EU Energy Performance of Buildings Directive (EPBD Recast) - Directive (EU) 2024/1275

Article 10 requires Member States to ensure the deployment of suitable solar energy installations on the following buildings (where technically suitable and economically feasible): new public + non-residential buildings with useful floor area over 250 m2 from 31 December 2026; all existing public buildings with useful floor area over 2,000 m2 / 750 m2 / 250 m2 by 31 December 2027 / 2028 / 2030; covered car parks adjacent to buildings from 31 December 2027; all new residential buildings from 31 December 2029; non-residential buildings undergoing major renovation from 31 December 2027.

• Building-portfolio solar-deployment calendar aligned with Article 10 staged thresholds
• Technical-suitability + economic-feasibility assessment records where deployment is deferred

• Eligible building lacking a documented technical-suitability / economic-feasibility analysis
• Deployment plan that does not meet the Article 10 staged thresholds

Article 11 specifies the ZEB standard per Annex III: very high energy performance (with primary energy use below maximum thresholds set by Member State per building type), and zero on-site GHG emissions from fossil fuels (operationally; on-site renewable generation, district heating/cooling under Article 24 of the Renewable Energy Directive, energy from efficient district networks, or carbon-free energy sources are compatible). The ZEB standard underpins Article 7 (new buildings) and is increasingly the target for deep renovations.

• ZEB conformity evidence per Annex III at building commissioning
• Energy-source documentation (no on-site fossil-fuel emissions; renewable + efficient district network sources)

• Building marketed as ZEB without Annex III conformity
• On-site fossil-fuel emissions in a building claimed as ZEB

Article 12 requires Member States to introduce a voluntary scheme for renovation passports by 29 May 2026. A renovation passport is a customised long-term plan setting a roadmap for the deep renovation of a specific building in a maximum number of steps, indicating the energy and non-energy benefits, the estimated energy savings, the expected operational cost reductions, the financing options and any available technical assistance, and is delivered by a qualified independent expert. The renovation passport is the consumer-side instrument enabling owners to plan staged deep renovation toward ZEB.

• Engagement with the national renovation-passport scheme where the entity owns / occupies eligible buildings
• Issued renovation-passport records (passports held by the entity for its portfolio)

• Major renovation programme that does not consider available renovation passports
• Building marketed for deep-renovation finance without a renovation-passport-equivalent roadmap

Article 17 requires Member States to provide financial incentives, including for staged deep renovations following renovation passports, with priority for worst-performing buildings and vulnerable households (energy-poverty alleviation). Article 17 also requires upskilling and reskilling of the building workforce (architects, energy auditors, installers). Article 18 requires Member States to establish one-stop shops by 29 May 2026: integrated points of advice on the regulatory and financial aspects of renovation, including the EPC, the renovation passport, available finance and skills networks.

• Reliance records on Member State Article 17 incentives where eligible
• Engagement with the relevant Article 18 one-stop shops
• Workforce upskilling plans aligned with Article 17

• Investment plan that does not check Article 17 incentive availability

Article 19 requires the issue of EPCs in defined cases: construction, sale, new lease (Article 19), with the EPC class shown in property advertisements. Article 19(7) requires Member States to introduce, by 29 May 2026, an A+++ to G scale (where A+++ corresponds to ZEB; A to NZEB; G is the worst performing 15% of national stock). Article 20 governs the issue of EPCs (independent expert; quality assurance; 5- or 10-year validity). Article 21 requires the display of EPCs in buildings over 250 m2 occupied by a public authority and frequently visited by the public, and in commercial premises occupied by businesses and frequently visited by the public. Article 22 requires Member States to set up EPC databases connected to the Building Stock Observatory.

• EPC issue records (construction / sale / lease)
• EPC class in property advertisements + sale-particulars
• Display of valid EPC where Article 21 applies
• Article 22 EPC database connection

• Sale or new lease without a valid EPC
• EPC not displayed in eligible public-facing buildings

Article 1 sets the subject matter: the Directive promotes the improvement of energy performance of buildings and the reduction of greenhouse-gas (GHG) emissions in the buildings sector across the Union with a view to achieving climate neutrality by 2050. Article 2 supplies the definitions used throughout, including: 'building', 'building unit', 'nearly zero-energy building (NZEB)', 'zero-emission building (ZEB)', 'deep renovation', 'staged deep renovation', 'energy performance certificate (EPC)', 'technical building system', 'smart readiness indicator (SRI)', 'minimum energy performance standards (MEPS)', 'fossil-fuel boiler', 'renovation passport'.

• Internal scope determination identifying which EPBD regime(s) apply to the entity (developer / owner / occupier / EPC issuer / TBS operator / Member State authority)
• Definitions glossary aligning the entity's terminology to Article 2 (in particular ZEB vs NZEB and the renovation-passport definition)

• Inconsistent use of ZEB / NZEB / 'low-emission building' across internal documents

Article 28 requires the Commission to review the Directive by 2028 and every five years thereafter, in particular regarding the ZEB thresholds and the MEPS / trajectory ambition. Article 29 obliges Member States to provide information to building owners and occupants on energy performance, available financial instruments, the EPC, and the renovation passport. Article 30 requires Member States to consult stakeholders on the NBRP and on related measures.

