EPBD: The EU Energy Performance of Buildings  Directive – obligations, deadlines, and  implementation in Germany

Binding targets, specific obligations, clear deadlines: the EU Energy Performance of Buildings Directive (EPBD) is no walk in the park. For owners of existing buildings, local authorities, and the industrial and commercial sectors, the EPBD primarily means costs associated with energy-efficient refurbishment. But energy consultants, engineers, architectural firms, specialist planners and construction companies also need to implement the EPBD requirements efficiently. We explain the specific requirements, obligations and deadlines, and show how you can use digital data collection and automated data processing to carry out energy-efficient renovations in a data-driven, fast and cost-effective manner.

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What is the EPBD? 

The EPBD – Energy Performance of Buildings Directive – is the EU building directive aimed at  decarbonising the building sector and improving its energy efficiency (Directive  2024/1275/EU). With this key instrument, the European Union (EU) aims to make the building  sector climate-neutral. The directive is part of the European Green Deal and the EU Commission’s Fit for 55 package (55% reduction in emissions by 2030). First adopted in  2002, it was last fundamentally revised in May 2024. 

The key points of the EPBD Directive are: 

• From 2030, new buildings must be constructed as zero-emission buildings.
• Existing buildings must be renovated according to the ‘worst first’ principle: the buildings with  the poorest energy performance must be tackled first. 
• Fossil fuel heating systems will be phased out. 
• New requirements apply for CO₂ life-cycle assessments, solar installations,  charging infrastructure and building automation. 
• Germany must transpose the directive into national law – its political implementation is currently under debate. 
• Digital building models, such as BIM models, and digital verification systems will become  mandatory as the basis for planning, operation, verification and funding. 
• This affects owners, planners, architects and the entire housing sector. 

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Requirements: What does the EU Energy Performance of Buildings  Directive (EPBD) stipulate? 

The current EPBD obliges owners to undertake a binding transformation of the building sector:  ambitious renovation targets, the phase-out of fossil fuels and widespread digitalisation are intended  to ensure climate neutrality by 2050. The following overview categorises the most important  requirements according to their thematic focus.

Requirements for existing buildings: housing sector and building owners 

Renovation obligations & the ‘worst first’ principle 

The EPBD makes a strict distinction between building types: for non-residential buildings, there are  strict thresholds, known as Minimum Energy Performance Standards (MEPS); for residential  buildings, there are flexible reduction pathways. 

• Fixed renovation deadlines apply to non-residential buildings: the bottom 16% must be  renovated by 2030, and the bottom 26% by 2033. 
• For residential buildings, there are no individual obligations, but rather a national  energy-saving target, such as a 16% reduction in consumption by 2030. The ‘worst-first principle’ applies: more than half of these savings must be achieved through the  renovation of the buildings with the poorest energy performance. 

The requirements for this are set out in Article 9 (“Minimum energy performance standards for non residential buildings and pathways for the phased renovation of the residential building stock”). 

Ban on fossil fuel heating systems: deadlines for phasing out 

There is no immediate, EU-wide ban on existing gas and oil heating systems. The EU merely sets  out the framework for phasing out fossil fuel heating. Member States must draw up their own  binding phase-out plans to make the buildings sector completely climate-neutral by 2050. 2040 is  often targeted as the deadline for heating systems. However, one strict deadline has already been  implemented: from 1 January 2025, standalone fossil fuel heating systems may no longer receive  state funding. 

The requirements can be found in the recitals, Article 13 (Building services systems) and Article 17  (Financial incentives). 

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Reporting requirements and data basis: Energy consultants & property  management companies 

Energy performance certificate reform: Standardised scale (A to G) and data collection 

The EU is replacing the patchwork of energy performance certificates with a Europe-wide  standardised scale from A to G. Class A will in future denote zero-emission buildings, whilst Class G  will mark the buildings with the poorest energy efficiency within the national building stock. For  energy consultants and property managers, this means: existing certificates will eventually, and data collection for new certificates must be significantly more precise, digital and  standardised. 

The provisions on the harmonisation of energy performance certificates are set out in Article 19  (‘Energy performance certificates’).

