The revised Energy Performance of Buildings Directive reached its general national transposition deadline on 29 May 2026. Individual projects still need a careful check of the national rules applicable to them.
The EU implementation timetable
The Commission reported on 15 July 2026 that it had opened infringement procedures concerning incomplete transposition in all Member States. That announcement concerns the position at that date; it is not a substitute for checking subsequent national measures.
The project-level implication
Separate EU policy objectives, national statutory duties and the performance voluntarily promised in the contract. New construction, major renovation and existing buildings can have different triggers. Do not assume that every directive requirement is directly enforceable against a private owner in the same way.
Make energy obligations measurable
Specify the performance target, calculation basis, testing and handover records. Coordinate energy measures with fire safety, heritage, use and operating requirements. A project contract should identify who monitors legal changes and who bears the consequences of a changed design.
Four practical examples
Illustrative scenarios: the appropriate steps depend on the contract, evidence and applicable law. These are not reports of client matters.
A major office renovation
Check the national requirements triggered by the proposed works and the relevant date.
A heritage building
Coordinate energy targets with protected features and available legal routes.
A contractual green target
Distinguish the promised standard from the minimum statutory duty.
A phased project
Assess which requirements apply to each phase and approval.
Further guidance
Legal framework & further reading
Reviewed: 12 November 2026. Statutory references are to German law unless stated otherwise.