About
The Energy Labelling Scheme, which is governed by the Building Energy Labelling Regulations, requires both energy certificates and energy assessment of heating and air conditioning systems. The energy certificate requirement is applicable to new buildings (the same applies to major renovations of existing homes or buildings), buildings where at least 250 sqm of the building’s usable area is utilized by public authorities, and the building is frequently accessed by the general public, as well as upon the sale and letting of buildings. The responsibility is continuous, and the duty persists irrespective of whether the previous owner or potentially the builder has failed to fulfil the requirements.
The energy certificate is as a main rule valid for ten years. It comprises, amongst other, an energy rating and a list of suggestions for specific energy measures to improve the building's energy performance. The new energy rating, which enters into force on 1 January 2026, shall be determined in accordance with a new calculation method as specified in SN-NPEK 3031:2021, which will rate the building solely on a scale from A (best) to G (weakest). The previous (current) energy label also included a separate heating rating which was based on a five tier colour ranking from green to red. Under the new calculation method, the heating rating is included in the energy rating scale. I.e. it will not be a separate colour rating in addition to the scale of letters.
Owners of buildings that has a combined heated usable area exceeding 500 sqm and is frequently accessed by the general public, are in addition required to display a summary of the energy certificate for the users.
Under the new calculation method, the letter A (best) will only be given to buildings that outperform the energy requirements of TEK17 by at least 15%. Furthermore, buildings that fulfil the energy requirements of TEK17 shall be given the letter B. The letter G (weakest) shall be given to buildings considered to be among the 15% least energy efficient buildings within each specific building category. The remaining buildings shall be allocated across the letters C to F within each building category.
The requirement for energy assessment of heating and air conditioning systems applies to and shall be conducted every fourth year for heating systems that have a total installed capacity exceeding 20 kW, where the air conditioning systems have a total installed capacity exceeding 12 kW, or where the air conditioning systems collectively serve a heated, usable, area exceeding 500 sqm. If the heating system has a nominal effect in excess of 100 kW, a new energy assessment shall be conducted every other year).
Who does it impact?
Under the Building Energy Labelling Regulations, the obligation to obtain an energy certificate has been placed with any person who (i) is registered as holding title to a building; (ii) owns a unit in a building; (iii) holds an interest in a housing cooperative; or (iv) holds a share of a company owning a residential property or building, with an associated right of use.
Responsibility for energy assessment has been placed with the owner of the facilities.
Status: In force
The Energy Labelling Scheme is governed by the Regulations relating to Energy Labelling of Buildings and Energy Assessment of Heating and Air Conditioning Systems (the Building Energy Labelling Regulations). The Regulations entered into effect on 1 July 2010, it underwent a revision on 1 March 2024 and underwent its most recent revision on 2 April 2025. The newest changes will enter into force on 1 January 2026.
Relation to other initiatives and regulations
The Energy Labelling Scheme is based on the EU Energy Performance of Buildings Directive (2002/91/EC), and the EU Energy Performance of Buildings Directive (recast) (2010/31/EU).
Thommessen's comments
The Energy Labelling Scheme shall ensure market disclosure of information on the energy status of residential properties, other buildings, as well as heating and air conditioning systems, according to an amendment to the Energy Labelling Scheme from and including 1 January 2026 the energy label shall also suggest specific measures for improvement of the building's energy performance. One thereby seeks to generate more interest in specific energy measures and conversion to renewable energy sources, as well as to contribute to more appropriate valuation of residential properties and other buildings when selling or letting these.
It is our experience that the lack of an energy label often crops up as an issue in connection with property transactions. Energy labelling is considered both for the valuation of buildings and for the assessment of investment risk, used by the banks in connection with issuance of green loans and is also of interest from a purely environmental perspective. We also note that inadequate energy labelling, if any, tends to be highlighted during the buyer’s due diligence investigation, and often results in price reduction or seller's obligation.
There is extensive research on the use and significance of various classification systems, including for energy labelling of buildings. Both national and international studies show that buildings with strong energy ratings will, inter alia, have higher market value, higher rent revenues, lower operating costs and reduced financial risk. As it is expected that the revised calculation method will cause many buildings to receive a higher rating, it should be considered to renew labels even though they are not expired, before going to market in a sale process.
A building’s energy rating is also relevant for compliance with some of the technical screening criteria under the EU taxonomy. The amendments better aligns the Energy Labelling Scheme with the taxonomy, as the new calculation method described below is used to assess whether a building is among the 15% or 30% nationally best energy performing buildings built before 31 December 2020. which makes it easier for the banks to use and rely on the energy label when assessing green loans.