Building Renovation Passport: A tool for step-by-step renovation roadmaps

The Building Renovation Passport (BRP) will be introduced by mid-2026 as a new, key tool. It  offers owners a tailored, step-by-step roadmap to transform their building into a zero-emission  building by 2050 at the latest. Although the directive stipulates an “inspection by experts” for the  issuance of the pass, it expressly permits this to take place virtually. This is precisely where  rapid, digital building surveying via 3D scans becomes a decisive factor for success: it  enables energy consultants to manage the enormous workload and issue well-founded passes  without having to be physically on site for every building. 

The requirements for the new renovation certificate are set out in Article 12 (“Renovation Certificate”)  and Article 2 (“Definitions”).

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Technical retrofitting obligations: Building services engineers & facility  management 

Building Automation (BACS): Mandatory smart control systems for large installations 

The new EPBD significantly raises the standards for building automation in non-residential  buildings. By the end of 2024, an intelligent control and monitoring system will be mandatory for  large heating, air conditioning and ventilation systems with a rated output of more than 290 kW. By  the end of 2029, the requirement will apply from a threshold of 70 kW. Building services engineers  and facility managers are thus facing a massive wave of retrofitting: the aim is to monitor energy  consumption seamlessly, identify inefficiencies immediately and perfectly coordinate all building  services systems. 

The requirements for building automation are set out in Article 13 (‘Building Services  Systems’).

Infrastructure: Mandatory solar panels and charging infrastructure (e-mobility) in car parks 

The EPBD introduces a phased solar requirement: new public and commercial buildings will be the  first to be covered from 2027. Existing non-residential buildings will follow from 2028, and finally all  new residential buildings from 2030. This is accompanied by stricter requirements for e-mobility:  where non-residential buildings with more than five parking spaces are newly constructed or  extensively renovated, a charging point will be mandatory for every fifth parking space in future. In  addition, pre-wiring must be integrated for at least half of the parking spaces. 

The requirements are set out in Article 10 (‘Solar energy in buildings’) and Article 14  (‘Infrastructure for sustainable mobility’).

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New standards for planning and new construction: architects & project  developers 

Zero-emission buildings: The new standard from 2028/2030 

With the new EPBD, the previous ‘nearly zero-energy building’ standard for new construction will be “zero-emission building” (ZEB). In concrete terms, this means: these buildings have extremely low  energy requirements, which are met entirely from renewable sources – local CO₂ emissions from  fossil fuels are therefore prohibited. For new public buildings, this ZEB standard will become  mandatory from 2028, whilst for all other new buildings it will apply from 2030. 

The requirements are set out in Article 7 (‘New Buildings’) and Article 11 (‘Zero emission buildings’). 

CO₂ life-cycle analysis (GWP): The new requirement for embodied energy 

In addition to pure operational emissions, the EPBD now takes the entire life cycle of a  building into account: the life cycle greenhouse gas potential, also known as GWP (Global

Warming Potential), must be calculated and reported in the energy performance certificate from  2028 for large buildings and from 2030 for all new buildings. This means that the so-called  ‘embodied energy’ of building materials must be accounted for and minimised as early as the  planning phase. Embodied energy primarily covers manufacturing, transport and disposal. 

The requirements are set out in Article 7 (‘New Buildings’). 

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EPBD deadlines: Which obligations apply from when? 

As previous voluntary approaches and regulatory requirements have failed to drive the necessary  transformation forward – the building sector in Germany has repeatedly missed its reduction targets  – the EPBD Directive 2024 responds with binding requirements, minimum standards and deadlines. 

The EPBD was voted on by the European Parliament on 12 March 2024, adopted by the Council of  the European Union on 24 April 2024, and entered into force on 28 May 2024. 

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By when must the EPBD be implemented? 

The EPBD Directive must be transposed into national law by Member States by 29 May 2026. By  then, they must submit national implementation plans. In Germany, this is the Building Energy Act  (GEG). 

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What deadlines does the EPBD set for new buildings? 

