Directive (EU) 2024/1275 on the energy performance of build…

Which of my buildings must hit zero-emission standards first, and what happens if they do not?

Every new building in the EU must be zero-emission from 1 January 2030 (public buildings from 1 January 2028), while the worst-performing 16 % of non-residential stock must be renovated by 2030 — Member States must impose effective, proportionate and dissuasive penalties for non-compliance [Art. 34].

Short Answer

The recast Energy Performance of Buildings Directive (EPBD) establishes a legally binding pathway to a zero-emission building stock by 2050. It mandates minimum energy performance standards (MEPS) that force renovation of the worst-performing non-residential buildings by 2030 and 2033, and requires Member States to set national trajectories cutting residential primary energy use by at least 16 % by 2030 [Art. 9]. All new buildings must meet a zero-emission standard defined in Article 11, supported by mandatory life-cycle global warming potential (GWP) disclosure in energy performance certificates [Art. 7]. Solar energy installations become compulsory on a staggered timetable starting 31 December 2026 for new public and non-residential buildings above 250 m2 [Art. 10].

Who is affected

All building owners, developers, and public bodies across EU Member States are affected. Non-residential building owners face hard renovation thresholds: the worst-performing 16 % of national stock by primary energy must be renovated by 2030, and the worst 26 % by 2033 [Art. 9(1)]. Developers of new buildings must deliver zero-emission buildings from 2028 (public) or 2030 (all). Owners of buildings with car parks exceeding 5 spaces face EV charging infrastructure obligations [Art. 14]. Operators of non-residential buildings with HVAC systems above 290 kW must install building automation and control systems by 31 December 2024, and those above 70 kW by 31 December 2029 [Art. 13(9)]. Exemptions exist for heritage buildings, places of worship, temporary structures under 2 years, stand-alone buildings under 50 m2, and military defence buildings [Art. 9(6)].

Deadline

The main transposition deadline of 29 May 2026 has passed [Art. 35(1)]. The next material deadline is 31 December 2026 — solar energy installations on all new public and non-residential buildings above 250 m2 [Art. 10(3)(a)]. Following that: life-cycle GWP roadmap publication by 1 January 2027 [Art. 7(5)]; zero-emission standard for new public buildings from 1 January 2028 [Art. 7(1)(a)]; GWP disclosure for new buildings above 1 000 m2 from 1 January 2028 [Art. 7(2)(a)]; worst 16 % non-residential MEPS by 2030 [Art. 9(1)(a)]; all new buildings zero-emission from 1 January 2030 [Art. 7(1)(b)]; worst 26 % non-residential MEPS by 2033 [Art. 9(1)(b)]; residential stock minus 20-22 % primary energy by 2035 [Art. 9(2)(b)].

Risk

The Directive does not set an EU-wide penalty ceiling. Member States must lay down penalties that are effective, proportionate and dissuasive [Art. 34]. For minimum energy performance standards, Article 9(7) specifically requires appropriate monitoring mechanisms and penalties. In practice, non-compliant building owners face potential restrictions on sale or rental of properties, financial penalties set by national law, and exclusion from public subsidies for fossil-fuel boiler installations effective since 1 January 2025 [Art. 17(15)]. The greatest financial exposure lies in portfolio-wide renovation costs to meet MEPS thresholds and the solar installation mandates.

Proof

Legal status

• In force
• as of 2026-06-07
• Original version, as amended by Delegated Regulation (EU) 2026/52 (Annex III replacement, in force 24 May 2026)

Primary sources

• EUR-Lex — Full text
• European Commission — Soil — EU soil policy

What to do now

Legal / DPO

•Review national transposition laws against the Directive's 29 May 2026 deadline and map any gold-plating or derogations exercised by your Member State, in particular for heritage building exemptions and penalty regimes [Art. 35, Art. 9(6), Art. 34].
•Assess whether existing lease and sale contracts contain energy performance disclosure clauses that satisfy the new EPC requirements and advertisement obligations, as non-compliant transactions may face penalties under national law [Art. 19, Art. 20, Art. 21].
•Verify that the organisation's building portfolio is not subject to the fossil fuel boiler subsidy ban effective since 1 January 2025, and update procurement policies to exclude stand-alone fossil fuel boiler installations [Art. 17(15)].

Compliance

•Classify every non-residential building by energy performance class against the national 16 % and 26 % worst-performing thresholds, and establish a renovation pipeline prioritising buildings that fall below the 2030 MEPS cut-off [Art. 9(1)].
•Ensure the national building renovation trajectory for residential buildings is tracked internally, with at least 55 % of the required energy reduction sourced from renovating the worst-performing 43 % of stock [Art. 9(2)].
•Establish a compliance calendar covering solar installation deadlines (31 December 2026 for new public/non-residential above 250 m2), BACS deadlines, and EV infrastructure milestones per building category [Art. 10(3), Art. 13(9), Art. 14].

