COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 2010/31/EU on the energy performance of buildings
Date: 2016-11-30
Institutions: Directorate-General for Energy, European Commission
Subjects: building, building services, energy consumption, energy efficiency, energy saving, improvement of housing, innovation, reduction of gas emissions, technological change

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, XXX  SWD(2016) 414   COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document Proposal for a Directive of the European Parliament and of the Council  amending Directive 2010/31/EU on the energy performance of buildings   {COM(2016) 765} {SWD(2016) 415}  
 
 
Table of Contents  

1 

INTRODUCTION ....................................................................................................... 4 

1.1  General context .................................................................................................. 4 

1.2  Review process .................................................................................................. 6 

1.3 

Impact assessment ............................................................................................. 7 

2  WHAT IS THE PROBLEM AND WHY IS IT A PROBLEM? ................................. 8 

2.1  Basic problem and its extent .............................................................................. 8 

2.2  The current legislative response and its evaluation ......................................... 10 

2.3  Problems and drivers ....................................................................................... 12 

2.4  The 'Smart Finance for Smart Buildings' Initiative ........................................ 17 

2.5  Who is affected and how? ............................................................................... 21 

2.6  How would the problems evolve? ................................................................... 22 

3  WHY SHOULD THE EU ACT? .............................................................................. 22 

3.1  Subsidiarity and proportionality ...................................................................... 22 

3.2  Macroeconomic and other benefits ................................................................. 24 

3.3  Energy and climate .......................................................................................... 25 

3.4  Coherence ........................................................................................................ 26 

4  WHAT OBJECTIVES SHOULD BE ACHIEVED? ................................................ 28 

4.1  General and specific objectives ....................................................................... 28 

4.2  Links to problems and drivers ......................................................................... 29 

4.3  Complementarities ........................................................................................... 30 

5  WHAT ARE THE OPTIONS TO ACHIEVE THE OBJECTIVES? ....................... 30 

5.1  No-change option ............................................................................................ 30 

5.2  Simplification measures .................................................................................. 31 

5.3  Measures to address the problems ................................................................... 31 

5.4  Bundling of measures into policy options ....................................................... 34 

6  HOW DO THE OPTIONS COMPARE? .................................................................. 37 

6.1  Assessment of the impacts of the policy options ............................................. 37 

6.2  Comparison of the options ............................................................................... 41 

6.3  Subsidiarity and proportionality ...................................................................... 43 

7  HOW WOULD IMPACTS BE MONITORED AND EVALUATED? ................... 44 

2 

 
 
 
Table of Annexes  

ANNEX 1 

ACRONYMS AND GLOSSARY ..................................................... 46  

ANNEX 2 

PROCEDURAL INFORMATION ................................................... 48  

ANNEX 3  

COST-EFFECTIVE SAVINGS POTENTIALS FOR 2030 ............. 52  

ANNEX 4 

MODELS SUPPORTING THE IMPACT ASSESSMENT .............. 56  

ANNEX 5 

DRIVERS ADDRESSED BY THE POLICY MEASURES ............ 72  

ANNEX 6 

DETAILED DESCRIPTION OF MEASURES ................................ 73  

ANNEX 7 

SPECIFIC IMPACTS OF THE MEASURES. ................................. 86  

ANNEX 8 

MACRO-ECONOMIC IMPACTS ................................................... 90  

ANNEX 9 

ESTIMATION OF ADMINISTRATIVE COSTS ............................ 97  

ANNEX 10 

INVESTMENTS IN ENERGY EFFICIENT BUILDINGS ........... 104  

ANNEX 11 

CHARACTERISTICS OF THE EU BUILDING STOCK ............. 106  

ANNEX 12 

STATE OF DEVELOPMENT OF EPC DATABASES ................. 110  

ANNEX 13 

THE EU BUILDING STOCK OBSERVATORY .......................... 111  

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1. 

INTRODUCTION  

1.1. 

General context  

The  Energy  Union1  and  the  Energy  and  Climate  Policy  Framework  for  2030  establish 
ambitious  European  Union  (EU)  commitments  to  further  reduce  greenhouse  gas 
emissions (at least 40% by 2030), to increase the share of renewable energy consumed (at 
least 27%), and to save at least 27% energy with a review "having in mind an EU level of 
30%"2 to increase Europe's energy security, competitiveness and sustainability.  

The EU is already achieving energy efficiency progress. Although the decline in energy 
consumption  could  be  partly  attributed  to  the  economic  crisis  and  its  aftermath  of 
restrained production, EU energy efficiency policies have also played a significant role in 
decoupling economic activity from energy consumption3.  

Figure 1: Primary energy consumption EU28 (Source: Eurostat)  

1 

2 

3 

Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic  and  Social  Committee,  the  Committee  of  the  Regions  and  the  European  Investment 
Bank –  A  framework  strategy  for  a  resilient  energy  union  with  a  forward-looking  climate  change 
policy; COM(2015) 80 final of 25 February 2015.  
Conclusions of the European Council, EUCO 169/14, CO EUR 13, CONCL 5, Brussels, 24 October 
2014.  
Communication  from  the  commission  to  the  European  Parliament  and  the  council  Energy 
Efficiency and its contribution to energy security and the 2030 – Framework for climate and energy 
policy; COM(2014) 520 final of 23 July 2014.  

4 

 
  
 
                                                 
The  level  of  investment  in  energy  efficiency  in  Europe  is  still  below  its  economic 
potential4. The cost-effective saving potential in the building sector is significantly higher 
than the savings achieved so far; investments with a payback time of four or five years 
are often not undertaken in the private and public sectors.  

Present  energy  efficiency  policies  and  strategies  focus  on  correcting  for  such  market 
failures.  This  serves  to  realise  this  potential,  by  triggering  investments  which  make 
economic  sense  but  do  not  take  place  because  of  market  or  regulatory  barriers  and/or 
failures.  

As described in the Energy Efficiency Impact Assessment 20145, the current 2020 energy 
efficiency framework is based on:  

  An indicative EU 2020 target underpinned by indicative national targets;  

  EU legislation for products traded in the internal market;  

  EU legislation coupled with administrative support in other areas, such as buildings 
and combined heat and power, providing general overall provisions, while leaving 
flexibility for the national and local level to implement them in an appropriate way;  

  National and local provisions not linked to common EU rules;  

  Financing through European, national and local sources.  

This  framework  is  designed  to  achieve  the  following  impacts,  using  a  number  of 
mutually reinforcing instruments:  

(1)  An overall decrease in energy consumption, via the set-up of a headline target to 
give public and private actors confidence that this is a sector worth investing in 
(Articles 1 and 3 of Directive 2012/27/EU on energy efficiency6 (EED))7;  

(2)  Measures to speed up the rate at which people and businesses choose to upgrade 
the energy performance of their buildings, systems and appliances (Article 7 of 
the EED, finance);  

(3)  Minimum  performance  requirements  (depth)  for  new  and  existing  buildings, 
new  appliances  and  new  vehicles  (Directive  2010/31/EU  on  the  energy 
performance of buildings8 (EPBD), eco-design and GHG emission standards for 
vehicles);  

4 

5  

6  

7  

8  

Energy  Efficiency  Financial  Institutions  Group  (EEFIG)  Final  Report,  February  2015  and 
COMMISSION/DG ECFIN, Note to the Economic Policy Committee Energy and Climate Change 
Working Group (19 April 2016): Investment in energy efficiency by households.  
Commission  Staff  Working  Document  final,  Impact  Assessment  Accompanying  the  document 
Communication  from  the  Commission  to  the  European  Parliament  and  the  Council  –  Energy 
Efficiency and its contribution to energy security and the 2030 Framework for climate and energy 
policy, SWD(2014) 255 of 23 July 2014.  
Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy 
efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC 
and 2006/32/EC; OJ L 315, 14.11.2012, p. 1-56. 
Article  1  of  the  EED  establishes  the  Union's  2020  20%  headline  target  on  energy  efficiency  and 
Article 3 of the EED specifies that this equals a primary energy efficiency consumption of not more 
than 1483 Mtoe or final energy consumption of no more than 1086 Mtoe in 2020. 
Directive 2010/31/EU of the European Parliament and of the Council of 19 May 2010 on the energy 
performance of buildings (recast); OJ L 153, 18.6.2010, p. 13-35. 

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(4) 

Information  for  consumers  and  industry  –  labels  for  products,  certificates  for 
buildings  and  consumer  rights  for  metering  and  billing  –  to  enable  them  to 
choose  the  efficiency  level  that  is  right  for  them  (Energy  labelling,  EPBD, 
Articles 8 and 9 to 11 of the EED);  

(5)  Research and innovation particularly through the Strategic Energy Technologies 
Plan,  for  development  to  bring  down  the  cost  of  key  technologies  that  are 
currently technically but not economically viable.  

In order to deliver on the energy efficiency ambition for 2030, the legislative framework 
is being updated.  

The review of the Ecodesign Directive concluded that the Directive is still considered fit 
for purpose and that a revision of the Ecodesign Directive is therefore not necessary. A 
legislative proposal on Energy Labelling is currently under negotiation with Council and 
Parliament and the process to review the EED and the EPBD is ongoing.  

In  parallel,  the  new  governance  system  will  ensure  that  a  transparent  and  reliable 
planning,  reporting  and  monitoring  system  is  in  place,  based  on  integrated  national 
energy and climate plans and streamlined progress reports by Member States.  

1.2. 

Review process  

The review of the EPBD, including the 'Smart Finance for Smart Buildings' Initiative is 
one  of  the  specific  actions  to  improve  the  energy  performance  of  buildings  in  the  EU 
included  in  the  Roadmap  for  the  Energy  Union9.  It  equally  delivers  on  the  legal 
obligation under Article 19 of the EPBD to evaluate the Directive by 1 January 2017 and, 
if necessary, make proposals.  

As presented in the Inception Impact Assessment roadmap10, the general objective of the 
review of the EPBD is to promote greater take-up of energy efficiency in buildings and 
deliver  cost-effective  greenhouse  gas  emission  reductions  as  well  as  to  contribute  to 
ensuring security of energy supply in the Union.  

The review has two specific objectives:  

  The  first  stems  from  the  political  mandate  of  the  Commission,  reflected  in  the 
Energy  Union  Strategy,  "to  review  the  Directive  and  propose  revisions  where 
needed to underpin the 2030 target".  

 

In addition, the review will "address the shortcomings identified by the evaluation 
of the Directive so as to ensure that it remains fit for purpose (REFIT component)".  

Although  the  EPBD  evaluation  report  identified  relatively  limited  regulatory  failures, 
there is scope for simplifying and streamlining outdated measures; enhancing compliance 
through fine tuning of existing provisions and better linking them with financial support; 
and  modernising  the  Directive  in  light  of  technological  developments  and  the  need  to 
increase building renovation and support decarbonisation of buildings.  

9  
10  

Roadmap for the energy union; Annex 1 to COM(2015) 80 final of 25 February 2015.  
http://ec.europa.eu/smart-regulation/roadmaps/docs/2016_ener_001_epbd_smart_buildings_en.pdf 
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1.3. 

Impact assessment  

This  impact  assessment  follows  the  Commission  Better  Regulation  Framework11,  in 
particular the Standard Cost Model therein12. The policy options explored in the present 
impact assessment deliver on the REFIT component whilst defining additional measures 
to underpin a 2030 ambition.  

The  Impact  Assessment  supports  as  preferred  option  targeted  amendments,  building 
and/or fine tuning already existing requirements, with a focus on the following aspects:  

  Add a long-term ambition level to the renovation strategies developed by Member 
States  under  Article  4  of  the  EED  in  order  to  mobilise  the  sector  towards  the 
transformation of the existing building stock;  

  Further strengthen the energy performance certification (EPC) schemes, improving 
the transparency of the underpinning calculation methodologies and building upon 
EPC registers/databases to reinforce compliance;  

  Enable,  within  these  EPC  registers/databases,  the  collection  of  information  on 
actual  energy  consumptions  to  improve  the  knowledge  on  the  building  stock  and 
better  inform  policy  makers  and  support  the  decisions  of  market  players,  in 
particular financial institutions;  

  Benefit better of the technological progress to:  

o  Support  a  more  efficient  implementation  of  the  certain  parts  of  the  EPBD 

(technical building systems, including their inspection);  

streaming 

o  Support  the  advent  of  ‘smarter’  building  and  create  enabling  conditions  to 
to  consumers  on  operational  energy 
provide 
consumption;  to  enable  the  adjustment  to  the  needs  of  the  user;  to  run  the 
efficient and comfortable operation of the buildings; to make buildings an active 
component of the modernised electricity market;  

information 

o  Remove  the  provisions  related  to  the  technical,  environmental  and  economic 
feasibility of high-efficiency alternative systems. With the obligation for all new 
buildings to be nearly  zero-energy buildings, the use  of locally available high-
efficiency alternative systems becomes an implicit obligation and this provisions 
become unnecessary;  

o  Support  the  support  of  emergence  of  electro-mobility  for  the  broader 
decarbonisation  of  the  economy  by  easing  the  later  installation  of  smart 
recharging points in private parking spaces.  

Acronyms and definitions of specific terms in use in the present document are provided 
in  Annex  1.  Procedural information,  information  on  the  consultation  with  stakeholders, 
the opinion of the scrutiny board and its follow-up is provided in Annex 2.  

In terms of consistency with the Charter for fundamental rights, the overarching aim of 
this proposal is to save energy and this is entirely in line with Article 37 of the Charter 
under which a high level of environmental protection and the improvement of the quality 

11  

12 

Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic  and  Social  Committee  and  the  Committee  of  the  Regions  -  Better  regulation  for  better 
results - An EU agenda; COM(2015) 215 final of 19 May 2015. 
http://ec.europa.eu/smart-regulation/refit/admin_burden/scm_en.htm  

7 

 
                                                 
of  the  environment  must  be  integrated  into  the  policies  of  the  Union  and  ensured  in 
accordance with the principle of sustainable development. The proposals to improve the 
energy  performance  of  buildings  do  not  interfere  with  the  right  to  own,  dispose  of  or 
bequeath  property  as  set  out  in  Article  17,  nor  do  they  have  an  impact  on  the  use  of 
property. 

2. 

WHAT IS THE PROBLEM AND WHY IS IT A PROBLEM?  

2.1. 

Basic problem and its extent  

2.1.1.  Large cost-effective saving potentials remain  

The  energy  sector  produces  the  lion’s  share  of  man-made  greenhouse  gas  emissions. 
Therefore, reducing greenhouse gas emissions by 2050 by over 80% will put particular 
pressure on energy systems.  

The EU needs to intensify efforts beyond 2020 and improving energy efficiency should 
remain  the  prime  focus13.  In  this  context,  higher  energy  efficiency  in  new  and  existing 
buildings is crucial, in order to decarbonise the EU Building Stock by 205014.  

The basic problem is that under business as usual, large amounts of cost-effective saving 
potentials and economically viable investments in energy efficiency in buildings will not 
take place. This  is damaging in  its own right, given the benefits  for security of supply, 
the  environment,  reduced  energy  costs  for  households  and  businesses  and  potential  for 
increased jobs and economy-wide economic activity. It is all the more problematic given 
that the achievement of a significantly higher rate of energy savings is a key part of the 
EU 2030 energy and climate targets.  

As established in Annex 3, within the scope of the EPBD (space and domestic hot water 
heating, cooling, ventilation and built-in lighting), cost-effective potentials for 2030 are 
estimated at:  

 

 

29.1  Mtoe  of  final  energy  from  measures  that  are  a)  cost-effective;  b)  work 
primarily on the depth of energy efficiency measures, using the EPBD architecture; 
and c) take place under normal market conditions and an active surrounding policy 
environment where current efforts in related policy areas are sustained;  

86.5 Mtoe of final energy from, in addition to the above-mentioned, measures that 
step up the rate at which people and businesses voluntarily choose to upgrade their 
buildings,  including  from  measures  which  are  not  cost-effective  in  a  financial 
perspective, or are out of the EPBD intervention scope.  

The largest cost-effective energy saving potential, additional to the savings delivered by 
the current legislative framework, is on existing buildings (close to 95% of the total).  

Significant  untapped  cost-effective  energy  saving  potentials  remains  in  all  Member 
States.  

13 
14 

COM(2011) 885 final 
A Roadmap for moving to a competitive low-carbon economy in 2050 (COM(2011) 112 final) 

8 

 
                                                 
Annex 3 also provides a detailed analysis of the cost effective energy saving potential by 
Member State, a disaggregation by sector and a split between new and existing buildings.  

2.1.2.  Potential  for  buildings  to  further  contribute  to  the  energy  system  and  the 

decarbonisation of the economy  

Technological progress towards ‘smarter’ building systems creates enabling conditions to 
provide  information  to  consumers  on  operational  energy  consumption;  to  adjust  to  the 
needs  of  the  user;  to  run  the  efficient  and  comfortable  operation  of  the  buildings;  its 
readiness  to  connect  to  electric  vehicle  charging,  to  host  energy  storage  and  to  support 
demand response in an modernised electricity market.  

Energy  efficiency  in  transport,  in  particular  efficient  vehicles  and  incentives  for 
behavioural change are also required to move from 2020 to 2050 low carbon goals. The 
electrification  of  transport  is  of  pivotal  importance  for  decarbonising  the  sector  and 
raising  the  share  of  renewable  energy  therein.  The  impact  of  electric  vehicles  will  be 
important  in  this  regard.  EU  legislation  already  supports  deployment  of  public 
infrastructure  via  Directive  2014/94/EU  on  the  deployment  of  alternative  fuels 
infrastructure,  and  monitors  developments  inter  alia  via the European  Alternative  fuels 
Observatory15.  

The projected deployment of electric vehicles in 2020 will amount to approximately 6-
8% of vehicle sales in 2020, reaching a fleet average of approximately 10% in cities by 
2030. An EU intervention in this field is necessary since Member States do not have the 
instruments to achieve pan-European coordination in terms of technical specifications of 
infrastructure and timing of investments16.  

Since  the  availability  of  recharging  stations  is  not  only  a  technical  prerequisite  for  the 
functioning of alternative fuel vehicles, but also one of the most critical components for 
consumer  acceptance, 
largely 
importance  of  accessible 
acknowledged.  Vehicle  parking  spaces  are  central  to  any  overarching  policy  for  the 
promotion of electro-mobility.  

infrastructure 

the 

is 

While  the  existing  legislation  only  mandates  public  accessible  recharging  points,  an 
estimated  90%  of  recharging17  takes  place  in  areas  that  are  not  publicly  accessible.  In 
order to address this regulatory gap in transport policy, installation of recharging points 
in private parking spaces, typically inside or flanked to buildings, is essential to support 
the  market  of  electric  vehicles,  complementing  the  Directive  2014/94/EU  In  multi-
apartment block and non-residential buildings, the freedom to install recharging points is 
limited by the necessity to get an agreement from the other co-owners to intervene on the 
building infrastructure or to cross private spaces. Following the example of the measures 
adopted  e.g.  in  France18  or  in  Spain19,  the  construction  and  the  major  renovation  of 

15 
16 

17 
18  

19  

www.eafo.eu  
Commission Staff Working Document – Impact Assessment accompanying the document Proposal 
for a Directive on the deployment of alternative fuels infrastructure; SWD(2013)05 final 
Ibid; SWD(2013)05 final 
Decree  2011/273  of  25  July  2011  established  obligations  regarding  the  equipment  of  new  and 
existing buildings. 
Royal Decree 1053/2014, of 12 December 2014 set an obligation: to prepare all new buildings for 
charging  points  with  the  electric  pre-installation;  and  to  equip  with  one  charging  point  every  40 
parking sites in new public buildings. 

9 

 
                                                 
buildings  should  provide  the  opportunities  to  install  recharging  points,  or  at  least 
facilitate their later installation.  

National electricity grids have an increasing percentage of renewable energy production. 
Fewer conventional powertrains mean a shift to cleaner energy sources and an improved 
air  quality  and  consequently  public  health.  This  could  be  better  achieved  if  with  smart 
recharging  points,  capable  of  starting  and  stopping  charging  in  reaction  to  network 
signals.  

2.1.3.  Large potential for tapping other benefits  

There  is  also  a  large  potential  for  tapping  other  economic,  social  and  environmental 
benefits. Successive studies have shown that energy efficiency offers many of the most 
cost-effective  options  for  meeting  global  emission  targets.  In  many  cases,  energy 
efficiency measures have been shown to be  ‘negative cost’, meaning it is economically 
advantageous to implement them.  

The  IEA’s  authoritative  report  ‘Capturing  the  multiple  benefits  of  energy  efficiency’ 
shows  that  the  potential  benefits  from  improved  energy  efficiency  are  not  only  socio-
economic  but  could  help  to  address  a  range  of  political,  social,  economic  and 
environmental issues. Energy efficiency measures in the building sector were found to be 
able  to  have  positive  impacts  on  the  economy  and  labour  market  (GDP  growth,  job 
creation,  etc.),  health  and  well-being  (through  better  indoor  and  outdoor  air  quality), 
environmental  impact  (reduced  CO2  emissions),  social  aspects  (mitigation  of  energy 
poverty), industrial competitiveness and the value of buildings as assets.  

2.2. 

The current legislative response and its evaluation  

Directive  2010/31/EU  (EPBD)  aims  at  promoting  the  improvement  of  the  energy 
performance  of  buildings  within  the  Union.  Its  evaluation  covered  the  whole  European 
Union,  on  the  basis  of  the  latest  available  data.  The  problem  defined  above  has  been 
addressed by the current policy framework through a three-pronged approach:  

  Creating  a  demand-driven  market  for  energy  efficient  buildings,  through  the 

provision of information through certification and inspection;  

  Setting minimum building energy performance requirements at cost-optimal level, 

and consequently prevent sub-optimal investments;  

  Further  catalysing  the  increase  in  energy  performance  of  buildings  and  the 
transition to nearly zero-energy buildings with measures, including of financial and 
fiscal nature.  

2.2.1.  Key findings of the evaluation  

The evaluation20 shows that the Directive is effective and is delivering on its general and 
specific objectives. Implementation to date shows broadly good performance on the other 
four analysed criteria: efficiency, relevance, coherence, and EU added value.  

There  is  evidence  of  around  48.9  Mtoe  of  additional  final  energy  savings  in  2014  in 
buildings  compared  to  the  2007  baseline  of  the  EPBD.  These  savings  occur  mainly 

20 

Evaluation EPBD SWD […](2016) draft 

10 

 
                                                 
within the scope of the EPBD – space heating, cooling and domestic hot water  – and a 
significant part can be attributed to factors influenced by policy interventions.  

This figure of 48.9 Mtoe in 2014 is in line with the 2008 Impact Assessment supporting 
the  EPBD,  which  estimated  that  the  Directive  would  deliver  60  to  80  Mtoe  of  final 
energy savings by 2020.  

The evaluation shows that the overall architecture of the Directive, combining minimum 
requirements and certification, is working, in particular for new buildings.  

Targets for all new buildings to be of nearly zero-energy by 2020 have proved to set a 
'future-proof' vision for the sector and mobilise stakeholders accordingly. 

Moreover, for both new and existing buildings, the choice of a cost-optimal methodology 
to steer existing national energy performance requirements towards cost-efficient levels 
has  proved  to  be  an  efficient  approach.  Analysis  of  national  reports  shows  that  it  is 
ensuring  reasonably  ambitious  levels  of  requirements21.  A  large  cost  effective  energy 
saving potential remains in the building sector (see Annex 3). Increasing the rate, quality 
and effectiveness of the renovation of existing buildings is the biggest challenge for the 
coming decades. The long term renovation strategies developed by Member States under 
Article  4  of  the  EED  should  result  in  increased  renovation  rates  through  mobilising 
finance and investments. These strategies should be combined in a clear forward looking 
vision with 2030 and 2050 perspectives, creating market signals for households, building 
owners/managers, businesses and investors.  

The  evaluation  shows  that  certification  of  the  energy  performance  of  buildings  is 
delivering a demand-driven market signal for energy efficient buildings and is achieving 
its aim to encourage consumers to buy or rent more energy efficient buildings. However, 
national certification schemes and independent control systems are yet at early stages in 
several Member States and their usefulness could be enhanced.  

Due to the diversity and disaggregation of the buildings sector, it remains challenging to 
acquire  good  data  on  building  characteristics,  energy  use,  and  financial  implications  of 
renovation  in  terms  of  cost  savings  or  asset  values.  This  lack  of  data  has  negative 
consequences  on  the  market  perception  of  the  cost-effective  energy  saving  potential  of 
the  EU  building  stock,  on  enforcement  tracking,  on  monitoring  and  evaluation.  EPC 
registers/databases  can  be  a  key  instrument  for  reinforced  compliance,  improve  the 
knowledge  on  the  building  stock  and  better  inform  policy  makers  and  support  the 
decisions of market players.  

2.2.2. 

Scope for improvements  

The  evaluation  identified  ways  in  which  national  transposition  and  implementation  can 
be further developed through better enforcement, compliance monitoring and evaluation.  

At EU level, opportunities for simplification or modernisation of outdated provisions and 
streamlining existing provisions in the light  of technological progress  were detected, in 
particular:  

21  

Report  from  the  Commission  to  the  European  Parliament  and  the  Council  –  Progress by  Member 
States in reaching cost-optimal levels of minimum energy performance requirements; COM(2016) 
464 final of 29 July 2016. 

11 

 
                                                 
  The requirement to assess the technical, environmental and economic feasibility of 

high-efficiency alternative systems, under Article 6(1)) of the EPBD;  

  The regular inspection of heating  and air  conditioning systems, under Articles  14 
and 15 of the EPBD, for which many Member States have opted out for alternative 
measures as allowed by the Directive.  

Technological progress towards ‘smarter’ building systems offers not only opportunities 
to support a more efficient implementation of the EPBD and in addition creates enabling 
conditions:  to  provide  information  to  consumers  and  investors  on  operational  energy 
consumption;  to  adjust  to  the  needs  of  the  user;  to  run  the  efficient  and  comfortable 
operation  of  the  buildings;  to  ensure  buildings'  readiness  to  connect  to  electric  vehicle 
charging;  to  host  energy  storage;  and  to  support  demand  response  in  a  modernised 
electricity market.  
In  conclusion,  the  evaluation  reveals  relatively  limited  regulatory  failures.  There  is 
however  scope  for  simplifying  and  streamlining  outdated  measures,  and  for  enhancing 
compliance  through  fine  tuning  of  existing  provisions  and  better  linking  them  with 
financial support. Additionally the evaluation points to the scope for modernisation of the 
Directive  in  light  of  technological  developments  and  the  need  to  increase  building 
renovation rates while supporting the decarbonisation of buildings in the long-term.  

2.3. 

Problems and drivers  

The reasons behind the slow transformation of the building stock and the slow tapping of 
the  significant  cost-effective  energy  saving  potentials  and  economically  viable 
investments in energy efficiency and renewable energy in buildings relate to drivers that 
are partly within the regulatory influence of the EPBD.  

Overall, these can be classified in three categories:  

  Contextual;  

  Market failures;  

  Regulatory failures.  

Table 1 presents a summary of the problem drivers by type of problem and according to 
the type of buildings and/or building tenure that are more likely to be associated with the 
drivers.  

12 

 
 
 
Table 1: Summary of the problem drivers by type of problem and according to the 
type of buildings and/or building tenure 

Existing buildings 

New buildings 

Residential 

Non-residential  Residential 

Non-residential 

Owner 
occupied 

Rented  
(incl. 
social 
housing) 

Public  Service 

Owner 
occupied 

Rented  
(incl. 
social 
housing) 

Public  Service 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+ 

+++ 

+++ 

+++ 

+++ 

++ 

++ 

++ 

++ 

+ 

+++ 

+++ 

+++ 

++ 

+ 

+ 

++ 

++ 

+++ 

+++ 

+ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

++ 

++ 

++ 

++ 

++ 

++ 

+++ 

+++ 

++ 

++ 

++ 

++ 

+++ 

+++ 

+++ 

+++ 

++ 

++ 

++ 

++ 

Type of 
problem 

Drivers 

Structural 

Market 
failures 

Regulatory 
failures 

Characteristics 
of the building 
stock 
Characteristics 
of the market 
Lack of 
understanding 
on energy use 
and potential 
savings 
Limited 
activity in a 
post-crisis 
context 
Split incentives 
Lack of 
attractive 
financing 
products 
Limited 
information on 
building stock 
Limited uptake 
of efficient and 
smart 
technologies 
Potential for 
improvement 
of the national 
implementation 
Potential for 
simplification 
of provisions 
Potential to 
better avoid 
potential 
negative 
effects 

2.3.1. 

Structural 

With construction rate significantly higher than the demolition rates, the building stock is 
naturally expanding in size. With more space to heat, cool, ventilate, etc. the increasing 
size  is  bound  to  increasing  energy  consumption  and  hence  increasing  carbon  dioxide 
emissions.  However,  when  all  new  buildings  are  nearly-zero  energy  buildings,  i.e.  by 
2021, the cost-effective saving potentials remain for new construction will be small.  

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Buildings are assets with a long lifetime, much longer than appliances, or cars, meaning 
that  buildings  have  a  natural  trend  for  low  replacement  and  refurbishment  rates.  With 
current  construction  and  demolition  rates,  around  70%  of  the  buildings  that  we  will 
occupy in 2050 are already built. At current renovation rates it will take more than 100 
years to renovate the EU building stock. Ensuring cost-optimal22 depth of renovation is 
not sufficient; a long term vision and strategy are needed. Increasing the rate, quality and 
effectiveness  of  building  renovations  is  certainly  the  biggest  challenge  for  the  coming 
decades.  Due  to  the  slow  turnover  of  buildings,  a  strong  market  signal  (for  Member 
States and for investors) is needed now, and the evaluation clearly indicated that this is 
lacking. The long term renovation strategies under Article 4 of the EED could play this 
role but would need to be reinforced with clear milestones for 2030 and 2050 (having in 
mind the EU goal for a decarbonised system by 2050).  

The  characteristics  of  the  building  stock  are  rather  different  across  Member  States, 
building ownership and the construction sector is highly fragmented by nature. The bulk 
of  building  renovations  consists  of  small  scale  projects  and  relatively  low  investment. 
The  lack  of  aggregation  of  small  scale  renovation  into  larger  scale  investments  (to 
decrease the transaction costs and the level of risk perceived) is an important barrier for 
building renovation.  

2.3.2.  Market failures  

There is a general lack of understanding among households and building owners of their 
energy  use,  and  potential  savings  related  to  different  energy  efficiency  measures23,24  as 
well  as  insufficient  knowledge  on  financial  and  other  benefits  related  to  building 
renovation.  The  provisions  of  the  EPBD  focus  on  the  depth  of  energy  efficiency 
measures  in  buildings.  The  reported  gap  between  the  estimated  savings  at  design  stage 
and  actual  savings  after  renovation25  can  create  mistrust  and  contribute  to  lower  the 
impact of the information given to citizens.  

The  EPBD  does  not  (and  will  not)  mandate  any  increase  in  new  construction  and/or 
renovation  activity.  The  EPBD  aims  at  addressing  informational  barrier  to  create  a 
demand-driven  market;  however,  the  decision  to  take  action  to  upgrade  the  energy 
performance of buildings is entirely left to market actors. The economic context therefore 
plays an important role in the observed renovation rates. As shown in the evaluation, the 
construction  sector  was  strongly  hit  by  the  global  crisis  with  a  decrease  of  economic 
output  and  absolute  number  of  jobs.  Only  strong  market  signals  such  as  'nearly  zero-
energy building' target can mobilise the sector. The evaluation indicated that such signal 
was missing for existing buildings, i.e. for building renovation.  

Despite being cost-effective, the renovation of buildings requires up-front investment. It 
is  important  to  highlight  that  30%  of  the  EU  population  live  as  tenants,  according  to 
Eurostat. Landlords may have little incentive to invest in housing stock improvements as 
return on capital employed can be limited. Split incentives play an important role and are 

22  

23 

24 
25 

Assessment of cost-optimal calculations in the context of the EPBD, 2015, European Commission 
(with the support of an external contractor, Ecofys) 
Public  perceptions  of  energy  consumption  and  savings.  Procedings  of  the  National  Academy  of 
Science of the USA. 2010 
Domestic energy use and householders' energy behaviour. Energy Policy. 2012 
See  e.g.  "Introducing  the  prebound  effect:  the  gap  between  performance  and  actual  energy 
consumption", Minna Sunikka-Blank & Ray Galvin (2012), Building Research & Information, 40:3, 
260-273, DOI: 10.1080/09613218.2012.690952/ 

14 

 
                                                 
also present in office buildings and other rented space such as shopping malls. However, 
there are no provisions in the EPBD with regards to split incentives. These are indirectly 
addressed by other legislation (e.g. Article 7 of the EED, which is having an effect on the 
renovation rate in some regions).  

In  response  to  these  challenges,  there  is  a  lack  of  attractive  financing  products  on  the 
market, in particular because financial institutions do not incorporate all the benefits of 
energy efficiency investments (higher asset value, better liquidity position of borrowers, 
lower  credit  default  rate  of  renovation  loans  compared  to  standard  loans)  into  their 
offering  of  financial  products.  In  the  public  buildings  segment,  the  level  of  investment 
financed  through  commercial  finance  (outside  public  finance  grants)  is  influenced  by 
Eurostat accounting rules and of Stability and Growth Pact rules.  

Due to the diversity and disaggregation of the buildings sector, it remains challenging to 
acquire  good  data  on  building  characteristics,  energy  use,  and  financial  implications  of 
renovation  in  terms  of  cost  savings  or  asset  values.  This  generalised  lack  of  data  has 
negative  consequences  on  the  market  perception  of  the  cost-effective  energy  saving 
potential of the EU building stock, enforcement tracking, monitoring and evaluation.  