• 2024: Since 1 January 2024, 65% of the energy used to power new heating systems in  new buildings must come from renewable sources. This does not apply to new buildings  constructed on vacant plots. This effectively bans the installation of fossil fuel boilers, such  as gas or oil. In cities with more than 100,000 inhabitants, this applies to all heating  system replacements by 30 June 2026; for smaller towns, by 30 June 2028. 

• 29 May 2026: 
  
  • For new buildings (as well as for extensively renovated residential and  non-residential buildings), the provision of charging infrastructure for electric vehicles and bicycle parking spaces will be mandatory. 
  • Digital energy performance certificates are now mandatory 
  • The digital energy performance certificate is now part of the building permit and documentation. All new buildings must be certified according to the new A–G scale.

• 2028: 
  
  • For large new buildings (> 1,000 m²), a CO₂ life-cycle analysis (GWP assessment) will become mandatory. The global warming potential of the building materials must be calculated and stated in the energy performance  certificate. Furthermore, the solar obligation applies to these buildings. 
  • New public buildings: From 2028, they must meet the net-zero emissions  standard (ZEB). This means they must no longer generate any on-site CO₂ emissions from fossil fuels. 

• 2030: 
  
  • From 1 January 2030, the zero-emission standard (ZEB) will apply to all new  buildings: they must no longer cause any on-site CO₂ emissions from fossil fuels. ○ In addition, the CO₂ life cycle analysis (GWP) applies to all new buildings: Proof of  global warming potential becomes mandatory for all new buildings and must be  included in the energy performance certificate. 
  • Furthermore, the solar requirement applies to all new buildings: all new buildings  must be equipped with solar installations (including a ‘solar-ready’ requirement in  the planning stage).

Exceptions: Historic buildings, churches and temporary structures, amongst others, may be  exempted from the renovation requirements. 

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What deadlines does the EPBD set for existing buildings? 

• 1 January 2025:  From January 2025, the automation requirement (BACS) applies to large-scale  systems/non-residential buildings (>290 kW). 

• 29 Maiy2026: 
  
  • For comprehensively renovated residential and non-residential buildings  (as well as new builds), charging infrastructure for electric vehicles and  
  • bicycle parking spaces must be provided. 
  • Digital renovation certificates will be officially introduced. 
  • The requirement for a digital energy performance certificate comes into force as  soon as a building is sold, re-let or undergoes a comprehensive refurbishment.  Existing certificates generally remain valid until their expiry date (usually 10 years),  but any new certificates issued from May 2026 onwards must comply with the new  standard, i.e. be certified according to the new A–G scale.
  • From 1 January 2028 (deadline: 31 December 2027), the solar obligation will apply to all public and non-residential buildings.
• 2030:  ‍
  
  • Mandatory renovation targets apply to inefficient non-residential buildings: at least  16% of buildings in the lowest energy efficiency class must be renovated by 2030. ○ For residential buildings, a national savings target applies: average energy  consumption must be reduced by 16% by 2030 and by at least 20% by 2035. In  accordance with the so-called ‘worst-first principle’, at least 55% of these savings  must be achieved where consumption is highest – namely in the 43% of residential  buildings that are the least efficient. 
  • Note: Germany must set the exact deadlines for 2030 by 29 May 2026 as part  of the GEG amendment. At present, there are no specific deadlines for the  individual renovation steps. 
  • From 1 January 2030, an extended monitoring and automation requirement (BACS)  will apply to non-residential buildings with a rated output of 70 kW or more. 
  • In addition, the solar obligation will apply to public buildings and to non residential buildings undergoing major renovation.

• ‍2033: Existing buildings with poor energy efficiency must meet mandatory renovation  requirements. At least 26% of non-residential buildings in the lowest energy efficiency class  must be renovated. 

Transition periods for fossil fuels: gas and oil 

According to the EPBD’s strategic target, the complete phase-out of fossil fuels is to be achieved  by 2040 at the latest. Member States may independently impose national installation bans. With  the Building Energy Act (GEG), Germany goes a step further than the EU’s minimum requirement  (2050) and sets the target for climate neutrality in buildings at 2045. 

In the existing building stock, the transition from fossil fuels to renewable heating energy is more  complex than in new builds. Here, Germany links the installation bans to local heating plans and  relies on a mix of deadlines and financial incentives. 