• Information materials provided to occupants on energy performance and renovation options
• Consultation engagement records

Article 31 enables the Commission to adopt delegated acts adapting Annex I to technical progress and reviewing the Annex III ZEB requirements. Article 32 governs the exercise of the delegation. Article 33 sets the committee procedure (Committee on the Energy Performance of Buildings).

• Tracking of delegated-act updates to Annex I / Annex III that may re-shape the ZEB or methodology requirements

Article 34 requires Member States to lay down the rules on penalties applicable to infringements of national provisions adopted pursuant to the Directive. Penalties must be effective, proportionate and dissuasive. Member States notify the Commission of those rules by the transposition date (29 May 2026).

• Awareness of the applicable national-law penalty regime in each Member State the entity operates in
• Compliance program managing exposure against the Article 34 penalty regime

Article 35 requires Member States to bring into force the laws, regulations and administrative provisions necessary to comply with the Directive by 29 May 2026 (24 months after entry into force). Article 36 repeals Directive 2010/31/EU (the prior EPBD) from 30 May 2026, without prejudice to Member States' obligations under that Directive for the periods preceding repeal. Article 37 provides that the Directive entered into force on 28 May 2024 (twentieth day after publication in OJ L 2024/1275 of 8 May 2024). Article 38 addresses the Directive to the Member States.

• Compliance calendar reflecting 28 May 2024 entry into force, 29 May 2026 transposition deadline, 30 May 2026 repeal of 2010/31/EU

• Operating against the 2010/31/EU baseline after 30 May 2026 (repealed)

Article 23 requires regular inspections of accessible parts of HVAC systems above defined kW thresholds (heating + combined heating-and-ventilation above 70 kW; air-conditioning + combined air-conditioning-and-ventilation above 70 kW). Inspection covers the efficiency and dimensioning of the system. Article 24 requires inspection reports made available to the building owner.

• Inspection-cycle calendar for HVAC systems above 70 kW
• Inspection reports retained and made available to the building owner

• HVAC system above 70 kW lacking inspection records on schedule

Article 25 requires that EPCs, inspections, renovation passports and SRI assessments are carried out by qualified or accredited experts operating independently. Article 26 requires Member States to put in place certification or equivalent qualification schemes for relevant building professionals. Article 27 requires Member States to operate an independent control system to verify the quality of issued EPCs and inspection reports (random sample of at least 25%).

• Engagement with certified / accredited experts only
• Internal QA records aligned with the Member State Article 27 independent control system

• Engagement of unaccredited experts for EPC issue or inspection
• No internal-QA process supporting the Article 27 sample-based checks

Article 3 requires each Member State to establish a National Building Renovation Plan (NBRP) by 31 December 2025 (with the first plan covering the period to 2050) and every 5 years thereafter. The NBRP sets the trajectory to decarbonise the national building stock by 2050, includes evidence-based targets, instruments and milestones, and is integrated with the National Energy and Climate Plan (NECP) under Regulation (EU) 2018/1999. NBRPs are consulted with stakeholders and published.

• Engagement records with the Member State NBRP consultation
• Internal portfolio alignment with the NBRP trajectory
• Reference to the NBRP in the entity's transition plan

• Building-portfolio investment that contradicts the Member State NBRP trajectory
• No engagement with the NBRP consultation

Article 4 requires Member States to adopt a methodology for calculating the energy performance of buildings in accordance with Annex I (numerical indicator of primary energy use expressed in kWh/(m2.year), plus indicators for net useful energy demand and operational GHG emissions in kg CO2eq/(m2.year)). Article 5 sets minimum energy performance requirements (national thresholds) for buildings or building units. Article 6 requires the calculation of cost-optimal levels of minimum energy performance requirements every 5 years (in accordance with the comparative methodology framework), and gap reporting where the national requirement differs by more than 15% from the cost-optimal level.

• Methodology documentation aligned with Annex I
• Cost-optimal calculation submitted to the Commission per Article 6

• National threshold materially below the cost-optimal level without justification (Article 6 gap reporting)

Article 7 requires that all new buildings constructed in the Union are zero-emission buildings (ZEB) per Article 11 from: 1 January 2028 for new buildings owned by public bodies; 1 January 2030 for all other new buildings. Article 7(2) requires the calculation of life-cycle GHG emissions (Global Warming Potential, GWP) of new buildings of over 1,000 m2 floor area from 1 January 2028, and for all new buildings from 1 January 2030. Article 7(4) requires that new buildings are designed to optimise solar energy potential per Article 10.

