EU Energy Performance of Buildings Directive

By Daniel O’Reilly l ARCH x TECTURE

As the EU prepares for a full decarbonisation by 2050, various directives regarding the decarbonisation of new and existing buildings are steadily progressing through the institutions of the EU. To support decarbonisation, 97% of existing EU building stock must be renovated to achieve a zero emission building – ZEB standard 1. This is a massive challenge for property owners, architects and policy makers to achieve. The final version of the directive has yet to be agreed on, however there is a rare common unity between the branches of the EU on implementing radical changes to building practices and standards. Key new metrics to take into account are:


Zero Emissions & Near Zero Emission Buildings

Zero-emission building (ZEB) means a building that has a very high energy performance, while the nearly zero or very low amount of energy required should be covered in entirety by energy from renewable sources, including energy from renewable sources produced on-site or nearby. In addition the building should be a net energy contributor, whether this be through heat reclamation, micro-generation or similar means of positive impact to the energy neighbourhood. 

Nearly zero-emission building (NZEB) means a building that has a very high energy performance, while the nearly zero or very low amount of energy required should be covered to a very significant extent by energy from renewable sources, including energy from renewable sources produced on-site or nearby


The Life-Cycle Global Warming Potential

Soon architects and stakeholders will have to consider the potential lifecycle carbon impact of decisions taken during the planning process. This comes in the form of a new EU defined metric, the GWP (global warming potential).

“The global warming potential (GWP) over the whole life-cycle indicates the building’s overall contribution to emissions that lead to climate change. It brings together greenhouse gas emissions embodied in construction products with direct and indirect emissions from the use stage.” 

– EU Parliament Report 2023

Calculation of a building’s GWP will become mandatory for new buildings over 2000m2 as of January 2027 and all new buildings as of 2030. The exact limits and ramifications of having an excessive GWP have yet to be established, and shall vary by each member state. This should not factor significantly into existing buildings, where the majority of their carbon has already been expended. Instead increasing the building’s energy performance shall be the main consideration for renovation works.


Minimum Energy Performance Standards

Building energy performance certificates is not a new concept in Europe. However, there is still a significant divergence between standards in each member state. Countries such as Germany and Spain have acquired a poor reputation for energy efficiency4, whereas nearby countries in similar climates, such as Denmark and Portugal, have a much higher level of energy efficient buildings. The EU aims to address this by harmonising these standards. 

Under the updated certification system, the worst 15% of building stock shall be labelled as G, the lowest rating available. These G rated buildings shall be the first to be renovated under national renovation plans, with both F and G rated stock set to be fully upgraded by the end of the decade. Each member state must develop their own national renovation plan, with the ultimate goal of every building, both new and existing, being rated a ZEB standard by 2050. Currently only 2% of buildings in Germany qualify for a ZEB or NZEB rating, meaning 98% of Germany’s existing building stock must be renovated.

Renovation Specific Proposals

The EU makes a distinction between deep and major renovations.

Major renovation

Shall be defined in law, by each member state as either in terms of a percentage of the surface of the building envelope or in terms of the value of the building. (likely 25% of building surface or 25% of a building’s value)

Deep renovation

Before January 2030, a deep renovation is defined as a renovation which transforms a building into a NZEB. After January 2030, this is defined as a renovation which transforms a building into a ZEB.


Building Renovation Passports

The use of building renovation passports to stage and plan for long term renovations up to the ZEB standards is encouraged. This can aid with the financial cost and minimise the disruption of renovating a building, by splitting the overall goal of a ZEB into multiple stages of work. Individual measures can be completed at each stage, rather than one large scale building project. 

EU Definition:

A Building Renovation Passport (BRP) is a document – in electronic or paper format – outlining a long-term (up to 15-20 years) step-by-step renovation roadmap to achieve deep renovation for a specific building.

Draft Timeline

Current EU Parliament Proposal

New public buildings must have a solar installation

New non-residential buildings over 250m2 must have a solar installation


New public buildings must be ZEB

Existing public and non-residential buildings must achieve a F energy rating

Existing non-residential buildings, over 400m2 undergoing significant renovations must have a solar installation

Member states must implement special administrative and financial measures to support the upgrade of G, F & E rated building stock, to NZEB standard. 


All new public buildings must be zero-emission


All new residential buildings must have solar installed


All new buildings must be ZEB

Existing public and non-residential buildings must achieve an E energy rating

Existing residential buildings must achieve a F energy rating


Existing residential buildings must achieve a E energy rating

The average energy rating of building stock in a country should be D


All buildings must be zero emission

Draft Measures from Date of Enactment

Not dependent on a specific date

Complete ban on the use of fossil fuel heating systems in new buildings and buildings undergoing major renovation, deep renovation, or renovation of the heating system.

24 Months

Member States shall ensure that all new buildings are designed to optimise their solar energy generation


Each EU country will be in charge of defining their own list of exceptions to the renovation criteria under the Parliament’s proposal. However, they would comply with these general categories for exceptions.

  • protected buildings (for their environment, architecture, or historical merits)
  • buildings used as places of worship and for religious activities;
  • industrial or temporary buildings
  • secondary residential buildings (occupied for four months of the year or consumes less than 25% of energy, for year round use)
  • stand-alone buildings with a total useful floor area of less than 50 m2

There is still much disagreement over the nature and extent of renovations on architecturally and historically significant buildings, without monument/listed status. This shall likely be a focus of the tripartite negotiations between the Parliament, Council and Commission, with exceptions and specific guidance per building typology produced by the member states. 


The EU hasn’t a reputation for quick decisions, so this directive and accompanying measures may be stuck in the legislative process for some time yet. What is currently summarised may also differ to the final text, with these proposals being the most recent by parliament. With the EU’s tripartite (three legislative bodies) decision making process, compromise must be reached between the Council, Commission & Parliament. This could mean that other branches of the EU will ‘water-down’ parliament’s initial proposals, or may even propose more radical changes. 

Regardless of minor changes agreed inter-institutionally, there is common agreement that the future of construction in Europe will be defined by ZEB & NZEB new builds and renovations. Poorer standards will become a thing of the past, and micro-generation (through solar or heat reclamation) will become a feature of the vast majority of buildings.

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