The  building  sector  is  relatively  conservative,  in  particular  for  the  uptake  of  technical 
innovation. The evaluation identified rapid technical progress associated with the supply 
of new efficient technologies. It also observed that some investments do not take place 
despite very short pay-back periods of less than five years26. The timid recommendations 
in  Article  8  of  the  EPBD  have  not  been  sufficient  to  overcome  barriers  preventing  the 
integration of technical progress on key enabling technologies for 'smart buildings'.  

Similarly, the building infrastructure offers large potential to support the decarbonisation 
of  the  economy,  for  instance  by  hosting  recharging  points  for  electric  vehicles.  But, 
whilst  90%  of  recharging  takes  place  in  private  spaces,  existing  transport  legislation 
tackles  only  publicly  accessible  parking  spaces.  A  ‘principal-agent’-type  market  failure 
exists, which is manifested in the scarce interest of landlords in providing charging points 
for tenants/users in private dwellings and in office buildings.  

2.3.3.  Regulatory failures  

Some of the barriers directly or indirectly addressed by the current legal framework are 
not yet fully solved through its implementation. With minimum requirements set at cost-
optimal  level,  the  depth  of  interventions  should  guarantee  the  reaping  of  the  cost 
effective  potential,  as  far  as  the  decisions  are  made  to  renovate  buildings  ("renovation 
rate"  factor).  This  ideal  scenario  supposes  an  effective  implementation  of  the  EPBD 
takes place, which is not yet the case in all Member States:  

  National/regional  calculation  methodologies  for  the  energy  performance  of 
building must be unbiased and consider fairly all technologies that can contribute 
to the improvement of the energy performance of buildings, in particular emerging 
efficient technologies, including technologies using renewable sources;  

26 

Building  energy  management  systems  allow  savings  in  existing  buildings  arising  from  a  more 
efficient operation of space heating in the range of 2-30% and for cooling 37-73% depending on the 
climate  and  building  type  (Improving  energy  efficiency  via  smart  building  energy  management 
systems: A comparison with policy measures. Energy and Buildings. Volume 88, 1 February 2015, 
Pages 203–213) 

15 

 
                                                 
  Minimum  requirements  should  continue  to  be  periodically  reviewed  and  the 
calculated  cost  optimal  level  be  swiftly  implemented  in  the  national/regional 
legislation27.  The  EPBD  leaves  5  years  ("by  the  next  review")  to  reduce  any 
significant  gap  between  the  regulatory  and  the  cost-optimal  levels.  A  shorter 
implementation  timeline  could  be  envisaged  when  the  gap  to  cost-optimality  is 
limited;  

  Member  States  must  take  the  relevant  actions  to  ensure  that  by  2019  (public 
buildings)  and  2021  (privately-owned  buildings)  all  new  buildings  placed  on  the 
market will effectively be nearly zero-energy buildings (NZEB)28;  

  Enforcement and compliance of the EPBD could be stronger. Levels of compliance 
with  national  transposition  measures  hamper  reaping  a  potential  of  around  40% 
additional energy savings29, mainly because of lack of compliance with minimum 
requirements in existing buildings;  

  The  measures  adopted  to  further  catalyse  the  increase  in  energy  performance  of 

buildings should prevent lock-in effects or other negative effects.  

As  mentioned  above,  the  evaluation  identified  that  certain  components  of  the  EPBD 
could  be  streamlined  and  simplified.  This  concerns  specifically  the  requirements  for 
inspections of heating and cooling systems30 (no longer in tune with progress in building 
systems31)  and  the  technical,  economic  and  environmental  assessment  of  alternative 
heating and cooling systems, including decentralised or district solutions, preceding the 
construction of new buildings32 (which should be part of the proper setting of minimum 
requirements for new buildings).  

When  not  covered  by  other  pieces  of  EU  legislation,  Member  States  keep  the 
responsibility to ensure that the implementation of the EPBD improves and is coherent. 
Gaps  in  the  national  regulatory  framework  were  observed  regarding  the  indoor 
environment  quality  (i.e.  indoor  air  quality,  thermal  comfort,  noise  and  lighting)  and 
ventilation  requirements33,  in  particular  for  existing  buildings  where  health-based 
mandatory minimum IEQ requirements can hardly be found in several national/regional 
building codes.  

27  

28  

29  

30 

31  

32 

33  

Report  from  the  Commission  to  the  European  Parliament  and  the  Council  –  Progress by  Member 
States in reaching cost-optimal levels of minimum energy performance requirements; COM(2016) 
464 final of 29 July 2016. 
Commission Recommendation (EU) 2016/1318 of 29 July 2016 on guidelines for the promotion of 
nearly zero-energy buildings and best practices to ensure that, by 2020, all new buildings are nearly 
zero-energy buildings; ; OJ L 208, 2.8.2016, p. 46–57.  
Energy  Performance  of  Buildings  Directive  (EPBD)  -  Compliance  Study,  2015,  European 
Commission (written by ICF international) 
Concerted  Action  3,  2016,  Implementing  the  Energy  Performance  of  Buildings  Directive  book, 
2016 
Electronic  monitoring  systems  can  deliver  on  the  same  objectives,  in  real  time  (e.g.  iServCMB 
project) 
Commission Communication on an EU strategy on Heating and Cooling, COM(2016) 51 final of 16 
February 2016 
“Promoting healthy and energy efficient buildings in the European Union: National implementation 
of  related  requirements  of  the  Energy  Performance  Buildings  Directive  (2010/31/EU)”,  2016, 
European Commission’s JRC report (EUR 27665 EN) 

16 

 
                                                 
2.4. 

The 'Smart Finance for Smart Buildings' Initiative  

The  effect  of  the  EPBD  on  the  depth  of  building  works  in  new  and  existing  buildings, 
combined  with  labelling  informing  consumers,  acts  in  synergy  with  other  policy 
measures and financing schemes which speed up the rate of renovation.  

The EPBD ensures that when building works are engaged they respect the required level 
of  quality  and,  in  this  regard,  access  to  finance  is  not  a  pre-condition  per  se  for  the 
effectiveness  of  the  EPBD.  Access  to  attractive  and  appropriate  financing  is  however 
necessary  to  underpin  a  higher  investment  rate  in  energy  efficiency  in  buildings,  as 
induced  by  policy  intervention.  This  is  particularly  important  in  the  area  of  building 
renovation  where  access  to  financing  remains  an  obstacle  for  many  project  promoters 
who need to mobilise dedicated up-front capital to benefit from lower energy bills in the 
future.  

Flanking measures under the 'Smart Finance for Smart Buildings' (SFSB) Initiative will 
contribute  to  the  development  of  an  improved  financing  environment  for  energy 
efficiency  investments.  This  initiative  will  bring  practical  solutions  to  address  the 
remaining  barriers  to  capital  mobility  and  affordable  access  to  finance.  It  will  unlock 
more private financing for energy efficiency, and hence enable market actors realise the 
related business opportunities and environmental and financial benefits. These measures 
will be presented in the Communication accompanying the energy efficiency package34.  

The European market for energy efficiency in buildings is already sizeable. Although it 
varies according to macro-economic activity, consumer demand or regulatory signals, it 
can be estimated that around €120 billion (Cf. Annex 4, Figure 12) is spent each year on 
building envelopes and heating, cooling and ventilation systems. This level of investment 
might be increased by up to €47.6 billion in 2030 in the preferred policy option. Overall, 
although  substantial,  these  investments  represent  only  a  small  part  of  the  overall  EU 
market for building renovation that amounts to around €500 billion per year, and of the 
annual market for new construction estimated at around €400 billion35. A quarter of total 
investments in the EU-28 is in fact allocated to dwellings, which represent around 5% of 
the EU-28 GDP.  

Most of the current energy efficiency investment flow is coming from private financing 
in  the  form  of  savings  from  households,  equity  from  companies  or  commercial  debt 
originated from small consumer loans by retail banks to large-scale green bonds issued 
on  the  capital  markets36.  This  mobilisation  of  private  financing  is  reinforced  and 
underpinned by a number of public schemes across Europe (around 200), which take the 
form  of  grants  or  subsidies,  low  interest  rate  credit  lines37,  tax  rebates  and  guarantees. 
Most  of  these  schemes  target  the  building  sector.  For  instance,  tax  credit  schemes  in 

34  
35  
36 

37 

Commission Communication accompanying the energy efficiency package, COM […](2016) draft 
Estimations based on EUROCONSTRUCT - EC 19 
For example, ABN Amro in the Netherlands has in 2015 issued a covered bond to finance €10bn 
worth  of  investment  in  its  real  estate  portfolio,  enabling  its  clients  to  invest  for  energy  efficiency 
upgrades. The financing offered allows the coverage of 100% of the buildings upgrade. ABM Amro 
is  also  leading  by  example,  by  investing  into  renovation  of  own  buildings  and  has  received  2016 
BREAM Award for its headquarters' buildings. 
Energy  Efficiency  Fund  operated  by  VIPA  in  Lithuania  provides  loans  (worth  €65M)  for  central 
government buildings retrofits through Energy performance contracts and guarantees (worth €15M) 
for  street  lighting  modernisation.  Further,  it  provides  loans  (worth  €74M)  for  multi-apartment 
buildings renovations. VIPA is preparing for securitisation of these loan portfolios and entering the 
capital markets, as a first Financial Instruments established with ESIF allocations. 

17 

 
                                                 
France  have  already  helped  about  8  million  households  purchase  more  energy  efficient 
materials and equipment for the energy refurbishment of their main residence38.  

At EU level, the most important financing streams for energy efficiency are the European 
Structural and Investment Funds (ESIF) that represent around €18 billion over the period 
2014-2020, representing a tripling of allocations compared to 2007-2013 and confirming 
the  commitment  and  the  importance  Member  States  and  regions  attach  to  energy 
efficiency. Energy Efficiency has also been a big beneficiary of the European Fund for 
Strategic  Investments  (EFSI)  during  its  first  year  of  operation,  catalysing  €2.7  billion 
investments and accounting for more than 10% of the EFSI guarantee usage39.  

Some of these projects are combining ESIF/other public funds and EFSI funds in a way 
to provide risk sharing and technical assistance. A solid base of good practices to build 
upon can be found therein in order to leverage more investments in this area.  

In  addition,  there  are  two  specific  EU  financial  instruments  for  energy  efficiency,  the 
European  Energy  Efficiency  Fund40  (initial  capital  of  €265  million),  which  provides 
market-based  financing  to  public  projects  and  PF4EE,  (Private  Finance  for  Energy 
Efficiency)41  that  combines  lending  from  the  EIB  to  private  banks  together  with 
guarantees  and  technical  assistance  with  a  view  to  trigger  €650  million  of  investment. 
Absorption  on  this  instrument  is  a  good  indication  that  there  is  market  appetite  for  an 
instrument that combines bank financing with technical assistance.  

In  2013  the  types  of  publicly  supported  financing  instruments  for  energy  efficiency 
investments in residential and non-residential buildings (for Member States that provided 
the information) were according to  

38  

39 
40 

41 

Crédit  d'impôt  pour  la  transition  énergétique  (CITE)  tax  credits  for  households  in  France  can 
represent  up  to  30%  of  the  eligible  capital  expenditures  for  energy  efficiency  improvements  in 
residential buildings 
Under the EFSI Infrastructure window. 
Set up in 2011, the initial capitalization of the fund is €265 million and it aims at attracting private 
investors, to reach a total size of €700 million. 
Launched  in  January  2015,  PF4EE  is  a  financial  instrument  to  drive  investment  in  energy 
efficiency.  It  combines  lending  from  the  EIB  to  intermediary  banks  in  Member  States  with 
guarantees and technical assistance provided by the Commission's budget (€80 million from LIFE+ 
committed for 2014-17). It is anticipated that it could finance around €650 million. 

18 

 
 
                                                 
Figure 2 (residential buildings) and Figure 3 (non-residential buildings).  

19 

 
 
 
Figure  2:  Sources  of  financing  for  energy  efficiency  investment  in  residential 
buildings 
(Source: JRC / EU Building Stock Observatory)  

Figure  3:  Sources  of  financing  for  energy  efficiency  investment  in  non-residential 
buildings (Source: JRC / EU Building Stock Observatory)  

In  the  next  decade,  the  key  financing  strands  for  energy  efficiency  are  expected  to  be: 
savings  and  equity  when  available,  energy  efficiency-tuned  commercial  debt  including 
'green  mortgages'42,  funds  from  energy  efficiency  obligation  schemes  (EED  Article  7) 
and low-carbon financing instruments, and third-party financing.  

In  the  period  post-COP  21,  the  abundant  liquidity  from  the  capital  markets  has 
potentially  an  increasing  role  to  play,  as  large  institutional  investors  are  keen  to  re-
allocate their asset holdings in more sustainable sectors. Such a development requires the 
creation  of  a  well-established  secondary  (re-financing)  market  for  energy  efficiency 
investments in order to allow investors/lenders to refinance their assets and invest their 
money into new projects.  

42 

A 'sleeping giant' is represented by the mortgage market – in 2014, gross residential loans issues in 
the  EU  represented  a  value  of  862  billion  Eur.  Should  the  underwriting  practise  (loan  to  value 
considerations) reflect the cash savings of the borrowers and in the same time increased asset value, 
this could lead to additional capital provided as "green mortgages", at the same terms to borrowers. 
Even  with  a  conservative  5%  capital  provision  increase,  this  might  represent  about  €20bn  made 
available per year specifically for energy efficiency retrofits of existing buildings 

20 

 
  
  
                                                 
The  SFSB  Initiative  will  contribute  to  unlock  all  these  private  financing  strands  by: 
supporting  the  better  use  of  public  funds  via  new  or  up-scaled  financial  instruments, 
helping project developers bringing good project idea to maturity, and making the energy 
efficiency market more trusted and investible for investors. Together with other measures 
stemming  from  the  EPBD  review,  the  implementation  of  these  actions  will  support  the 
rapid  shift  of  existing  investment  flows  towards  energy  efficiency  projects,  while 
maximising the impact of existing public finance.  

The SFSB Initiative builds upon a threefold strategy:  

(1)  Maximising  the  impact  of  available  public  funds  and  leveraging  more  private 
capital  by  further  deploying  financial  instruments  and  better  using  subsidies 
towards  energy  poverty  or  specific  market  failures:  to  support  Member  States 
and  market  actors  in  this  challenge,  the  SFSB  initiative  will  put  forward  a 
practical  model  for  combining  various  public  and  private  funding  sources  and 
deploy  investment  platforms,  as  appropriate  and  according  to  market  needs.  A 
capacity  building  campaign  will  also  be  established  to  deliver  assistance  with 
structuring  and  deployment  of  financial  instruments  and  investment  platforms. 
In parallel, the initiative aims at enabling more investments in public assets by 
addressing,  where  appropriate,  existing  accounting  issues  currently  deterring 
public  bodies  from  making  investments,  such  as  in  the  form  of  Energy 
Performance Contracting.  

(2) 

Promote aggregation of projects, and project development assistance to secure a 
sustainable  large-scale  pipeline  of  bankable  projects  to  feed  investment 
platforms and financial instruments: the SFSB initiative will aim at reinforcing 
the European Local Energy Assistance Facility43 and make it more accessible at 
the regional or local level, in accordance with the market need. This is expected 
to trigger additional energy efficiency investments of more than €1 billion each 
year.  In  addition,  the  initiative  will  encourage  Member  States  to  develop 
dedicated  local  one-stop-shop  facilities  that  cover  the  whole  customer  journey 
and that ultimately connect the supply of finance with demand for it.  

(3)  Help investors and financiers better understand the risks and benefits of energy 
efficiency investments based on market evidence and performance track record: 
the  SFSB  initiative  will  provide  private  sector  investors  access  to  more  and 
better  information  in  order  to  ensure  that  key  fundamentals  such  as  lower 
probability of default on energy saving loans or increased value of assets due to 
higher energy performance of properties are progressively reflected in pricing of 
financing  products  offered.  To  underpin  this  market  transformation,  the 
initiative  will  build  upon  the  EPBD  review  including  more  reliable  Energy 
Performance  Certificates  for  buildings,  the  disclosure  of  actual  energy 
consumption  of  public  buildings  or  the  evaluation  of  energy  efficiency 
programmes  supported  by  public  funds.  In  addition,  the  initiative  will  include 
the launch of a De-Risking Platform (DEEP)44, revealing real performance data 
from  hundreds  of  implemented  and  monitored  energy  efficiency  investments 
across  the  EU.  Finally,  the  initiative  will  support  the  development  of  a 
consensual  framework  for  energy  efficiency  investment  underwriting  in  close 
collaboration with the finance industry. All these measures are crucial to support 
the incorporation of the key energy efficiency benefits into the business practice 

43  
44  

ELENA, http://www.eib.org/products/advising/elena/index.htm  
http://www.eefig.eu/index.php/about-the-project  

21 

 
                                                 
and  thus  make  energy  efficiency  investments  attractive  and  trusted  for  private 
capital.  The  development  of  'green  mortgages'  in  Europe  would  for  instance 
benefit  from  these  actions  and  could  seriously  influence  the  market  for  gross 
residential loans amounting to €862 billion in 2014. If increased asset value of 
energy efficiency buildings were fully taken into account when determining the 
loan-to-value  ratio,  this  could  lead  to  additional  capital  provided  that  might 
represent about €20 billion per year specifically for energy efficiency retrofits of 
existing buildings.  

The  'Smart  Finance  for  Smart  Buildings'  Initiative  does  not  directly  require  legislative 
intervention. The three pillars of the initiative are already under way or project related. 
The present impact assessment looks at supporting measures directly linked to the EPBD 
and to its Article 10 on financial incentives and market barriers.  

2.5.  Who is affected and how?  

This  initiative  of  reviewing  the  EPBD  has  practical  implications  on  a  variety  of 
stakeholders; 
local), 
entrepreneurs,  labour  market  participants,  households,  investors  and  other  financial 
actors.  

the  public  authorities  (national,  regional  and 

inter  alia, 

Being responsible for the implementation of necessary policies and legislation, Member 
States  are  the  first  and  foremost  stakeholders  that  are  affected  by  this  initiative.  As  the 
initiative  envisages  a  number  of  provisions  for  different  levels;  public  authorities  at 
national, regional  and  local levels are in  charge of taking  action.  A pilot assessment of 
potential territorial impacts of the EPBD45 showed rather positive effects in the fields of 
economy, society, environment and governance. But these effects largely depend on the 
quality of transposition and enforcement.  

Secondly, the initiative has direct implications on the construction sector, both in terms 
of  new  business  opportunities  and  planned  links  to  finance.  Energy  efficiency  and 
renewable energy installations proposed by the Directive require the development of new 
business initiatives. Moreover, policy options under consideration include actions to link 
financing opportunities with  EPCs, renovation plans to improve  energy performance  of 
buildings  to  NZEB  levels,  which  will  also  have  a  positive  impact  on  the  construction 
sector, namely construction products manufacturers or construction service providers.  

Thirdly, as the initiative covers both residential and non-residential buildings, it will have 
a  direct  impact  on  the  energy  bills  of  households  (owners  and  tenants),  companies  and 
public bodies owning and/or occupying non-residential buildings. Additionally, increased 
energy  performance  of  buildings  can  have  positive  impacts  on  health  conditions  and 
energy poverty, mainly through the improvement of indoor climate conditions.  

Finally,  the  initiative  will  have  direct  implications  on  investors  and  other  financial 
institutions  that  may  obtain  a  clear  framework  and  business  environment,  which  will 
contribute to lower perceived risk and transactional costs.  

45 

Pilot Test on the Territorial Impact Assessment of the Energy Performance of Buildings Directive, 
2016, European Commission 

22 

 
                                                 
2.6. 

How would the problems evolve?  

In the absence of changes to the EPBD and changes to the way it is implemented, further 
energy  savings  would  be  achieved.  Detailed  information  on  the  scenarios  analysed  is 
provided in Annex 4. If nothing is changed, the continuous 5-year cycle of tightening of 
national  minimum  requirements  in  line  with  the  cost-optimal  methodology,  will  still 
ensure  an  adequate  level  of  savings.  This  tightening  of  the  minimum  requirements  is 
already  being  accounted  for  in  the  baseline  of  this  impact  assessment.  However,  if 
nothing changes the lessons learned and the experience gained during the application of 
the EPBD would be missed.  

In  the  absence  of  changes,  the  remaining  cost-effective  potential  in  existing  buildings 
would  continue  untapped  and  a  significant  share  of  the  buildings  in  the  EU  would 
continue to perform below adequate performance levels. There may be also other missed 
potential  in  the  absence  of  changes  to  the  EPBD,  due,  for  instance,  to  the  insufficient 
uptake of smart technologies in buildings and the limited use of new standards.  

According  to  the  EU  Reference  scenario  2016  (REF2016)46,  which  takes  into  account 
global and EU market trends and the energy and climate policies already adopted by the 
EU  and  its  Member  States,  the  distribution  of  final  energy  consumption  across  sectors 
will remain broadly identical, keeping with around 40% of the final energy consumption 
for  these  two  sectors.  Without  further  action,  the  limited  decreasing  trends  for  final 
energy  consumptions  in  the  households  and  tertiary  sector  (-0.5%  per  annum)  would 
slow  down  between  2020  and  2030  (-0.3  to  -0.4%  per  annum)  and  will  return  to  an 
increasing trend between 2030 and 2050 (+0.1% per annum).  

As  illustrated  in  Annex  3,  significant  untapped  cost  effective  final  energy  saving 
potentials can be expected in all EU Member States. The analysis in  Annex 3 confirms 
that 64 – 76% of these 2030 saving potentials lay within the scope of the EPBD.  

3. 

WHY SHOULD THE EU ACT?  

3.1. 

Subsidiarity and proportionality  

The EPBD is based on Article 194(2) of the Treaty on the Functioning of the European 
Union, the legal base for a Union policy to promote energy efficiency and energy saving.  

EU intervention on energy efficiency of buildings expanded prudently, only where it was 
justified  and  leaving  significant  flexibility  to  Member  States.  The  EPBD  respects 
subsidiarity by setting a common minimum framework and leaving implementation and 
adaptation to national and local conditions to Member States, with significant margin for 
taking into account the local conditions.  

Just  as  products'  efficiency,  the  EPBD  works  through  a  combination  of  minimum 
standards  (driving  the  market  towards  higher  efficiency)  and  labelling  (stimulating  the 
creation  of  a  market  for  energy  efficient  buildings).  However,  the  EPBD  leaves  the 
development  of  these  instruments  to  the  national/regional/local  authorities,  under  the 
principle of subsidiarity.  

46 

EU  Reference  Scenario  2016  –  Energy,  transport  and  GHG  emissions  –  Trends  to  2050,  2016, 
European Commission 

23 

 
                                                 
For instance, Member States are free to:  

  Adopt  a  calculation  methodology  for  the  energy  performance  of  buildings,  at 

national or regional level, provided that it fulfils a general framework;  

  Define  the set-up and management of the EPC schemes,  in light of achieving  the 

objectives proposed in the Directive;  

  Differentiate  or  not  the  minimum  requirements  for  new  and  existing  buildings, 
different building categories, designated functions, age groups of the buildings. The 
cost optimal framework methodology ensures a common ambition level across the 
EU without establishing uniform performance requirements;  

Member states remain responsible for taking appropriate measures to:  

  Avoid negative effects on the quality of the indoor environment,  

  Design  the  supporting  measures  in  such  a  way  that,  e.g.  these  contribute  to 

reducing energy poverty, split incentives, financial support, etc.  

The EPBD addresses the information barrier by ensuring informed decisions on buying, 
renting and investing in buildings. The Directive does not directly mandate investments 
and, under the EPBD, building owners remain single decision-makers to invest or not.  

The increasing mobility of Europeans47 and the increasing number of businesses having 
operations across the EU are valid reasons to examine the need for more harmonisation. 
At the same time, the building market, especially the housing market, is generally local 
and buildings are stationary. Building typologies and local and climatic conditions also 
vary across Europe.  

Construction  products  and  services,  heating,  air-conditioning  and  lighting  devices,  as 
well  as  on-building  renewable  systems,  smart  controls,  building  automation  systems, 
smart meters, etc. are an important part of the internal market.  

Larger  markets  for  efficient  technologies  can  have  a  positive  impact  on  the  cost-
optimality  of  minimum  energy  performance  requirements.  For  example,  the  evaluation 
revealed that this market can be affected by how the energy performance of buildings is 
calculated  and  if  national/regional  methodologies  consider,  or  not,  all  technologies,  in 
particular emerging efficient technologies, at the same level playing field.  

It  is  therefore  not  a  surprise  that,  during  the  public  consultation,  construction  industry 
and stakeholders operating cross-border (e.g. owners of service-providing chains such as 
supermarkets,  hotels,  multinational  companies,  etc.)  called  for  more  unified  and 
comparable  methods  for  the  calculation  of  energy  performance  and  for  common 
principles for building regulations.  

Similarly,  more  comparability  of  energy  performance  measurements  across  the  EU  is 
demanded  by  the  finance  industry.  Standardisation  and  improvement  of  buildings 
certification and an open source EU Buildings energy database are called for to facilitate 
the financing of energy efficiency investments at EU level.  

47 

At the end of 2012, 14.1 million EU citizens were residing in another Member State (2.8% of the 
total 
http://ec.europa.eu/justice/citizen/document/files/com_2013_837_free-
movement_en.pdf and http://europa.eu/rapid/press-release_MEMO-14-541_en.htm  

population).  See 

24 

 
                                                 
Comparable  methods  of  measuring  energy  performance  of  the  buildings  would  mean  a 
significant decrease of administrative burden of investors and would e.g. facilitate the re-
financing of bundled investments in energy efficiency, with positive impacts on interest 
rates.  

Subsidiarity and proportionality of measures are fully discussed and justified within this 
impact assessment,  in  particular in  Annex 6 for individual measures and in  Section 6.3 
when presenting the comparison of policy options.  

3.2.  Macroeconomic and other benefits  

EU  action  on  energy  performance  of  buildings  has  a  positive  impact  on  the 
competitiveness of related sectors and ultimately on growth and jobs.  

Overall, the building sector has a significant impact on economic activity in other sectors. 
Building services, business activities and the supply of raw material and equipment are 
responsible for 70% of overall building output. Also, a strong EU building sector is also 
important for its leadership outside of the EU.  

The  value  chain  of  the  building  sector  goes  beyond  the  building  work  itself.  Since  the 
adoption  of  the  EPBD  in  2010,  new  technology  developments  and  cost  reduction  of 
efficient and on-building renewable energy technologies were observed. Furthermore, a 
stable  and  long  term  EU  regulatory  framework  is  the  top  first  investment  driver  for 
building renovation identified in the EEFIG report.  

EU action can tackle the problem of the sub-optimal rate of improvement of buildings’ 
energy  performance;  however,  building  renovation  has  many  other  benefits,  notably 
economic  (security  of  supply,  GDP),  social  (employment,  energy  poverty,  affordability 
of  housing,  health)  and  environmental  (pollution).  It  contributes  to  EU  policy  goals  on 
climate change, energy security, environment and growth and jobs.  

Energy  poverty48  is  a  serious  problem  in  the  EU.  It  is  linked  to  general  poverty  and 
results from a number of underlying conditions including health, social inclusion and low 
income issues. The following chart presents one of the consequences associated to energy 
poverty, the inability to maintain indoor comfort in winter.  

48 

Energy  poverty  occurs  when  households  are  not  able  to  adequately  heat  or  have  other  required 
energy services in their homes at affordable cost. The EU Survey on Income and Living Conditions 
(EU SILC) estimates that 54 million European citizens (11% of the EU population) were unable to 
keep their home adequately warm in 2014, with similar numbers being reported with regard to the 
late payment of utility bills. Around 16% of the EU population was living in dwellings with leaking 
roofs  and  damp  walls.  This  problem  is  more  severe  in  in  Central  Eastern  and  Southern  Europe 
Member States. 

25 

 
 
 
                                                 
Figure  4:  Households  unable  to  keep  homes  adequately  warm  (Source  Eurostat 
SILC)  

The quality and energy performance of buildings have a major impact on affordability of 
housing  and  on  energy  poverty.  Energy  savings  and  efficiency  improvement  of  the 
housing  stock  would  enable  many  households  to  escape  energy  poverty.  EU  action  is 
needed  to  address  common  underlying  market  and  regulatory  failures  that  could 
contribute  to  tackle  energy  poverty,  taking  into  account  the  responsibilities  of  Member 
States  in  this  regard.  This  issue  is  also  highlighted  in  the  recently  adopted  European 
Parliament resolution of 14 April 2016 on meeting the antipoverty target in the light of 
increasing household costs49.  

3.3. 

Energy and climate  

Climate  change,  security  of  energy  supply  and  environmental  protection  are  challenges 
that cannot be sufficiently addressed at national level only. Energy efficiency and on-site 
renewables  in  buildings  provide  part  of  the  solution  of  these  problems  and  the 
instruments that have already been adopted at EU level reflect this need for EU action. 
More  specifically,  there  is  a  strong  Union  dimension  that  justifies  setting  a  common 
ambition  level  for  energy  efficiency  in  buildings  as  a  way  to  ensure  that  the  EU  as  a 
whole achieves its GHG reduction targets in the most cost effective way.  

The buildings that people will use in 2050 already exist or are being designed and built 
now.  As  highlighted  by  financial  institutions,  mobilising  low-carbon  investments  in 
buildings  requires  a  strong,  stable  and  effectively  enforced  EU  regulatory  framework 
which ensures the good use of EU funds to leverage private funds and provide technical 
assistance at national and regional levels50. The role of the EU is crucial to make sure that 
the  regulatory  framework  across  the  EU  reaches  comparable  ambition  levels  and  is 
consistently enforced.  

The  underlying  market  and  regulatory  failures  prove  to  be  similar  in  all  EU  MS.  The 
Directive 2002/91/EC and Directive 2010/31/EU played an important role to ensure that 

49 
50 

2015/2223(INI) 
Energy Efficiency Financial Institutions Group (EEFIG), "Energy Efficiency – the first fuel for the 
EU  Economy.  How  to  drive  new  finance  for  energy  efficiency  investments",  February  2015, 
www.eefig.eu  

26 

 
  
                                                 
all  Member  States  have  energy  efficiency  requirements  related  to  new  and  existing 
buildings in their building codes, based on cost-optimality. These minimum requirements 
are used in reference for the use of EU Funding under the Cohesion Policy and play an 
important role to ensure that EU funding is focused on the effective delivery of Europe 
2020 objectives and targets.  

Similarly, the role of the EU is fundamental to tackle common barriers across Member 
States  preventing  the  development  of  the  energy  services  and  Energy  Performance 
Contracting51 market in the EU.  

The evaluation identified that additional EU added value is brought through the support 
to  national  regulators,  stimulating  research  and  innovation  at  a  higher  scale,  support  to 
the  single  market  integration  for  building  products  and  services  (including  financial 
services)  and  international  leadership  in  the  field  of  energy  performance  of  buildings. 
Action  at  EU  level  offers  a  better  leverage  in  mobilising  the  sector  around  a  common 
ambition  and offer higher expected market outcomes  than in a fragmented  market. The 
setting of a pan-European ambition for all new buildings to be of nearly zero-energy by 
2020  has  proved  to  set  a  'future-proof'  vision  for  the  sector  and  mobilise  stakeholders 
accordingly.  Similar  market  signals  were  found  to  be  missing  for  the  existing  building 
stock, which represents the largest share (95%) of the cost-effective potential.  

Finally,  buildings  are  an  important  part  of  the  non-ETS  sector.  To  achieve  the  40% 
reduction target for greenhouse gas emissions in 2030, established in line with the cost-
effective  pathway  described  in  the  2050  Roadmaps52,  the  non-ETS  sectors  (buildings, 
transport and agriculture) need to cut emissions by 30% (compared to 2005). Achieving 
the  2050  target  of  at  least  80-95%  reduction  requires  that  the  residential  and  tertiary 
sectors together reduce their GHG emissions by 88 to 91% (compared to 1990 levels)53.  

The impact assessment underpinning the non-ETS proposal demonstrated that in a cost-
effective  GHG  reduction  scenario  for  the  EU54,  all  Member  States  need  to  improve 
energy efficiency in a similar way and without an EU legislative instrument for buildings 
not all Member States would act (e.g. some can meet their Effort Sharing target without 
additional action). Even if there are no classic cross-border effects of national policies on 
energy  efficient  buildings,  EU  measures  on  energy  efficiency  in  buildings  allow 
individual  Member  States  to  fulfil  their  obligations  under  the  Effort  Sharing  Decision 
more  easily  and  cheaply.  One  or  several  Member  States  not  acting  in  the  area  of 
buildings would imply overall higher GHG abatement costs for the EU as a whole.  

3.4. 

Coherence  

The evaluation concluded that there is internal coherence in the Directive. The provisions 
related to the setting of minimum requirements for new and existing buildings, on EPCs 
and  on  more  general  measures  to  address  market  barriers  focus  on  different  and 
complementary aspects. These provisions support each other and should be implemented 
so that they work in synergy.  

51 

52 
53 
54  

Energy  Performance  Contracting  (EPC)  is  a  form  of  ‘creative  innovative  financing’  for  capital 
energy  retrofitting  improvement  which  allows  funding  energy  upgrades  from  cost  reductions  by 
providing a guarantee on energy savings; upfront investments may be financed by the contractor or 
by the building owner. 
COM(2011) 112, COM(2011) 144 final, and COM(2011) 885 final 
A Roadmap for moving to a competitive low-carbon economy in 2050 (COM(2011) 112 final) 
COM(2014) 482 

27 

 
                                                 
The  evaluation  also  concluded  that  EPBD  work  in  synergy  with  other  relevant  EU 
legislation:  

  The objective of the EPBD to support the increase of building renovation depth and 
rates  is  supported  by  other  EU  legislation;  inter  alia,  by  the  EED  and  by  the 
European Structural Investment Funds (ESIF) regulatory framework;  

  The  obligations  arising  from  the  EPBD  to  set  and  ensure  minimum  energy 
performance  requirements  for  building  elements,  on  the  one  hand,  and  the  EU 
legislation on ecodesign and energy labelling energy efficiency of products, on the 
other hand, were found coherent;  

  The provisions of the EPBD naturally drive the use of renewable energy sources, 

consistently with Directive 2009/28/EC;  

  As  mentioned  before  to  achieve  the  40%  reduction  target  for  greenhouse  gas 
emissions in 2030, established in line with the cost-effective pathway described in 
the  2050  Roadmaps55,  the  non-ETS  sectors  (buildings,  transport  and  agriculture) 
need to cut emissions by 30% (compared to 2005); 

  The  EPBD  and  Directive  2014/61/EU56  (in  particular  Article  8  "In-building 
physical  infrastructure")  can  be  mutually  supportive  by  creating  respectively  the 
demand and the offer for high-speed electronic communication networks.  

