EPBD implementation in France and Italy: from regulation to asset-level impact

April 20, 2026

The Energy Performance of Buildings Directive (EPBD) ((EU) 2024/1275) replaces the previous Directive 2010/31/EU and sets out a common EU structure for how building energy performance is defined, measured and progressively tightened.

It is part of the EU’s broader climate and energy acquis and sits alongside the Energy Efficiency Directive and Renewable Energy Directive as one of the core implementation tools for the 2030 and 2050 climate targets. Its scope covers both new and existing buildings, including residential and non-residential stock, and it combines performance standards, renovation trajectories and system requirements into a single framework.

By the time the EPBD is fully transposed, most of its effects will already have been absorbed.

That reflects the scale of what the directive is trying to move. Buildings account for around 40% of EU energy consumption and 36% of greenhouse gas emissions, making them the largest single energy-using sector in Europe. Around 75% of the building stock is energy inefficient, 35% is over 50 years old, and renovation rates have remained close to 1% per year for years, according to the European Commission and the European Defence Agency’s overview of the sector.

Those figures sit behind the EU’s macro trajectory. The EPBD is one of the core delivery tools for the European Green Deal and the Fit for 55 package, which together anchor the legally binding target to reduce emissions by at least 55% by 2030 and reach climate neutrality by 2050. The European Parliament Research Service frames the directive in exactly those terms, as a structural lever for economy-wide decarbonisation rather than a sectoral measure. The European Environment Agency makes a related point, noting that more than half of building energy use remains fossil-based, particularly for heating, which explains the focus on system replacement alongside efficiency.

There is also a macroeconomic layer that tends to be underplayed. Construction and renovation represent roughly 9% of EU GDP and 18 million jobs, and several policy institutes, including Bruegel, have pointed to the EPBD as a key driver of industrial activity over the next decade, particularly in electrification, materials and building systems.

The Directive itself leaves relatively little ambiguity on timing. Member States are expected to transpose by 29 May 2026, with a shorter deadline of 31 December 2025 for provisions on the removal of incentives for standalone fossil-fuel boilers. From 1 January 2028, all new public buildings must be zero-emission, followed by all new buildings from 1 January 2030. Alongside that, Article 9 introduces minimum energy performance standards (MEPS) for non-residential buildings, requiring the worst-performing stock to be addressed progressively. The Commission’s overview of the Directive sets out these milestones in detail.

Those dates tend to be read as future milestones. In practice, they are already shaping how national frameworks are being adjusted, a point increasingly reflected in financial press coverage where EPBD is treated as a near-term valuation issue rather than a distant compliance exercise.

France: alignment through existing instruments

France enters this phase with most of the structural pieces already in place.

The Décret Tertiaire effectively operationalises a trajectory logic comparable to Article 9, requiring staged reductions in energy consumption across the tertiary stock (−40% by 2030, −50% by 2040, −60% by 2050). While not formally framed as MEPS, it produces a similar outcome in which persistent underperformance becomes increasingly difficult to maintain.

Energy performance certificates (DPE) already function as a filtering mechanism for the residential sector, with restrictions on leasing for the lowest-rated dwellings tightening progressively. This sits alongside the EPBD’s focus on addressing the worst-performing buildings first.

Where the directive begins to reshape the French framework is in areas that were previously less central.

Article 7 and 8, which cover new buildings and major renovations, introduce the zero-emission building standard and strengthen requirements around technical building systems. France’s RE2020 regulation already integrates carbon into new construction, but the EPBD pushes toward a more explicit convergence between operational and embodied emissions. EU technical platforms such as BUILD UP have been signalling this shift for several years, particularly around lifecycle carbon methodologies.

Article 13, on building automation and control systems, reinforces an area where France has already moved early. Existing BACS obligations are likely to be extended and more closely linked to ongoing performance verification. Research published through EU technical forums highlights persistent “performance gaps” between designed and actual building energy use, sometimes reaching 40–50%, which helps explain the policy emphasis on monitoring and control systems.