• 1 August 2022: Germany has implemented the ban on subsidies for fossil fuel heating  systems: the installation of new fossil fuel heating systems – i.e. systems running solely on  gas or oil – is no longer eligible for state subsidies. Subsidies are now only available for  renewable systems such as heat pumps or district heating connections. These can be  subsidised by up to 70%. The EU Buildings Directive for this regulation had set 2025 as the  target date. Germany is therefore leading the way here. 

• Transition periods for oil and gas:In existing buildings and in new builds on vacant plots,  fossil fuel heating systems may continue to be installed for the time being, provided the  relevant local authority has not yet submitted a binding heating plan. The 65% rule also  applies to existing buildings from the date the local heating plan is available (but no later  than the expiry of these deadlines). When replacing heating systems, no pure fossil fuel boilers. Towns and local authorities are obliged to implement such plans by  the following deadlines.

• 30 June 2026: By this deadline, large cities (>100,000 inhabitants) must submit their  heating plan 

• 30 June 2028: Smaller towns must submit their heating plans by this deadline.

• 2024: The regulations for heating systems will become significantly stricter: new gas-fired  heating systems installed after 2024 must, from 2029 onwards, be capable of running partly  on biomass or hydrogen (with an increasing proportion). 
  
  • 1 January 2029: at least 15% biomass or hydrogen 
  • 1 January 2035: at least 30%. 
  • 1 January 2040: at least 60%. 
  • 1 January 2045: 100%. From this point onwards, a total ban on the use of fossil  fuels such as natural gas or heating oil will finally come into force. By then,  replacement or a complete switch to climate-neutral gases will be mandatory. 

Financing tip: The government is helping homeowners with heating system replacements and  energy-efficient renovations – BAFA and KfW subsidise these measures by up to 70%. 

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Objectives of the EPBD: Why does the EU want to decarbonise the  building sector  

The EU aims to become climate-neutral by 2050, meaning it will no longer emit any net  greenhouse gases. With the EU climate package “Fit for 55”, it is targeting a 55% reduction in  emissions by 2030. Germany aims to achieve greenhouse gas neutrality as early as 2045. By  2030, emissions are set to fall by 65% compared to 1990 levels. 

The buildings sector is the biggest lever here: 

• It ranks first in energy consumption: buildings account for 40% of the EU’s energy  consumption and 36% of energy-related greenhouse gas emissions. Heating, cooling  and hot water production are responsible for 80% of household energy consumption. 
• Around 75% of the building stock is classified as energy-inefficient, according to the  Joint Research Centre, the European Commission’s scientific service. 
• At the same time, the annual renovation rate stands at just 1% per year.

The EPBD is now intended to trigger a wave of renovation and thereby 

1. reduce dependence on fossil fuels 
2. strengthen energy independence and security, and 
3. reduce energy costs for consumers. 

The European Commission aims to double the renovation rate over the next ten years (from 2020)  from 1% to at least 2%. Environmental organisations, such as the German Environmental Action  Network (DUH), even consider a rate of at least 3% per year to be necessary to achieve the targets.

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EPBD and GEG – how do the EU Directive and German law ( )  relate to one another? 

The current Building Energy Act (GEG 2024) has transposed the requirements of the old EU Buildings Directive into German law. However, the current version of the EPBD from May 2024  is not yet reflected in it. The GEG 2024 is a ‘heating law’, whilst the EPBD is a ‘building renovation  law’. Germany must bring the GEG into line with the requirements of the new EU Directive by 29  May 2026, particularly regarding the energy-efficient refurbishment of existing buildings (MEPS)  and the net-zero emissions standard for new buildings. 

In addition, amendments to other laws, particularly the state building regulations, are to be  expected. The corresponding draft of the Building Modernisation Act (GMG) is currently being  negotiated. 

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What does the GEG already cover? 

The GEG 2024 has already implemented key provisions at national level: 

• 65% renewable energy (RE) for heating system replacements: From 1 January 2024 (or in  conjunction with municipal heat planning), new heating systems must be powered  predominantly by renewable energy. 
• Municipal heating plans: Linking heating system replacements to municipal heating plans by 2026/2028 is a key component of the German implementation roadmap.
• System technology in operation: Regulations on heating system inspection, optimisation  and hydraulic balancing ensure more efficient operation. 
• Minimum standards for refurbishment: Existing buildings must meet the minimum efficiency requirements.