• Project-level compliance calendar tracking the Article 7 staged dates (public 2028, all 2030, GWP >=1,000 m2 2028, GWP all 2030)
• Solar-energy potential analysis per Article 7(4)
• Life-cycle GWP calculation per the Annex III methodology

• New building project initiated for occupation after 2028 (public) / 2030 (private) that is not designed to the ZEB standard
• No life-cycle GWP calculation for new buildings >1,000 m2 from 2028

Article 8 requires that, when buildings undergo major renovation, their energy performance is upgraded in order to meet the minimum energy performance requirements set in Article 5, in so far as that is technically, functionally and economically feasible. Article 8(2) requires that, where a Member State applies a building element approach (rather than whole-building), it ensures that the elements achieve the minimum energy performance requirements for those elements. Article 8(7) requires Member States to phase out fossil-fuel boilers from buildings as soon as possible and at the latest by 1 January 2040.

• Renovation-trigger procedure ensuring Article 8 compliance at major-renovation moments
• Heating-system replacement strategy aligned with the 1 Jan 2040 fossil-fuel-boiler phase-out
• Internal portfolio decarbonisation roadmap

• Major renovation completed without bringing building elements to Article 5 minimum
• New fossil-fuel boiler installations late in the depreciation horizon (incompatible with 2040 phase-out)

Article 9 introduces MEPS for non-residential buildings: Member States establish maximum energy-performance thresholds, with the existing non-residential stock above the 16% worst performing buildings to be brought below that threshold by 2030, and the 26% worst-performing threshold by 2033. Article 9(3) requires Member States to set national trajectories for the progressive improvement of the residential building stock, aligned with the 2050 climate-neutrality target, with milestones for 2030, 2040 and 2050 (16% reduction in average primary energy use by 2030; 20-22% reduction by 2035; at least 55% of the reduction from worst-performing buildings).

• Asset-level MEPS-compliance roadmap (non-residential >=16% threshold by 2030, >=26% by 2033)
• Residential portfolio decarbonisation trajectory aligned with the Member State Article 9(3) plan

• Non-residential portfolio with assets in the worst-performing 16% lacking a 2030 plan
• Residential investment plan that ignores the 16%/2030 + 20-22%/2035 milestones

Article 13 requires Member States to set system requirements in relation to the overall energy performance, the proper installation, and the appropriate dimensioning, adjustment and control of the technical building systems (TBS) installed in existing buildings, namely heating, hot water, cooling, ventilation, large built-in lighting, building automation and control (BACS), on-site renewable energy systems, on-site electricity generation, EV recharging infrastructure, and combinations of the above. Article 13(8) requires non-residential buildings with effective HVAC output over 290 kW to be equipped with BACS by 31 December 2024; over 70 kW by 31 December 2029. Article 13(13) requires residential building automation similarly.

• BACS deployment calendar aligned with Article 13(8) (290 kW by 2024) and Article 13(8)(b) (70 kW by 2029)
• TBS conformity records at installation + system reset / commissioning

• Eligible non-residential building above 290 kW HVAC output without BACS by 31 Dec 2024
• TBS replaced without Article 13 documentation

Article 14 requires Member States to ensure the installation of electric-vehicle (EV) recharging points and bicycle parking spaces in non-residential and residential buildings. Non-residential: new and major renovation with more than 5 car parking spaces: at least 1 recharging point per 5 spaces + bicycle parking; existing non-residential with more than 20 car parking spaces: at least 1 recharging point per 10 spaces by 1 January 2027. Residential: new and major renovation with more than 3 car parking spaces: pre-cabling/ducting for 50% + 1 recharging point. Public-sector buildings: heightened requirements.

• Project-level Article 14 design records for new + major-renovation buildings
• Existing-non-residential 20+ space buildings retrofit plan for 1 Jan 2027 deadline
• Public-sector heightened requirements applied where relevant

• New building over 5 non-residential parking spaces without EV recharging point
• Major renovation that does not add the Article 14 ducting / bicycle parking

Article 15 requires Member States to apply, on a mandatory basis for non-residential buildings above 290 kW effective HVAC output (from a date set by Member States) and on a voluntary basis for residential, the common Union Smart Readiness Indicator (SRI) per Commission Delegated Regulation (EU) 2020/2155 and Implementing Regulation (EU) 2020/2156. The SRI rates the building's capacity to interact with occupants, the grid and to operate efficiently.

• SRI assessment records for non-residential buildings above 290 kW where mandatory in the Member State
• Voluntary SRI ratings issued for residential portfolio

• Non-residential building above 290 kW HVAC output without an SRI rating where mandatory

Article 16 requires Member States to ensure that building owners, tenants and managers can have direct access to their building data via a single secure access point, including data from the technical building systems (Article 13), the EPC databases (Article 22), the renovation passport (Article 12) and any related metering / sub-metering data. Data sharing follows the GDPR for personal data and may follow the Data Act for non-personal data.

• Single secure access point for building data integrated with TBS / EPC / passport / metering
• Data-sharing terms aligned with GDPR (personal data) + Data Act (non-personal)

• TBS data locked behind proprietary interfaces without owner / tenant / manager access
• No alignment with GDPR + Data Act for the building data exchange