Moreover, the future Fitness Check of the Construction Sector (due in 2017) looks at EU 
legislation on energy efficiency and renewable energy, internal market, environment, and 
health and safety and its impact on the competitiveness and sustainability of the sector. 
Corroborating the outcome of the evaluation of the EPBD, the supporting study for the 
construction fitness check concerning EU legislation in the fields of Internal Market and 
Energy Efficiency (version: 13 July 2016) shows that there is great synergy with regard 
to the objectives and effects of the EED, EPBD and RES.  

The study indicates that EU legislation had a positive impact to increase the demand for 
energy  efficient  construction  products  and  for  energy  efficiency-related  professional 
services,  and  positive  effects  across  the  whole  supply  chain,  resulting  in  a  meaningful 
contribution to sustain the level of activity during this difficult period for the construction 
industry.  

The costs associated with higher energy performance standards are supported by building 
owners  who  benefit  from  lower  energy  consumption  and/or  from  higher  value  of  their 
building  on  the  market.  The  cost-optimal  methodology  informs  the  setting  of  cost-
effective minimum energy performance requirements, which are in line with the current 
energy saving potential of the different national/regional specific building typologies.  

The  study  points  out  that  improved  coherence  for  EPCs,  inspections  and  energy  audits 
could be sought in the national implementation of the EPBD and EED. This question was 
addressed  in  the  Commission  Communication  on  implementing  the  Energy  Efficiency 
Directive57 and its accompanying Staff Working Document58, where the link between the 

55 
56  

57 
58 

COM(2011) 112, COM(2011) 144 final, and COM(2011) 885 final 
Directive 2014/61/EU of the European Parliament and of the Council of 15 May 2014 concerning 
measures to reduce the cost of deploying high-speed electronic communication networks 
COM(2013) 762 final 
SWD(2013) 447 final.  

28 

 
                                                 
obligations  on  energy  audits  in  large  enterprises  under  the  EED  and  the  obligations  to 
issue  Energy  Performance  Certificate  for  buildings  for  rent  or  sale  are  explained.  The 
measures are complementary: a building EPC is one of the inputs to energy audits, which 
have a broader scope. The above-mentioned Staff Working Document provides guidance 
for  Member  States  to  ensure  that  national  transposition  measures  exploit  synergies 
between both pieces of legislation, including in relation to training programmes for the 
qualification of energy auditors and independent experts.  

Increasing  building  renovation  depth  and  rates  can  contribute  to  the  sustainability  and 
competitiveness of the construction sector, e.g. by improving environmental performance 
and  creating  business  opportunities  in  line  with  the  Strategy  for  the  sustainable 
competitiveness of the construction sector and its enterprises59. The energy performance 
of  buildings  during  their  operation  is  only  one  element  of  the  much  broader 
environmental  performance  of  a  building  over  its  life-cycle.  The  Communication  on 
resource  efficiency  opportunities  in  the  building  sector60  paves  the  way  to  more  global 
approaches  to  consider  environmental  impacts  throughout  a  building's  life  cycle.  This 
includes taking account of both embodied and operational energy during the life cycle of 
a building. Similarly, this Communication as well as the recent EU Action Plan for the 
Circular Economy61 stresses the importance of recycling of construction and demolition 
waste, already laid down in the Waste Framework Directive. This waste stream makes up 
about  a  third  of  EU  total  generated  waste.  To  enable  recycling,  selective  demolition 
where  materials  are  easily  separated  at  the  end  of  life  stage  is  imperative.  This  in  turn 
requires considerations at the construction and renovation stages, with suitable materials 
being put together for easy disassembly. Failure to do so is likely to result in increased 
land  filling  of  construction  and  demolition  waste.  These  considerations  are  particularly 
critical during renovation. Recycling construction materials, as opposed to ending up in 
landfills, is crucial to  the circular economy. These manufacturing, recycling and end-of 
life aspects are, however, outside the scope of the EPBD. Nevertheless, if implemented 
with  care,  the  EPBD  can  work  in  synergy  with  the  circular  economy  and  resource 
efficiency objectives.  

Ways to preserve and, whenever possible, to reinforce these existing internal and external 
complementarities and synergies is an integral part of the objectives of the present impact 
assessment.  

4. 

WHAT OBJECTIVES SHOULD BE ACHIEVED?  

4.1. 

General and specific objectives  

The objective of the EPBD is to promote the improvement of the energy performance of 
buildings within the Union, taking into account outdoor climatic and local conditions, as 
well as indoor climate requirements and cost-effectiveness.  

The EPBD defines the energy performance of a building as the amount of primary energy 
needed, in the use phase, to meet the energy demand associated with a typical use of the 

59 

60 

61 

Communication  COM(2012)  433  final  of  31  July  2012  on  a  Strategy  for  the  sustainable 
competitiveness of the construction sector and its enterprises 
Communication COM(2014) 445 of 1 July 2014 on resource efficiency opportunities in the building 
sector 
Communication COM(2015) 614 final on Closing the loop  – An EU Action Plan for the Circular 
Economy 

29 

 
                                                 
building,  which  includes,  inter  alia,  energy  used  for  heating,  cooling,  ventilation,  hot 
water and built-in lighting (mainly in non-residential buildings).  

As presented in the Inception Impact Assessment roadmap62, the general objective of the 
review  of  the  EPBD,  including  the  'Smart  Finance  for  Smart  Buildings'  Initiative  is  to 
promote  greater  take-up  of  energy  efficiency  in  the  buildings  sector  and  deliver  cost-
effective greenhouse gas emission reductions as well as to contribute to ensuring security 
of energy supply in the Union.  

Specific objectives of the initiative are (1) to address the shortcomings identified by the 
evaluation of the EPBD so as  to  ensure it remains fit for purpose (REFIT component); 
and (2) to consider the need for additional measures relating to energy efficiency and the 
use  of renewable  energy in  buildings, with  a  2030 perspective; (3) to  deliver improved 
access to funding and stimulate investments ('Smart Financing for Smart Buildings').  

4.2. 

Links to problems and drivers  

The  evaluation  and  the  above  problem  definition  confirm  the  relevance  of  the  review's 
general  objective.  Large  energy  saving  potential  is  identified  for  2030  and  the 
transformation  of  the  building  stock  is  found  to  be  relatively  slow.  Under  the  current 
trend the potential will only be partially achieved.  

The  relevance  of  the  specific  objectives  of  the  review  are  also  confirmed  by  the 
evaluation:  

(1)  Although  the  EPBD  is  found  to  be  fit  for  purpose  in  its  objective,  scope  and 
identified  scope  for  simplifying  and 

the  evaluation 

intervention 
logic, 
streamlining outdated measures:  

a.  The technical, environmental and economic feasibility of high-efficiency 
alternative  systems  that  becomes  an  implicit  obligation  with  the 
requirement to only build nearly zero-energy buildings;  

b.  The  expected  effects  of  the  regular  inspection  of  heating  and  air 
conditioning  systems  could  be  more  efficiently  achieved  with  the 
support of technology;  

(2)  The  evaluation  also  identified  the  possibility  to  enhance  compliance  through 
fine tuning of existing provisions and better linking them with financial support 
and 
technological  developments. 
Improvement  of  the  EPBD  must  also  consider  possible  additional  measures  in 
order to:  

to  modernise 

the  EPBD 

light  of 

in 

a.  Make  buildings  further  contribute  to  the  energy  system  and  to  the 

decarbonisation of the economy;  

b.  Tap other benefits in conjunction with the energy transformation of the 

building stock; 

(3)  The lack of sufficiently attractive financing products on the market is part of the 
reason  for  limited  renovation  rates.  This  specific  objective  associated  'Smart 
Finance  for  Smart  Buildings'  Initiative  is  explored  in  more  details  in  Section 
2.4.  

62  

http://ec.europa.eu/smart-regulation/roadmaps/docs/2016_ener_001_epbd_smart_buildings_en.pdf 
30 

 
                                                 
4.3. 

Complementarities  

The proposed objectives complement each other and ensure better energy performance of 
existing and new buildings and accelerated progress.  

There are synergies between the specific objectives of the review: further enhancing the 
removal of barriers and streamlining and modernising outdated provisions will maximise 
the role of the EPBD in raising renovation rates and in facilitating financing into building 
renovation.  

Similarly,  facilitating the  uptake of smart  technologies and innovation in buildings will 
help in contributing to tapping the saving potential of more efficient building operation 
and in facilitating the development of clean mobility.  

The  'Smart  Finance  for  Smart  Buildings'  Initiative  does  not  directly  require  legislative 
intervention. The three pillars of the initiative are already being addressed by supporting 
initiatives  and  projects.  The  present  impact  assessment  looks  at  supporting  measures 
directly  linked  to  the  EPBD  and  to  its  Article  10  on  financial  incentives  and  market 
barriers.  

5. 

WHAT ARE THE OPTIONS TO ACHIEVE THE OBJECTIVES?  

On  the  basis  of  the  evaluation  report  and  wide  stakeholder  consultation,  a  number  of 
actions  were  identified  to  address  remaining  barriers  to  energy  performance  in  the 
buildings sector.  

5.1. 

No-change option  

The  no-change  option  does  not  assume  that  nothing  will  happen.  This  option  implies 
continued implementation of the current EPBD and related regulatory and non-regulatory 
instruments  and  support  measures  such  as  sharing  of  good  practices,  stimulated  by 
exchange platforms (e.g. Concerted Action), but no additional EU measures as a result of 
a revised EPBD.  

The ongoing implementation of the Directive would continue, for instance with respect to 
the common EU voluntary certification scheme (Article 11(9) of the EPBD) to provide 
market participants in the non-residential sector with a tool for the reliable comparison of 
buildings’  energy  use  across  borders.  The  EPBD  would  deliver  on  NZEB  and 
continuously  reassess  the  cost-optimality  and  eventually  tighten  national  minimum 
requirements in 5-years cycles.  

However,  this  option  would  not  enable  addressing  the  conclusions  of  the  recent 
evaluation of the EPBD and would prevent simplifications of outdated provisions to be 
introduced, enhancing  compliance  through  fine  tuning  of  existing  provisions  and  better 
linking them with financial support; and modernising the EPBD in light of technological 
developments and the need to accelerate renovation rates and support decarbonisation of 
buildings.  

31 

 
5.2. 

Simplification measures  

To remove outdated or inefficient provisions identified during the implementation of the 
current  Directive,  two  simplification  measures  are  identified  on  the  basis  of  the 
evaluation. 

5.2.1.  Remove  the  mandatory  study  of  the  feasibility  of  high-efficiency  alternative 

systems  

The  Directive  would  be  amended  to  remove  the  need  to  document  and  verify  the 
assessment of alternative heating and cooling systems preceding the construction of new 
buildings.  

With the obligation for all new buildings to be nearly zero-energy buildings, the use of 
locally available high-efficiency alternative systems becomes an implicit obligation and 
this provision becomes an unnecessary burden.  

5.2.2. 

Simplify the provision on regular inspections and ensure that their objective is 
achieved more effectively  

The  Directive  would  be  amended  to  simplify  and  modernise  the  provisions  on 
inspections  of  heating  and  air-conditioning  systems,  benefiting  of  the  technological 
progress.  

This measure would address the fact that inspections of the energy efficiency of heating 
and  cooling  systems  tend  to  be  burdensome,  difficult  to  implement,  and  partially 
duplicating  EPC’s  recommendations.  Many  Member  States  have  already  opted  out  and 
taken  the  opportunity  to  implement  alternative  equivalent  measures,  as  allowed  by  the 
EPBD.  Measure  3A  is  considered  as  substitution  measure  to  ensure  that  technical 
building systems' performance in operation is adequately maintained overtime.  

5.3.  Measures to address the problems  

A  set  of  policy  measures  including  non-legislative  and  legislative  alternatives  are 
considered in order to address the drivers of the problems identified above.  

The  measures  considered  are  detailed  in  Annex  6  and  their  key  elements  are  as 
summarised below:  

5.3.1.  Measure  1:  Accelerate  the  decarbonisation  of  buildings  by  significantly 

increasing renovation rates  

This measure intends to address some market failures and includes two sub-measures:  

 

 

1A, send clear market signals by requiring Member States to set milestones for the 
decarbonisation  of  buildings  by  2050  as  part  of  their  long  term  renovation 
strategies for mobilising investment in the renovation under Article 4 of the EED; 
and  

1B  (alternatively  or  additionally),  a  more  direct  intervention  requiring  Member 
States to oblige building owners to ensure that their properties reach a given energy 
performance standard before being sold or rented out.  

32 

 
5.3.2.  Measure  2:  Fine  tune  the  implementation  of  minimum  energy  performance 

requirements  

This measure intends to address some regulatory failures and includes two sub-measures:  

 

 

2A,  providing  guidance  to  member  States  to  ensure  more  transparency  of 
calculation  methodologies  based  on  cost-optimality,  which  ultimately  will 
contribute  to  address  the  performance  gap  between  calculated  energy  demand  of 
existing buildings and actual consumption and informs the sector about upcoming 
requirements to improve their uptake; and  

2B, amending the cost-optimal methodology set up in Delegated Regulation (EU) 
No  244/2012  to  (i)  include  additional  benefits;  and  (ii)  go  beyond  cost-optimal 
levels of minimum requirements.  

5.3.3.  Measure  3:  Modernisation  using  smart  technologies  and  simplification  of 

outdated provisions for the benefit of citizens  

This measure intends to address some regulatory and market failures and includes three 
sub-measures:  

 

 

 

3A,  as  a  replacement  of  the  outdated  provisions  on  inspection  obligations, 
mandatory installation of electronic monitoring ability for large central systems in 
multi-family  house  buildings,  and  installation  of  building  automation  systems  in 
big non-residential buildings;  

3B,  modernising  provisions  on  technical  building  systems  to  progress  on  smart 
technologies by introducing  a smartness  indicator  for all buildings at  the  moment 
of transaction (sale or rent);  

and 3C, supporting electro-mobility by requiring that newly constructed buildings 
and  specifically  their  parking  places  have  the  necessary  electric  infrastructure  in 
place  to  enable  the  later  installation  of  smart  charging  points  (i.e.,  parking  lots 
prepared to receive charging points).  

5.3.4.  Measure  4:  Enhance  financial  support  and  information  to  users  through 

reinforced energy performance certificates  

This measure intends to address some market failures and includes two sub-measures:  

 

4A, a) reinforcing current requirements for independent control systems and energy 
performance certification by defining a minimum list of information to be collected 
and registered regional or national EPC databases and minimum requirements for 
databases in particular the regarding the facility for voluntary disclosure of actual 
energy  consumption;  b)  reinforcing  the  link  between  energy  performance 
certification  and  financial  support  by  requiring  that  when  renovation  works  are 
supported by public funding, an EPC is issued after renovation works, which would 
ensure efficient financial support and enable the alignment of the intensity of public 
financing support to the achieved depth of renovation;  

 

4B,  setting  up  an  harmonised  template  for  EPCs  based  on  a  common  list  of 
parameters/indicators  shown  on  the  certificate,  such  as  calculated  annual  final 
energy  use, share  of  renewable  energy  used,  past  (climate  corrected)  final  energy 

33 

 
consumptions and energy expenditure, comfort levels (as proposed in Measure 2B) 
or the level of smartness (as proposed in Measure 3B).  

Figure 5 presents a problem tree, linking problem types, drivers and policy measures.  

34 

 
 
 
Figure 5: Problem tree  

Table 14 in Annex 6 presents the target groups, the type of obligation and the scope of 
the  different  measures  in  detail.  These  measures  work  equally  well  for  all  buildings 
types,  unless  indicated  differently.  Annex  6  also  develops  further  the  analysis  on 
subsidiarity and proportionality aspects of individual measures.  

5.4. 

Bundling of measures into policy options  

Table  2  presents  the  grouping  of  the  proposed  measures  presented  above,  into  policy 
options.  

The grouping of measures into policy options is based on the instruments needed for the 
implementation, in particular:  

 

 

Implemented via soft law (Option I);  

Implemented  via  targeted  amendments  of  the  current  EPBD  (Option  II,  the 
preferred option);  

  Requiring a fundamental revision of the current EPBD (Option III).  

35 

 
  
 
 
Table 2: Policy options. 

Measures 

Reference: No-
change option 

Option I: 
Enhanced 
implementation 
and further 
guidance  

Option II: 
Enhanced 
implementation 
including 
targeted 
amendments 
for 
strengthening 
of current 
provisions 

Option III:  
Enhanced 
implementation 
towards further 
harmonization 
and higher 
ambition 

2A 

2A 

1A 

1A  
1B 

Measure 1. Accelerate the 
decarbonisation of buildings by 
significantly increasing 
renovation rates 
Measure 2. Fine tune the 
implementation of minimum 
energy performance requirements 
Measure 3. Modernisation using 
smart technologies and 
simplification of outdated 
provisions for the benefit of 
citizens 
Measure 4. Enhance financial 
support and information to users 
through reinforced energy 
performance certificates 
(*) This measure includes a simplification component addressing outdated provisions in Articles 6, 7, 14, 15 
and 16 of the current Directive  
(**) These two measures modernise current provisions in light of technical development and the need to support 
smart technologies and electro-mobility 

3A(*) 
3B (**) 
3C (**) 

3A 
3B 
3C 

2A 
2B 

4A 
4B 

4A 

5.4.1.  Reference scenario for modelling policy options  

The  EPBD  is  co-delivering  in  synergy  with  other  energy  efficiency  legislation  (EED, 
Ecodesign,  Energy  Labelling)  and  financial  support  under  the  European  Structural  and 
Investment  fund  and  financial  support  measures.  As  a  consequence,  the  reference 
scenario assumes a set of boundary conditions for the policy environment as presented in 
Annex 4.  

5.4.2.  Option I: Enhanced implementation and further guidance  

This option considers the set of proposals that enhance the implementation of the existing 
regulatory framework without amending the Directive. It builds on the work being done 
at EU, national and regional levels to actively implement the Directive. Compared with 
the  no-change  option,  it  goes  one  step  further  in  proposing  soft  law  and  guidance  that 
could  improve  the  implementation  and  enforcement  of  the  legislation  and  the  use  of 
voluntary measures which have not yet been explored by Member States.  

With guidance for clarifying the calculation of the energy performance of buildings and 
the calculations and implementation of the cost-optimal levels of minimum requirements 
(Measure  2A),  Option  I  proposes  an  answer  to  intensify  implementation  of  the  current 
legislation.  In  this  case  this  would  be  accomplished,  for  example,  by  ensuring  that  the 
potential for the integration of renewable energy sources and the highly efficient systems 
are considered as required by the Directive.  

36 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
5.4.3.  Option  II:  Enhanced  implementation,  including  targeted  amendments  for 

strengthening current provisions  

This option goes beyond measures in Option I and requires targeted amendments of the 
current  EPBD  to  address  the  problem  drivers  more  extensively.  However,  contrary  to 
Option III, this option stays in line with the intervention logic of the current EPBD.  

Table 3 lists the drivers and indicates which measures of Option II are addressing them.  

Table 3: Drivers addressed by measures in policy option II 

Drivers 

Measure(s) addressing it 

Lack of understanding on energy use 
and potential savings 

Limited activity in a post-crisis context 

Split incentives 

Lack of attractive financing products 

Limited information on building stock 

Limited uptake of efficient and smart 
technologies 

Potential for improvement of the 
national implementation 

Potential for simplification  

Potential to better avoid potential 
negative effects 

4A. Reinforced quality of energy performance certificates 
quality to enhance the financial support 
1A. Set milestones for the decarbonisation of the building stock 
by 2050 
1A. Set milestones for the decarbonisation of the building stock 
by 2050 
1A. Set milestones for the decarbonisation of the building stock 
by 2050 
4A. Reinforced quality of energy performance certificates 
quality to enhance the financial support 
2A. Clarify provisions on calculation methodologies and on 
implementation of cost-optimal levels of minimum 
performance requirements  
3A. Document the initial performance of technical building 
systems and maintain their operational performance over time  
3B. Framework for the introduction of a smartness indicator  
3C. Support to electro-mobility 
2A. Clarify provisions on calculation methodologies and on 
implementation of cost-optimal levels of minimum 
performance requirements  
4A. Reinforced quality of energy performance certificates 
quality to enhance the financial support 
3A. Document the initial performance of technical building 
systems and maintain their operational performance over time 
2A. Clarify provisions on calculation methodologies and on 
implementation of cost-optimal levels of minimum 
performance requirements 

Option II addresses most drivers associated to market failures by:  

  Sending  a  clear  signal  to  the  market  regarding  existing  buildings  by  placing  the 
long  term  renovation  strategy  within  the  ambition  for  the  building  sector  to  be 
decarbonised by 2050, with milestones in 2030;  

  Developing  a  framework  to  support  the  flowing  of  financial  resources  into  the 

buildings sector, in particular for building renovation; 

  Developing  a  smartness  indicator  that  informs  consumers  about  the  ability  of 
buildings to operate more efficiently, monitor and control energy use and interact 
with users and the grids;  

  Support  the  development  of  infrastructure  to  support  the  roll-out  of  electro-

mobility solutions.  

37 

 
  
Option II also addresses drivers associated to regulatory failures by:  

 

Improving the effectiveness of EPCs with measures that strengthen, modernise and 
further  integrate  the  EPC  schemes  within  a  framework  that  aids  compliance 
checking and effectiveness of financial support;  

  Simplify the EPBD with measures that modernise the provisions related to regular 
inspections with ICT and repeal of the provisions related to mandatory documented 
feasibility study for efficient systems.  

5.4.4.  Option III: Enhanced implementation towards further harmonization and higher 

ambition  

This policy option includes the most ambitious measures explored, some of which going 
beyond the current intervention logic of the EPBD.  

Option III further addresses drivers associated to market failures by:  

  Having  a  more  direct  market  action  to  boost  the  activity  and  investments.  In 
requiring  buildings  to  reach  a  given  standard  before  they  are  sold  or  rented,  the 
intervention  goes  beyond  the  logic  of  setting  minimum  energy  performance 
standards in building codes.  

Option III also further addresses drivers associated to regulatory failures by harmonising 
aspects so far left to subsidiarity:  

  Additional sustainability co-benefits in the cost-optimal calculation framework;  

  New  targeted  ambition  for  new  buildings  in  2030,  beyond  cost-optimality  and 
including  the  mandatory  setting  for  minimum  requirements  for  the  indoor 
environment;  

  Further harmonisation of the EPCs.  

6. 

HOW DO THE OPTIONS COMPARE?  

6.1. 

Assessment of the impacts of the policy options  

Impacts  of  policy  options  have  been  assessed  with  the  models  and  underlying 
assumptions explained in Annex 4.  

Annex 4 also describes and assesses the reference scenario against which the following 
results are presented.  

6.1.1. 

Impacts of Option I  

The implementation of this  option would contribute to the reduction of the demand for 
space  and  water  heating  final  energy  consumptions  in  residential  and  non-residential 
buildings of around 2 Mtoe by 2030 relative to the reference scenario. This would be a 
result  of  improving  the  national  calculation  methodologies,  progress  towards  cost-
optimal and easier enforcement of minimum requirements.  

Compared to the reference scenario, energy and climate results for Option I are presented 
in Table 4.  

38 

 
Table 4: Energy and climate results for policy option I 

Energy and climate by 2030 (Compared to the reference) 
Total final energy savings 
Increase of on-site renewable electricity generation 
(Net) primary energy savings 
Improvement of the average energy performance of the building 
stock 
GHG emissions reduction 
Improvement of GHG emission per square meter 

2 Mtoe 
0.3 Mtoe 
2 Mtoe 
0.76kWh/(m².y) 

3.2MtCO2 
0.11kgCO2/m² 

The  macroeconomic  impacts  of  this  policy  option  are  modest.  Overall,  there is  a  slight 
positive impact on GDP.  

The share of EU total final energy used in GDP by 2030 is small. This option will only 
contribute marginally to the competitiveness of European industry (mainly insulation and 
flat glass) by increasing their market, and have somehow an impact in renovation market 
for SMEs. EU additional energy related activity (roof insulation, windows replacement, 
building  system  upgrade,  etc.)  for  the  construction  sector  associated  with  this  option  is 
approximately €2bn.  

The option does not mandate or impose investment on households, businesses or public 
authorities.  Additional  activity  results  of  decision  taken  by  individuals  based  on  better 
information.  

Overall,  the  impacts  of  this  option,  including  on  energy  poverty,  are  rather  small. 
Detailed macroeconomic impacts figures are presented in Annex 8.  

6.1.2. 

Impacts of Option II  

The implementation of this  option would contribute to the reduction of the demand for 
space  and  water  heating  final  energy  consumptions  in  residential  and  non-residential 
buildings.  The  estimated  reduction  of  final  energy  consumption  for  space  and  water 
heating final energy consumptions in households and services is around 28 Mtoe by 2030 
relative to the reference scenario. The full details and assumptions used for estimating the 
impacts of this option are presented in detail below and in Annexes 4 to 9.  

Compared  to  the  reference  scenario,  energy  and  climate  results  for  Option  II  are 
presented in Table 5.  

Table 5: Energy and climate results for Policy option II 

Energy and climate by 2030 (Compared to the reference) 
Total final energy savings 
Increase of on-site renewable electricity generation 
(Net) primary energy savings 
Improvement of the average energy performance of the building 
stock 
GHG emissions reduction 
Improvement of GHG emission per square meter 

28 Mtoe 
2 Mtoe 
30 Mtoe 
8.06kWh/(m².y) 

38MtCO2 
1.32kgCO2/m² 

39 

 
  
  
The  relative  impacts  of  the  measures  that  compose  this  policy  option  are  presented  in 
Table 6.  

Table 6: Impact of the different measures of policy option II 

Measures 

Impacts on 
savings 
in 2030 

Impacts on 
annual energy 
expenditures in 
2030 

Impacts on associated 
construction activity 
(annual average for 
2020 - 2030) 

4 – 6 Mtoe 

4 – 6 bn€/a 

8 – 12 bn€/a 

Measure 1. Accelerate the decarbonisation of buildings by significantly increasing renovation rates 
1A. Set milestones for contributing to the 
decarbonisation of the building stock by 
2050 
Measure 2. Fine tune the implementation of minimum energy performance requirements 
2A. Improve transparency of calculation 
methodologies and provide further 
clarification on the cost-optimal setting of 
minimum performance requirements 
Measure 3. Modernisation using smart technologies and simplification of outdated provisions for the 
benefit of citizens 
3A. Document the initial performance of 
technical building systems and maintain 
their operational performance over time 
3B. Framework for the introduction of a 
smartness indicator 
3C. Support to electro-mobility 

2 – 4 bn €/a 
(Mandated 1 – 3 bn€/a) 

8 – 10 bn€/a 

8 – 10 Mtoe 

5 – 6 bn €/a 

1 – 3 bn€/a 

1 – 3 bn€/a 

5 – 7 bn€/a 

1 – 3 Mtoe 

5 – 7 Mtoe 

N.C. 

N.C. 

3 – 4 bn €/a 
(Mandated 0.5bn€/a) 

Measure 4. Enhance financial support and information to users through reinforced energy 
performance certificates 
4A. Reinforced quality of energy 
performance certificates quality to 
enhance the financial support 
TOTAL (all measures included as in 
Option III) 

26 – 38 Mtoe  26 – 38 Mtoe 

8 – 12 bn€/a 

8 – 12 Mtoe 

35 – 53 bn€/a 
(Mandated 1 – 4 bn€/a) 

16 – 24 bn €/a 

The share of EU total final energy used in GDP decreases by 0.3% by 2030, and between 
515 thousand to 3.2 million households (from a total of 23.3 million households) would 
be taken out from energy poverty63.  

This option contributes significantly to the competitiveness of European industry (mainly 
insulation and flat glass) by increasing their market by €23.8bn at EU level in 2030, and 
creating a renovation market for SMEs with a value between €80bn to €120bn involving 
about 220,000 retained/created jobs from the reference scenario in 2030.  

63 

These  figures  are  based  on  Eurostat  EU-SILC  longitudinal  study,  which  includes  243,140 
observations in which energy poverty was operationalised by the following indicators in EU-SILC: 
leaking roof, damp walls/floors/foundation, or rot in window frames or floor, ability to keep home 
adequately  warm  and  arrears  on  utility  bills.  These  indicators  are  deemed  suitable  to  sufficiently 
capture  the  presence  of  energy  poverty  as  they  reflect  different  symptoms  experienced  or 
characteristics demonstrated by energy poor households (EPEE 2009) and have been used in prior 
research to assess the prevalence of fuel poverty across the EU (Healy/Clinch 2002; Thomson/Snell 
2013). These indicators are directly influenced by policies that improve the energy performance of 
buildings. 

40 

 
  
                                                 
EU  additional  energy  related  activity  (roof  insulation,  windows  replacement,  building 
system  upgrade,  etc.)  for  the  construction  sector  estimated  for  this  option  is 
approximately €47.6bn.  

Only  €1bn  to  €4bn  would  be  directly  mandated  by  the  measures  of  this  option,  as 
presented  in  the  table  above.  The  majority  of  the  estimated  additional  activity  would 
result 
taken  by  national/regional/local  authorities, 
organisations and individuals based on better information regarding energy performance 
of buildings.  

investment  decisions 

from 

Therefore, it is clearly a cost-effective policy option considering the economic impacts, 
and  even  more  positive  when  put  into  perspective  all  the  other  additional  social  and 
environmental  benefits.  Detailed  macroeconomic  impacts  figures  are  presented  in 
Annex 8.  

Taken  together,  the  measures  of  this  preferred  policy  option  would  reduce  the 
administrative  burden  of  the  Directive  by  €98.1  million  per  year.  Calculation  of  the 
impact on administrative burden for the preferred option can be found in Annex 9.  

6.1.3. 

Impacts of Option III  

The implementation of this  option would contribute to the reduction of the demand for 
space  and  water  heating  final  energy  consumptions  in  residential  and  non-residential 
buildings.  The  estimated  reduction  of  final  energy  consumption  for  space  and  water 
heating final energy consumptions in households and services is around 72 Mtoe by 2030 
relative to the reference scenario.  

Compared  to  the  reference  scenario,  energy  and  climate  results  for  Option  III  are 
presented in Table 7.  

Table 7: Energy and climate results for policy option III 

Energy and climate by 2030 (Compared to the reference) 
Total final energy savings 
Increase of on-site renewable electricity generation 
(Net) primary energy savings 
Improvement of the average energy performance of the building 
stock 
GHG emissions reduction 
Improvement of GHG emission per square meter 

72 Mtoe 
2 Mtoe 
74 Mtoe 
25.81kWh/(m².y) 

134MtCO2 
4.62kgCO2/m² 

The  relative  impacts  of  the  measures  that  compose  this  policy  option  are  presented  in 
Annex 7, Table 15.  

As the share of EU total final energy used in GDP decreases by -0.7% by 2030, between 
1.5 million to 8.3 million households (from a total of 23.3 million households) would be 
taken out from fuel poverty.  

This  option  will  also  contribute  to  the  competitiveness  of  European  industry  (mainly 
insulation and flat glass) by increasing their market by €30bn at EU level in 2030, and 
creating a renovation market for SMEs with a value between €167bn and €250bn. It will 

41 

 
 
retain/create more than 500 thousand additional jobs compared to the reference scenario 
in 2030.  

EU  additional  energy  related  activity  (roof  insulation,  windows  replacement,  building 
system  upgrade,  etc.)  for  the  construction  sector  associated  with  this  option  is 
approximately €101bn.  

Amongst  these,  €52bn  to  €59bn  would  be  directly  mandated  by  the  measures  of  this 
option,  mainly  by  the  Measure  1B  that  introduces  mandatory  requirements  to 
significantly reduce the number of very inefficient buildings.  

limits  of  EU 

intervention.  However, 

It  is  also  cost-effective  policy  option  considering  the  economic  impacts  but,  with 
uncertain impact on the real estate market and probably stepping out of subsidiarity and 
proportionality 
the  additional  social  and 
environmental benefits of this option are proportionally higher; or significantly higher as 
the case of energy poverty alleviation, because the very inefficient buildings targeted by 
measure 1B are probably mostly occupied by low income people. Nevertheless, detailed 
statistical  data  on  national  building  stocks,  linked  with  socio-economic  indicators  is  a 
precondition  for  setting  obligations  on  building  renovation;  however,  this  data  is 
currently not available. These  types of data is being collected by some Member States in 
order to assess and/or design more ambitious interventions, as the proposed by Measure 
1B.  

Detailed macroeconomic impacts figures for all the options are presented in Annex 8.  

6.2. 

Comparison of the options  

Table 8 summarises the impacts of the different policy options.  

Table 8: Comparison of policy options 

Reference: No-
change option 

Option I: Enhanced 
implementation 
and further 
guidance  

Option II: 
Enhanced 
implementation, 
including targeted 
amendments for 
strengthening of 
current provisions 

Option III:  
Enhanced 
implementation 
towards further 
harmonization and 
higher ambition 

Additional 
final energy 
savings in 
2030 
Additional 
associated 
construction 
activity in 
2030 
Economic 
growth, incl. 
SMEs in 2030 
Jobs 
retained/ 
created 
Energy 
poverty 
alleviation 

- 

- 

- 

- 

- 

2 Mtoe 

28 Mtoe 

72 Mtoe 

€2.15bn 

€47.6bn  
(€1 – €4 bn 
mandated by the 
Option) 

€101bn  
(€52 – €59 bn 
mandated by the 
Option) 

€2.4bn - €10.1bn 

€103.8bn - €143.8bn 

€197bn - €280bn 

9k 

220k 

500k 

20k – 120k 
households 

515k - 3.2M 
households 

1.5M to 8.3M 
households 

42 

 
 
 
 
Reference: No-
change option 

Option I: Enhanced 
implementation 
and further 
guidance  

The policy 
objectives are only 
partially addressed 
through guidance. 
Further opportunities 
identified in the 
evaluation are not 
considered. 
Continuation of slow 
improvement of 
building energy 
performance, similar 
to reference. 