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Where adjustments are needed 

The following points have not yet been implemented at national level. These must be transposed  into national law by 29 May 2026 via an amendment to the GEG: 

• Zero-emission buildings (ZEB) as the standard for new construction: From 2028 (public  buildings) and 2030 (all new buildings) respectively, the ‘zero-emission building’ standard  will be mandatory. The GEG has so far mostly targeted EH-55 or EH-40 (nearly zero-energy  buildings), whilst the EPBD requires even higher efficiency levels that no longer use fossil  fuels. 

• Minimum energy performance standards (MEPS) for existing buildings: The EPBD  requires the renovation of the worst-performing non-residential buildings (16% by 2030,  26% by 2033). For residential buildings, there is no individual renovation requirement, but  rather a national average trajectory: a 16% reduction in primary energy consumption by  2030, and a 20–22% reduction by 2035 compared to 2020. This means mandatory  renovations for energy classes G/H, which is currently missing from the GEG.

• Life-cycle emissions: From 2028, the global warming potential of the entire life cycle  (building materials, construction, demolition) must be calculated and reported for  new buildings. 

• Building Pass / Renovation Pass: A standardised, voluntary renovation pass for buildings  is planned to enable the phased planning of refurbishments. 

• New energy performance certificate scale A–G: The current GEG uses a scale from A+ to H  (based on final energy consumption). The EPBD stipulates an EU-wide harmonised scale  from A to G, whereby ‘G’ denotes the bottom 15% of the national building stock in terms of  energy performance and ‘A’ stands for zero-emission buildings. This requires a complete  recalibration of the German classes. 

• Solar mandate: Whilst some federal states (e.g. Baden-Württemberg, Berlin) already have  their own solar mandates, the GEG lacks a uniform nationwide regulation. The EPBD now  requires fixed deadlines: for new public and large non-residential buildings (>250m²) from  1 January 2027, and for all new residential buildings from 1 January 2030. 

• National Building Renovation Plan: This new strategic instrument replaces the previous  long-term renovation strategy. Germany must submit a detailed plan by 31 December 2026  setting out how the entire building stock will become climate-neutral by 2050, including  interim targets for 2030 and 2040. 

• Fossil fuel heating systems by 2040: The GEG 2024 currently permits the operation of  fossil fuel heating systems until 31 December 2044. However, the EPBD requires a  complete phase-out of fossil fuels in heat supply by 2040 at the latest. German legislators  must make adjustments here. 

• Expansion of charging infrastructure: The EPBD significantly tightens the requirements for e mobility. In future, car parks at residential and non-residential buildings must be equipped  with charging stations and the necessary pre-wiring to a far greater extent than is currently  specified in the GEG. 

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Current status: When will the EPBD be implemented in Germany? 

EU Member States have until 29 May 2026 to transpose the EPBD Directive, which came into  force in May 2024, into national law. In Germany, this primarily concerns an amendment to the  Building Energy Act (GEG). Whether this deadline will be met is currently unclear – a concrete  draft bill has not yet been presented. 

Implementation is facing political headwinds. The new federal government plans to use the  Building Modernisation Act (GMG) to water down parts of the GEG in 2024 – in particular, the  65% renewable energy requirement for heating system replacements is set to be relaxed. 

At the same time, Germany must implement the EPBD by the deadline, which in turn calls for a  complete phase-out of fossil fuel heating systems by 2040. This contradiction – relaxing  requirements at national level whilst tightening them at European level – is causing considerable  uncertainty among property owners, planners and the housing sector.

One thing is clear: the EPBD sets the binding framework against which the GMG must also be  measured. Anyone investing today should therefore base their decisions on the European minimum  standards – not on any potential short-term concessions. 

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Obligations: What does the EPBD mean for existing buildings? 