IT / Security

•Implement or upgrade building automation and control systems (BACS) in non-residential buildings with HVAC above 290 kW (deadline passed: 31 December 2024) and plan deployment for buildings above 70 kW by 31 December 2029, including cybersecurity hardening of networked BACS [Art. 13(9)].
•Ensure the data exchange infrastructure for building systems meets the interoperability requirements, providing building owners and tenants direct access to metering and operational data without additional charges [Art. 16].
•Prepare systems for integration with national EPC databases, ensuring digital energy performance certificates can be issued, stored, and transferred in machine-readable format as required by the national transposition [Art. 22].

Product / Engineering

•Align new building designs with the zero-emission building definition in Article 11, ensuring on-site or nearby renewable energy supply covers operational energy demand, with maximum primary energy thresholds set by national rules [Art. 7, Art. 11].
•Integrate life-cycle GWP calculation into the design process using the harmonised framework in Annex III as replaced by Delegated Regulation (EU) 2026/52 — 50-year reference study period, EN 15978 methodology, and the data hierarchy from Construction Products Regulation data down to default values [Art. 7(2), Annex III as amended by 32026R0052].
•Design new buildings with pre-cabling for EV charging (at least 50 % of parking spaces), recharging points (1 per 5 spaces in non-residential, 1 per 2 in offices), and bicycle parking for at least 15 % of average daily user capacity [Art. 14].

Key Terms

Zero-emission building: A building with very high energy performance where the very low amount of energy still required is fully covered by energy from renewable sources generated on-site, from a renewable energy community, or from a district heating and cooling system, as defined in Article 11.
Nearly zero-energy building (NZEB): A building with very high energy performance where the nearly zero or very low amount of energy required is covered to a very significant extent by energy from renewable sources. The NZEB standard is the interim requirement until the zero-emission standard applies [Art. 2(2)].
Energy performance certificate (EPC): A certificate recognised by a Member State or a legal person designated by it, which indicates the energy performance of a building or building unit calculated according to the methodology adopted pursuant to Article 4 [Art. 2(15)].
Minimum energy performance standard (MEPS): A regulatory threshold requiring buildings with the worst energy performance in national stock to be renovated to a defined level within a set deadline, applied per Article 9 to the worst-performing 16 % and 26 % of non-residential buildings.
Life-cycle global warming potential (GWP): An indicator measuring the total greenhouse gas emissions over a building's entire life cycle — from raw material extraction through construction, use, and end-of-life — expressed in kg CO2-equivalent per m2 of useful floor area over a 50-year reference study period [Art. 7, Annex III as amended by 32026R0052].
Major renovation: The renovation of a building where the total cost of the renovation relating to the building envelope or the technical building systems exceeds 25 % of the value of the building (excluding land value) or more than 25 % of the surface of the building envelope undergoes renovation [Art. 2(19)].
Building automation and control system (BACS): A system comprising all products, software and engineering services that can support energy-efficient, economical and safe operation of technical building systems through automatic controls and by facilitating manual management [Art. 2(42)].
Renovation passport: A document that provides a tailored roadmap for the renovation of a specific building in a maximum number of steps that will transform it into a zero-emission building by 2050 at the latest [Art. 12].

Frequently Asked Questions

When must all new buildings in the EU be zero-emission?

All new buildings must be zero-emission from 1 January 2030. New buildings owned or occupied by public bodies must meet this standard two years earlier, from 1 January 2028 [Art. 7(1)].

What are the minimum energy performance standards (MEPS) for existing non-residential buildings?

Member States must set thresholds so that the worst-performing 16 % of non-residential building stock (by primary energy use) is renovated by 2030, and the worst-performing 26 % by 2033. Further thresholds for 2040 and 2050 must be set in national roadmaps [Art. 9(1)].

How does the Directive affect residential buildings?

Member States must establish a national renovation trajectory reducing average primary energy use of the residential stock by at least 16 % by 2030 and 20-22 % by 2035 compared to 2020 levels. At least 55 % of this reduction must come from renovating the worst-performing 43 % of residential buildings [Art. 9(2)].

When do solar energy installation obligations begin?

From 31 December 2026, solar installations are required on all new public and non-residential buildings above 250 m2. Deadlines extend through 2030 for existing public buildings and new residential buildings [Art. 10(3)].

What is the life-cycle GWP disclosure requirement?

The life-cycle global warming potential must be calculated and disclosed in energy performance certificates for new buildings above 1 000 m2 from 1 January 2028, and for all new buildings from 1 January 2030. The harmonised calculation framework is set out in Annex III as replaced by Delegated Regulation (EU) 2026/52, using a 50-year reference study period and EN 15978 methodology [Art. 7(2), Annex III as amended by 32026R0052].

What penalties apply for non-compliance?

The Directive does not prescribe specific penalty amounts. Member States must lay down their own penalty rules, which must be effective, proportionate and dissuasive [Art. 34]. For MEPS enforcement, monitoring mechanisms and penalties must also consider the financial situation of homeowners, in particular vulnerable households [Art. 9(7)].

Which buildings are exempt from MEPS?

Exemptions apply to officially protected heritage buildings, places of worship, temporary buildings used for less than 2 years, industrial sites, agricultural buildings with low energy demand, residential buildings used less than 4 months per year, stand-alone buildings under 50 m2, and buildings used for national defence purposes [Art. 9(6)].

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