The impacts of the 
EPBD are difficult 
to determine but 
appear to be very 
similar to the 
reference scenario, 
i.e. the no policy 
change option. 

The coherence of the 
EPBD in this option 
is similar to the no 
policy change 
option. 

Effectiveness  The policy 

objectives are 
not fully met, 
and the 
opportunities for 
further 
enhancing the 
removal of 
barriers to 
energy 
efficiency, 
improving the 
effectiveness of 
the regulatory 
framework, are 
not exploited. 
The impact of 
the EPBD 
remains 
relatively limited 
and in line with 
the findings of 
the evaluation 
and projections 
included in this 
impact 
assessment. 

Coherence with 
other 
instruments is 
kept but 
identified 
opportunities for 
improvement are 
not taken 
forward. 
No impact on 
current level of 
subsidiarity 

Efficiency 

Coherence 

Subsidiarity 

Option III:  
Enhanced 
implementation 
towards further 
harmonization and 
higher ambition 

All policy objectives 
are addressed, and 
harmonisation of the 
implementation is 
achieved. The depth 
and rate of 
renovations is 
increased by gradual 
compulsory 
renovation of 
existing buildings. 
However it raises 
practical and 
subsidiarity 
concerns. 

The impacts are high 
mainly due to the 
more ambitious 
mandatory 
requirements 
introduced, increased 
harmonisation and by 
going beyond cost-
optimality. Important 
contribution to 
energy poverty 
alleviation. 
The coherence of the 
EPBD in the option 
is similar to Option 
II.  

Option II: 
Enhanced 
implementation, 
including targeted 
amendments for 
strengthening of 
current provisions 

Most of the policy 
objectives are 
addressed, and the 
cost-effective energy 
saving potential of 
existing buildings is 
ensured, but at the 
current rate of 
renovation and 
construction. The net 
administrative costs 
are negative. 

The impacts are 
significant in all the 
3 areas (economic, 
social and 
environmental). No 
significant changes 
to the existing 
framework, which 
allows for plenty of 
flexibility to Member 
States.  

The coherence of the 
EPBD in this option 
is significantly 
improved through 
better integration of 
existing provisions, 
links with financing, 
and related policies. 

No impact on 
current level of 
subsidiarity 

Low impact on 
current level of 
subsidiarity 

High impact on 
subsidiarity 

Option  I  is  mainly  focusing  on  continuous  enforcement  of  the  current  EPBD,  while 
supporting  Member  States  by  providing  guidance  and  support.  The  opportunity  to 
address opportunities identified in the evaluation report and public consultation to further 
enhance the removal of barriers to energy efficiency in buildings is therefore missed.  

Option III includes ambitious measures for increasing the renovation rate and therefore 
the  resulting  impact  is  very  high.  Option  III  introduces  a  significant  change  in  the 
building  sector,  in  particular  by  making  mandatory  the  renovation  of  thousands  of 
buildings.  However,  this  measure  raises  some  issues  such  as  (i)  obligatory  investment, 
which  (ii)  might  not  be  considered  cost-effective  in  a  purely  financial  perspective;  (ii) 

43 

 
 
 
 
  
raises  practical  concerns  (e.g.  further  harmonisation  of  energy  performance  calculation 
methodologies,  or  Energy  Performance  Certificates);  and/or  raise  concerns  regarding 
practical  implementation  (e.g.  obligations  to  renovate  buildings  when  changing 
ownership  or  tenancy,  financial  support  of  mandatory  thermal  building  renovation,  and 
mandatory  training  of  builders  and  installers).  However,  Option  III  has  significantly 
higher  impacts  than  the  other  options,  namely  because  of  the  introduction  of  the 
mandatory  requirements  for  renovation.  Member  States  could  find  useful  exploring  the 
opportunities  offered  by  the  additional  policy measures  proposed  in  Option  III. In  fact, 
some  are  already  assessing  and  gradually  putting  in  place  building  renovation 
requirements  (e.g.  Scotland  regarding  renovation  of  social  housing)  which  have 
significant  impacts  not  only  in  terms  of  energy  savings,  but  also  on  energy  poverty 
mitigation. 

Option  II  is  the  preferred  option  because  it  is  the  best  aligned  with  the  outcome  and 
findings of the evaluation of the EPBD and the existing European framework for climate 
and energy towards 2020 and 2030:  

 

 

 

 

It allows keeping the prudent and step by step expansion of the intervention scope 
underpinning  EU  action  on  buildings’  efficiency,  with  careful  attention  to 
leaving  significant 
subsidiarity,  proportionality,  and  cost-effectiveness  and 
flexibility to Member States;  

It preserves the main objectives, principles and overall architecture of the Directive 
(minimum standards for all types of building works and labelling, underpinned by 
the  cost-optimal  methodology  and  nearly  zero-energy  building  targets  for  new 
buildings)  as  it  shows  good  performance  and  is  supported  by  stakeholders, 
including Member States;  

It  favours  amendments  of  targeted nature, allowing  for  continued implementation 
of key provisions in the current Directive that are already delivering, and are cost-
effective;  

It  strikes  a  balance  between  guidance  (e.g.  to  facilitate  the  uptake  of  minimum 
requirements  in  line  with  the  current  legislation)  with  limited  legal  revisions  to 
introduce  new  focused  provisions  to  modernise  national  regulations  in  the 
buildings sector and to address in particular the existing building stock (less tackled 
by the provisions of the current Directive) and the link to finance.  

This option introduces significant improvements to the EPBD and the overall regulatory 
framework  for  improved  energy  performance  of  buildings  via  targeted  amendments, 
while  allowing  a  high  level  of  flexibility  for  the  implementation  at  national  level. 
However,  and  because  of  it  high  impacts,  the  measures  in  Option  III  appropriate  for 
further investigation at national and regional levels than for implementation at European 
level today.  

6.3. 

Subsidiarity and proportionality  

The  measures  of  the  preferred  policy  option  generally  keep  the  current  level  of 
subsidiarity  left  to  Member  States.  Subsidiarity  and  proportionality  concerns  were 
carefully considered in the definition of these two new measures, as explained in detail in 
Annex  6.  Subsidiarity  and  proportionality  were  important  elements  that  led  to  the 
exclusion of measures in Option III.  

44 

 
Most measures of the preferred Option II intend to:  

  Clarify  aspects  that  should  be  common  practice  (e.g.  setting  clear  milestones  in 
national  long-term  renovation  strategies,  requiring  that  adequate  information  is 
handed  over  to  the  building  owner  after  intervention  on  a  technical  building 
system,  public  financial  support  linked  to  the  level  of  energy  efficiency 
improvement, etc.);  

  Recommend best practises and set up common elements at EU level of approaches 
important  number  of  Member  States  (e.g.  EPC 

already  shared  by  an 
registers/databases in practically all Member States);  

 

Improve  transparency  of  implementation  (e.g.  on  the  calculation  of  the  energy 
performance of buildings).  

Two fundamentally new measures are introduced by the preferred policy option:  

  Smartness  indicator:  The  measure  builds  on  the  provision  of  information  and 
empowerment  rather  than  direct  obligation  to  install  electronic  monitoring.  EU 
intervention  is  justified  by  the  necessity  to  create  a  market  of  a  sufficient  size  to 
improve  the  cost-effectiveness  of  investments  in  research  and  development.  No 
investment is directly mandated by the measure;  

  Support to electro-mobility: As established in the above Section 2.1.2, the density 
of  the  network  for  charging  points,  in  particular  in  private  parking  spaces,  is 
recognised  to  be  a  key-enabler  for  the  development  of  electro-mobility.  The 
construction and the major renovation of buildings are good opportunities to install 
smart  recharging  points,  or  at  least  facilitate  their  later  installation.  The  proposed 
measure is  proportionate as  only  mandates the minimum infrastructure to  remove 
the  barrier  to  the  later  installation  of  recharging  points.  The  approach  is  also 
differentiated  for  large  multi-apartment  blocks  and  non-residential  (e.g.  office 
buildings  and  building  frequently  visited  by  the  public).  As  a  consequence,  the 
economic impact of the measure itself would be negligible compared to the cost of 
the building.  

7. 

HOW WOULD IMPACTS BE MONITORED AND EVALUATED?  

The  2008  Impact  Assessment  supporting  the  EPBD  did  not  address  monitoring 
arrangements  and  indicators  in  detail.  The  implementation  of  the  Directive  and  its 
different  provisions  has  been  mainly  followed  up  through  the  work  of  the  Committee 
established  in  Article  26  of  the  Directive,  the  transposition  checks  and  dialogues  with 
Member  States  on  national  implementation,  and  the  role  of  the  work  of  the  EPBD 
Concerted Action as explained in the evaluation report.  

The  evaluation  of  the  EPBD  identified  two  main  reasons  for  the  lack  of  structured 
monitoring  data.  Firstly,  there  is  limited  available  data  on  disaggregated  energy 
consumption in the households sector and, even more, in the services sector. Secondly, 
the  timeline  for  the  evaluation  (end  of  2016)  does  not  allow  sufficient  time  to  have 
Eurostat global annual energy data more recent than 2014 whilst the application deadline 
for most provisions was January 2013.  

45 

 
Nevertheless,  efforts  have  been  undertaken  since  the  2008  Impact  Assessment  to 
overcome  this  problem  in  the  future.  The  EU  Building  Stock  Observatory64,  currently 
under  development  by  the  European  Commission,  will  be  as  of  mid-2016  an  essential 
tool for monitoring and steering the improvement of energy efficiency in buildings and to 
support  the  implementation  of  the  EPBD.  Data  from  readily  available  sources  at 
European and national levels are being collected by external contractors under a service 
contract.  The  Observatory  includes  indicators  on  building  stock,  in  use  energy 
consumption,  fuel  mix,  technical  systems;  certification,  financing  and  energy  poverty 
(see  Annex  13  for  the  detailed  list  of  indicators).  The  list  of  indicators  has  been 
elaborated  with  the  collaboration  of  national  authorities  and  industry  stakeholders. 
Extracts of the data already available in the EU Building Stock Observatory are presented 
in Annex 11.  

In  addition,  the  Energy  Statistics  Regulation  (EC)  No  1099/2008  of  the  European 
Parliament  and  of  the  Council  has  been  amended  in  2014,  in  order  to  cover  the  final 
energy consumption in households not only by type of fuel but also by type of use (space 
heating, space cooling, water heating, cooking, lighting and appliances, and other uses). 
The  first  legally  binding  data  collection  will  cover  the  reference  year  2015;  in  the 
meantime  Eurostat  has  encouraged  Member  States  to  proceed  to  a  voluntary  data 
collection  –  one third of the Member States  have  participated. Furthermore, Eurostat is 
currently working together with Member States for the further disaggregation of energy 
data in the sector 'Industry' and further sectors, as for example 'Services', will be tackled 
in the medium term.  

Similarly,  a  methodology65  to  evaluate  the  energy  performance  of  existing  and  new 
buildings at municipal scale is being developed and would contribute to fill information 
gaps in future evaluations.  

Indicators  of  success  in  line  with  the  preferred  option  to  enter  into  force  once  the 
proposal  is  adopted,  would  be  the  gradual  improvement  of  energy  performance  of 
buildings  and  the  progressive  closure  of  the  gap  between  minimum  requirements  and 
cost-optimal  levels,  the  increasing  uptake  of  smart  and  renewable  technologies  and 
progress  across  Member  States  in  reinforcing  accompanying  measures  to  make  EPCs 
more reliable and a true accelerator of building renovation.  

The  EU  building  Stock  Observatory  will  be  the  central  point  for  the  collection  of  all 
relevant  information  on  the  EU  Building  Stock,  and  will  ultimately  enable  monitoring 
and evaluation of the impacts of the measures proposed in the preferred policy option.  

64 
65 

https://ec.europa.eu/energy/en (to be launched in July 2016) 
JRC/LUISA approach for EU-wide energy related indicators, Upcoming, 2016 

46 

 
                                                 
ANNEX 1  ACRONYMS AND GLOSSARY  

Acronyms  

CPR: Construction Product Regulation  

EED: Energy Efficiency Directive  

EPBD:  Directive  2010/31/EU  Energy  Performance  of  Buildings  Directive  (recast), 
inclusive of the provisions kept from the Directive 2002/91/EC it recast.  

EPC: Energy Performance Certificate  

NZEB: Nearly-Zero Energy Buildings  

MS: Member States  

SFSB: Smart Finance for Smart Buildings  

Glossary  

Building:  Buildings  are  roofed  constructions  that  can  be  used  separately  and  built  for 
permanent  purposes,  which  can  be  entered  by  persons  and  are  suitable  or  intended  for 
protecting  persons,  animals  or  objects  (Eurostat,  CC1998).  The  EPBD  applies  only  to 
buildings  with  walls  for  which  energy  is  used  to  condition  the  indoor  climate  (EPBD, 
Article 2(1)).  

Building stock: All buildings from residential and services sectors (i.e. residential, and 
non-residential buildings).  

Residential buildings: Buildings at least half of which is used for housing purposes. If 
less than half of the overall useful floor area is used for housing purposes, the building is 
classified under non-residential buildings in accordance with its purpose-oriented design. 
(Eurostat,  CC1998).  The  residential  building  category  can  be  further  divided,  e.g. 
depending on the ownership and the tenure status.  

Non-residential  buildings:  Buildings  which  are  mainly  used  or  intended  for  purposes 
other  than  housing.  If  at  least  half  of  the  overall  useful  floor  area  is  used  for  housing 
purposes,  the  building  is  classified  as  a  residential  building.  (Eurostat,  CC1998).  The 
non-residential building category can be further subdivided depending, e.g. on the nature 
of the occupant (public or  private), the nature of the occupation  (retail shops,  etc.),  the 
frequentation (visited by the public or not).  

Building unit: Section within a building designed or altered to be used separately (e.g. 
an apartment in a multi-apartment block, a retail shop at the ground floor of a residential 
building).  

Building  product:  Any  product  which  is  produced  and  placed  on  the  market  for 
incorporation  in  a  permanent  manner  in  building  works  or  parts  thereof  and  the 
performance  of  which  has  an  effect  on  the  performance  of  the  building  works  with 
respect to the basic requirements for building works (Derived from CPR, Article 2(1)).  

Building code: Set of rules regulating the basic requirements for building works in both 
new  and  existing  building.  Basic  requirements  may  include  requirements  on:  1. 

47 

 
Mechanical resistance and stability; 2. Safety in case of fire; 3. Hygiene, health and the 
environment;  4.  Safety  and  accessibility  in  use;  5.  Protection  against  noise;  6.  Energy 
economy  and  heat  retention;  7.  Sustainable  use  of  natural  resources  (Framework  from 
CPR Annex 1).  

Building envelope: Integrated elements of a building which separate its interior from the 
outdoor  environment  (EPBD,  Article  2(7)).  The  elements  that  are  part  of  buildings' 
envelope (wall, roof, glazed parts, etc.) generally consist of a system of building products 
separating the interior from the outdoor environment.  

Building  element:  Either  a  technical  building  system  or  an  element  of  the  building 
envelope (Adapted from EPBD, Article 2(9))  

Construction work: Buildings and civil engineering works (CPR, Article 2(3)).  

Embodied  energy:  Total  of  all  energy  consumed  in  the  processes  associated  with  the 
production  (and  transport)  of  the  materials  and  components  that  go  into  a  building  or 
structure.  

Energy performance of a building: Amount of net primary energy needed to meet the 
different needs associated with its typical use and shall reflect the heating energy needs 
and cooling energy needs (energy needed to avoid overheating) to maintain the envisaged 
temperature  conditions  of  the  building,  domestic  hot  water  needs  and  built-in  lighting. 
The energy performance of a building must be expressed in a transparent manner with an 
energy  performance  indicator  and  a  numeric  indicator  of  primary  energy  use  (Adapted 
from EPBD Article 2(4) and Annex I).  

Nearly  zero-energy  building:  Building  that  has  a  very  high  energy  performance.  The 
nearly  zero  or  very  low  amount  of  energy  required  should  be  covered  to  a  very 
significant extent by energy from renewable sources.  

Major renovation: Building works of a certain cost (cost higher than 25% of the value 
of  the  building)  or  magnitude  (affecting  more  than  25%  of  the  surface  of  the  building 
envelope)  that provide  a special  opportunity  to  take cost-effective measures to  enhance 
energy performance, beyond the simple retrofit of building elements.  

Specific (primary/final) energy use: (Primary/final) energy use within the EPBD scope, 
space and water heating, space cooling, ventilation and lighting.  

Energy  performance  of  a  building  element:  Performance  related  to  energy  for  the 
integrated building element, expressed by level or class, or in a description  

Technical building systems: Technical equipment for the heating, cooling, ventilation, 
hot water, lighting or for a combination thereof (EPBD, Article 2(3)).  

Cost-optimal  level:  Energy  performance  level  which  leads  to  the  lowest  global  cost 
during the estimated economic lifecycle. The cost-optimal level shall lie within the range 
of  performance  levels  where  the  cost  benefit  analysis  calculated  over  the  estimated 
economic lifecycle is positive.  

48 

 
ANNEX 2 

PROCEDURAL INFORMATION  

General information  

Lead DG  
DG ENER  

(COMP),  Economic  and  Financial  Affairs 

Associated Commission Services:  
SG,  Legal  Service  (SJ),  Agriculture  and  Rural  Development  (AGRI),  Budget  (BUDG), 
Climate  Action  (CLIMA),  Communications  Networks,  Content  and  Technology 
(CNECT),  Competition 
(ECFIN), 
Employment,  Social  Affairs  and  Inclusion  (EMPL),  Environment  (ENV),  Eurostat 
(ESTAT),  Financial  Stability,  Financial  Services  and  Capital  Markets  Union  (FISMA), 
Health  and  Food  Safety  (SANTE),  Internal  Market,  Industry,  Entrepreneurship  and 
SMEs (GROW), Joint Research Centre (JRC), Justice and Consumers (JUST), Mobility 
and Transport (MOVE), Regional and Urban Policy (REGIO), Research and Innovation 
(RTD), Taxation and Customs Union (TAXUD), Trade (TRADE), Executive Agency for 
Small and Medium-sized Enterprises (EASME).  

Agenda planning/WP references: 2016/ENER/001  
The  preparatory  work  to  assess  the  implementation  of  the  EPBD,  financing  of  energy 
efficiency  and  knowledge  about  the  building  stock  started  in  2014  to  ensure  that  the 
information would be ready for the IA in 2016. Additional studies in support of the ex-
post evaluation of the EPBD, ex-ante analysis of policy options and modelling including 
of 'Smart Financing for Smart Buildings' and modelling were launched in the first quarter 
of  2015  in  the  light  of  the  evaluation66  and  Inception  Impact  Assessment67  roadmaps, 
which were published respectively in July and November 2015.  

The Secretariat General (SG) has set up an ISG on the review of the EED, the EPBD and 
the 'Smart Financing for Smart Buildings'- initiative. The group met in total nine times in 
support of the full review process, from 30 April 2015 to 28 June 2016.  

Consultation with stakeholders  

Supplementing  the  consultation  activities  undertaken  for  the  evaluation,  including 
external  expertise  used,  which  are  presented  in  Annex  4  of  the  Evaluation  report,  the 
Commission organised a stakeholder event that took place on 14 March 2016.  

Approximately  300  participants  from  European  industry  and  civil  society  organisations 
and from Member States took part in this event.  

During  the  Event,  the  Commission  Services  outlined  preliminary  findings  of  the 
evaluations of selected articles of the Energy Efficiency Directive and of the EPBD. The 
afternoon  session  was  specifically  dedicated  to  the  EPBD  and  provided  inputs  to  the 
Impact Assessment.  

66 

67 

http://ec.europa.eu/smart-
regulation/roadmaps/docs/2016_ener_023_evaluation_energy_performance_of_buildings_directive
_en.pdf  
http://ec.europa.eu/smart-regulation/roadmaps/docs/2016_ener_001_epbd_smart_buildings_en.pdf  
49 

 
                                                 
Some  stakeholders  strongly  advocated  that  the  EPBD  should  remain  at  the  level  of  the 
building, without considering the district level. Other defended the integrated approach, 
considering the influence of energy supply. The Commission Services reminded that, as 
the  energy performance  of  buildings  is  established  in  primary  energy, the  efficiency  of 
the supply side is already valued through the conversion factors to primary energy.  

There was also a suggestion to better link the EPBD to other Directives e.g. by linking 
audits required under the EED to maintenance requirements under the EPBD.  

Regarding renovation of existing buildings, there was support for a clear 2030 and 2050 
vision for the existing building stock similar to the current targets for new buildings.  

Much  of  the  discussion  concentrated  on  EPCs.  Certain  stakeholders  asked  for  further 
harmonization  of  the  EPCs  given  the  big  differences  in  implementation  by  Member 
States, and to put forward minimum requirements that allow more reliable ratings; other 
stakeholders also highlighted the fundamental differences in the quality of EPCs across 
Member States.  In  some  Member States,  the EPCs can  be ordered via a website where 
other Member states require an extensive audit.  

The discussion on finance covered VAT rates and treatment in public accounts.  

Regulatory Scrutiny Board  

The Regulatory Scrutiny Board of the European Commission assessed a draft version of 
the present impact assessment report and issued its opinions on 9 June 201668 and 26 July 
201669. The Regulatory Scrutiny Board made the following recommendations:  

First submission  

On the draft version  of  3 May 2016 the Board  gave  a negative opinion stating that the 
report contained shortcomings that need to be addressed, particularly with respect to the 
following issues:  

(1)  The  case  for  further  policy  action  in  this  area  at  this  point  in  time  should  be 
clarified, given the relatively recent entry into force of the current Directive and 
the lack of clear regulatory failure. In particular, the problem and its key drivers 
should be explored in more depth.  

(2)  The  options  section  and  analysis  should  be  revised  to  clarify  the  link  between 
the individual measures and the identified problems. The report needs to show 
to what extent the proposed additional measures can be justified on the basis of 
proportionality and subsidiarity, and what their expected impacts are (costs and 
benefits).  

(3)  The links between the different options the associated investment needs and the 
envisaged  financing  sources/incentives  should  be  clarified,  since  the  lack  of 
financing  for  the  required  investments  is  admittedly  a  major  constraint  in  the 
delivery of the expected improvements in the energy performance of buildings.  

(4)  Given the REFIT nature of this initiative, a more elaborate analysis and, where 

possible, quantification of administrative costs/burdens is required.  

68 
69  

Ares(2016)2686314 
Ares(2016)3925038 

50 

 
                                                 
Second submission  

On the draft version of 1 July 2016; the Board gave a positive opinion, requiring however 
that the report be adjusted in order to integrate the Board's recommendations and address 
a number of the shortcomings identified in its first Opinion that had not, it stated,  been 
dealt with satisfactorily.  

The Board considered that the revised report had generally been improved: The problem 
drivers  had  been  further  analysed  acknowledging  the  importance  of  contextual  factors 
(e.g. economic crisis) and recognising that regulatory failures remain relatively limited. 
The  report  had  also  streamlined  the  individual  measures  providing  clearer  information 
per  measure  regarding  the  costs,  the  impacts  on  energy  savings  and  on  annual  energy 
expenditure  as  well  as  regarding  the  argumentation  in  terms  of  subsidiarity  and 
proportionality. More details had been provided on the various envisaged options and the 
required  financing  needs.  In  REFIT  terms,  the  standard  cost  model  had  been  used  to 
calculate the net administrative burden reduction.  

The  Board  was  of  the  opinion  that  the  report  as  it  stood  still  contained  a  number  of 
shortcomings and areas where additional improvements were necessary:  

(1)  Notwithstanding  the  more  elaborate  subsidiarity  and  proportionality  analysis 
already  undertaken,  for  a  number  of  measures  a  stronger  subsidiarity 
argumentation  needed  to  be  provided  including  for  the  measure  that  aims  to 
support  'electro-mobility'  and  the  measure  requiring  an  energy  audit  for 
renovation with public funding;  

(2)  While  more  detailed  information  had  been  provided  on  estimating  the 
administrative  costs  of  the  individual  measures,  the  report  should  also  include 
an overall assessment of the regulatory cost, and in particular an estimate which 
is directly linked to the compliance with the new requirements of the Directive 
(building automation, electro-mobility, etc.). It should indicate how much of the 
annual  investment  of  €48bn  by  2030  for  the  preferred  option  is  directly 
mandated by the future measures;  

(3)  On  the  financing  side,  the  "Smart  Finance  for  Smart  Buildings"  Initiative  had 
been included but had been presented in very general terms. It remains unclear 
whether  and  how  it  could  significantly  contribute  to  the  financing  of  the 
considerable investment efforts required by the preferred option.  

The  lead  DG  shall  ensure  that  the  report  is  adjusted  accordingly  prior  to  launching  the 
inter-service consultation.  

Follow-up  

Following the Board's recommendations for improvement, the document has been further 
amended, in the present version, as follow:  

(1) 

Justification had been added in Sections 2.1.2 and 6.3 as regards the measure to 
prepare buildings for the installation of recharging points; 

(2)  The  measure  requiring  that  when  renovation  works  are  supported  by  public 
funding, an energy audit is carried out  to identify the most cost-effective step-
by-step  route  towards  an  overall  level  of  improvement  of  the  building  (e.g. 
towards a specific energy class) has been withdrawn;  

51 

 
(3)  The assessment of the regulatory cost, i.e. how much of the annual investment 
of  €48  bn  by  2030  for  the  preferred  option  is  directly  mandated  by  the  future 
measures,  is  presented  for  each  option  in  Section  6.1  and  calculation  details 
have been given in Annex 4; 

(4)  Although  substantial,  the  additional  investments  of  the  preferred  policy  option 
has to be considered in the perspective of the already sizeable market for energy 
efficiency  in  buildings  estimated  at  around  €120  billion  per  year,  and  in  the 
perspective  of  the  overall  EU  market  for  building  renovation  that  amounts  to 
around  €500  billion  per  year,  and  of  the  annual  market  for  new  construction 
estimated  at  around  €400  billion.  The  description  of  the  'Smart  Finance  for 
Smart Buildings' Initiative has been further elaborated in Section 2.4 in order to 
better  explain  how  the  Initiative  will  contribute  to  unlock  private  financing 
strands  by  supporting  a  shift  of  existing  investment  flows  towards  energy 
efficiency  projects,  while  maximising  the  impact  of  existing  public  financial 
support.  

52 

 
ANNEX 3   COST-EFFECTIVE SAVINGS POTENTIALS FOR 2030  

The EPBD defines the energy performance of a building as the amount of primary energy 
needed, in the use phase, to meet the energy demand associated with a typical use of the 
building,  which  includes,  inter  alia,  energy  used  for  heating,  cooling,  ventilation,  hot 
water and built-in lighting (mainly in non-residential buildings).  

The  current  Directive  addresses  both  new  and  existing  buildings,  using  different 
instruments, e.g. mandatory minimum performance requirements, providing information 
on  building  performance  to  the  market,  creating  a  vision  for  new  nearly  zero  energy 
buildings70,71,72.  

In  2014,  Fraunhofer  ISI  conducted  a  study73  to  report  on  the  evaluation  of  the 
achievement of the 2020 energy efficiency target of 20% and to discuss energy efficiency 
potentials in two different time horizons (2020, 2030).  

Regarding the residential and tertiary sector, the  modelling analysis done for this study 
was carried out with the following models:  

  The INVERT/EE-Lab model (run by TU Wien);  

  The FORECAST platform (run by Fraunhofer ISI);  

These bottom-up models enabled a very detailed level of decomposition, which, contrary 
to  other  sources  of  information,  gave  an  insight  of  the  trends  within  the  scope  of  the 
EPBD (space heating, space cooling, ventilation, domestic hot water, and lighting in non-
residential  buildings)  and  outside  the  scope  of  the  EPBD  (other  uses,  e.g.  appliances, 
elevators, cooking, etc.).  

The  following  scenarios  are  relevant  for  the  purpose  of  identifying  the  cost-effective 
saving potentials for 2030:  

  The baseline with measures, which contains measures which are already accepted 
or close to being accepted in 2014 and the near future. This scenario includes the 
EPBD;  

  The potential with low policy intensity (LPI), meaning with high discount rates and 
barriers persisting. The discount rates applied for the study are sector and partially 
country specific;  

  The potential with high policy intensity (HPI), with low discount rates and barriers 

(partially or totally) removed;  

The  near  economic  (NE)  potential  scenario  was  discarded.  This  scenario  includes 
potential which are not economic.  

70 

71 
72 

73  

the  National  Plans  for  Nearly  Zero-Energy  Buildings,  2016 

JRC  Synthesis  Report  on 
(http://iet.jrc.ec.europa.eu/energyefficiency/publications/all) 
Progress by EU countries towards nearly zero-energy buildings, COM(2013) 483/2 final 
Overview of MS information on NZEBs - Background paper and progress report, 2014, European 
Commission (with support of an external contractor, ECOFYS) 
Study  evaluating  the  current  energy  efficiency  policy  framework  in  the  EU  and  providing 
orientation on policy options for realising the cost-effective energy efficiency/saving potential until 
2020 and beyond, 2014, Fraunhofer ISI. 

53 

 
                                                 
The  LPI  scenario  foresees  a  clear  regulatory  framework,  which  ensures  that  cost-
effective  energy  saving  measures  are  taken  up  through  enforcement  of  building  codes 
with  good  compliance  at  national/regional  levels.  The  comparison  of  the  baseline 
scenario and this other policy scenario can therefore be used as a proxy to determine the 
cost-effective energy saving potential that lies within the scope of the Directive.  

The estimated energy saving potential of the EPBD by 2030 is around 29.1 Mtoe (13.1 
Mtoe for residential buildings and 16.1 Mtoe for non-residential buildings), as presented 
in Table 9.  

Table  9:  Cost-effective  energy  saving  potential  (  Mtoe)  for  new  and  existing 
buildings by 2030 comparing to low policy scenario (Source: Fraunhofer ISI) 

Space heating (New buildings) 

Space heating (Existing buildings) 

Domestic hot water 

Ventilation and air conditioning 

Lighting (non-residential) 

Total within the EPBD scope 

Other uses 

Residential 

Non-residential  Total 

0.9 

9.7 

2.2 

0.2 

13.0 

7.2 

0.3 

3.6 

0.4 

8.2 

3.6 

16.1 

7.0 

1.2 

13.2 

2.6 

8.4 

3.6 

29.1 

14.3 

Total for all energy use items 
43.4 
Around  two  third  of  the  saving  potentials  are  within  the  scope  of  the  EPBD.  The  rest 
relates  to  appliances, regulated under the legislation  applicable to  products. The largest 
cost-effective energy saving potential, additional to the savings delivered by the current 
legislative framework, is on existing buildings (close to 95% of the total).  

20.2 

23.2 

The  HPI  the  potential  for  energy  savings  in  buildings  is  estimated  to  be  86.5  Mtoe,  as 
presented in Table 10. This scenario also considers good compliance with building codes 
and standards, but it adds ambitious measures for increasing the renovation rate, namely:  

 

 

 

obligations to increase energy efficiency standards in case that there is a change in 
ownerships or tenancy of a building;  

financial support of thermal building renovation;  

training  of  builders  and  installers  to  improve  the  practical  implementation  of 
measures and increase the impact of efficiency measures in real life.  

54 

 
 
  
 
 
Table  10:  Cost-effective  energy  saving  potential  (  Mtoe)  for  new  and  existing 
buildings by 2030 comparing to high policy scenario (Source: Fraunhofer ISI) 

Space heating (New buildings) 

Space heating (Existing buildings) 

Domestic hot water 

Ventilation and air conditioning 

Lighting (non-residential) 

Total within the EPBD scope 

Other uses 

Residential 

Non-residential  Total 

3.8 

41.0 

8.2 

0.2 

53.2 

16.2 

1.4 

15.9 

1.8 

8.2 

6.1 

33.3 

8.9 

5.2 

56.9 

10.0 

8.4 

6.1 

86.5 

25.1 

Total for all energy use items 
The  study  provides  figures  by  Member  States  which  shows  potential  in  all  Member 
States as indicated in Figure 6. This figure reads as follow:  

111.6 

42.2 

69.4 

  Total  bars  (Grey  +  Red  +  Green)  indicate  the  projected  2030  consumptions 

(Residential + Non-residential) for the 'Baseline with measures' scenario;  

  The  green  parts  indicate  the  potential  final  energy  savings  with  the  LPI  scenario. 

The labelled figures are the amount of these potential in Mtoe;  

  The bed parts indicate the additional potential for the HPI scenario compared to the 

LPI scenario.  

The study does not disaggregate the national figures by end use and therefore does not 
allow to establish national figures within the EPBD scope.  

55 

 
 
  
 
 
Figure  6:  2030  potential  energy  savings  (  Mtoe)  by  Member  States  for  the 
residential and non-residential sector (all energy uses) (Source: Fraunhofer ISI)  

56 

 
  
ANNEX 4  MODELS SUPPORTING THE IMPACT ASSESSMENT  

The robustness of the results and their policy implications is ensured by the combination 
of  a  bottom-up  buildings  physics  model  (BEAM²)  with  a  top-down  macro-economic 
model (E3ME).  

The Built-Environment-Analysis Model (BEAM²).  

The  main  model  used  for  quantification  of  energy  related  impacts  is  the  Built-
Environment-Analysis Model (BEAM²), property of Ecofys.  