The formal legislative process is still ongoing, with additional measures expected on solar deployment under Article 10, EV infrastructure under Article 14, and renovation planning. The timeline remains aligned with the 2026 deadline, but much of the substance is already functioning in practice.

What changes for companies is not the presence of new rules, but the way existing ones connect to a European baseline that is becoming harder to deviate from.

Italy: structure catching up with policy direction

Italy’s timeline is formally the same. Transposition is due by May 2026, with early application of the fossil boiler incentive ban from January 2025. The way those milestones are being approached is different.

The removal of incentives for standalone fossil boilers, required under Article 17, has already been reflected in national policy direction, although implementation has not been entirely linear. Incentive schemes remain central to how Italy drives renovation, and their interaction with EPBD requirements continues to evolve. This has been widely discussed in Italian and European press, particularly in relation to the fiscal cost and redesign of the Superbonus scheme.

The more structural elements of the directive are expected to take clearer shape over the next 12 to 18 months.

Article 9 will require a more explicit definition of performance thresholds across the non-residential stock, something that does not yet exist in a fully consolidated form. Similarly, the national building renovation plan under Article 3, which is intended to map out trajectories to 2030, 2040 and 2050, remains in development. At EU level, these plans are expected to anchor the transition of the existing stock, particularly given that over 85% of today’s buildings will still be standing in 2050, as highlighted in Commission materials and policy analysis.

For new buildings, the zero-emission requirement from 2030 under Article 7 aligns with existing efficiency standards but will require further integration of renewable energy and system performance criteria. Solar obligations under Article 10 are also likely to accelerate deployment, particularly in commercial assets.

What distinguishes Italy is not a lack of movement, but the sequencing. Policy signals such as tax credits, electrification incentives, and the phased withdrawal of fossil systems are already pushing the market in the direction set by the EPBD. The regulatory framework that consolidates those signals is arriving more gradually.

For companies, that means working with a structure that is still taking shape, where key parameters such as thresholds, timelines and enforcement mechanisms are still being fixed.

Asset-level impact

Across both countries, the most immediate effects tend to cluster around a few articles.

Article 9 introduces a forward constraint on the lowest-performing assets, even before national thresholds are formally defined. This matters in a context where around three quarters of EU buildings are inefficient, implying that a significant share of assets will eventually fall within scope.

Article 7 and 8 bring the zero-emission standard into new construction and major renovation. The move from nearly-zero to zero-emission buildings builds on earlier regulatory cycles but now removes on-site fossil emissions entirely.

Article 13 on technical building systems and Article 14 on infrastructure for sustainable mobility extend compliance into operational and infrastructural domains, including automation, monitoring, and EV readiness.

Article 10, which addresses solar energy in buildings, is likely to have a visible impact in both jurisdictions. These provisions interact with financing conditions, disclosure requirements and national incentives. This is where their practical weight tends to accumulate.

Implications for compliance programmes

The 2025 and 2026 deadlines provide structure, but they are not the point at which the Directive starts to matter. The requirements on new buildings in 2028 and 2030, along with the progressive tightening under Article 9, extend that structure further into the decade.

In France, the priority is coherence. Existing obligations already cover much of the EPBD scope, but aligning them across energy, carbon, systems and reporting requires more coordination than before.

In Italy, the priority is adaptability. Directional clarity allows investment decisions to move ahead, but the absence of fully fixed parameters means those decisions need to accommodate adjustment.

Across both, certain elements are difficult to defer. Data structures capable of handling energy and carbon together, visibility at portfolio level, and early integration of system-level requirements such as automation and electrification readiness tend to reduce friction later.

What is already visible is how those future points are being pulled forward into present decisions through financing, tenant expectations and national policy adjustments. This dynamic is increasingly reflected in policy analysis and market commentary, where EPBD is treated as a valuation framework as much as a regulatory one.

France shows how that process can take place within an established regulatory system. Italy shows how it unfolds while that system is still consolidating.

In both cases, the endpoint is fixed. What remains variable is how directly each step toward it is expressed in national law at any given moment.

CPM