About
The key focus of the directive is energy efficiency, in order to reduce greenhouse gas emissions from the EU building stock in furtherance of the objectives of reducing greenhouse gas emissions by a minimum of 55% by 2030 and attaining a climate-neutral union by 2050.
The amendments proposed in the revised directive include a requirement for all new buildings to be zero-emission buildings by 1 January 2030. New buildings that are owned by public authorities shall be subject to corresponding requirements from 1 January 2028. In somewhat simplified terms, a "zero-emission building" is defined as a building with a very high energy performance, requiring zero or a very low amount of energy, producing zero on-site carbon emissions from fossil fuels and producing zero or a very low amount of operational greenhouse gas emissions.
As for concrete requirements applicable to existing building, the proposal distinguishes between residential and non-residential buildings.
For residential buildings, each Member States shall ensure that the average primary energy use is reduced by at least 16% by 2030 and at least 20-22% by 2035. This gives the Member States flexibility to take into account national circumstances and to decide which buildings to target and which measures to take. The national measures will have to ensure that at least 55% of the decrease of the average primary energy use is achieved through the renovation of the worst-performing buildings.
For the non-residential building stock, each Member State shall introduce minimum requirements for the energy performance (socalled Minimum Energy Performance Standards, MEPS) to ensure that inefficient buildings are renovated first. Through the implementation of such standards, they shall ensure that the 16% worst-performing buildings are renovated by 2030 and that the 26% worst-performing buildings are renovated by 2033.
Exceptions from the requirements may be made for several categories of buildings, such as agricultural buildings, historical buildings, religious buildings, holiday homes etc.
Where technicaly suitable and economically and functionally feasible, solar energy installations must be installed gradually from 2027 (dependend on the size of the building) for new public buildings and non-residential buildings and on existing public buildings and existing residential buildings undergoing an action requiring a relevant administrative permit. The same applies for all new residential buildings from 2030.
It is also proposed that the energy performance certificates will be based on a common EU template with common criteria, with the scale being from A to G and the caracter A meaning a zero-emission building.
Who does it impact?
- EU member states
- EEA relevant
- Property owners
Status: In force
Adopted in the EU, on public hearing in Norway until 1 January 2026.
Participants
EU Member states and EEA
Thommessen's comments
The revised Energy Performance of Buildings Directive forms part of the comprehensive "Fit for 55" package and the EU Renovation Wave Strategy for Europe. An energy-efficient European building stock is of key importance to meeting the objective of a climate-neutral union by 2050, and is also a crucial step for reducing the dependence on Russian energy. Hence, the proposals for stricter absolute energy performance and energy efficiency requirements are consistent with stated objectives and regulatory developments in this field. We also note that some EU member states have already introduced stricter requirements for the energy performance of buildings.
The EU member state has been given two years to incorporate the directive in their national legislation. Norway has historically been lagging behind in the implementation of the earlier EU Energy Performance of Buildings Directives. For example, the directive from 2010 was not implemented in the EEA before April 2022 and didn't come into force in Norway until 1 March 2024. Furthermore, the revised directive from 2018 was implemented in the EEA on 11 July 2025. It is not clear whether and when the revised directive from 2024 will be implemented in Norway, but it is currently on public hearing in Norway until 5 January 2026.
If the directive is implemented in Norway, it will have implications for Norwegian property owners. The minimum requirements applicable to existing buildings may mean that energy-efficiency measures will have to be taken in respect of part of the current building stock, outside the context of any building conversion, change of use or other measure that would require planning authority approval. We believe that Norwegian property market participants should in any case be prepared for energy efficiency to not only be commercially prudent, but also an absolute necessity.