BEAM²  is  a  bottom-up  balancing  model  based  on  building  physics  that  applies  policy 
options and measures to a building stock inventory described in a disaggregated manner.  

The following summarises the key elements of the model.  

Building stock disaggregation  

For  the  purpose  of  the  present  Impact  assessment,  the  following  disaggregation  was 
considered:  

 

 

 

 

5 reference zones,  

9 building types (3 for residential buildings and 6 for non-residential buildings),  

5 age groups, and  

2 sub-groups of retrofit level.  

Model inputs  

The  following  inputs  were  defined  for  each  segment  of  the  above  described  building 
stock disaggregation:  

  Floor areas,  

  Characteristics of:  

o  Building elements part of the envelope (walls, windows, floor and roof),  

o  Technical  building  systems  (space  heating,  hot  water,  cooling,  ventilation  and 

solar thermal systems).  

Additional inputs were defined for each of the 5 reference zones:  

  For calibration purposes, energy consumptions per reference zone,  

  Specific investments cost-curves, 

  Differentiated for new and retrofit of existing buildings,  

  For interventions on the insulation, on windows, on space and water heating, solar 

thermal, ventilation and space cooling systems, 

  Energy price and discount rate used for global cost calculation,  

  Primary energy factors,  

57 

 
  CO2 emission factors.  

For  the  setting  of  the  reference  scenario,  at  least  the  three  following  approaches  were 
possible:  

(1)  Assuming  the  application  of  existing  pieces  of  legislation  as  they  are  today, 
meaning with closing dates where they exist, without renewed effort after 2020,  

(2)  Assuming a continuation of the current level of effort post 2020,  

(3)  Assuming an increased level of effort post 2020 according to the most intensive 
policy options explored in preparation of the energy efficiency package.  

Although the first approach corresponds to the current legal situation, it would bias the 
results upwards by considering that, after 2020, the EPBD stands alone and supports all 
required efforts. The third approach would be going too far in the opposite direction.  

As  a  consequence,  the  second  approach  was  chosen  as  a  conservative  assumption, 
presenting the role of the EPBD in the context of the legislative and financial framework 
of the package as a whole.  

The reference scenario that underpins the calculation of impacts considers the no-change 
option  for  the  EPBD  and  assumes  normal  market  development  and  the  continuation  of 
the current level of efforts in areas that are outside of the scope of the EPBD but acting in 
synergy with it, as follows:  

  The proposed revision of the Energy labelling directive, the implementation of the 
measures  already  identified  under  past  Ecodesign  working  plans  and  any  new 
product groups identified in the Ecodesign working plan 2015-1774, 

  The  continuation  of  the  energy  efficiency  obligation  scheme  as  it  is,  post  2020 

(EED, Art.7),  

  The continuation of current level of support to improve the energy performance of 

buildings from European Structural and Investment Funds, post 2020,  

  The  continuation  of  the  efforts  currently  funded  from  the  Horizon  2020  research 
and  innovation  budget  post  2020  and  in  particular  the  continuation  of  the  project 
development assistance currently funded from that budget post 2017.  

Absolute energy and climate reference values for 2030 are presented in Table 11.  

74 

To be adopted in Autumn 2016 

58 

 
 
 
                                                 
Table 11: Information related to the reference scenario 

Total final energy use75 
305 Mtoe 
On-site renewable electricity generation 
15 Mtoe 
Total (net) primary76 
283 Mtoe 
Average energy performance of the building stock 
113kWh/(m².y) 
Total CO2 emissions 
644MtCO2 
GHG emission per square meter 
22.16kgCO2/m² 
Associated annual construction activity in 203077 
143 bn€ 
Costs associated to electro-mobility 
N/A 
Energy expenditure in 2030 
343 bn€ 
In  addition, specific  scenario parameters were  established to describe the impact of the 
different  policy  options.  These  parameters  are  not  the  result  of  the  economical 
optimization process; instead, they are used as an additional input to the model. They are 
based  on  Ecofys'  expert  assessment,  cross-checked  with  available  literature  and 
calibrated with available top-down statistical data from Eurostat. These scenario specific 
inputs are presented in Table 12.  

75 

76 

77 

These figures correspond to the energy use of EPBD scope: space and water heating, space cooling, 
ventilation and their auxiliary, and lighting in the non-residential sector. 
Net  primary  energy  is  obtained  by  discounting  electricity  generated  from  PV,  according  to  the 
definition of the EPBD, the cost-optimal regulation and its subsequent guidelines. 
Annual  "investments"  defined  as  the  energy  related  activity  for  the  construction  sector  associated 
with  the  transformation  of  the  building  stock  (new  construction  and  renovation).  These  cover  all 
building  elements  as  defined  by  the  EPBD:  parts  of  the  building  envelope  and  technical  building 
systems.  These  are  considering  total  installation/replacement  costs  but,  because  comparison  of 
options is done by difference, marginal impacts of options (additional energy related activity for the 
construction sector) is used as element of comparison of the different options. 

59 

 
 
 
                                                 
Table 12: Key assumptions of the BEAM² modelling 

Reference 
2017-2020: Cost 
optimal U-values 
according to MS reports  
2021-2025: Introduction 
of NZEBs (approx. 
12.5% improvement)  
2026-2030: 7.5% 
improvement due to 
new cost optimality 
values 
Residential (2015-
2030): 0.61 - 0.95%  
Non-residential (2015-
2030): 0.70 - 1.05% 
2018-2022: Cost 
optimal U-values from 
MS reports  
2023-2027: 5% 
improvement compared 
to 2018-2022  
2028-2030: 5% 
improvement compared 
to 2023-2027 
2015-2030: 3.6 - 4.1% 

Option I 
2017-2020: Cost 
optimal U-values 
according to MS reports  
2021-2025: Introduction 
of NZEBs (approx. 
12.5% improvement)  
2026-2030: 7.5% 
improvement due to 
new cost optimality 
values 
Residential (2015-
2030): 0.61 - 1.03%  
Non-residential (2015-
2030): 0.70 – 1.14% 
2017-2020: Cost 
optimal U-values from 
MS reports  
2021-2025: 5% 
improvement compared 
to 2017-2020  
2026-2030: 5% 
improvement compared 
to 2021-2025 
2015-2030: 3.6 - 4.2% 

Options II/III78 
2017-2020: Cost 
optimal U-values 
according to MS reports  
2021-2025: Introduction 
of NZEBs (approx. 
12.5% improvement)  
2026-2030: 7.5% 
improvement due to 
new cost optimality 
values 
Residential (2015-
2030): 0.61 - 1.60%  
Non-residential (2015-
2030): 0.70 – 1.70% 
2017-2020: Cost 
optimal U-values from 
MS reports  
2021-2025: 5% 
improvement compared 
to 2017-2020  
2026-2030: 5% 
improvement compared 
to 2021-2025 
2015-2030: 3.6 - 4.2% 

Thermal qualities of 
new buildings 

Equivalent full thermal 
renovation rate79 

Thermal qualities of 
renovations 

Heating system 
exchange rates80 

Model processing  

Based  on  the  above  detailed  floor  area  inventory,  differentiated  by  reference  zone, 
building  type,  age  group,  retrofit  level,  for  which  space  floor  area  and  thermal 
characteristics  are  defined,  the  useful  heating  and  cooling  energy  need  is  calculated 
following the calculation procedures of EN ISO 13790.  

Taking  the  parameters  of  the  HVAC  systems  into  account,  the  final  energy  used  by 
building systems to cover the above useful energy need is calculated and calibrated with 
the available top-down statistical data.  

Apart from heating, hot water and cooling as well as the auxiliary energy for ventilation, 
heat recovery for heating and cooling systems (and lighting for non-residential buildings) 
is addressed.  

Based on the final energy use, the primary energy and greenhouse gas emissions for all 
energy carriers are calculated by applying primary energy and greenhouse gas emission 
factors.  

78 

79 

80 

As  Option  III  involves  additional  measures  to  Option  II  that  are  modelled  outside  BEAM²  (Cf. 
below), the input to BEAM² modelling are the same for Option II and III. 
The  full  thermal  renovation  rate  reflects  the  amount  of  buildings  that  undergo  a  renovation  and 
upgrade of the total building envelope (roof, external walls, windows and ground floor) developed 
as an equivalent rate of renovations that include all or only parts of these different components. The 
full  thermal  renovation  rate  is  therefore  an  indicator  that  describes  the  number  and  scope  of 
renovations  of  the  building  envelope,  while  not  describing  the  ambition  level  (e.g.  thickness  of 
insulation)  of  the  single  measures.  These  assumptions  are  established  based  on  the  Invert/EE-Lab 
(TU Vienna). 
Replacement/upgrade of heating systems 

60 

 
 
                                                 
The contribution of electricity generated from on-site photovoltaic system is determined 
and the net primary energy need calculated.  

The calculation  process over the scenario time frame is  organized as  follows: based on 
the  initial  floor  area  distribution  along  the  different  segments  of  the  disaggregated 
building  stock,  the  building  stock  which  will  be  transformed  in  the  future  is  projected. 
New buildings, demolition and retrofit programs for all or parts of these combinations are 
taken  into  account.  All  construction/renovation  activities  considered  in  year  i  have  an 
effect starting in year i+1.  

The  energy  costs  per  year  and  the  investment  costs  for  new  buildings  and  retrofitted 
buildings are calculated at the very end, based on the previous proceedings.  

Model output – EU 28  

Based  on  the  above  processing,  the  following  outputs  are  given  for  each  year  and  the 
below graphs illustrate some of the results for the reference scenario:  

  Floor Area (per building type),  

Figure  7:  Reference,  Floor  area  per  building  type  [Mio.m²]  (Source:  BEAM², 
Ecofys)  

  Useful energy demand (TWh) (space heating, hot water, cooling),  

  Useful energy demand for heating (TWh) (per building type),  

  Final energy demand (TWh) (space heating, hot water, cooling, auxiliary, lighting 

(non-residential),  

  Final energy demand for heating (TWh) (per age band),  

  Final energy demand for heating (TWh) (per heating technology),  

61 

 
  
 
 
Figure  8:  Reference,  Final  energy  per  heating  system  [TWh/a]  (Source:  BEAM², 
Ecofys)  

  Shares  of  on-site  renewable  energy  source  (kWh)  (Biomass,  heat  pump,  solar 

thermal),  

Figure  9:  Reference,  on-site  renewable  energy  sources  (based  on  useful  energy) 
[TWh/a] 
(Source: BEAM², Ecofys)  

  Primary  energy  demand  (kWh)  (space  heating,  hot  water,  cooling,  auxiliary, 

lighting (non-residential),  

62 

 
  
  
 
 
Figure  10:  Reference,  Primary  energy  per  application  of  the  EPBD  [TWh/a] 
(Source: BEAM², Ecofys)  

  CO2  emissions  (kg)  (space  heating,  hot  water,  cooling,  auxiliary,  lighting  (non-

residential),  

Figure  11:  Reference,  CO2-emissions  per  application  of  the  EPBD  [Mt/a]  (Source: 
BEAM², Ecofys)  

 

Investment costs (€) (Building envelope and HVAC systems),  

63 

 
  
  
 
 
Figure 12: Reference, Investment costs [bn€/a] (Source: BEAM², Ecofys)  

  Final energy expenditures (€)) (space heating, hot water, cooling, auxiliary, lighting 

(non-residential).  

Figure 13: Reference, Energy expenditures [bn€/a] (Source: BEAM², Ecofys)  

For  future  evaluations,  and  in  order  to  perform  Territorial  Impact  Assessment  (in  line 
with the Better Regulation guidelines) at regional and urban (municipal) scales, the Land 
Use-based  Integrated  Sustainability  Assessment  (LUISA)  81  modelling  platform  – 
already adopted to evaluate the status and trends of EU Regions and Cities82, will provide 
indicators  at  fine  geographical  resolution  on  energy  consumption  levels  of  buildings, 
differentiate by typology, age, geographical position and climatic conditions.  

81 
82 

https://ec.europa.eu/jrc/en/luisa 
Sixth report on economic, social and territorial cohesion. 

64 

020406080100120140160201320142015201620172018201920202021202220232024202520262027202820292030Billion EUR/aInvestment costsBuilding envelopeHVAC-Systems 
  
  
                                                 
Others assumptions  

BEAM²  model  was  not  appropriate  to  model  the  following  measures  and  other 
assumptions, described in Table 13, were necessary to evaluate their impacts:  

 

 

 

 

introduction of a smart-readiness indicator, 

development of on-site electricity generation, 

support to electro-mobility, 

obligation for buildings to reach a given standard before they are sold or rented.  

Table 13: Additional assumptions for specific measures 

Specific 
assumptions for 
the obligation for 
buildings to 
reach a given 
standard before 
they are sold or 
rented 
On-site 
renewable 
electricity 
generation 

Smartness 
indicator 

Reference 
Not applicable 

Option I 
Not applicable 

Option II 
Not applicable 

Option III 
Target: 5% of the 
residential and 2% of the 
non-residential building 
stock are considered to 
perform four times 
worse than the average 

-10% of 
PRIMES's 
optimum level of 
on-site PV 

PRIMES's 
optimum level of 
on-site PV, thanks 
to equal footing 
EE/RES in 
calculations 

Level of on-site PV 
according to Primes 
economic optimum 
thanks to equal footing 
EE/RES 

PRIMES 
reference 
scenario for on-
site PV 
development 
(-12% to the 
economic 
optimum) 
Not applicable 

Not applicable 

Share of the stock 
impacted by 2030: 0.4% 
of the residential sector, 
24% of the non-
residential stock.  
Level of impact of the 
action taken: 20% of the 
average performance 

Normal charging point 
on a dedicated parking 
space in large multi-
apartment blocks  
Fast charging point on a 
shared parking space in 
non residential buildings 

Share of the stock 
impacted by 2030: 
0.4% of the 
residential sector, 
24% of the non-
residential stock.  
Level of impact of 
the action taken: 
20% of the 
average 
performance 
Normal charging 
point on a 
dedicated parking 
space in large 
multi-apartment 
blocks  
Fast charging 
point on a shared 
parking space in 
non residential 
buildings 

Support to 
electro-mobility 

Not applicable 

Not applicable 

In addition, some supporting assumptions that formed the active policy framework were 
not possible to be modelled with existing analytical models. For example, the benefit of 
achieving  the  common  framework  for  energy  efficiency  investments  underwriting, 
according  to  expert  estimates,  could  lead  to  reducing  of  the  risk  margins  charged  by 
Financial Institutions by around 0.5% base point (assuming current interest rates charged 
for energy efficiency projects, being around 6% for consumption loans to households in 

65 

 
 
the  euro  area  (without  collateral  or  guarantees)  and  around  2-3%  for  non-financial 
corporations, depending on the loan amount and rate fixation strategy). Exact impacts are 
not possible to track as such common framework only needs to be established.  

The E3ME macroeconomic and co-benefits modelling and calculations  

E3ME is a computer-based model of the world’s economic and energy systems and the 
environment. It was originally developed through the European Commission’s research 
framework  programmes  and  is  now  widely  used  in  Europe  and  beyond  for  policy 
assessment, for forecasting and for research purposes. It was applied in the recent study 
for  DG  ENER  that  provided  inputs  to  the  assessment  of  the  2030  targets  and  was  also 
used in the Impact Assessment of the Energy Efficiency Directive.  

The  economic  structure  of  E3ME  is  based  on  the  system  of  national  accounts,  with 
further  linkages  to  energy  demand  and  environmental  emissions.  The  labour  market  is 
also covered in detail, including both voluntary and involuntary unemployment. In total 
there  are  33  sets  of  econometrically  estimated  equations,  including  the  components  of 
GDP  (consumption,  investment,  and  international  trade),  the  labour  market,  prices, 
energy demand and materials demand. Each equation set is disaggregated by country and 
by  sector.  Each  EU  Member  State  is  disaggregated  and  broken  down  to  69  economic 
sectors, although for presentational purposes the sectors will be aggregated to show key 
impacts more clearly.  

E3ME’s historical database covers the period 1970-2015 and the model projects forward 
annually  to  2050.  The  main  data  sources  for  European  countries  are  Eurostat  and  the 
IEA, supplemented by the OECD’s STAN database and other sources where appropriate.  

The E3ME baseline used in this analysis has been made consistent to the latest trends in 
PRIMES  2016  (Reference  case).  This  includes  energy,  energy  prices,  carbon  price, 
population and economic projections where applicable.  

As a general model of the economy, based on the full structure of the national accounts, 
E3ME is capable of producing a broad range of economic indicators. In addition there is 
range  of  energy  and  environment  indicators.  The  following  list  provides  a  summary  of 
the most common model outputs:  

  GDP  and  the  aggregate  components  of  GDP  (household  expenditure,  investment, 

government expenditure and international trade);  

 

 

 

 

 

sectoral output and Gross Value Added (GVA), prices, trade and competitiveness 
effects;  

international trade by sector, origin and destination;  

consumer prices and expenditures;  

sectoral employment, unemployment, sectoral wage rates and labour supply;  

energy demand, by sector and by fuel, energy prices;  

  CO2 emissions by sector and by fuel;  

 

other air-borne emissions;  

  material demands.  

66 

 
Model inputs  

BEAM² provided key inputs to the E3ME model:  

(1)  EU28  final  energy  demand  for  heating  (+breakdown  by  fuels),  hot  water, 

cooling, auxiliary and lighting, 2013-2030 in TWh/a  

(2) 

Investment costs (3 types: Building envelope, HVAC-Systems, financing costs), 
2013-2030 in €billion  

Note that the E3ME model calculates own energy costs and CO2 emissions from energy 
inputs. Only energy demand (and investment) are needed as inputs.  

Model Output – EU 28  

Macroeconomic results  

  Results  are  compared  to  the  E3ME  reference  (Reference:  No-change  option) 

scenario as% differences.  

  Magnitude of results is fairly small throughout, reflecting inputs.  

  For  example,  in  Option  III  where  the  EE  investment  is  the  largest,  additional 
investment  in  2030  for  EU28  is  €101bn.  Compared  with  EU28  GDP  of  €14tr  in 
2014, this level of additional investment will not result in any significant economic 
impacts.  

  Overall, the EU results show positive impact on GDP and small but positive impact 

on employment.  

  Positive GDP results are driven by extra energy efficiency investment.  

  Consumer spending falls slightly in the short run due to redistribution of household 

spending to pay for building investment.  

 

In  the  long  run  (beyond  2030)  consumer  spending  is  expected  to  increase  due  to 
energy savings (more money to spend on other goods and services).  

  Overall average prices fall despite industry charging higher price to cover costs of 
investment, as a result of energy efficiency. This is because of the EU economy is 
moving away from expensive products (i.e. energy).  

  Trade  results  are  ambiguous,  energy  imports  decrease  while  imports  of  products 
and  raw  materials  required  for  energy  efficiency  investment  increases.  Overall 
there are reductions in EU imports.  

Energy security  

  Two  different  energy  security  measure  results:  share  of  total  final  energy  used  in 
GDP  and  share  of  energy  imports  in  GDP  in  2030  by  Member  State  (note  the 
results are in nominal figure not percentage differences).  

  The two measures show there is some small improvements in energy security in the 

scenarios (although the impacts are very small in magnitude).  

67 

 
Public budget  

  Public  budget  is  based  on  the  results  from  E3ME  together  with  expansion  of  the 

model results to take into account certain specific factors.  

  The results in monetary terms are in current price and so many reductions reflect 
price reduction in the scenario. It is better therefore to look at budget impacts as% 
of GDP results.  

  On  income  side,  there  are  small  reduction  in  energy  excise  revenues  and  ETS 

prices.  

  There  is  a  reduction  in  overall  VAT  revenues  which  also  includes  VAT  from 

energy.  

  Deflationary  impacts  in  the  scenarios  result  in  small  reduction  in  tax  revenues  in 

current price.  

  Revenues  from corporation tax increase as  firms make  profit from cutting energy 

costs.  

  On  the  expenditure  side,  government  spend  less  on  energy  after  implementing 

energy efficiency measures.  

 

Investment  in  energy  efficiency  is  essentially  paid  for  from  reduction  in 
government energy spending.  

  Reductions in other expenditures due to deflationary impacts in the scenarios.  

Environmental impacts  

  Most  of  the  changes  that  occur  within  final  energy  demand  are  in  the  buildings 

sector, the E3ME results also include some rebound effects.  

  Changes in energy consumption in other sectors are the result of indirect impacts 
(e.g. rebound effects) so the figures include both the direct energy savings from the 
bottom-up analysis and any indirect effects.  

  Emissions  of  greenhouse  gases  follow  from  the  results  for  primary  fuel 

consumption.  

  CO2 and GHG in the EU decrease in all scenarios.  

  The  relative  changes  in  the  primary  consumption  of  fossil  fuels  (e.g.  from 
reduction  in  gas  and  coal  combustion  in  power  generation)  also  impact  on  the 
quantity of so called local air pollution.  

  Air pollutants (CO, NOX and SO2) in all scenarios.  

  This helps to limit health and environmental damages from air pollutants.  

Calculation of healthcare cost savings and mortality and morbidity costs savings  

This calculation was completed outside E3ME. For each Policy option, given the energy 
savings calculated at the Member State (MS) level, we estimate the total square meters of 
buildings renovated in each MS. This is based on the difference between the mean energy 
consumption level, and the theoretical energy consumption level of renovated buildings. 
Using the total area of residential and non-residential buildings renovated each year, we 
estimate the cost savings by multiplying the total square meters renovated by the ratios 

68 

 
drawn  from  the  literature  review.  Indeed,  the  literature  review  showed  that  total 
morbidity & mortality costs and healthcare costs can be estimated to €139bn in EU28, for 
a total of 25bn square meters of buildings. The mean cost saving per renovated building 
can be estimated to 5.6€/m², and we assume that the cost are divided by two in renovated 
buildings (cost saving of 2.3€/ renovated m²).  

Calculation of productivity gains related to better indoor air quality  

This calculation was completed outside E3ME. For each Policy option, given the energy 
savings  calculated  at  the  MS  level,  we  estimate  the  total  square  meters  of  buildings 
renovated  in  each  MS.  This  is  based  on  the  difference  between  the  mean  energy 
consumption level, and the theoretical energy consumption level of renovated buildings. 
Using  the  total  area  of  non-residential  buildings  renovated  each  year,  we  estimate  the 
productivity gains by multiplying the total square meters renovated by the ratios drawn 
from the literature review (cost savings between 0,6 and 1€/m² renovated). This leads to a 
minimum and maximum value for the productivity gains.  

Calculation of the potential effects of the EPBD in energy poverty in the EU  

This  calculation  was  completed  outside  E3ME.  The  indicators  analysed  were:  Leaking 
roof,  damp  walls/floors/foundation,  or  rot  in  window  frames  or  floor,  ability  to  keep 
home  adequately  warm,  and  arrears  on  utility  bills.  The  ongoing  study  on  the 
construction of a 'Fuel Poverty Index' for all EU MS was also used as a basis. The data 
used was EU-SILC waves 2004-2013 (1,919,732 observations across EU).  

Energy  poverty  has  many  drivers,  and  households’  respond  to  this  problem  differently 
(e.g. curtailment, arrears on energy bills, etc.). In order to measure the extent and severity 
of the problem, a variety of energy poverty indicators exist and are applied differently in 
several countries. However, there is no agreed framework at EU level to measure energy 
poverty.  A  recent  study  contracted  by  DG  Energy,  reviewed  the  indicators  used  at 
Member State  level and suggested those  that are most  meaningful for policy-makers in 
getting  a  high-level  understanding  of  the  problem,  which  can  then  be  used  to  help 
develop  and 
include 
Expenditure-based indicators (e.g. household is energy poor if a share of income spent on 
energy services is larger than a certain amount) and Consensual-based (e.g. Household is 
energy poor if it declares not to be able to warm the house during cold season – EU SILC 
indicators).  

target  policies  and  measures.  These  proposed 

indicators 

From the study it is also clear that the physical infrastructure including the building stock 
affects a range of issues relating to energy consumption levels, access to energy supply, 
and  ability  to  improve  building  fabric.  Energy  consumption  levels  are  impacted  by 
building  energy  efficiency,  size  of  households  and  the  types  and  efficiency  of  heating 
systems available. The efficiency of buildings (and necessary investment) can be affected 
by the tenure of those buildings (social housing, private rental or private ownership), and 
the  building  type.  For  example,  some  building  types  are  more  suitable  for  large-scale 
retrofit  programmes.  Therefore,  energy  efficiency  policies  in  the  buildings  sector 
specifically  targeting  vulnerable  consumers  and  supported  by  accompanying  measures 
can  have  a  positive  impact  in  addressing  energy  poverty.  A  follow-up  study  is  being 
launched to start the monitoring of energy poverty by geographic area and income level, 
which will enable the assessment  of income distributional impacts of energy and social 
policies (to address energy poverty) across the EU-28.  

69 

 
For  the  impact  assessment,  and  in  order  to  quantify  the  impact  of  the  different  policy 
options in terms of energy poverty alleviation over time the starting point was the trend 
projection based on historical energy poverty development by country in order to account 
for the effect of existing policies including those targeting poverty and social inequality 
in general. It is expected that with a positive trend (i.e. decreasing numbers of fuel poor 
households), it gets increasingly difficult to reach those energy poor households that have 
not  yet  been  reached  by  the  same  policy  instrument  up  to  a  certain  point  and  that  the 
trend  thus  slows  down.  For  a  negative  trend  (i.e.  increasing  numbers  of  fuel  poor 
households)  we  expect  that  it  will  be  increasingly  offset  by  the  implementation  of 
targeted policies flanking the EPBD recast transposition and therefore equally expect it to 
slow down. It is therefore assumed that the historical trend effect diminishes by 50% p.a. 
From the resulting projected number of households living in energy poverty according to 
the  respective  indicator,  the  policy  impact  is  deducted.  The  policy  impact  is  quantified 
based on the share of energy poor households affected by additional renovation activity 
multiplied with an impact factor reflecting uncertainties with regard to renovation depth 
(50%-200%),  the degree to  which the actually implemented policies target energy-poor 
households, as well as different levels of fuel poverty among households not reflected by 
the binary indicators. Finally, the yearly impact figures have been aggregated to reflect 
the total impact of the different policy options by 2030.  

The methodology used can be summarised in the Figure 14.  

Figure 14: Methodology used to calculate the effects on energy poverty in the EU  

The assumptions used are the following:  

  A1: EPBD impact on renovation rate (in% points): Impact on renovation rates are 
assumed 0 for the reference, +0.15% for policy option I, +0.4% for policy option II 
and  1.15%  for  policy  option  III  (based  on  information  provided  by  the  European 
Commission and the Fraunhofer ISI potential study, Eichhammer et al. 2014).  

  A2:  EPBD  impact  on  additional  energy  savings  (in%):  Additional  yearly  energy 
savings in existing buildings as a result of policy implementation are assumed 0% 
for the reference, 0.04% for policy option I, 0.4% for policy option II and 1.5% for 
policy option III.  

70 

 
  
  A3:  Share  of  energy-poor  households  affected  by  renovations:  The  share  of 
renovations implemented in buildings inhabited by fuel-poor households is highly 
uncertain  and  depends  strongly  on  the  specific  policy  design  as  well  as  its 
implementation. One proxy is the share of energy-poor households relative to the 
total number of households. We use a range around this proxy value by country and 
energy poverty indicator.  

  A4:  Impact  of  additional  energy  savings  in  existing  buildings  on  fuel  poverty 
alleviation: Deeper renovations resulting in higher energy savings can be expected 
to  have  a  positive  impact  on  energy  poverty  alleviation.  Accordingly,  we  assume 
that a 1% increase in additional energy savings (according to A2) results in a 1% 
increase of household numbers lifted from fuel poverty.  

Energy efficiency and building value  

This  calculation  was  done  outside  E3ME  and  was  based  on  comprehensive  literature 
review.  As  stated  by  the  research  of  Mudgal,  et.  al.  (2013),  many  actors  expect  the 
energy performance of buildings to affect the value of buildings as it saves money and is 
also  in  line  with  changing  social  norms  vis-à-vis  the  environment.  The  energy 
performance of  buildings is  expected to  affect the  monetary value  of property,  because 
there are numerous benefits associated with buildings that are more energy efficient: i.e. 
energy efficient buildings provide a greater level of services (Ürge-Vorsatz et al., 2009). 
Information  provision  through  energy  performance  labelling  can  help  render  the 
differences  between  otherwise  comparable  properties  more  readable,  enabling  market 
actors to act on this information when they perceive it to be salient to them (Mudgal, et. 
al., 2013).  

The research of Mudgal, et. al. (2013) provides an analysis of 22 papers in which hedonic 
regression  has  been  applied  to  determine  the  relationship  between  energy  performance 
certificates and exchange value of both residential and commercial real estate (both rental 
and  sales  value),  in  a  period  from  1995  to  2012.  In  19  of  the  22  reports,  a  positive 
relationship on either rental and/or sales value was identified: the labelled buildings (e.g. 
Energy Star or LEED) have an increased price compared to non-labelled objects.  

Within this research, the existing (scientific) literature regarding the relationship between 
energy  efficiency  labels  and  transaction  prices  (rental  and  sales  values)  is  divided 
according  to  two  categories  of  residential  real  estate  and  commercial  real  estate.  More 
detailed  information  regarding  the  impact  of  energy  labels  on  the  rental  and/or  sales 
value of real estate in each of these categories is provided in the next paragraphs, based 
on the research of Mudgal et. al. and extended with additional researches.  

Residential  

Most literature studies for residential real estate focus on the effect on transaction prices. 
Based on the reviewed literature considering residential real estate, conflicting results are 
observed  for  the  effect  on  transaction  prices.  In  some  cases  the  studies  focusing  on 
transaction  prices  of  residential  real  estate  show  evidence  that  a  positive  relationship 
exists between energy efficiency labels and transaction prices. However, these studies do 
not investigate occupancy premiums and only three studies investigate rental premiums. 
Regarding these factors and the effect on time to sale the existing literature is thin.  

All studies in Europe show price premiums for energy efficient buildings, though some 
are  unquantified.  Several  European  studies  summarized  in  the  research  of  Copenhagen 

71 

 
Economics  (2015)  show  a  positive  significant  effect  on  rental  and  sales  prices.  These 
studies were conducted in several countries (NL, UK and Ireland) and show the increase 
of the sale prices relative to a EPC D-label. Noted must be that, by far, not all European 
countries  are  represented  in  the  existing  literature.  In  all  four  countries  for  which 
information  on  both  sales  and  rental  markets  was  available  –  Austria,  Belgium,  The 
Netherlands and Ireland – there is a positive significant effect on rental prices. However, 
according  to  three  of  these  studies  the  estimated  rental  premium  for  energy  efficiency 
was smaller than the estimated sales price premium. This attenuated rental effect suggests 
that owners reap a benefit that is additional to the ongoing monthly benefits, i.e. reduced 
energy  bills,  which  accrue  to  all  occupiers  including  tenants.  In  addition,  there  is 
contrasting evidence about how the energy efficiency premium varies by location (cities 
or non-city areas). In Ireland and in Belgium, the effect is smaller – in percentage terms – 
in cities than in non-city areas. This seems plausible, as potential savings (in €/m²terms) 
would not vary much by location, while the €/m²cost of a dwelling will be significantly 
greater in central urban areas. Nonetheless, in Austria, the evidence is to the contrary: the 
percentage effect is larger in Vienna than in the surrounding area. An explanation may lie 
in market conditions. Further research on whether market conditions matter to the value 
market  agents  place  on  energy  efficiency  ratings  would  be  necessary,  but  comparing 
across  countries,  the  percentage  effect  of  the  EPC  appears  stronger  where  selling 
conditions are easier.  

Service buildings  

According  to  the  existing  scientific  literature,  there  are  more  studies  available  for  the 
commercial  and  service  segment  than  for  residential  buildings.  The  studies  within  this 
research  that  were  concerned  with  the  non-residential  (office/commercial)  sector  were 
geographically a lot more homogeneous, with the majority focusing on the United States, 
one study on the Netherlands and two studies on the UK. Of the studies examining the 
impact  on  sales  value,  90%  found  that  the  presence  of  energy/environmental  labelling 
had a positive impact on the sales value (Mudgal, et. al., 2013).  

The results on the impact of energy performance on the value of buildings presented in 
this impact assessment are therefore based on the finding of empirical research.  

Calibration of the models  

Additional steps were taken to correctly calibrate the modelling tools in order to ensure 
consistency of results:  

  The  baseline  used  by  BEAM²  was  calibrated  using  Eurostat  data  and  PRIMES 

2016 reference scenario, similarly to E3ME baseline; and  

  The  overall  modelling  results  were  calibrated  using  the  2014  energy  efficiency 
cost-effective  potentials  study.  This  comprehensive  study  used  a  wide  set  of 
modelling tools of primary/final energy demand (e.g. INVERT/EE-Lab model (run 
by  TU  Wien)  for  residential  and  non-residential  buildings,  FORECAST  platform 
electricity uses in the residential and service sector, etc.).  

72 

 
ANNEX 5  DRIVERS ADDRESSED BY THE POLICY MEASURES  

Table  14  links  all  measures  analysed  in  the  context  of  the  Impact  assessment  with  the 
drivers.  

Table 14: Analysed policy measures with the drivers that they address. 

