Rehearsing these scenarios can help test your arrangements. Clear records of the outage timeline, notifications, mitigation steps and key decisions can help you explain your response to regulators, customers, insurers and business partners afterwards.
How we can help you
Osborne Clarke helps organisations on the Dutch grid build practical, joined-up blackout resilience. Our team combines energy regulation and grid-code knowledge, project and contract experience, technology and cyber expertise, and disputes and investigations capability – and works with colleagues across Europe when you operate in more than one market. We can help you with:
- Obligations and governance - clarifying how Dutch and EU resilience and cyber requirements apply to you, how responsibilities sit at board and management level, and whether your risk assessments, continuity plans and incident-response arrangements form a coherent approach.
- Contracts and projects - reviewing priority agreements, including PPAs, direct-line and private-wire arrangements, EPC and O&M contracts, storage and flexibility agreements, energy communities, heat networks and data-centre and telecoms SLAs. We can assess relief provisions, service levels, notice and mitigation obligations, liability terms, suspension and termination rights, payment protections and performance deadlines.
- Continuity, investigations and disputes - mapping the operational impact on your key services and sites, and helping you prepare for regulatory or commercial scrutiny, including by identifying records that may be relevant if claims, investigations or disputes follow.
- Insurance and risk allocation - reviewing how business-interruption and cyber insurance wording may interact with your contracts and with the potential financial effects of an interruption or curtailment. Whether cover applies depends on the policy wording and the circumstances.
We combine knowledge of the Dutch grid and regulatory framework with a firm-wide European perspective. This helps you see where requirements in the Netherlands differ from other markets, prioritise the issues that matter and plan practical steps to strengthen resilience.
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