Obligations for (private) owners of existing buildings 

The EPBD does not impose an individual obligation to renovate your residential building. However, if  your building falls into energy efficiency class G or H, you should assume that targeted policy  measures will be directed at you – for example, through stricter EEC requirements or eligibility criteria. Furthermore, Member States are obliged to impose effective  and dissuasive penalties. It is likely that – as is the case under the existing EEC – breaches of  renovation obligations will be subject to fines. 

Check the energy performance of your building now and seek advice. Those who renovate early  secure better funding conditions and avoid future loss of value. 

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Local authorities and the public sector – special deadlines 

If you are responsible for public buildings, the strictest deadlines apply to you. Your new buildings  must meet the net-zero emissions standard from as early as 2028. For your non-residential  buildings, the MEPS renovation deadlines apply directly. Furthermore, you must drive forward local  heating planning and establish the infrastructure for the heating transition on the ground. Start now  by taking stock of your building portfolio and prioritise the properties with the poorest energy  performance. 

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Industry and commerce – the strictest deadlines 

If you own or operate commercial non-residential buildings, such as offices, factories or warehouses,  you are subject to the strictest requirements of the EPBD. In addition to the MEPS renovation  deadlines, you must retrofit building automation systems, install solar panels on suitable roof areas  and expand charging infrastructure in your car parks. Get a systematic overview of your building  portfolio now and identify which properties need to be renovated first. 

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Energy consultancy, architecture and specialist planning – opportunities and  challenges 

In addition to standard energy performance certificates, you will in future need to issue renovation  certificates, calculate CO₂ life-cycle assessments and apply the new EU scale. As an architect or specialist  planner, you must account for the embodied energy of building materials as early as the initial  planning phase. Important: Even if the directive does not currently impose an immediate legal obligation, you may be contractually obliged to comply with the new standards. You  should therefore take these requirements into account now in order to advise your clients with  foresight and future-proofing in mind.

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Construction and renovation – a growing market 

The construction and renovation market is growing significantly as a result of the EPBD – the  renovation rate is set to rise sharply in the coming years. At the same time, the shortage of skilled  workers is becoming more acute.  Invest now in training your teams and in standardised renovation concepts to meet the rising  demand and secure a competitive advantage.

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Property management firms – the central hub 

You coordinate between owners, tenants, energy consultants and contractors. Particularly in the  case of multi-family homes and mixed-use buildings, you must initiate renovation processes, prepare  resolutions and oversee implementation. Be prepared for the fact that the new obligations – energy  performance certificates, renovation passports, MEPS deadlines – will significantly increase your administrative workload. Establish the necessary  processes and partnerships now. 

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Implement the EPBD efficiently with digital data collection 

The EPBD requires property owners, local authorities and the housing sector to undertake an  unprecedented wave of refurbishments. Renovation certificates, new energy performance  certificates on an A–G scale, CO₂ life-cycle assessments, MEPS certificates – all of this requires a robust database. Without  precise, up-to-date building data, not a single one of these obligations can be fulfilled efficiently.  Those who view the new requirements not merely as a regulatory burden but as a strategic  opportunity, and who invest in digital tools, can significantly accelerate the process – and secure  competitive advantages in the process. 

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Digitised building inventory is the first step towards refurbishment 

Before refurbishment, planning or the issuance of a renovation certificate can take place, a  comprehensive inventory is required. In practice, manual data collection and processing alone can  consume up to 35% of the total project duration of an energy consultancy – involving multiple on-site  visits, handwritten notes and error-prone data transfers. 

Lumoview’s LumoScanner eliminates this bottleneck: the patented 3D laser scanning system  captures rooms in 2 seconds per scan – up to 10 times faster than traditional methods. It delivers  precise geometric data, automatically masks out furniture and people, and creates 360° infrared  images to identify thermal bridges. 

Combined with drone photogrammetry for façades and roofs, this creates a complete digital twin –  the ideal basis for energy performance certificates, renovation certificates and renovation roadmaps. Site inspection times are reduced by up to 80%, and the overall effort is cut by  up to two-thirds. 

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Automated data processing for planning and implementation 

The captured data is automatically processed into 3D CAD models, floor plans, room schedules  and thermal analyses – AI-supported and without manual rework. Via Lumoview’s cloud-based  platform, all results are available in industry-standard formats (IFC, RVT, AutoCAD, DWG, PDF)  and can be seamlessly integrated into existing systems. 