Drivers 

Measures 
Measure 1. Accelerate the decarbonisation of buildings by significantly increasing renovation rates 
1A. Set milestones for the 
decarbonisation of the building 
stock by 2050 

Limited activity in a post-crisis context  
Split incentives  
Lack of attractive financing products 

Potential to better avoid potential negative effects 

Limited activity in a post-crisis context  
Split incentives 

Limited uptake of efficient and smart technologies  
Potential for improvement of the national implementation  
Potential to better avoid potential negative effects 

1B. Oblige the renovation of 
buildings to reach a given standard 
before transactions 
Measure 2. Fine tune the implementation of minimum energy performance requirements 
2A. Clarify provisions on 
calculation methodologies and on 
implementation of cost-optimal 
levels of minimum performance 
requirements 
2B. Change the framework for cost-
optimal calculations by including 
additional co-benefits when setting 
minimum requirements 
Measure 3. Modernisation using smart technologies and simplification of outdated provisions for the 
benefit of citizens 
3A. Document the initial 
performance of technical building 
systems and maintain their 
operational performance over time 
3B. Framework for the introduction 
of a smartness indicator 
3C. Support to electro-mobility 
Measure 4. Enhance financial support and information to users through reinforced energy 
performance certificates 
4A. Reinforced quality of energy 
performance certificates to enhance 
the financial support 

Limited uptake of efficient and smart technologies  
Limited information on building stock  
Potential for simplification 

Limited uptake of efficient and smart technologies 

Limited uptake of efficient and smart technologies 

Lack of understanding on energy use and potential savings  
Lack of attractive financing products  
Limited information on building stock  
Potential for improvement of the national implementation 
Lack of understanding on energy use and potential savings  
Potential for improvement of the national implementation  
Potential to better avoid potential negative effects 

4B. Harmonised template for 
certificates 

73 

 
ANNEX 6  DETAILED DESCRIPTION OF MEASURES  

The  following  describes  all  the  measures  that  have  been  studied  by  the  present  impact 
assessment, including the analysis of their subsidiarity and proportionality.  

These  have  been  grouped  into  policy  options  according  to  the  nature  and  scope  of  the 
changes to be introduced in the current EPBD (i.e. option I no changes to the legislative 
text, option II targeted amendments and option III more ambitious changes).  

An overview of the measures is presented in Table 15, at the very end of this annex.  

Measure 1:  Accelerate the decarbonisation of buildings by significantly increasing 

renovation rates  

The EU is committed to the 2050 goal to have a secured, competitive and decarbonised 
energy system in 2050. As part of their strategies to decarbonise the building stock, some 
Member  States  are  pursuing  the  phasing  out  of  worse  performing  buildings  in  their 
territory.  

The  evaluation  report  revealed  that  a  strong  market  signal  (for  Member  States  and  for 
investors)  for  the  renovation  of  existing  buildings  is  missing  in  the  current  energy 
efficiency legislation to ensure that the 2050 goal is achieved.  

Measure 1A builds on the national long-term renovation strategies under Article 4 of the 
EED,  requiring  the  definition  of  clear  milestones  and  measures  combining  renovation 
rates  and  depth,  energy  efficiency  measures  and  on-site  building  renewable  energy 
sources,  while  retaining  flexibility  for  Member  States  to  build  their  own  long-term 
renovation strategies, and targets.  

Measure  1B,  alternatively  or  additionally,  establishes  a  more  direct  intervention, 
requiring buildings to reach a given standard before they are sold or rented. The measure 
addresses directly specific problem  drivers such as  split incentives and long  lifetime of 
buildings.  

Measure 1A:  Set milestones for the decarbonisation of buildings by 2050  

The  Energy  Performance  of  Buildings  Directive  will  be  amended  to  require  Member 
States  to  define,  as  part  of  their  long-term  renovation  strategies,  a  roadmap  with  clear 
milestones and measures to decarbonise their national building stock up to a nearly zero-
energy standard by 2050. In order to clarify the overall obligation, the amendment of the 
EPBD will also incorporate Article 4 of the EED.  

A  first  version  of  this  roadmap  will  have  to  be  included  in  the  long-term  renovation 
strategy that is due by 30 April 2023. Specific milestones for 2030 will be included in the 
long-term  renovation  strategies  that  are  due  by  30  April  2020.  The  2020  and  2023 
deadlines for submitting updated long-term renovation strategies are likely to align this 
measure with the with the yet to be defined EU follow up to the COP21 Paris Agreement.  

On  the  basis  of  the  conclusions  of  the  assessment  of  the  long-term  renovation 
strategies83,  the  Commission  will  issue  accompanying  guidance  on  how  to  update  and 

83 

Synthesis  Report  on  the  assessment  of  Member  States'  building  renovation  strategies,  2015, 
European Commission (JRC) 

74 

 
                                                 
reinforce the long-term renovation strategies. The guidance will address in particular the 
weakest  aspects  of  national  strategies  i.e.  investment  plans  and  forward-looking 
perspective to guide investment decisions, and quantification of expected energy savings 
and  wider  benefits.  It  will  make  the  link  to  national  measures  to  stimulate  the 
refurbishment  of  existing  buildings  towards  NZEB  levels  in  line  with  Article  9  of  the 
EPBD. The guidance will also cover aspects to be considered to avoid potential negative 
effects  to  energy  renovation  (embodied  energy,  resource  intensity,  construction  waste, 
etc.)  and  to  maximise  positive  benefits  (improvement  of  indoor  environmental  quality, 
resource efficiency, alleviation of energy poverty, etc.). 

Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Scope 

Building 
category 

New / Existing 

Amendment 

Member States 

Definition of long-term 
renovation strategies 

All 

Existing 

Subsidiarity and proportionality:  
This measure makes explicit an aspect of the long-term renovation strategies that have been omitted by 
some Member States in the first long-term renovation strategies and builds upon the COP21 international 
agreement. Following the subsidiarity principle, it leaves to Member States the responsibility to establish 
the most appropriate and cost-effective approach and specific milestones to address the necessary 
transformation of the building stock. It therefore appears a proportionate solution.  
No investment is directly mandated by the measure. 

Measure 1B:  Oblige the renovation of buildings to reach a given standard before 
transactions  

The  Energy  Performance  of  Buildings  Directive  would  be  amended  to  introduce  a 
requirement to renovate worse performing buildings before they are sold or rented. As a 
result, owners and/or landlords would be not allowed to sell or lease a property that has 
an EPC below a certain class (e.g. class F or G). This would apply to both residential and 
non-residential  buildings,  while  ensuring  some  degree  of  flexibility  to  ensure  the  cost-
effectiveness of the required intervention. The entry into force would be gradual (first for 
public buildings, e.g. social housing) and be accompanied by an increased availability of 
related financing solutions and support measures.  

This  measure  has  a  significant  impact  on  increasing  the  rate  of  building  renovation,  as 
owners and landlords would be compelled to invest in upgrading their properties before 
transactions.  This  measure  would  de  facto  shift  poorly  performing  buildings  towards 
better  performance  and  bring  significant  impacts  on  improved  health  and  wellbeing, 
lower  energy  bills  (and  less  energy  poverty),  reduction  of  pollution  levels,  and  other 
macro-economic  benefits  from  the  creation  of a  dynamic  renovation  market,  more  jobs 
and growth. 

75 

 
Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Scope 

Building 
category 

Amendment 

Building owners 

Transactions (sale and/or 
rent) 

All 

New / Existing 

Lowest 
performing 
existing 

Subsidiarity and proportionality:  
It would be possible to introduce a renovation obligation and still respect subsidiarity and proportionality, 
by leaving the flexibility to Member States decide on the specific performance standard below which it 
would mandatory to renovate. However,,detailed statistical data on national building stocks is a 
precondition for the setting obligations on building renovation and is generally not available in the majority 
of Member States. So, the impact of this measure on the real estate market is uncertain. Nevertheless, 
similar measures are being explored (e.g. UK) and applied (e.g. in Scotland) and have significant impact on 
increasing renovation rates. So, this type of obligation would be something that Member States can already 
start pursuing.  
The measure would directly mandate investments from building owners. This measure was nevertheless 
not retained in the preferred option due primarily to concerns regarding practical implementation. 

Measure 2:  Fine  tune  the  implementation  of  minimum  energy  performance 

requirements  

The evaluation identified several shortcomings related to the way minimum requirements 
are set and ensured at national level.  

Measure  2A  addresses  the  findings  of  the  evaluation  showing  that  that  the  common 
general  framework  for  the  calculation  of  energy  performance  of  buildings84  is  not 
sufficiently detailed and transparently and efficiently implemented at national level, e.g. 
to  ensure  that  efficient  systems  with  renewable  energy  are  properly  valued  in  the 
calculation. This measure also addresses the performance gap between calculated energy 
demand  of  existing  buildings  and  actual  consumption85  and  informs  the  sector  about 
upcoming requirements to improve their uptake.  

Measure 2B tackles the fact that the cost-optimal framework methodology does not take 
into account all benefits of improved energy performance, intends to address the patchy 
consideration  of  indoor  climate  conditions  at  national  level  when  setting  (tighter) 
minimum  energy  performance  requirements  and  to  complement  the  2020  target  for 
NZEB with a 2030 vision for new buildings, beyond cost-optimality.  

Measure 2A:  Improve transparency of calculation methodologies and provide further 
clarification on the cost-optimal setting of minimum performance requirements  
The Commission will issue a Recommendation, based on Member States’ best practices 
on:  

 

the  integration  of  EPCs,  minimum  requirements  and  the  design  of  information 
campaigns and support schemes by proposing a single calculation of performance 
for both building certification and minimum energy performance requirements, and 
to indicate the required minimum levels of energy performance in EPCs (as already 
recommended in EPBD Art.11(1));  

84 
85 

Set out in Annex I of the Directive 
See  e.g.  "Introducing  the  prebound  effect:  the  gap  between  performance  and  actual  energy 
consumption", Minna Sunikka-Blank & Ray Galvin (2012), Building Research & Information, 40:3, 
260-273, DOI: 10.1080/09613218.2012.690952/ 

76 

 
 
                                                 
 

 

ensuring indoor environment quality, in particular indoor air quality;  

ensuring a technology neutral approach in line with points 3 and 4 of Annex I and 
promoting  the  national  annex  framework  of  related  European  standards86  (in 
particular  prEN  ISO  52000-187)  to  transparently  describe  their  national/regional 
calculation methodology together with their report on cost optimal-calculations;  

  with  the  support  of  reinforced  quality  of  energy  performance  certificates  (Cf. 
measure  4A),  calibrating  calculation  methodologies  to  ensure  that,  on  average, 
asset rating with typical use conditions matches with actual energy use in actual use 
conditions (hence partly tackle the issue of performance gaps between design and 
actual performance);  

 

proposing that:  

o  the  cost-optimal  calculations  add  a  forward-looking  projection  of  cost-optimal 
levels  for  +5  and  +10  years  to  better  prepare  the  market  for  future  minimum 
requirements; and  

o  gaps  resulting  from  cost-optimal  calculations  are  reduced  to  a  non-significant 

size within 1 year (instead of 'by the next five-year review'). 

Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Scope 

Building 
category 

Recommendation 

Member States 

Cost-optimal calculations  

All 

New / 
Existing 

New and 
existing 

Subsidiarity and proportionality:  
The measure will address inefficient implementation practises identified during the evaluation, with a 
limited but significant impact by 2030.  
Issuing a recommendation to intensify implementation efforts fundamentally respects the subsidiarity 
principle. The envisaged recommended approaches will build on best practises already adopted by some 
Member States, which will ensure proportionality and cost-effectiveness.  
No investment is directly mandated by the measure. 

Measure 2B:  Change the framework for cost-optimal calculations by including 
additional co-benefits and going beyond cost-optimality when setting minimum 
requirements  
The  cost-optimal  methodology  defined  in  Delegated  Regulation  (EU)  No  244/201288 
would be amended to require the consideration of additional benefits (i.e. increased asset 
value,  comfort  level,  improved  indoor  environmental  quality,  embodied  energy,  and 
other sustainability benefits) as part of the cost-optimal calculations. This measure would 
be consistent with current practices in approximately 1/4 of the Member States, which set 
minimum  requirements  more  ambitious  than  cost  optimal  levels.  This  allows  them  to 
take into account the increase in building value of better performing buildings and further 
co-benefits that result from the application of energy efficiency measures and the use of 
renewable  energy  sources.  This  update  of  the  cost-optimal  methodology  should  be 
aligned  with  the  common  EU  framework  for  assessment  of  sustainable  or  ‘resource 

86 

87 

88 

CEN standards developed under mandate M/480 aimed at enabling the presentation of national and 
regional choices on a comparable basis. 
International  Standard  (under  approval)  that  provides  a  systematic,  comprehensive  and  modular 
overall structure on the integrated energy performance of buildings, in order to ensure consistency 
all EPB standards required to calculate the energy performance of buildings. 
OJ L 81, 21.3.2012, p. 18–36 

77 

 
                                                 
efficient  buildings’  that  the  Commission  is  currently  developing89,  and  existing 
sustainable building certification schemes.  

Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Scope 

Building 
category 

Amendment 

Member States 

Cost-optimal calculations 

All 

New / Existing 

New and 
existing 

Subsidiarity and proportionality:  
The evaluation indicated that the indoor environment was not always appropriately covered by the 
national/regional regulators to ensure that energy renovation of buildings does not create negative effect 
such as inadequate ventilation. By focusing on the cost-optimal calculations and raising awareness rather 
than by imposing to Member States the setting of additional indoor environment requirements, subsidiarity, 
proportionality and cost-effectiveness are preserved. 
In addition to the above, the Directive would be amended to set up a ceiling for nearly 
zero-energy  buildings  as  of  2020  and  define  net  zero  energy90  and  positive  energy 
buildings  as  the  new  target  for  2030.  Although  the  5-year  review  of  the  cost-optimal 
levels ensures that minimum requirements for new buildings remain updated after 2020 
and that NZEB levels are regularly tightened, this measure would  address the feedback 
from  several  respondents  to  the  public  consultation  requiring  a  commonly  defined 
ambition for NZEB and additional measures for 2030.  

The  definition  of  net  zero  energy  and  positive  energy  buildings  would  include  indoor 
climate  requirements,  given  that  the  risk  of  potential  negative  effects  is  higher  for 
buildings with very high performance. These requirements for indoor air climate would 
focus  on  temperature,  air  quality  and  daylight,  all  of  which  can  be  easily  integrated  in 
building codes. The balance between performance and indoor climate requirements could 
be monitored and controlled using smart systems technologies (e.g. ventilation controlled 
using CO2 sensors, etc.). 

89 

90 

This framework will define indicators for the environmental performance of buildings and is part of 
the  work  to  respond  to  the  need  identified  in  the  Communication  ‘Resource  Efficiency 
Opportunities in the Building Sector’ COM (2014)445 for a common European approach to assess 
the environmental performance of buildings throughout their lifecycle, taking into account the use 
of resources such as energy, materials and water.  
A  net  zero  energy  building  could  be  defined  as  a  building  that  on  an  annual  basis  the  energy 
consumption  is  roughly  the  same  as  the  amount  of  renewable  energy  generated  on  the  site.  A 
positive  energy  building  can  be  defined  as  a  building  that  produces  more  energy  than  what  is 
consumes. 

78 

 
                                                 
Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Amendment 

Building owners 

Construction and 
renovation with more 
stringent (beyond cost-
optimal) requirements 

Scope 

Building 
category 

New / Existing 

All 

New and 
existing 

Subsidiarity and proportionality:  
The requirements for net zero (and positive) energy buildings would not be linked to cost-optimal levels 
and might significantly differ. In terms of energy savings, with the nearly zero-energy building standard in 
force in 2020 little potential remains for new buildings. Benefits would be sought in other benefits, energy 
(integration into the energy system) and non-energy (indoor environment, ressources efficiency) related. 
The continued periodic review of the cost-optimality of minimum requirements is considered to be a 
sufficient approach, reason for exclusion of this measure from the preferred option.  
No investment is directly mandated by the measure. However, pushing further minimum requirements 
beyond cost-optimality would require investors to put in place non-cost effective solutions from a financial 
perspective, i.e. require accompanying financial support. 

Measure 3:  Modernisation  using  smart  technologies  and  simplification  of 

outdated provisions for the benefit of citizens  

The  evaluation  concluded  that  some  of  the  provisions  of  the  Directive  were  becoming 
outdated  and  not  delivering  efficiently,  in  particular  the  feasibility  study  to  ensure  that 
before  the  construction  starts  efficient  systems  were  considered,  the  enforcement  of 
minimum  requirements  for  technical  systems  and  the  regular  inspection  of  heating  and 
air-conditioning  systems.  Measure  3A  investigates  modernised  and  proportionate 
approaches substituting to the outdated provisions while pursuing the same objectives.  

Considering  the  slow  uptake  of  key  enabling  technologies  for  'smart  buildings'91, 
measure 3B would modernise the provisions on technical building systems to progress in 
technologies and solutions, tap the related saving potential of more efficient operation of 
buildings92 and accelerate their transformation.  

Finally,  as  buildings  can  play  a  larger  role  in  the  energy  transition  to  a  low  carbon 
economy,  measure  3C  would  deploy  the  foundations  of  the  infrastructure  to  facilitate 
electro-mobility.  

Measure 3A:  Document initial performance of technical building systems and 
maintain their operational performance over time  
The  Energy  Performance  of  Buildings  Directive  will  be  amended  to  require  that 
following  the  installation  or  upgrade  of  any  new,  respectively  upgraded,  technical 
building systems (including on-site renewable energy systems) relevant documentation is 
handed  over to  the  building  owner together with the final  deliverable and/or invoice as 
part  of  the  normal  commissioning  for  such  upgrades  of  technical  systems.  This 

91 

92 

Smart  building  systems  enable  ICT-based  services  for  the  purposes  to  enhance  the  building 
performance, allowing reduced energy and water consumption, empower the building occupant (and 
increase comfort, well-being, health and care, safety, security, social inclusion, independent living, 
etc.),  and  allow  integration  with  grid  infrastructure  and  other  information  and  communication 
technology and equipment. 
Building  energy  management  systems  allow  savings  in  existing  buildings  arising  from  a  more 
efficient operation of space heating in the range of 2-30% and for cooling 37-73% depending on the 
climate  and  building  type  (Improving  energy  efficiency  via  smart  building  energy  management 
systems: A comparison with policy measures. Energy and Buildings. Volume 88, 1 February 2015, 
Pages 203–213) 

79 

 
                                                 
documentation, provided by qualified installers, will guarantee that the minimum energy 
performance requirements set  in the national building codes are met and could be used 
later for compliance checking. It could also have other uses such as input to EPCs. 

Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Amendment 

Building owners 
& installers 

Installation/upgrade of 
technical building system 

Scope 

Building 
category 

All 

New / Existing 

New and 
existing 

Subsidiarity and proportionality:  
Provide adequate information to the building owner after any intervention on technical building system 
should already be common practise. Requiring Member States to standardise the nature and format of the 
information to be provided by installers requires little additional effort, improves the information given to 
citizen and enables a more efficient compliance checking with minimum requirements.  
No investment is directly mandated by the measure 
In addition to the above, the EPBD will be amended to repeal the provisions related to 
regular inspections and introduce mandatory requirements to:  

  Equip  with  electronic  monitoring  ability  centralised  technical  building  systems  in 
residential  buildings  with  generation  power  of  more  than  a  given  effective  rated 
output (e.g. 100kW);  

  Equip  with  active  energy  management  systems  non-residential  buildings  whose 
total  annual  primary  energy  use  in  typical  use  conditions  is  more  than  a  given 
annual consumption (e.g. 250MWh93).  

Electronic  monitoring  of 
inform  building 
owners/managers  when  the  system  efficiency  has  significantly  decreased  and  when 
system  servicing  is  necessary)  has  proven  to  be  an  effective  substitution  to  the  regular 
inspection with physical visit of inspectors (project iSERVcmb94).  

technical  building 

systems 

(that 

The  presence  of  electronic  monitoring  functionalities  will  be  one  component  of  the 
smartness  indicator  (Cf.  Measure  3B).  When  connected,  electronic  monitoring  would 
enable the automatic feeding of databases supporting the voluntary disclosure of energy 
use (Cf. Measure 4A). 

93  

According  to  Pacific  Northwest  National  Laboratory,  a  20,000  square  feet  commercial  building 
typically uses 234MWh/y (20,000*11.72kW/(sf.y)) and has a sufficient energy saving potential to 
cover the investments of a full building automation and control system with a 3years payback time 
("Low  Cost  Building  Automation  System  for  Small-  and  Medium-Sized  Commercial  Buildings", 
Srinivas  Katipamula,  Ph.D,  Staff  Scientist,  Pacific  Northwest  National  Laboratory;  Presentation 
retrieved from http://e3tnw.org/). 
94   More info at: http://www.iservcmb.info/ 

80 

 
                                                 
Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Amendment 

Building owners 

Application date of the 
amendment 

Scope 

Building 
category 

Big non-
residential and 
multi-family 
house with 
central systems 

New / Existing 

New and 
existing 

Subsidiarity and proportionality:  
The measure is considered to be more efficient approach than the regular inspection with a physical visit 
and provides information that is easy to understand by building owners/managers. The threshold would be 
set in terms of energy consumption per year, with the aim to reach a three year payback period, making the 
measure more proportionate because linked to the saving potential.  
The measure replaces a mandatory service (regular inspections) by the installation of a mandatory 
system/system function. 

Measure 3B:  Framework for the introduction of a smartness indicator  
The  Energy  Performance  of  Buildings  Directive  will  be  amended  to  empower  the 
Commission to develop a framework calculation of a smartness indicator and enable the 
implementation of a common framework to assess and certify smart-readiness.  

A smartness indicator will reflect the ability of buildings to (i) adjust to the needs of the 
user  and  empower  building  occupants  providing  information  on  operational  energy 
consumption  (complementing  the  energy  performance  information  provided  in  the 
EPCs),  (ii)  ensure  efficient  and  comfortable  building  operation,  signal  when  systems 
need  maintenance or  repair, and (iii) readiness of the building to  participate in  demand 
response, charge electric vehicles and host energy storage systems.  

During a transaction, this indicator will act as a reward mechanism for buildings with a 
high  level  of  energy  performance-oriented  smartness,  which  can  be  achieved  through 
ICT-based  solutions  such  as:  electronic  monitoring  systems,  remotely  controlled 
equipment/systems, predictive features, self-diagnosis and adaptability.  

Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Amendment 

Building owners 

Transaction (sale and/or 
rent) 

Scope 

Building 
category 

All 

New / Existing 

New and 
existing 

Subsidiarity and proportionality:  
The measure builds on the provision of information and empowerment rather than direct obligation to 
install. EU intervention is justified by the necessity to create a market of a sufficient size to improve the 
cost-effectiveness of R&D investments.  
No investment is directly mandated by the measure. 

Measure 3C:  Support to electro-mobility  
Article  4  of  Directive  2014/94  on  the  deployment  of  alternative  fuels  infrastructure 
requires  Member  States  to  ensure  that  an  appropriate  number  of  recharging  points 
accessible to the public are put in place and to encourage and facilitate the deployment of 
recharging points not accessible to the public.  

Transport and mobility is  usually out  of the scope of building  codes (and consequently 
out  of  the  EPBD  scope),  although  nothing  in  Article  1  of  the  EPBD,  which  defines  its 
subject  matter,  explicitly  excludes  transport  issues.  Nevertheless,  building  codes  can 
support the deployment of recharging points in the parking that are built in buildings (not 

81 

 
accessible to the public) by requiring that the necessary electric infrastructure is in place 
to ease the later installation of smart charging points.  

Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Amendment 

Building owners 

Construction 

Scope 

Building 
category 

Big non-
residential and 
multi-family 
house 

New / Existing 

New 

Subsidiarity and proportionality:  
As established in the above Section 2.1.2, the granularity of the network for charging points, in particular 
in private parking spaces, is recognised to be a key-enabler for the development of electro-mobility. The 
construction and the major renovation of buildings are good opportunities to install smart recharging 
points, or at least facilitate their later installation. Pre-equipped buildings can have significant benefits for 
the property industry as they positively impact on the investment value of those buildings, enhance the 
reputation of the owner by assisting developers and occupiers in achieving their corporate sustainability 
targets and provide easy access for office building employees to safely und securely recharge their electric 
vehicles while they are not in use. Following the experience of existing green building certification credit 
points for electric car schemes (BREEAM Innovation credits, LEED alternative-fuel refuelling stations 
credit), this electro-mobility readiness would be a visible part of the smartness indicator.  
The measure only mandates that new buildings provide for the minimum infrastructure to enable, at the 
initiative of the end-user, the later installation of recharging points. The economic impact of the measure 
itself would be negligible compared to the cost of the building. Although limited to new buildings, Member 
States could consider applying the measure to existing buildings, following the example of e.g. France.  
Costs vary on a scale of one to ten depending on whether normal recharging or fast recharging are provided 
for and this choice will also vary according to type of building (office building with longer parking times 
vs. shopping centre with shorter stays). To ensure proportionality of the intervention, the approach would 
be different for large multi-apartment blocks and non-residential (e.g. office buildings and building 
frequently visited by the public). 
The  Energy  Performance  of  Buildings  Directive  will  be  amended  to  require  that  new 
buildings  with  more  than  10  parking  spaces  are  pre-equipped  with  the  dedicated 
infrastructure (power lines that are suitable and available to allow for the installation of a 
recharging point) needed to install, without re-intervention on the building infrastructure, 
recharging  points  for  charge  electric  vehicles  as  defined  in  Article  2,  paragraph  2,  of 
Directive  2014/94  on  the  deployment  of  alternative  fuels  infrastructure  and  if  possible 
powered  through  on-site  renewable  energy.  Small  scale  parking  space  (e.g.  in  single 
family  houses)  are  not  considered  as  the  electric  infrastructure  (distribution  of 
220V/16A)  is  generally  present  and  sufficient  for  the  installation  of  a  normal  power 
recharging point.  

As a result, buildings will support electro-mobility by reinforcing the network of smart 
charging  points.  The  measure  will  distinguish  between  residential  and  office  buildings 
where normal smart charging points would generally be adapted to the parking times and 
non-residential buildings where fast charging point are to be considered.  

It should be noted that, for transparency, the estimate of investments not only values the 
cost of the infrastructure for the charging  points (strict  application of the measure)  that 
are estimated to but also the final equipment, without which the measure would not make 
much sense and which would take place by 2030.  

82 

 
Measure 4:  Enhance  financial  support  and 

information  to  users  through 

reinforced energy performance certificates  

The  certification  schemes  for  the  energy  performance  of  buildings  have  proven  some 
effects  in  transforming  the  real-estate  market.  However,  the  evaluation  identified 
weaknesses and several ways of reinforcing the role that EPCs can play, e.g. to facilitate 
compliance checking, to improve the efficiency of financing schemes, and to contribute 
to gathering data and build statistics on national building stocks.  

It  is  acknowledged  that high  quality  data  on  the  building  stock  is  needed,  and  that  this 
data could be partially generated by EPC registers/databases that practically all Member 
States are developing and managing.  

Consultation with Member States through the EPBD Concerted Action showed a lack of 
sufficient links between the regulatory framework and the design of financing schemes. 
The  technical  guidance  on  Cohesion  Policy  funding  supports  the  introduction  of 
requirements  for  conducting  energy  audits  before  renovation  works  to  clearly  assess 
alternative  measures  and  prepare  a  tailored-made  renovation  plan.  The  guidance  also 
suggests issuing EPCs before (as part of the initial energy audit) and after renovation (at 
least  when  public  funding  is  made  available),  as  it  brings  added  value  and  provides  an 
input to the energy audit. Accordingly, EPCs could be used as a tool to link the depth of 
the renovation with financial support intensity (i.e. renovation projects that improve the 
building rating by 3 classes – from G to D – could receive more financial incentives than 
a project improving the rating by only 1 performance class – G to F).  

Measure 4A:  Reinforced quality of energy performance certificates to enhance the 
financial support  
The Energy Performance of Buildings Directive will be amended to reinforce the current 
independent  control  systems  for  energy  performance  certifications,  (i)  defining  a 
minimum  list  of  information  to  be  collected  and  registered  regional  or  national  EPC 
databases  at  the  time  of  issuing  EPCs;  and  (ii)  minimum  requirements  that  those 
databases  need  to  fulfil,  including  the  enabling  facility  for  the  voluntary  disclosure  of 
actual energy consumptions.  

National  EPC  registers/databases  are  already  operational  in  a  majority  of  Member 
States95 as described in Annex 12. Accompanied by clear requirements, these databases 
would  facilitate  quality  assurance  of  certification,  compliance  checks, transparency  and 
improved  data  collection.  This  measure  will  tackle  weaknesses  in  the  way  some 
certification  schemes  and  facilitate  their  role  in  informing  higher  renovation  rates. 
Similarly, such EPC databases will provide necessary information for market actors and 
decision makers to design building renovation programmes, target investments, identify 
priority interventions areas and map risk areas for energy poverty.  

The disclosure of actual energy consumption in EPC databases will be made mandatory 
for public buildings (of a certain size) and encouraged in other non-residential buildings 
(relevant  for  businesses’  corporate  social  responsibility  reporting)  and  when  public 
financial support is given.  

95 

In 2014, 24 Member States had an operational regional of national EPC database (plus Norway). In 
addition,  Poland,  Latvia,  Luxembourg  and  the  Czech  Republic  are  lining  up  to  launch  their  own 
databases. 

83 

 
                                                 
Some  countries96  (have  put  in  place  electronic  platforms  to  provide,  in  addition  to 
mandatory EPCs, simplified self-pre-assessment of the energy performance of residential 
buildings. These platforms can be powerful information tools. Connected to the regional 
or  national  EPC  databases,  such  platforms  can  improve  data  availability  if  data  are 
quality controlled and handled with sufficient precaution.  

This measure, combined with measure 2A on more transparent and robust determination 
of the energy performance of buildings, will also help strengthen, modernise and enable a 
reinforced  compliance  with  minimum  energy  performance  requirements  and  quality 
control of Energy Performance Certificates.  

Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Amendment 

Member States 

Application date of the 
amendment 

Scope 

Building 
category 

All 

New / Existing 

New and 
existing 

Subsidiarity and proportionality:  
The EPC registers/databases offer opportunities to collect data on the building stock, including on actual 
energy consumption, and provide additional information to citizens and market actors. A pre-requisite is to 
keep supporting Member States in the improvement of the quality of EPCs.  
Confrontation of EPC ratings and actual energy consumptions enables the calibration of calculation 
methodologies to address the performance gap (Cf. Measure 2A) and can better inform market players 
about the actual business case for energy renovation. Some market players, including finance institutions, 
intervene globally and EU harmonisation has been identified as a key-enabler for the demand and supply of 
finance. The proportionality of this harmonisation will be ensured by taking the current national/regional 
practises as a reference for the definition minimum requirements that those databases need to fulfil.  
No investment is directly mandated by the measure. 
In  addition,  the  Directive  will  be  amended  to  require  that,  when  renovation  works  are 
supported  by  public  funding  an  updated  EPC  is  issued  after  renovation  works,  which 
would  ensure  efficient  financial  support  and  enable  the  alignment  of  the  intensity  of 
public financing support to the achieved depth of renovation. Recommendations in EPCs 
should consider energy efficiency and renewable packages and factor in other constraints 
and benefits, such as indoor air quality, and resource efficiency.  

This measure will reinforce the value of EPCs and ensure better compliance checking of 
retrofitting  and  renovation  works  (which  are  otherwise  generally  conducted  without 
needing  a  building  permit).  This  will  make  visible  the  savings  achieved  by  renovation 
projects and financing schemes.  

96 

The Netherlands, Norway 

84 

 
                                                 
Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Scope 

Building 
category 

New / Existing 

Amendment 

Application date of the 
amendment 

Applicants to 
public financial 
support 
Subsidiarity and proportionality:  
The measure intends to generalise best practises that have already been promoted towards authorities 
managing the ERDF funds. With the scarcity of public finance, including from the EU, effective and 
efficient use of public funding is of absolute necessity and the obligation has been targeted to the critical 
points in order to be proportionate.  
No investment is directly mandated by the measure. 

New and 
existing 

All 

Measure 4B:  Harmonised template for energy performance certificates  
The  Energy  Performance  of  Buildings  Directive  would  be  amended  to  set  up  an 
harmonised  template  for  EPCs  based  on  a  common  list  of  parameters/indicators  shown 
on the certificate, such as calculated annual final energy use, share of renewable energy 
used,  past  (climate  corrected)  final  energy  consumptions  and  energy  expenditure, 
comfort  levels  (as  proposed  in  measure  2D)  or  the  level  of  smartness  (as  proposed  in 
measure 3C). 

Instrument 

Obligated 
parties 

Trigger point for the 
obligations 

Amendment 

Member States 

Application date of the 
amendment 

Scope 

Building 
category 

All 

New / Existing 

New and 
existing 

Subsidiarity and proportionality:  
Therefore it was never considered necessary to have a harmonised EPC and each Member State could 
adapt the EPC as appropriate.  
During the consultation, exploring options for more harmonisation, e.g. harmonised EPCs received support 
from stakeholders, who claimed that this would bring benefits to the business environment. Whilst 
buildings do not move, people do. Given the increasing intra-EU mobility (more and more EU citizens live 
in different countries e.g. in different periods in their life; as student, working abroad), people are more and 
more in a position to compare EPCs from different countries. Therefore the option has more relevance than 
previously.  
Although harmonised EPCs seem an attractive measure, without fully harmonised calculation methodology 
for the energy performance of buildings, which at this point in times is premature, harmonised EPCs would 
create more confusion than clarity.  
No investment is directly mandated by the measure. 

