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EPBD IV: De nieuwe standaard voor duurzame gebouwen in Europa

Deze blog beschrijft de Energy Performance of Buildings Directive IV (EPBD IV) en de gevolgen ervan voor gebouweigenaren, ontwikkelaars en investeerders. Daarnaast biedt de blog een overzicht van recente ontwikkelingen op het gebied van ESG-governance, transparantie, financiële regelgeving en juridische vraagstukken.

8 May 2025

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Deze blog gaat verder in het Engels:

The Energy Performance of Buildings Directive IV (EPBD IV) marks the next step towards decarbonising the European building sector. With buildings accounting for 40% of the energy consumed and 36% of energy-related greenhouse gas emissions in the EU, the transition of the building sector is crucial for achieving the Fit-for-55 climate targets. The EPBD IV outlines key measures to ensure that both new and existing buildings are aligned with these ambitious targets. Here is what to expect and how to prepare.

Implementation into Dutch law

The EPBD IV entered into force on 28 May 2024. As an EU Directive, it requires transposition into national laws to take effect. The implementation deadline for member states is 30 May 2026. In the Netherlands, most provisions will be incorporated into the Environment Buildings Decree (Besluit bouwwerken leefomgeving). The Dutch government expects to publish the implementation texts for consultation around mid-Q2 2025.

Transition to Zero Emission Buildings

From 2030 onwards, all new buildings in the EU must be Zero Emission Buildings (ZEBs). For existing buildings, the goal is full alignment by 2050. ZEBs are buildings with exceptionally high energy performance that consume minimal or no energy, emit zero on-site carbon from fossil fuels, and generate little to no operational greenhouse gas emissions. Operational greenhouse gas emissions are those released during the use of a building, such as those from heating, cooling, lighting, and appliances. While specific criteria for ZEBs will vary between member states, all must adhere to energy demand thresholds based on cost-optimal performance levels. The Commission will update the methodology for calculating these levels by 2028. Until the ZEB standards take full effect in 2030, new buildings must meet nearly-zero emissions energy standards (NZEB) and comply with any additional national standards. Buildings for which planning applications are submitted before the ZEB deadlines may be excluded, depending on the rules of a member state.

Strengthening digitalisation, solar-readiness and sustainable infrastructure

The EPBD IV emphasises the digitalisation of energy systems in buildings, promoting smarter energy management. New buildings must be designed to maximise their potential for solar energy generation and be solar-ready. The EPBD IV also supports the development of infrastructure for sustainable mobility, including the installation of charging stations for electric vehicles in both new and renovated buildings. Member states may adapt these standards to their national contexts, taking into account factors such as grid capacity or congestion.

Minimum Energy Performance Standards

The EPBD IV introduces minimum energy performance standards (MEPS) for both new and existing buildings. These standards set out a pathway for gradually improving the energy efficiency of the building stock, starting with the least energy-efficient buildings. Measures include replacing outdated heating systems, ventilation and electrical equipment, as well as improving insulation in walls, roofs, and floors. For residential buildings, the EPBD IV sets targets to reduce average primary energy use by at least 16% by 2030, compared to 2020 levels. Further reductions are required by 2035 and 2050. Non-residential buildings must also meet specific performance requirements. By 2030, Member States have to renovate the worst-performing 16% of non-residential buildings, with this threshold increasing to 26% by 2033.

Harmonised energy labels

Currently, energy label systems vary significantly between member states, making intra-EU comparisons between buildings difficult. The EPBD IV harmonises the energy performance criteria across the EU. All member states are required to adopt a revised rating system ranging from A to G, where A represents zero-emission buildings and G denotes the worst-performing buildings. As a result of the harmonisation, all existing A+ labels in the Netherlands will disappear from 2030 onwards when new energy labels are issued. These will be replaced by new levels. Member states have some flexibility in setting rating levels for classes B to F based on the characteristics of their building stock. The new system applies to EPCs issued after 29 May 2026, except in certain cases, such as buildings with complex energy systems, where it will take effect on 31 December 2029. This harmonisation will improve cross-border comparisons and facilitate informed decision-making.

Incentivising financial institutions to finance renovations

By 29 May 2025 the Commission will publish a voluntary portfolio framework to help financial institutions scale up their lending volumes for energy renovations, for instance using green loans or energy performance contracts. By complementing the existing measures with financial incentives such as tax breaks or subsidies, renovation rates can be significantly increased. Upgrading buildings for EPBD IV compliance will typically qualify as a Taxonomy-aligned economic activity. EPBD IV will also enhance the financial sector’s information position on the energy performance of EU real estate, as the EPBD IV renovation passport will be publicly accessible through national databases.

Connecting EPBD IV to CSRD: supporting accurate sustainability reporting

Buildings are often among a company’s most energy-intensive assets, representing a significant share of their scope 1 emissions. Under the Corporate Sustainability Reporting Directive (CSRD), companies within scope are required to disclose a breakdown of their real estate, categorised by their energy performance classes under the EPBD IV, or by energy consumption ranges. The harmonisation of energy performance criteria under EPBD IV will enhance comparability of EU-wide reporting on this subject. Reporting entities may include additional disclosures in their CSRD report regarding the energy-efficiency improvements made to their real estate under EPBD IV, such as digitalisation measures, solar-readiness and sustainable infrastructure.

Conclusion

The EPBD IV will introduce significant changes to building legislation, aiming to enhance the energy-efficiency of the EU’s built environment. This will provide benefits such as reduced energy consumption, lower carbon emissions and potentially increased property values. However, the rules will also pose challenges for building owners, developers and investors. The costs of improving building energy efficiency can vary significantly, and renovation measures may affect building availability and lease agreements.

To navigate these changes effectively, it is necessary to understand the EPBD IV requirements and plan renovations in a timely and cost-efficient manner. By strategically improving energy efficiency and sustainability, building owners, developers and investors not only contribute to a sustainable future but also protect and enhance the long-term value of their assets.

What it means for you

  • Companies should incorporate the minimum energy performance standards (MEPS) into their long-term strategy and decision making on their real estate. This includes identifying which buildings may fall below future thresholds and prioritising them for upgrades.
  • Energy labels issued after 29 May 2026 may be classified differently, even if based on the same building data, depending on national implementation. A current A+ rating could be downgraded under the new EU-wide A–G scale. Companies should reassess how energy label changes might affect property valuations, lease terms, or financing conditions.
  • Developers will need to apply the EPBD IV’s regulations, particularly with regard to ZEBs and MEPS. It may be prudent to start applying stricter energy efficiency and solar-readiness criteria now to avoid redesigns, delays, or non-compliance later.
  • Compliance with the national rules emanating from EPBD IV may require significant financial investments in adjustments and renovations. Companies should duly anticipate these financial investments and practical implications of adjustments and renovations. Start budgeting early and explore funding opportunities, including green loans, subsidies, or Taxonomy-aligned investment vehicles.
  • Companies that act early can reduce future costs, enhance sustainability credentials, and protect the long-term value of their assets. Proactive upgrades not only support compliance but also improve tenant appeal, lower operating expenses, and strengthen ESG reporting under the CSRD.

Bron: NautaDutilh

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