This provides energy consultants, architects and property managers with a unified, digital database  for iSFP, renovation planning, documentation and subsidy verification. Instead of paper chaos and  media discontinuities, Lumoview creates a seamless, digital process from data capture to the final  verification. 

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Frequently asked questions about the EPBD (FAQ) 

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What is a zero-emission building? 

A zero-emission building requires little or no energy, produces no CO₂ emissions from fossil fuels  on site, and minimises greenhouse gas emissions. Instead, it meets its energy needs primarily  through renewable energy sources. Furthermore, where technically and economically feasible, it  should be able to respond to external signals – key concepts: smart readiness and load flexibility. 

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What energy efficiency class must a house have by 2030? 

Private residential buildings do not need to achieve a specific energy efficiency class (such as E or  F) by 2030. These original plans were rejected in the final text of the EPBD. Instead, the national  target in Germany is to reduce the average energy consumption of all residential buildings by 16%  by 2030.  The situation is different for non-residential buildings (such as offices or industrial premises): here, a  strict quota applies. The 16% of buildings with the worst energy performance must be mandatorily  renovated by 2030. 

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Which buildings must be renovated by 2030? 

This depends largely on the type of building: 

• Non-residential buildings (commercial, industrial, municipal) are subject to strict  requirements: the 16% of the national building stock with the poorest energy  performance must be renovated by 2030.
• There is no direct EU obligation to renovate private residential buildings. However, Germany  is focusing on the worst 43% of the stock (mostly energy efficiency classes G and H, built  before 1978). The risk for owners: even without a direct EU requirement, the situation in  Germany remains critical due to the GEG – strict retrofitting obligations come into effect at  the latest when there is a change of ownership. Those who fail to act risk massive losses in  value due to future regulations and falling demand. 

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What penalties apply for breaches of the EPBD? 

The EPBD itself does not contain a specific list of fines. However, it obliges EU countries to  introduce ‘effective, proportionate and dissuasive’ penalties. In Germany, these are currently  regulated by the Building Energy Act (GEG) and the 

Building Electromobility Infrastructure Act (GEIG) – further tightening of the rules is possible. In practical terms, this means for owners and developers: 

• €5,000 to €50,000 (GEG): These fines may be imposed for energy-related  administrative offences, such as failing to replace old boilers, a lack of pipe insulation or incorrect information on the energy performance certificate. 
• Up to €10,000 (GEIG): This penalty applies if requirements regarding  electric vehicle charging infrastructure in new buildings or major renovations are ignored. 

The government is also under pressure. If Germany implements the EPBD too late or incompletely,  it faces infringement proceedings before the European Court of Justice (ECJ), heavy fines and the  withdrawal of EU funding. 

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What will be mandatory for homeowners from 2026? 

There is no blanket renovation obligation for homeowners from 2026 onwards. However, once a district heating plan has been submitted in their local authority area, homeowners  are obliged to use at least 65% renewable energy when replacing their heating systems – although  the new federal government intends to replace this requirement with a more flexible green gas  quota in the planned Building Modernisation Act (GMG). 

The existing GEG obligations remain in place: 

• the obligation to replace constant-temperature boilers over 30 years old 
• retrofitting obligations in the event of a change of ownership (floor insulation, pipe insulation) 
• the requirement for an energy performance certificate when selling or letting. 

In addition, the CO₂ price will rise further in 2026, making fossil fuel heating noticeably more  expensive. 

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Is an energy consumption certificate still permitted? 

Yes, the energy performance certificate will generally remain valid after May 2026 – though only to a  limited extent.

• An energy consumption certificate will only be permitted for larger apartment blocks  with five or more residential units, provided the building meets at least the  requirements of the 1977 Thermal Insulation Ordinance. 
• For single-family to four-family homes, the energy performance certificate remains  mandatory – as has already been the case for unrenovated buildings with planning  permission granted before November 1977. Energy performance certificates already issued  remain valid for ten years, even if they still use the old scale (A+ to H).