85 

 
Table 15: Overview of measures 

Measures 

Target group  

Type of obligation / 
Obligation frequency 

Scope 

Building 
category 

New / 
Existing 

Existing 

Lowest 
performing 
existing 

All 

Member States 

Building 
owners 

Transactions 
(sale and/or rent) 

Definition of long-term 
renovation strategies 

Measure 1. Accelerate the decarbonisation of buildings by significantly increasing renovation rates 
1A. Set milestones for the 
decarbonisation of the 
building stock by 2050 
1B. Oblige the renovation of 
buildings to reach a given 
standard before transactions 
Measure 2. Fine tune the implementation of minimum energy performance requirements 
2A. Improve transparency of 
calculation methodologies 
and provide further 
clarification on the cost-
optimal setting of minimum 
performance requirements 
2B. Change the framework 
for cost-optimal calculations 
by including additional co-
benefits and going beyond 
cost-optimality when setting 
minimum requirements 

Construction and 
renovation with more 
stringent (beyond cost-
optimal) requirements 

Member States  Cost-optimal calculations  

Member States  Cost-optimal calculations 

Building 
owners 

All 

All 

All 

All 

New and 
existing 

New and 
existing 

New and 
existing 

Measure 3. Modernisation using smart technologies and simplification of outdated provisions for the 
benefit of citizens 
3A. Document the initial 
performance of technical 
building systems and 
maintain their operational 
performance over time 

Installation/upgrade of 
technical building system 

Building 
owners & 
installers 

New and 
existing 

All 

Building 
owners 

Application date of the 
amendment 

New and 
existing 

Big non-
residential and 
multi-family 
house with 
central systems 

3B. Framework for the 
introduction of a smart-
readiness indicator 
3C. Support to electro-
mobility 

Building 
owners 

Transaction (sale and/or 
rent) 

All 

New and 
existing 

Building 
owners 

Construction 

Big non-
residential and 
multi-family 
house 

New 

Measure 4. Enhance financial support and information to users through reinforced energy 
performance certificates 
4A. Reinforced quality of 
energy performance 
certificates to enhance 
financial support  

Application date of the 
amendment 

Member States 

All 

Applicants to 
public 
financial 
support or on a 
voluntary basis 

Application date of the 
amendment 

New and 
existing 

4B. Harmonised template for 
certificates 

Member States 

Application date of the 
amendment 

All 

New and 
existing 

86 

 
ANNEX 7 

SPECIFIC IMPACTS OF THE MEASURES.  

Section  6  of  the  present  impact  assessment  provides  aggregated  impacts  related  to  the 
different  policy  options.  These  aggregated  results  are  direct  outputs  of  the  modelling 
activities explained in the above Annex 4.  

The  present  annex  intends  to  give  a  deeper  in-sight  regarding  the  individual  measures: 
their impact on savings in 2030, impacts on annual energy expenditure in 2030, impact 
on associated construction activity, and on other costs supported by the stakeholders.  

Estimates of impacts on energy savings  

Except for measures 1B, 3C and 3D that  were assessed outside the BEAM²  model, the 
specific impacts of measures were estimated through an analytical work to determine the 
weight  of  each  individual  measures  in  reaching  the  overall  result  coming  out  of  the 
modelling work.  

It should be kept in mind that impacts on final energy consumption are given within the 
scope  of  the  Directive,  i.e.  only  refer  to  the  consumptions  associated  with  space  and 
water heating, space cooling, ventilation and lighting in non-residential buildings.  

Estimates of impacts on energy expenditures  

From the results of Ecofys modelling work, it was established that, on average, 1 Mtoe of 
energy saved is equivalent to €1bn of reduction of energy expenditure. This is equivalent 
to an average energy price of 0.86€/kWh.  

Calculated  upon  the  above  impacts  on  energy  savings,  the  reduction  of  energy 
expenditure is also to be associated to the scope of the Directive.  

Estimates of impacts associated with construction activities  

From  the  results  of  Ecofys  modelling  work,  it  was  established  that,  on  average,  the 
transformation of the building stock to increase the energy savings by 1 Mtoe of energy 
saved in 2030 involves around €20bn of energy related activity (roof insulation, windows 
replacement, building system upgrade, etc.) for the construction sector in the 2020-2030 
period97.  €20bn  investments  in  the  2020-2030  period  correspond  to  an  annual  average 
investment of €2bn each year.  

However,  contrary  to  the  impact  on  energy  expenditure  that  can  be  assumed  to  be 
proportional to energy savings, this ratio cannot be applied across the board. There is no 
direct correlation between construction activity and the level of energy saving achieved. 
An analytical work was therefore performed for each individual measure.  

Measures  1B,  3B  and  3C  were  not  part  of  Ecofys  modelling  work  and  were  analysed 
individually,  following  the  assumptions  presented  in  Annex  4,  to  which  the  following 
cost ratio were applied:  

97 

Because 1 Mtoe of additional saving corresponds to €1bn of reduction of energy expenditures, this 
is consistent with an average simple pay-back period of around 20 years (i.e. consistent with cost-
optimal minimum requirements). 

87 

 
                                                 
  For measure 1B the estimate assumed that very bad performing buildings would be, 
on  average,  consuming  four  times  more  than  this  average  level  of  the  respective 
residential  or  non-residential  building  stock.  'Very  badly  performing  buildings' 
implies that basic features are missing or not properly maintained in the considered 
building:  broken  window  panes,  absence  of  roof  insulation,  total  absence  of 
temperature control, etc. An average 400 €/m² in residential buildings and 600 €/m² 
in  non-residential  buildings  was  estimated  to  bring  such  buildings  to  the  average 
performance level.  

  For  measure  3B,  the  average  cost  of  upgrade  to  smarter  buildings  is  estimated  to 

12€/m² in residential buildings and 30 €/m² in non-residential buildings98.  

  Regarding measure 3D, it should be noted that the estimates not only value the cost 
of the infrastructure for the charging points (strict application of the measure) that 
are  estimated  to  but  also  the  final  equipment  of  one  parking  space  every  10, 
without  which  the  measure  would  not  make  much  sense  and  which  would  take 
place by 2030.  

Measures  2B  and  2C  add  non-energy  saving  related  investments,  associated  with  other 
co-benefits.  Investments  are  de-correlated  from  savings  and  were  estimated  separately 
with an additional average 12 – 30 €/m² for new and existing buildings.  

Measures  1A  and  4A  stimulate  new  energy  related  activity  for  the  construction  sector. 
Therefore the average ratio of €2bn per additional Mtoe, derived from Ecofys modelling) 
was used for these measures.  

Measures 2A and 3A generally ensure a better quality of activity already performed. This 
involves  marginal  extra  investments  and  the  average  ratio  of  €1bn  per  additional  Mtoe 
was applied.  

Measure 4B comes on top of Measure 4A and is considered to have marginal additional 
effect to the later.  

Investment costs directly mandated by the measures  

The EPBD does not mandate any construction or renovation activity. If the EPBD aims 
at addressing informational barrier to create a demand-driven market, the decision to take 
action to upgrade the energy performance of buildings is entirely left to market actors.  

Most  of  the  measures  considered  keep  with  this  logic  and  the  above  impacts  on 
construction activities result of decision taken by the building owner, based on the costs-
benefits perceived by building owner, ideally aligned with the macro-economic optimum.  

The  following  three  measures  totally  or  partially  derogate  to  this  principle  and  directly 
mandate investments:  

  Measure  1B:  the  average  50  –  55  bn€/a  would  be  directly  mandated  by  the 

measure;  

98 

Source: Contribution of EU-bac to the stakeholder event of 14 March 2016 "…the investments are 
capital-light  (typically  30  €/m²in  non-residential  buildings  and  12  €/m²in  residential  buildings  – 
procurement, installation and commissioning), with fast payback period (3-5 years)" 

88 

 
                                                 
  Measure 3A: Part of the measure replaces a mandatory service (regular inspections) 
by the installation of a mandatory system/system function. It therefore mandates an 
average  €1bn  –  €3bn  average  annual  investment.  The  application  threshold  is 
however designed to target a 3 years pay-back period;  

  Measure  3C:  For  transparency,  full  costs  investments  were  considered,  not  only 
values  the  mandated  cost  of  the  infrastructure  for  the  charging  points  (strict 
application  of  the  measure)  but  also  the  final  equipment,  without  which  the 
measure  would  not  make  much  sense  and  which  would  take  place  by  2030.  For 
new  buildings,  the  costs  to  leave  the  necessary  recesses  in  the  infrastructure  are 
considered to be totally marginal.  When electric pre-cabling (power lines that are 
suitable and available for  the installation of a  recharging  point) is  also mandated, 
the burden placed on individuals can be estimated at €0.3k per parking spaces in all 
cases. The mandated part is estimated to €4.66bn over the 2020-2030 period, i.e. an 
average €0.47bn each year.  

This leads to the following mandated investments for the different policy options:  

  Option I: None;  

  Option II: annual average of €1bn – €4bn (Measures 3A and 3C);  

  Option III: annual average of €51bn – €59bn (Measures 1B, 3A and 3C).  

Table 16 summarises these results.  

89 

 
 
 
Table 16: Impacts of the different measures. 

Measures 

Impacts on 
savings 
in 2030 

Impacts on 
annual energy 
expenditures in 
2030 

Impacts on associated 
construction activity 
(annual average for 
2020 - 2030) 

4 – 6 Mtoe 

4 – 6 bn€/a 

8 – 12 bn€/a 

40 – 45 Mtoe 

40 – 45 bn€/a 

50 – 55 bn€/a 
(Mandated 50 – 55 bn€/a) 

Measure 1. Accelerate the decarbonisation of buildings by significantly increasing renovation rates 
1A. Set milestones for the 
decarbonisation of the building stock by 
2050 
1B. Oblige the renovation of buildings to 
reach a given standard before they are 
sold or rented 
Measure 2. Fine tune the implementation of minimum energy performance requirements 
2A. Improve transparency of calculation 
methodologies and provide further 
clarification on the cost-optimal setting of 
minimum performance requirements 
2B. Change the framework for cost-
optimal calculations by including 
additional co-benefits when setting 
minimum requirements 
Measure 3. Modernisation using smart technologies and simplification of outdated provisions for the 
benefit of citizens 
3A. Document the initial performance of 
technical building systems and maintain 
their operational performance over time 
3B. Framework for the introduction of a 
smartness indicator 
3C. Support to electro-mobility 

2 – 4 bn €/a 
(Mandated 1 – 3 bn€/a) 

8 – 10 bn€/a 

8 – 10 bn€/a 

8 – 10 Mtoe 

5 – 6 bn €/a 

1 – 3 bn€/a 

1 – 3 bn€/a 

1 – 3 bn€/a 

5 – 7 bn€/a 

1 – 3 Mtoe 

5 – 7 Mtoe 

1 – 3 Mtoe 

N.C. 

N.C. 

3 – 4 bn €/a 
(Mandated 0.5bn€/a) 

Measure 4. Enhance financial support and information to users through reinforced energy 
performance certificates 
4A. Reinforced quality of energy 
performance certificates quality to 
enhance the financial support 
4B. Harmonised template for certificates 
TOTAL (all measures included as in 
Option III) 

67 – 86 bn€/a 

67 – 86 Mtoe 

8 – 12 bn€/a 

8 – 12 Mtoe 

± 0 bn€/a 

± 0 Mtoe 

± 0 bn €/a 
93 – 118 bn€/a 
(Mandated 52 – 59 bn€/a) 

16 – 24 bn €/a 

90 

 
ANNEX 8  MACRO-ECONOMIC IMPACTS  

Qualitative 

Quantitative 

Option I 

Economic 

Economic growth  

Investment 

Industrial 
competitiveness  

SMEs growth 

Overall, there is a slightly positive impact on 
GDP.  
Positive GDP results are driven by extra 
energy efficiency investment and reduction in 
energy imports. 
Small additional investment in building 
energy efficiency compared with reference 
scenario. 
The main industries impacted by the 
Directive are insulation, and flat glass. There 
are positive impacts on these industries. 
Other industries positively affected are 
mainly engineering and construction-related 
sectors. 

SMEs benefit from investment in building 
renovation and higher demand from 
consumers. 

Public budget 

The budget position is not significantly 
affected and impact is very small.  

Consumers and 
households 

Energy Independence 

Value of buildings 

Consumer spending is not strongly affected 
as spending on energy savings by households 
will be compensated by lower energy bills in 
the long run.  
Inflation is lower in the scenario as economy 
move away from expensive energy product.  
Small improvement to EU energy security. 

Better energy performant buildings show 
shorter vacancy periods, have a lower loss of 
rental income due to changing tenants and, as 
such, show a more positive operating impact 
for the owner.  
The impact of this scenario in the value of 
buildings is in lower end of the scale. 

The results of the administrative costs 
calculations, using the standard cost model, 
show that this option does not affect 
significantly the administrative burden for 
both public and private sectors. 

Administrative costs 

91 

+0.01% increase in GDP by 
2030 compared with reference 
scenario 

EU additional building energy 
efficiency investment in 2030 
is approximately €2bn  
Insulation industry market: 
steady market (approx. €750m 
at EU level in 2030)  
Flat glass industry market: 
steady market (approx. €1.0bn 
at EU level in 2030) 

Renovation market: steady 
market (approx. €0.5bn - 
€8.3bn at EU level in 2030) 

Public budget ratio to GDP not 
affected compared with 
reference scenario. 
Consumer expenditure not 
changed compared with 
reference scenario in 2030  
Consumer price index not 
changed compared with 
baseline scenario in 2030 
Share of EU total final energy 
used in GDP decreases by -0.01 
percentage points (pp) by 2030  
Share of energy imports in 
GDP decreases just slightly pp 
by 2030  
Lower end of the scale.  
Increased sale value of better 
performing buildings:  
- Service: +5.2% to +35%  
- Residential: 0% to +14%  
Increased rental value of better 
performing buildings:  
- Service: +2.5% - +11.8%  
- Residential: +1.4% - +5.2% 
Overall net burden reduction: - 
€0.7 million per year (€7 
million for the period 2020-
2030) mainly on the public 
sector  
Details of the administrative 
cost calculations can be found 
in specific Annex. 

 
 
Social 

Employment 

Public health & safety 

Energy poverty 

Environmental 
Climate change 

Qualitative 

Quantitative 

Employment impacts follow a similar pattern 
to GDP, albeit the impact is very small in 
scale because wage and labour intensity of 
sectors benefitting from additional 
investment also have impacts on employment 
demand  

Employment in energy and utilities sector 
falls slightly due to reduction in energy 
demand 
Mortality, morbidity and health care costs 
due to indoor climate are only marginally 
reduced in this option. Similar results were 
found for the loss of productivity at work 

Energy Poverty is predominant within old, 
non-refurbished buildings. This policy 
package does not have a strong impact in 
energy poverty alleviation  

EU28 total employment 
increases by 0.04%, 
(approximately 9 thousand 
persons) as compared to 
reference scenario in 2030 

Reduced costs savings from 
lower mortality & €3.5m lower 
healthcare costs in 2030.  

Reduced productivity gains in 
2030 (minimum-maximum)  

Number of households that are 
lifted from energy poverty 
across the EU by 2030 is not 
significant. 

Emissions of greenhouse gases follow from 
the results for primary fuel consumption. CO2 
and greenhouse gas emissions in all Member 
States decrease slightly  

The additional CO2 and GHG 
emissions reductions in 2030 
are small compared to 
reference scenario  

Fostering the efficient 
use of resources 
(renewable & non-
renewable) 

Small final energy demand reduction in the 
buildings sector.  

Small additional investment in building 
energy efficiency compared to reference 
scenario 

Preserving the quality 
of natural resources 

Demand for water in power generation 
affected by reduction in electricity demand.  

Building sector final energy 
consumption in 2030, -0.06% 
difference compared to 
reference scenario (-1.8 Mtoe)  

Small/no change to water 
demand used in power 
generation.  

Increase in demand for raw materials from 
construction and other energy efficiency 
related-products 

Small increase in domestic 
material consumption  

Option II 

Economic 
Economic growth  

Qualitative 

Quantitative 

Overall, there is a slightly positive impact on GDP. 
The impact is bigger in Option II compared to 
Option I.  
Positive GDP results are driven by extra energy 
efficiency investment and reduction in energy 
imports.  
Results at sector level shows boost to construction 
and engineering which are highly related to 
additional investment. 

+0.28% increase in GDP by 
2030 compared to reference 
scenario  
Key sectors in 2030:  
+0.1% Agriculture  
-1.2% Extraction and utility  
+0.2% Basic manufacturing  
+0.4% Engineering  
+1.1% Construction  

92 

 
 
  
  
  
 
  
 
  
  
 
  
  
 
Qualitative 

Quantitative 

Investment 

Additional investment in building energy 
efficiency compared with reference scenario. 

Industrial 
competitiveness  

The main industries impacted by the Directive are 
insulation, and flat glass. There are positive 
impacts on these industries.  
Other industries positively affected are mainly 
engineering and construction-related sectors.  
More specifically:  

  HVAC and building control systems  
  Green architecture and construction services  
 
  Appliances  
 

Professional energy services  

Energy-saving consumer products (e.g. 
smart meters)  
Lighting 

 

SMEs growth 

SMEs benefit from investment in building 
renovation and higher demand from consumers. 

Public budget 

The budget position improved slightly from higher 
economic activities in this option.  

Consumers and 
households 

Energy 
Independence 

Value of buildings 

Consumer spending falls slightly in the short run 
due to redistribution of household spending to pay 
for investments. In the long run consumer spending 
increases due to energy savings (more money to 
spend on other goods and services).  

Inflation is lower in the scenario as economy move 
away from expensive energy product. 
Moderate improvement to EU energy security 

Better energy performant buildings show shorter 
vacancy periods, have a lower loss of rental 
income due to changing tenants and, as such, show 
a more positive operating impact for the owner.  
The impact of this option in the value of buildings 
is moderate, i.e. in the middle of the scale. 

93 

+0.2% Services  
(compared to reference 
scenario) 
EU additional building 
energy efficiency investment 
in 2030 is approximately 
€47.6bn.  
Only €1 - €4bn would be 
directly mandated by the 
measures of this option. The 
rest of the additional activity 
results of decision taken by 
individuals based on better 
information. 
Insulation industry market: 
growing market (approx. 
€11bn at EU level in 2030)  
Flat glass industry market: 
growing market (approx. 
€12.8bn at EU level in 2030) 

Renovation market: growing 
market (approx. €80bn - 
€120bn at EU level in 2030) 
Public budget to GDP ratio 
improves by 0.05 pp in 2030 
compared with reference 
scenario. 
Consumer expenditure -
0.01% change compared with 
reference scenario in 2030  
Consumer price index -
0.41% change compared with 
reference scenario in 2030 

Share of EU total final 
energy used in GDP 
decreases by -0.3 pp by 2030  
Share of energy imports in 
GDP decreases by -0.2 pp by 
2030  
Middle of the scale  
Increased sale value of better 
performing buildings:  
- Service: +5.2% to +35%  
- Residential: 0% to +14%  
Increased rental value of 
better performing buildings:  

 
 
  
Qualitative 

Quantitative 

Administrative costs  The results of the administrative costs calculations, 
using standard cost model, show that the preferred 
policy option (this policy option) reduces the 
administrative burden for the private sector, but it 
increases slightly the administrative burden for the 
public sector. Nevertheless, the preferred option 
results in an overall net reduction of the 
administrative burden.  

Social 
Employment 

Public health & 
safety 

Employment impacts follow a similar pattern to 
GDP, albeit the impact is smaller in scale because 
wage and labour intensity of sectors benefitting 
from additional investment also have impacts on 
employment demand.  
Employment in energy and utilities sectors fall due 
to reduction in energy demand. 
Mortality, morbidity and health care costs due to 
indoor climate are significantly reduced in this 
option. Similar results were found for the loss of 
productivity at work. 

Energy poverty 

Energy Poverty is predominant within old, non-
refurbished buildings. This policy package has a 
moderate impact in energy poverty alleviation. 

Environmental 
Climate change 

Emissions of greenhouse gases follow from the 
results for primary fuel consumption. CO2 and 
greenhouse gas emissions in all Member States 
decrease slightly. 

Fostering the 
efficient use of 
resources 
(renewable & non-
renewable) 

Higher final energy demand reduction in the 
buildings sector  
Higher level of additional investment in building 
energy efficiency compared with reference 
scenario 

94 

- Service: +2.5% - +11.8%  
- Residential: +1.4% - +5.2% 
Overall net burden reduction: 
- €98.1 million per year 
(€981 million for the period 
2020-2030) divided as 
follows:  
- Private sector: -€31.8 
million  
- Public sector: €10.4 million  
Details of the administrative 
cost calculations can be 
found in specific Annex. 

EU28 total employment 
increases by +0.1%, 
(approximately 220 thousand 
persons) as compared to 
reference scenario in 2030 

€211m costs savings from 
lower mortality & €36m 
lower healthcare costs in 
2030.  
€14m-€24m productivity 
gains in 2030 (minimum-
maximum)  
Number of households that 
are lifted from energy 
poverty across the EU by 
2030 based on 3 indicators:  
- Arrears on utility bills": 
514,504 to 1,974,095  
- Presence of leak, damp, rot: 
822,046 to 3,154,379  
- Ability to keep home 
adequately warm: 617,636 to 
2,369,691  
In a total of 10.8% of 
households (i.e. 23.3m) 
living in energy poverty 
(Eurostat SILC) 

CO2 and GHG emissions 
reductions in 2030 are -2.4% 
and -1.9% respectively 
compared to reference 
scenario. 
Building sector final energy 
consumption in 2030, -6.4% 
difference as compared to 
reference scenario (-19.3 
Mtoe)  
EU additional building 
energy efficiency investment 
in 2030 is approximately 

 
 
 
Qualitative 

Quantitative 

€36bn (2013 price). 

Preserving the 
quality of natural 
resources 

Small reduction in demand for water in power 
generation from reduction in electricity demand.  
Increase in demand for raw materials from 
construction and other energy efficiency related-
products 

-0.9% reduction in water 
demand used in power 
generation as compared to 
reference scenario in 2030  
Increase in domestic material 
consumption (+0.8% 
compared to reference 
scenario in 2030)  

Option III 

Economic 

Economic growth 

Qualitative 

Quantitative 

Overall, there is a positive impact on GDP. GDP 
impact in Option III is the highest.  
Positive GDP results are driven by extra energy 
efficiency investment.  
Results at sector level shows boost to construction 
and engineering which are highly related to 
additional investment. 

Investment 

Large additional investment in building energy 
efficiency compared with reference scenario. 

The main industries impacted by the Directive are 
insulation, and flat glass. There are positive impacts 
on these industries.  
Other industries positively affected are mainly 
engineering and construction-related sectors. More 
specifically:  

Industrial 
competitiveness  

  HVAC and building control systems  
  Green architecture and construction services  
 
  Appliances  
 

Professional energy services  

Energy-saving consumer products (e.g. smart 
meters)  
Lighting 

 

SMEs growth 

Public budget 

SMEs (the majority of the construction industry) 
benefit from higher local investment in building 
renovation and higher demand from consumers in 
the long run. 
The budget position improved slightly from higher 
economic activities in this option.  

Consumers and 

Consumer spending falls in the short run due to 

95 

Renovation market: 
growing market (>. €167bn 
- €250bn at EU level in 
2030) 
Public budget ratio to GDP 
improves by 0.11 pp in 
2030 compared with 
reference scenario 
Consumer expenditure 

+0.61% increase in GDP 
by 2030 compared with 
reference scenario  
Key sectors in 2030:  
+0.3% Agriculture  
-2.5% Extraction and 
utility  
+0.6% Basic 
manufacturing  
+0.9% Engineering  
+2.4% Construction  
+0.5% Services  
(compared with reference 
scenario) 
EU additional building 
energy efficiency 
investment in 2030 is 
approximately €101bn  
Insulation industry market: 
growing market (approx. 
€15bn at EU level in 2030)  
Flat glass industry market: 
growing market (approx. 
€15bn at EU level in 2030) 

 
 
 
Qualitative 

redistribution of household spending to pay for 
investments. In the long run consumer spending 
increases due to energy savings (more money to 
spend on other goods and services).  
Inflation is lower in the scenario as economy move 
away from expensive energy product. 
Moderate improvement to EU energy security 

households 

Energy 
Independence 

Better energy performant buildings show shorter 
vacancy periods, have a lower loss of rental income 
due to changing tenants and, as such, show a more 
positive operating impact for the owner.  

Value of buildings 

The impact of this option in the value of buildings is 
in the higher of the scale. 

Quantitative 
+0.06% change compared 
with reference scenarios.  
Consumer price index -
0.88% change compared 
with reference scenario 

Share of EU total final 
energy used in GDP 
decreases by -0.7 pp by 
2030  
Share of energy imports in 
GDP decreases by -0.3 pp 
by 2030  
Higher end of the scale.  
Increased sale value of 
better performing 
buildings:  
- Service: +5.2% to +35%  
- Residential: 0% to +14%  
Increased rental value of 
better performing 
buildings:  
- Service: +2.5% - +11.8%  
- Residential: +1.4% - 
+5.2% 
Overall net burden would 
be slightly higher to the 
one estimated for the 
preferred option (policy 
option II). 

Administrative costs 

Social 

Employment 

Public health & 
safety 

Energy poverty 

This policy option would probably represent 
increased administrative costs for the public sector, 
in addition the preferred option. Some of these costs 
would still be cancelled out by the simplification 
measures introduced. Additional benefits could be 
generated for the private sector from the measure on 
harmonisation of the EPC templates. 

Employment impacts follow a similar pattern to 
GDP, albeit the impact is smaller in scale because 
wage and labour intensity of sectors benefitting from 
additional investment also have impacts on 
employment demand.  

EU28 total employment 
increases by +0.25%, 
(approximately 568 
thousand persons) 
compared with reference 
scenario in 2030 

Employment in energy and utilities sector falls due 
to reduction in energy demand. 
Mortality, morbidity and health care costs due to 
indoor climate are significantly reduced in this 
option. Similar results were found for the loss of 
productivity at work. 

Energy Poverty is predominant within old, non-
refurbished buildings. This policy package has a 
moderate impact in energy poverty alleviation.  

96 

€793m costs savings from 
lower mortality & €133m 
lower healthcare costs in 
2030  

€53m-€89m productivity 
gains (minimum-
maximum) 
Number of households that 
are lifted from energy 
poverty across the EU by 
2030 (Range Low-/High-
Impact-Scenario) based on 
3 indicators:  
- Arrears on utility bills": 
1,456,400 to 5,171,300  

 
 
  
  
  
Qualitative 

Environmental 
Climate change 

Fostering the 
efficient use of 
resources (renewable 
& non-renewable) 

Preserving the 
quality of natural 
resources 

Emissions of greenhouse gases follow from the 
results for primary fuel consumption. CO2 and 
greenhouse gas emissions in all Member States 
decreases in this option 

Higher final energy demand reduction in the 
buildings sector 

Small reduction in demand for water in power 
generation from reduction in electricity demand  
Increase in demand for raw materials from 
construction and other energy efficiency related-
products 

Quantitative 

- Presence of leak, damp, 
rot: 2,327,400 to 8,255,800  
- Ability to keep home 
adequately warm: 
1,748,400 to 6,203,800  
In a total of 10.8% of 
households (i.e. 23.3m) 
living in energy poverty 
(Eurostat SILC) 

CO2 and GHG emissions 
reductions in 2030 are <-
2.8% and <-2.2% 
respectively compared to 
reference scenario 
Building sector final 
energy consumption in 
2030, -25% difference 
from reference scenario (-
72 Mtoe) 
-2.8% reduction in water 
demand used in power 
generation from reference 
scenario in 2030  
Increase in domestic 
material consumption 
(+1.2% compared to 
reference scenario in 2030)  

97 

 
 
ANNEX 9 

ESTIMATION OF ADMINISTRATIVE COSTS  

The  estimation  of  the  administrative  costs  imposed  by  EU  legislation  was  conducted 
using the 'Standard Cost Model', in the sense that administrative burdens are calculated 
on the basis of the average cost of the required administrative activity (Price) multiplied 
by the total number of activities performed per year (Quantity).  

These  are  presented  in  detail  in  Table  17,  for  the  proposed  measures  of  the  preferred 
policy option, as also suggested by the Better Regulation guidelines. The savings induced 
by  simplification  measures  and  costs  of  Option  I  can  also  be  easily  derived  from  the 
table.  

The results of the exercise using the standard cost model for the preferred policy option 
show that, overall, there is a net reduction of the burden of €98.1 million per year. The 
burden on the private sector is reduced by €108.5 million per year, and there is a slight 
increase in the burden for the public sector of €10.4 million per year.  

A detailed explanation of the assumptions used, which can be seen as simplification of 
the complex reality of the Union. However, and to the extent possible, the assumptions 
are  in  line  with  the  step-by-step  application  of  the  model  as  in  the  specific  guidelines 
presented in Better Regulation TOOL #53. 

Simplification measures  

Remove the study of the feasibility of high-efficiency alternative systems  

This  is  a  simplification  measure,  which  eliminates  the  need  to  conduct  a  study  on  the 
feasibility  of  alternative  high  efficiency  alternative  systems  for  new  buildings  –  under 
Article 6 of the EPBD. The majority of Member States have implemented this provision. 
The burden to public administration (cost of compliance checking) can be considered to 
be included in the administrative costs related to the licensing procedure (i.e. issuing of 
the building permit). Therefore, no additional cost, in this case, saving, was included in 
the  calculation  of  the  administrative  burden  for the  public  sector.  However,  the  current 
cost for businesses and consumers need to be considered.  

Administrative cost-savings for the private sector:  

The  cost  of  the  feasibility  study  could  be  considered  to  be  equivalent  to  the  cost  of  an 
energy certificate = 1 €/m².  

Considering that the rate of new construction is around 1%99 per year this would create 
223 million m²of new floor area per year.  

Simplify regular inspections  

This  is  a  simplification  measure,  which  eliminates  the  need  that  Member  States  put  in 
place regular inspections schemes for heating and air conditioning systems, or equivalent 
alternative measures – under Articles 14-16 of the EPBD. Currently, 15 Member States 
chose to have regular inspection schemes for both heating and air conditioning systems 
(AT,  BE,  BG,  CY,  CZ,  ES,  GR,  HR,  IT,  LU,  LT,  PL,  RO,  SE  and  SK),  5  countries 

99 

This  is conservative  estimate; according  to Euroconstruct construction  activity will  increase  again 
from 2016 onwards, with growth of up to 3% per annum after 2018). 

98 

 
                                                 
decided to have regular inspections for air conditioning systems (DE, DK, FR, HU and 
UK),  and  the  remaining  Member  States  opted  for  alternative  measures.  Member  States 
interpreter differently the meaning of regular, and therefore a regular inspection in some 
countries happened every 3-5 years, and in others around 10 years. The burden to public 
administration  (cost  of  compliance  checking)  can  be  considered  to  be  included  in  the 
administrative costs related to the overall compliance checking of other provisions. As a 
result,  no  additional  cost,  in  this  case,  saving,  was  included  in  the  calculation  of  the 
administrative  burden  for  the  public  sector  regarding  this  simplification  measure. 
However, the current cost for businesses and consumers need to be considered.  

Administrative cost-savings for the private sector:  

For  calculation  purposes  it  is  assumed  that  these  obligations  would  only  affect  non-
domestic buildings because of the thresholds laid out in the Directive.  

The total number of non-domestic buildings in countries with inspections systems (listed 
above) is 13.5 million. It is also assumed that all these buildings will be inspected once 
(to  either  heating  or  air  conditioning  systems)  during  the  10  year  period  (2020-2030). 
The cost of inspections per building was reported by the CA EPBD to be in average 200€ 
for both types of inspections. Finally, a compliance rate of 50% is assumed. The costs of 
equivalent  measures  in  other  Member  States  are  not  known,  and  therefore  are  not 
included in the analysis. Overall, a conservative approach is followed to estimate burden 
reduction.  

Measures of the preferred policy option  

Measure 1:  Accelerate the decarbonisation of buildings by significantly increasing 
renovation rates  
Measure 1A:  Set milestones for the decarbonisation of buildings by 2050  

This measure is about building on the existing obligation to define long term renovation 
strategies  under  Article  4  of  the  Energy  Efficiency  Directive.  This  additional  measure 
addresses  public  administration  and  mainly  concerns  retrieving  information  and  study 
paths  towards  decarbonisation  of  national  building  stocks  (if  not  yet  available  from 
already existing Article 4 strategies).  

Administrative costs for the public sector:  

The  Commission  will  also  support  Member  States  in  preparing  the  updated  long-term 
renovation  roadmaps.  The  additional  costs  are  related  to  defining  clear  milestones  and 
measures  to  decarbonise  the  stock  by  2050.  Based  on  reported  costs  of  studies  by 
Member States, this cost can be estimated in 250,000 €/MS for all reporting in the period 
2020-2030.  Note  that  Commission  will  provide  additional  guidance,  which  may  also 
lower costs.  

99 

 
Measure 2:  Fine tune the implementation of minimum energy performance 
requirements  
Measure 2A:  Improve  transparency  of  calculation  methodologies  and  provide  further 
clarification on the cost-optimal setting of minimum performance requirements  

Administrative costs for the public sector:  

legislative  changes/adjustments  of  national 

Regarding  the  clarification  of  provisions  on  the  energy  performance  calculation 
methodologies,  the  proposed  measures  concern  a  request  to  review  methodologies  and 
links between different provisions. This requires an assessment of potential synergies in 
the  implementation  of  different  provisions  of  national  legislation,  to  make  it  more 
efficient.  This  is  a  task  for  the  central  administration  to  hold  meetings  (internal  or 
external with an auditor, lawyer, building experts, etc.) and potentially prepare proposals 
for 
implementation  measures.  The 
Commission  would  issue  additional  guidance  to  help  Member  States  pursuing  a  more 
efficient implementation by, for instance, linking EPCs with other provisions, ensuring a 
technological  neutral  approach  and  calibration  of  calculation  methodologies.  The  study 
on the evaluation of the national/regional calculation methodologies100, with a budget of 
150,000  EUR,  already  assessed  35  methodologies,  and  around  2/3  are  compliant.  The 
administrative costs associated to this measure are considered low (estimated in 50,000€ 
per country).  

Regarding the updates to the cost-optimal methodology, the measure proposes a change 
to the current guidelines in order to update minimum requirements faster and to be more 
forward looking in considering for instance nearly-zero energy buildings. However, the 
additional  cost  for  the  public  administration  is  negligible,  because  the  reporting 
obligations on cost-optimal already exist in the current EPBD. Accordingly, there is no 
additional administrative burden.  

The  measure  introduces  an  obligation  of  transparency  for  the  national  calculation 
methodologies,  i.e.  Member  States  have  to  conduct  a  self-assessment  of  their  current 
methodology  against  CEN/CENELEC  standard  framework.  This  assessment  should  be 
completed  within  the  obligation  to  report  on  the  cost-optimal  calculations  of  minimum 
energy performance requirements.  

This  assessment  is  to  be  conducted  by  the  central  administration  but  no  significant 
administrative  burden  is  expected.  However,  it  can  be  attributed  a  budget  of  50,000€ 
staff/study costs per Member State for assessing this issue.  

Finally, it can be said that improved calculation methodologies and anticipation of future 
cost-optimal  levels  can  have  additional  benefits  and  induce  cost-reductions  for  the 
building  sector  in  general.  However,  the  worst  case  scenario  was  considered,  and  the 
potential administrative burden reduction was not included in the calculations.  

100  

Technical assessment of national/regional calculation methodologies for the energy performance of 
buildings,  2015,  European  Commission  (written  by  CSTB/TSUS)  (Contract  ENER/C3/2013-
425/SI2.679523) 

100 

 
                                                 
Measure 3:  Modernisation using smart technologies and simplification of outdated 
provisions for the benefit of citizens  
Measure 3A:  Document initial performance of technical building systems  

This  measure  introduces  an  obligation  to  document  and  include  in  invoices  additional 
information  to  ensure  that  good  practice  in  technical  building  systems  installation  is 
followed.  Installers  should  anyway  conduct  an  initial  commissioning,  and  handover  to 
the  customer  all  relevant  documentation  when  installing  equipment.  This  measure 
protects customers by certifying that systems were installed and are working properly.  

The  costs  incurred  by  central  administration  concern  compliance  checking.  The 
administrative  costs  for  business  are  related  to  generate  invoices  that  certify  the  initial 
commissioning of technical building systems.  

Administrative costs for the public sector:  

The total  number of boilers, heat  pumps, solar systems and air conditioning systems in 
2014  was  estimated  at  5.8  million.  Considering  that  1%  per  year  of  invoices  related  to 
this  equipment  is  verified,  this  represents  58,000  invoices.  The  cost  of  compliance 
checking  could  be  contact  by  phone/email  the  customer  which  could  take  maximum  1 
hour. Therefore the individual verification costs would be 25 EUR.  

Administrative costs for the private sector:  

720,000  companies  registered  as  installation  of  electrical  wiring  and  fittings,  heating 
systems, plumbing, elevators and insulation can be affected by this measure. The actual 
initial  commissioning  should  be  done  anyway.  The  change  of  the  invoicing  system  to 
certify for the initial commissioning (adding a line to the invoice) could take 1 hour and 
cost in average 25€ per company every year.  

Measure 3B:  Framework for the introduction of a smartness indicator  

This measure implies the assessment of the smartness of buildings.  

For  the  cost  valuation,  it  is  assumed  that  the  smartness  is  systematically  included  on 
EPCs. This brings an additional administrative cost to the issuing of EPCs.  

The  public  administration  would  need  to  add  another  item/field  to  existing  EPC 
databases  on  the  smartness  indicator,  and  conduct  the  corresponding  compliance 
checking.  

However,  this  is  to  be  integrated  within  the  existing  certification  systems,  so  no 
additional  compliance  checking  costs  would  be  incurred.  Business  and  citizens  would 
need  to  pay  for  the  additional  costs  of  collecting  data  to  assess  the  smartness  of  the 
building.  

Administrative costs for the public sector:  

One-off cost of adapting the existing EPC database to include the indicator estimated in 
25,000€ per country.  

101 

 
Administrative costs for the private sector:  

The  additional  cost  of  assessing  the  smartness  of  the  building  is  estimated  to  be  20€ 
(10% of the average cost of EPCs, i.e. 15€ for residential and 100€ for non-residential). 
The number of EPCs issued between 2020 and 2030 was considered to be the same as the 
total  number  of  EPCs  issued  between  2005-2015  which  was  close  to  16  million,  so  on 
average about 1,6 million per year, of which the vast majority was issued for residential 
buildings (>95%).  

Measure 3C:  Support to electro-mobility  

The  proposed  measure  refers  to  the  introduction  of  requirements  to  pre-install  electric 
vehicle charging in all new buildings with more than 10 parking spaces. The cost of this 
measure  for  the  private  sector  is  already  accounted  for  in  the  estimate  for  investment 
needed for implementing this measure.  

Administrative costs-savings for the public sector:  

The cost of checking compliance with the requirements introduced for a total number of 
charging  points,  which  is  10%  of  the  total  number  of  parking  spaces  created  between 
2020  and  2030,  i.e.  436,000.  Before  construction,  compliance  checking  consists  in 
ensuring that the design of the electric system includes the pre-installation for charging of 
electric vehicles.  

The  additional  burden  could  be  estimated  in  1  hour  (25  EUR).  Compliance  after 
construction could be checked together with the production of the EPC, and in particular 
the  smartness  indicator.  The  cost  can  be  considered  to  be  included  in  the  transactional 
cost of the measure above.  

Measure 4:  Enhance financial support and information to users through reinforced 
energy performance certificates  
Measure 4A:  Reinforced quality of energy performance certificates to enhance financial 
support  

EPC quality and data availability: This policy measure aims at building on current best 
practices  on  EPC  databases,  in  particular  define  a  list  of  minimum  information  and 
features to be included in the databases and improving and clarifying existing obligations 
on  EPCs.  This  requirement  would  only  affect  some  Member  States  (with  less  robust 
databases),  and  might  imply  some  costs  to  the  authorities  managing  the  central  EPC 
databases in these countries.  

Administrative costs for the public sector:  

According  to  the  study  on  the  EPC,  around  18  Member  States  would  need  to  improve 
their  databases  and  allow  for  public  access  (with  adequate  data  protection  policy).  The 
average annual cost of maintaining EPC database reported by the CA EPBD is between 
150,000 and 350,000 EUR. We considered that this update would cost the average annual 
cost of running EPC databases, 250,000 EUR.  

Linking  public  financing  and  building  renovation  projects:  This  proposal  allows 
aligning  public  financial  support  with  the  energy  savings  targeted  by  the  building 
renovation project (the deeper the renovation, the higher the intensity of public support). 
As  it  is  generally  the  case,  EPCs  before  renovation  is  already  needed  to  receive  public 

102 

 
support.  After  renovation,  the  EPC  would  be  updated  to  track  the  achieved  energy 
savings. It would give an input to the usual monitoring of public financial support for this 
kind of projects.  

Administrative costs for the private sector:  

Considering  a  renovation  rate  of  1%,  about  223  million  m²of  building  floor  area  are 
renovated each year. The cost of an EPC, as reported by the CA EPBD is about 1 €/m². 
The cost for its update is considered to be 50% of the first issue, i.e. a total cost incurred 
of 1.5 €/m².  

Monitoring and disclosure of actual energy consumption: This measure introduces an 
obligation  for  disclosure  of  energy  consumption  information  in  public  buildings.  This 
measure brings administrative costs to central and local administration.  

Public  administrations  have  to  set-up  or  to  adapt  an  existing  central  EPC  buildings 
database to collect, store and process building energy consumption data, and be used as a 
platform to disclosure.  

Administrative costs for the public sector:  

Costs per country are 250,000€ for the inclusion of a disclosure facility in the database 
plus an annual running cost of 25,000€ in addition to the running costs of existing EPC 
databases, i.e. an annual average of 50,000€ per MS.  

The number of public buildings in the scope of the measure is estimated at 500,000. The 
cost of annual disclosure of data was considered to be 10€ per building and per year.  

Table 17 summarises the administrative costs for the public and the private sectors.  

103 

 
 
 
Table 17: Estimation of the administrative costs for each policy measure –option II 
(preferred option)  

104 

STANDARD COST MODELDESCRIPTION OF ADDITIONAL COSTS = ADMINISTRATIVE BURDENPRICE (€/unit)QUANTITY(units)TOTAL (M€/y)PRICE (€/unit)QUANTITY(units)TOTAL (M€/y)TOTAL (M€/y)SIMPLIFICATION MEASURESRemove the study of the feasibility of high-efficiency alternative systems-1 €/m²223 million m2 floor area-223.00-223.0Simplify regular inspections and ensure that their objective is achieved more effectively-200 €/inspect.1.35 million inspections-270.00-270.0PREFERRED OPTIONA. Set milestones for the decarbonisation of the building stock by 2050250,000 €/MS28 MS0.70.7A. Improve transparency of calculation methodologies and provide further clarification on the cost-optimal setting of minimum performance requirements2 x 50,000 €/MS28 MS0.30.3A. Ensure initial performance of technical systems with the documentation of oinitial performance25€/check58,000 invoices checked1.519.5B. Framework for the introduction of a smartness indicator50,000 €/MS28 MS0.132.1C. Support to electro-mobility25€/check43,600 parking space checked1.11.1A. Reinforced quality of energy performance certificates to enhance financial supportEPC quality and data availability250,000/MS18 MS0.50.5Linking public financing and building renovation projects1.5 €/m²223 million m2 floor area renovated334.5334.550,000/MS28MS1.41.410500,000 public buildings5.05.0TOTAL-108.510.4-98.1The implication of the measure which facilitate the instruction and monitoring of request for public support has been neglectedDisclosure of actual energy consumptionsVoluntary25€/installer20€/EPCPotential transaction costs to the private sector associated to this measure were considered to be included in the investment costs This measure was not considered to generate administrative burden for the private sectorMeasure 1. Accelerate the decarbonisation of buildings by significantly increasing renovation ratesMeasure 2. Fine tune the implementation of minimum energy performance requirementsMeasure 3. Modernisation using smart technologies and simplification of outdated provisions for the benefit of citizensMeasure 4.  Enhance financial support and information to users through reinforced energy performance certificatesBusinesses & consumersCentral AdministrationThe burden to public administration can be considered to be included in the administrative costs related to new buildings licensing procedure. No savings were considered.The burden to public administration can be considered to be included in the overall compliance checking of other provisions. No savings were considered.This measure was considered not to have direct transaction costs for the private sector.This measure does not produce direct transaction costs for the private sector. 
  
ANNEX 10 

INVESTMENTS IN ENERGY EFFICIENT BUILDINGS  

Most  energy  efficiency  projects  require  the  mobilisation  of  up-front  capital  in  order  to 
benefit from lower operating costs in the future. At EU level, current capital expenditure 
related to building envelope measures and HVAC-systems in Europe can be estimated at 
around  €120  billion  per  year101.  This  estimated  volume  of  yearly  spending  does  not 
represent  the  incremental  energy  efficiency  investment  costs  but  more  broadly  the 
construction activity associated with heating, cooling or ventilation. In addition, it has to 
be considered in the context of the overall EU construction sector, which represented a 
yearly turnover of around €1.2 trillion in 2011.  

Most of these investments are funded by the private finance in the form of: savings from 
households, equity from companies, commercial debt originated from consumer by retail 
banks, or corporate loans from financial institutions.  

In  Europe,  investments  into  dwellings  cover  about  a  quarter  of  total  investments  in  the 
EU-28 and around 5% of the EU-28 GDP, with some large discrepancies between some 
EU  Member  States102.  In  2014,  the  investment-to-GDP  ratio  related  to  the  residential 
sector  ranged  between  6.4%  in  Germany  and  2.6%  in  Latvia  and  Sweden  (Figure  15). 
Households contribute the most to the overall investment in the group of countries which 
were neither severely hit by the financial crisis.  

Figure  15:  Investment-to-GDP  ratio  by  countries  –  2014  (Source:  Eurostat,  own 
calculation)  

Dwellings represent around 90% of total investment by households. In most cases, it can 
be assumed that these investments have as one of their impacts an increase in the energy 
efficiency  of  the  building  stock.  This  assumption  is  supported  by  graph  below,  which 
shows a correlation between the share of residential investment and the energy intensity 
of households (Figure 16; points represent Member States).  

101 
102 

As modelled with BEAM² 
Investment in energy efficiency by households, note to the Economic Policy Committee Energy and 
Climate Change Working Group (19 April 2016), DG ECFIN 

105 

 
  
 
 
                                                 
Figure  16:  HH  Energy  intensity  growth  (HDD  adj.)  vs.  growth  of  share  of  total 
residential investment in total investment, 2000-2013 (Source: DG ECFIN)  

The  importance  of  private  financing  for  energy  efficiency  related  investments  in 
buildings  is  also  shown  by  national  studies.  In  France  for  instance,  in  2013103,  around 
50% of the "climate investments"104 in buildings were coming from savings and equity, 
30% from commercial debt, 10% from concessional debt, and around 10% from public 
subsidies.  In  Germany,  in  2011,  corporations  and  households  were  the  most  important 
investors  in  climate-specific  finance,  largely  based  on  concessionary  loans  from  public 
banks and commercial loans acquired on the capital markets105.  

103 

104 

105 

http://www.i4ce.org/wp-core/wp-content/uploads/2015/12/I4CE-Panorama-des-financements-
climat-rapport-complet-2015.pdf 
3%  for  Renewable  Energy  Sources  in  buildings,  65%  for  building  renovations,31%  for  new 
buildings 
http://climatepolicyinitiative.org/wp-content/uploads/2012/11/Landscape-of-Climate-Finance-in-
Germany-Full-Report.pdf 

106 

-80-60-40-200204060-30-20-1001020Energy Intensity HDD adj. (pct change)Share of residential investment (pp change) 
  
                                                 
ANNEX 11  CHARACTERISTICS OF THE EU BUILDING STOCK  

The following chart presents the wide range of energy consumption per m² of residential 
buildings across the EU-28. The graph clearly shows that countries with similar climate 
can have very different energy consumption, which further supports the fact that there is 
a large untapped cost-effective energy saving potential.  

Figure  17:  Energy  consumption  of  residential  buildings  per  m²  in  2014  -  climate 
corrected (Source: Eurostat / EU Building Stock Observatory)  

The analysis of the age of the EU Building Stock indicates that the majority of buildings 
in use today were built before most Member States had building codes.  

Figure  18:  Residential  buildings  by  construction  year  (Source:  EU  Building  Stock 
Observatory)  

107 

 
  
  
The  EU  building  stock  is  quite  heterogeneous.  Across  all  countries  the  majority  of  the 
floor area is composed by residential buildings, but the share varies considerably, going 
from 60% in Lithuania, Romania or Estonia to 90% in Greece, Malta or Portugal.  

Figure  19:  Breakdown  of  building  floor  area  (Source:  EU  Building  Stock 
Observatory)  

The type of buildings differs significantly across the EU. In the UK or in Ireland, single-
family  houses  are  dominant  (above  80%),  while  in  Spain  or  in  Estonia,  multi-family 
buildings represent more than 70% of all dwellings. If we look at the EU average, there is 
almost  an  equal  share  of  both  types  of  dwellings,  with  an  average  of  49%  for  multi-
family dwellings.  

Figure 20: Breakdown per type of residential building (Source: EU Building Stock 
Observatory)  

108 

 
  
  
Energy Performance Certificates provide valuable information on building performance 
to inform consumers' when renting/buying a house. Without prejudging the quality of the 
certificates, the number of buildings with energy performance certificates is increasing, 
with UK, Ireland and Netherlands leading in the number of certificates issued relatively 
to the total number of residential buildings, as presented in the chart below.  

Figure  21:  Share  of  residential  buildings  with  energy  performance  certificate  in 
2014 (Source: EU Building Stock Observatory)  

Figure 22: Number of NZEBs in new construction of residential buildings in 2014106 
(EU Building Stock Observatory)  

106 

Noting that the deadline for the obligation for all (non-public) new residential buildings to be NZEB 
is late 2020. This chart shows that a few countries are gradually anticipating this new standard. 

109 

 
  
  
                                                 
In  some  countries  the  rate  at  which  people  and  businesses  choose  to  upgrade  their 
buildings  is  above  1%,  as  shown  in  the  graph  below  for  Austria,  France,  Germany, 
Slovakia, Czech Republic and Lithuania.  

Figure 23: Building energy renovations in 2014 - countries participating in ZEBRA 
project (http://zebra2020.eu / EU Building Stock Observatory)  

110 

 
  
ANNEX 12  STATE OF DEVELOPMENT OF EPC DATABASES  

Table 18: EPC databases development and data availability at Member State level 

Country  Status  Scope 

Public availability 

AT 

BE 

BG 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LV 

LT 

NL 

NO 

PL 

PT 

RO 

SK 

SI 

SE 

UK 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

regional/central 

Access for some organisations 

Regional 

Central 

Central 

Central 

Central 

Central 

Depends on Region 

No public access 

under development 

No public access 

Public access with protected privacy 

Public access with protected privacy 

No public access 

Regional 

Depends on Region 

Central 

Central 

Central 

Central 

Central 

No public access 

Access for some organisations 

No public access 

Access for some organisations 

Public access with protected privacy 

Regional 

Depends on Region 

under development 

Central 

Central 

Central 

Central 

Central 

Central 

Central 

Central 

Central 

Public access with protected privacy 

Public access with protected privacy 

Public access with protected privacy 

No public access 

Public access with protected privacy 

No public access 

Public access with protected privacy 

Access for some organisations 

Public access with protected privacy 

Regional 

Public access with protected privacy 

111 

 
ANNEX 13  THE EU BUILDING STOCK OBSERVATORY  

The present annex lists the indicators of the EU Building Stock Observatory.  

Building Stock  

Building Stock  

  Share of buildings by type in total stock  

  Share of buildings by occupancy in total stock  

  Share of buildings by construction period in total stock  

  Share of buildings by ownership in total stock  

  Share of buildings by localisation in total stock  

  Share of buildings by size in total stock  

  Average floor area  

  Share of demolished building in total stock  

  Share of rented out building in total stock  

  Share of transactions in total stock  

Annual construction  

  Share of new dwellings in total stock  

  Average size of new dwellings  

  Building permits - number of total buildings  

  Building permits - m²of useful area  

Renovation  

  Share of renovated buildings in stock and/or floor area  

  Share of renovated buildings by level (light, deep, major renovation)  

NZEB  

  Share of NZEB in new construction  

  Share of nZEB in renovation  

Energy performance  

  Average energy performance level reached by the energy renovation and after the 

renovation  

  Average  energy  savings  achieved  by  the  energy  renovation  and  after  teh  energy 

renovation  

  Average energy performance of new construction  

  Average energy performance of nZEBs  

112 

 
Energy consumption  

Building Stock  

  Share of Final energy consumption by energy  

  Share of final energy by end-uses and energy  

  Share of final energy consumption by construction period  

  Share of heating energy consumption by construction year  

  Unit Energy consumption by type of building  

  Unit Energy consumption by end-uses  

  Unit Energy consumption by period construction  

Fuel mix  

Energy production  

  Electricity production by source  

  Heat production by source  

  %heat generated by waste  

  %heat generated by geothermal  

Building characteristics  

Building enveloppe  

  Air tightness of the building envelope by construction period and on the average  

  U-value of the building envelope by construction period and on the average  

  U-value of doors by construction period and on the average  

  U-value of external walls by construction period and on the average  

  U-value of floors by construction period and on the average  

  U-value of roofs by construction period and on the average  

  U-value of skylights by construction period and on the average  

  U-value of windows by construction period and on the average  

  Type of glazing by dwelling type and on the average for all dwellings  

  Type of glazing for non-residential buildings on the average  

  Type of window frame by dwelling type and on the average for all dwellings  

  Type of window frame for non-residential buildings on the average  

Technical system  

  On-site energy generation by technology used  

  Average conversion efficiency rate by on-site energy generation technology used  

  Space  heating  system  by  coverage  (central  and  local),  by  device  capacity,  by 

system level (individual and collective) and by centralisation (local, central)  

  Single or multifamily dwellings with central steam/hot water space heating  

113 

 
  Types of boilers  

  Average and BAT efficiency rate of boilers by type  

  Dwellings with built-in electric system  

  Dwelling with heat pumps by type  

  Average and BAT efficiency rate of heat pumps  

  Dwellings with solar heating system  

  Dwellings with a stove or fireplace  

  Dwellings with other heaters  

  Number of dwellings by fuel for heating  

  Age of the main heating system  

  Number of dwellings byspace cooling system type  

  Average and BAT efficiency rate of space cooling equipment  

  Age of cooling system  

  Number of dwellings with water heater/boiler  

  Tank size and age  

  Number of dwellings by type of the DHW technology  

  Number of dwellings by fuel used for the DHW technology  

  Average and BAT efficiency rate of water heating equipment  

  Number of dwellings by type of ventilation  

  Average and BAT efficiency rate of the heat recovery equipment  

  Share of lamps in a dwelling by lamp type  

  Average number of lamps in a dwelling by lamp type  

  Number of dwellings with cooking equipment by type  

  Average number of appliances (white goods, TV and computers) in a dwelling  

  Single or multifamily dwellings with shading devices  

  Single or multifamily dwellings with PV-panels  

Metering  

  Average number of thermostats in a dwelling by thermostat type  

  Number of smart metering systems and feedback systems  

 

Individual or collective metering  

Embodied energy  

  Amount of embodied energy for new construction, deep and major renovation  

114 

 
 
 
Certification  

  Share of buildings with EPC  

  Share of buildings by label (of which label A)  

  EPC distribution related to size of dwelling (<50 m², 51-100 m²etc)  

  Share of EPC displayed publicly in public buildings by label  

  Average building value by label  

  Average building rent value by label  

  Share of buildings rented out where EPCs were handed out  

  Effect of one letter improvement on property value by label  

  Effect of one letter improvement on rent price by label  

  Share of building with EPCs for which quality was controlled last year (by option 

type)  

  Share of building with voluntary certificates by type (Not EPCs)  

Financing  

  Total  volume  of  investments  renovation  per  building  type,  by  type  of  renovation 

and type of financial scheme  

  Total volume of energy related investments in renovation per building type, by type 

of renovation  

  Average  volume of total investments for renovation per  building  type, by type of 

renovation  

  Average volume of energy related investments for renovation per building type, by 

type of renovation  

  Average  volume  of  additional  energy  related  investments  for  renovation  per 

building type, by type of renovation  

  Average energy cost savings per retrofit per building type, by type of renovation  

  Average energy prices per building type and for energy carrier  

Energy poverty  

  Population at risk of poverty or social exclusion -% of the population  

  Proportion of inhabitants unable to keep home adequately warm  

  Proportion  of  inhabitants  who  are  living  in  a  dwelling  not  comfortably  cool  in 

summer  

  Share of households expenditures on housing (housing, water, electricity, gas and 

other housing fuels)  

  Arrears on utility bills  

  Population living in a dwelling with leaking roof or damp walls, etc.  

  Average  energy  spending  for  adequate  space  heating  per  household  (theoretical 

energy demand)  

115 

 
  Disposable  household  income  before  and  after  energy  expenditure  for  adequate 

space heating (theoretical energy demand)  

  Proportion  of  disposable  household  income  spent  on  adequate  energy  for  space 

heating (theoretical energy demand)  

  Share of households  falling below the poverty  line after covering  the energy cost 

for adequate space heating (theoretical energy demand)  

  Excess winter mortality/deaths  

  Share  of  total  population  living  in  a  dwelling  with  a  leaking  roof,  damp  walls, 

floors or foundation, or rot in window frames of floor  

  Share of population living in a dwelling not comfortably cool during summer time 

by income quintile and degree of urbanisation  

  Share of population having moved to other dwelling within the last five year period 

by tenure status and degree of urbanisation  

116 

 
 
ANNEX 14  ADDENDUM - UPDATED INFORMATION REGARDING THE MEASURE 

SUPPORTING ELECTRO-MOBILITY AND THE INSTALLATION OF SMART 
CHARGING POINTS 

The  impact  assessment  refers  to  the  introduction  of  requirements  to  pre-install  electric 
vehicle charging in buildings with more than 10 parking spaces. Although this measure 
would  have  ensured  the  potential  installation  of  the  sufficient  number  of  recharging 
points,  it  would  not  lead  immediately  to  the  required  infrastructure  deployment  that 
would enable a market shift towards electric vehicles.  

This addendum explores the alternative measure consisting of the full installation of the 
required number of recharging points. It provides new evidence regarding the support to 
electro-mobility, and justifies the related provisions included in the EPBD legal proposal. 

Context 

As  described  in  the  Impact  Assessment,  energy  efficiency  in  transport,  in  particular 
efficient vehicles and incentives for behavioural change are also required to move from 
2020 to 2050 low carbon goals. The electrification of transport is of pivotal importance 
for  decarbonising  the  sector  and  raising  the  share  of  renewable  energy  therein.  The 
impact  of  electric  vehicles  will  be  important  in  this  regard.  EU  legislation  already 
supports  deployment  of  public  infrastructure  via  Directive  2014/94/EU  on  the 
deployment of alternative fuels infrastructure, and monitors developments  inter alia via 
the European Alternative fuels Observatory107.  

The  projected  deployment  of  electric  vehicles  in  2030  will  amount  to  approximately 
10%,  and  concentrated  mainly  in  cities.  An  EU  intervention  in  this  field  is  necessary 
since Member States do not have the instruments to achieve pan-European coordination 
in terms of technical specifications of infrastructure and timing of investments. Vehicle 
parking  spaces,  mostly  within  buildings  are  central  to  any  overarching  policy  for  the 
promotion of electro-mobility.  

In the Energy legislative package of 2016, electro-mobility would be supported through a 
number of legislative measures across different texts:  

a) EPBD review addresses infrastructure deficit; 

b)  Electricity Market Design – promote charging when the cost of electricity is lower for 
consumers;  

c)    Renewable  Energy  Directive  review  –  incentives  the  use  of  RES  electricity  in  the 
transport sector. 

The  Renewable  energy  directive  includes  electricity  within  the  transport  mandate, 
without any cap. Thus electric mobility will be incentivised as part of the RES regime. 

Current situation 

In  2013,  the  European  Commission  proposed  the  setting  of  a  2020  target  to  make  sure 
that  sufficient  recharging  stations  are  in  place  to  allow  electric  cars to  ensure  EU  wide 

107 

www.eafo.eu  

117 

 
 
                                                 
travel  with  a  focus  on  densely  populated  areas.  Impact  assessment  for  this  proposal 
concluded  that  this  minimum  number  of  recharging  stations  should  be,  for  all  the  EU, 
8,000,000 of which 7,200,000 non publically accessible108. 

The adopted Directive 2014/94/EU reads as follows: 

  Recital  23:  "Member  States  should  ensure  that  recharging  points  accessible  to  the 
public  are  built  up  with  adequate  coverage,  in  order  to  enable  electric  vehicles  to 
circulate  at  least  in  urban/suburban  agglomerations  and  other  densely  populated 
areas, and, where appropriate, within networks determined by the Member States. The 
number  of  such  recharging  points  should  be  established  taking  into  account  the 
number  of  electric  vehicles  estimated  to  be  registered  by  the  end  of  2020  in  each 
Member State. As an indication, the appropriate average number of recharging points 
should  be  equivalent  to  at  least  one  recharging  point  per  10  cars,  also  taking  into 
consideration the type of cars, charging technology and available private recharging 
points."  

  Article  4(1):  "Member  States  shall  ensure,  by  means  of  their  national  policy 
frameworks, that an appropriate number of recharging points accessible to the public 
are put in place by 31 December 2020, in order to ensure that electric vehicles can 
circulate  at  least  in  urban/suburban  agglomerations  and  other  densely  populated 
areas, and, where appropriate, within networks determined by the Member States." 

  Article  4(2):  "The  Commission  shall  assess  the  application  of  the  requirements  in 
paragraph  1 and, as  appropriate, submit a proposal to  amend this Directive, taking 
into  account  the  development  of  the  market  for  electric  vehicles,  in  order  to  ensure 
that  an  additional  number  of  recharging  points  accessible  to  the  public  are  put  in 
place  in  each  Member  State  by  31  December  2025,  at  least  on  the  TEN-T  Core 
Network, in urban/suburban agglomerations and other densely populated areas."  

  Article  4(2):  "Member  States  shall  also  take  measures  within  their  national  policy 
frameworks  to  encourage  and  facilitate  the  deployment  of  recharging  points  not 
accessible to the public." 

Moreover, the Directive 2014/94/EU makes it mandatory to use a common connector109 
all across the EU, which will allow EU-wide mobility.  

The proposal 

While  the  existing  legislation  only  mandates  public  accessible  recharging  points,  an 
estimated  90%  of  recharging110  takes  place  in  areas  that  are  not  publicly  accessible.  In 
order to address this regulatory gap in transport policy, installation of recharging points 
in private parking spaces, typically inside or flanked to buildings, is essential to support 
the  market  of  electric  vehicles,  complementing  the  Directive  2014/94/EU.  In  multi-
apartment blocks and non-residential buildings, the freedom to install recharging points 
is limited by the necessity to get an agreement from the other co-owners to intervene on 
the  building  infrastructure  or  to  cross  private  spaces.  Following  the  example  of  the 

108 

Commission Staff Working Document – Impact Assessment accompanying the document Proposal 
for a Directive on the deployment of alternative fuels infrastructure; SWD(2013)06 final 

109 Above 3.7KW for private recharging points 

110 

Ibid; SWD(2013)05 final 

118 

 
                                                 
measures  adopted  e.g.  in  France111  or  in  Spain112,  the  construction  and  the  major 
renovation of buildings are a special opportunities to install recharging points, or at least 
facilitate their later installation. The purpose of this Annex is to present the assumption 
and  the  estimate  of  the  impacts  of  the  provision  on  electro-mobility  introduced  in  the 
EPBD legal proposal. 

Estimation of the number of parking space in Europe 

Table 1 reflects the space floor area development by building categories in the preferred 
option. 

Table 19: Floor Area (per building type) in million square meters (source: BEAM²) 

Building category 

Single family house 

Small multi-appartment (<10 flats) 

Large multi-appartment (>10 flats) 

Offices 

Trade 

Education 

Touristic 

Health 

Others 

2023 

12,193 

5,705 

2,586 

1,882 

1,860 

1,266 

794 

671 

1,034 

2030 

12,619 

5,898 

2,677 

1,971 

1,947 

1,326 

831 

704 

1,083 

Assuming  that  the  measure  starts  applying  as  of  1  January  2023,  this  provides  an 
estimate of new construction during the application period. 

To  convert  these  values  in  a  number  of  parking  spaces,  additional  assumption  must  be 
taken as regard a number of parking spaces per unit of floor area. For this purpose, we 
assumed: 

  1.25 space/100m² (1 parking space per household of 80m² on average); 

  1.00 space/100m² in non-residential buildings. 

As  the  measure  applies  for  buildings  with  parking  areas  with  more  than  10  parking 
spaces,  assumptions  must  be  taken  in  this  respect.  For  residential  buildings,  the 
distribution  comes  straight  forwardly  from  the  residential  buildings  sub  categories  of 
buildings.  For  non-residential,  assumptions  in  Table  2  were  established  based  on  the 
reference building cases taken for each sub-category. E.g. the representative building for 

111   Decree  2011/273  of  25  July  2011  established  obligations  regarding  the  equipment  of  new  and 

112  

existing buildings. 
Royal Decree 1053/2014, of 12 December 2014 set an obligation: to prepare all new buildings for 
charging  points  with  the  electric  pre-installation;  and  to  equip  with  one  charging  point  every  40 
parking sites in new public buildings. 

119 

 
                                                 
"Education and Health" is well above 1,000m² and therefore is assumed a higher share of 
such buildings being above 10 parking spaces.  

Average renovation rates were also assumed to observe what share of the 2023 existing 
stock  would  be  covered  by  the  application  to  the  major  renovation  clause.  These  are 
given in Table 2. 

Table 20: Additional assumptions 

Number of parking space 
for 100m² 

Share of 
buildings with 
more than 10 
parking space 

Average major 
renovation 
rate 

Single family house 

Small multi-appartment (<10 
flats) 

Large multi-appartment (>10 
flats) 

Offices 

Trade 

Education 

Touristic 

Health 

Others 

1.25 

1.25 

1.25 

1.00 

1.00 

1.00 

1.00 

1.00 

1.00 

0% 

0% 

0.50% 

0.50% 

100% 

0.75% 

50% 

50% 

75% 

50% 

75% 

50% 

1.25% 

1.25% 

1.00% 

1.00% 

1.00% 

1.00% 

This  set  of  assumptions  allows  the  determination  of  the  number  of  parking  space  for 
different cases as reflected in Table 3. Between 2023 and 2030: 
  12.4  million  new  parking  spaces  would  be  constructed  (3.1  million  in  parking  areas 

with more than 10 parking spaces), 

  15.8  million  parking  spaces  would  be  located  in  building  that  undergo  a  major 

renovation (5.1 million in parking areas with more than 10 parking spaces), 

  315.3 million parking spaces would remain unchanged. 

120 

 
 
 
 
Table 21: Number of parking spaces (in million units) by cases 

In buildings with 
less than 
10parking 
spaces 

In buildings with 
more than 
10parking 
spaces 

9.3 

10.7 

245.8 

265.7 

3.1 

5.1 

69.6 

77.8 

All 

12.4 

15.8 

315.3 

343.5 

In 2023-2030 new 

2023-2030 

In 
(major) 

renovated 

In others 

Total 

Estimation of costs 

The  total  CAPEX  of  a  Type2  smart  22kVA  charging  point  can  be  estimated  around 
€2,500/unit.  This  cost  includes  the  full  installation  (cabling  and  charging  point  itself) 
assuming  simple  configurations  (no  structural  work,  i.e.  no  drilling  of  walls  or  slabs). 
This cost also considers indoor recharging points (outdoor recharging points are typically 
more expensive). 

For example, if the requirement to install charging points is limited to new buildings and 
major renovations this would mean the installation of only 810,000 charging points, and 
a total cost of around €2 billion. 

However,  to  meet  the  number  of  charging  points  proposed  by  the  Commission  in  the 
2013  the  impact  assessment  of  Directive  2014/94/EU,  this  would  mean  having  1 
charging  point  for  every  10  parking  space  (of  the  existing  77.8  million  parking  space 
located in buildings with more than 10 parking spaces). This would trigger a maximum 
of 7,780,000 non-publically accessible recharging points, and would represent a cost of 
€19.5 billion.  

121