Annexes to the study 'Lessons learned to inform integrated approaches for the renovation and modernisation of the built environment'.
Date: 2021-06-02
Institutions: Directorate-General for Energy
Subjects: building industry, digital technology, energy efficiency, energy production, financing, improvement of housing, reduction of gas emissions, smart technology, sustainable development, town planning

Annexes to the study 'Lessons 
learned to inform integrated 
approaches for the renovation 
and modernisation of the built 
environment' 

ENER/C3/2019-468/03 

Written by:  
Buildings Performance Institute Europe ASBL (BPIE), 
CLIMACT SA,  
Creara Consultores SL, and  
Ecologic Institute 

December 2020 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Energy 
Directorate B — Just Transition, Consumers, Energy Efficiency and Innovation 
Unit B.3: Buildings and Products 

Contact: B.3 

E-mail:  ENER-BUILDINGS@ec.europa.eu   

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Annexes to the study 
'Lessons learned to inform 
integrated approaches for the 
renovation and 
modernisation of the built 
environment' 

ENER/C3/2019-468/03 

2021 

Directorate-General for Energy 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Luxembourg: Publications Office of the European Union, 2021 

ISBN 978-92-76-36355-2 
doi: 10.2833/177071 

© European Union, 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Lessons learned to inform integrated approaches for the modernisation and renovation of 
the built environment 

LIST OF ANNEXES 

ANNEX I – Scoping and key challenges 

ANNEX II – Strategic area factsheets 

ANNEX III – Good practices 

ANNEX IV – Report on MMR 

 
 
 
 
Lessons learned to inform 
integrated approaches for the 
renovation and modernisation 
of the built environment 

Annex I: Scoping and key challenges 

ENER/C3/2019-468/03 

Written by:  
Buildings Performance Institute Europe ASBL (BPIE), 
CLIMACT SA,  
Creara Consultores SL, and  
Ecologic Institute 

December 2020 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

CONTENTS 

ACTIVITY 1.1.: SCREENING OF AREAS ............................................................................. 1 

1. Introduction and methodology ............................................................................. 1 

2. Screening of areas ............................................................................................. 1 

2.1. European Green Deal .............................................................................. 2 

2.2 The Sustainable Europe Investment Plan .................................................... 3 

2.3 Circular Economy Action Plan .................................................................... 4 

2.4 A New Industrial Strategy for Europe ......................................................... 4 

2.5 Shaping Europe's digital future ................................................................. 5 

2.6 Commission Recommendation on building modernisation ............................. 6 

3. Addressing gaps ................................................................................................. 6 

4. Conclusions ....................................................................................................... 7 

ACTIVITY 1.2: STRATEGIC AREAS: SCOPE CLARIFICATION ................................................ 8 

1. Introduction and methodology ............................................................................. 8 

2. Clarifying the scope of each strategic area............................................................. 8 

2.1 Clean and sustainable mobility .................................................................. 8 

2.2 Digital technology ................................................................................... 9 

2.3 District approaches ................................................................................ 11 

2.4 Engaging transformation and phasing out inefficient buildings .................... 12 

2.5. Financing renovation ............................................................................ 13 

2.6 Built environment sustainability and adaptation to climate change .............. 14 

2.7 Health and well-being ............................................................................ 15 

3. Interactions between strategic areas .................................................................. 16 

ACTIVITY 1.3: KEY EU CHALLENGES .............................................................................. 20 

1. Introduction and methodology ........................................................................... 20 

2. Key EU challenges ............................................................................................ 20 

2.1 Key EU challenges in the ‘Clean and sustainable mobility’ strategic area ...... 20 

2.2 Key EU challenges in the ‘Digital technology’ strategic area ........................ 25 

2.3 Key EU challenges in the ‘District approaches’ strategic area ...................... 32 

2.4 Key EU challenges in the ‘Engaging transformation and phasing out inefficient 

buildings’ strategic area .................................................................. 36 

2.5 Key EU challenges in the ‘Financing renovation’ strategic area .................... 42 

2.6 Key EU challenges in the ‘Built environment sustainability and adaptation to 

climate change’ strategic area ......................................................... 50 

2.7 Key EU challenges in the ‘Health and well-being’ strategic area ................... 58 

BIBLIOGRAPHY ........................................................................................................... 62 

 
 
 
 
 
 
Annex I: Scoping and key challenges 

LIST OF TABLES 

Table 1: EGD’s relevant priority areas and how they are addressed in the project ....................... 3 

Table 2: SEIP’s relevant priority areas and how they are addressed in the project ....................... 4 

Table 3: CEAP’s relevant priority areas and how they are addressed in the project ...................... 4 

Table 4: New Industrial Strategy’s relevant priority areas and how they are addressed in the project
 ................................................................................................................................. 5 

Table 5: Shaping Europe’s digital future’s relevant priority areas and how they are addressed in the 
project........................................................................................................................ 6 

Table 6: Second Commission Recommendation on EPBD implementation’s relevant priority areas and 
how they are addressed in the project ............................................................................ 6 

Table 7: Key interactions between strategic areas .................................................................. 19 

Table 8: Summary of key barriers and success factors for ‘Creating sustainable city layouts’ ....... 22 

Table 9: Summary of key barriers and success factors for the EU challenge “Making buildings ready 
for e-mobility ............................................................................................................. 23 

Table 10: Summary of key barriers and success factors for ‘Increasing joint investment in buildings 
and mobility’ .............................................................................................................. 24 

Table  11:  Summary  of  key  barriers  and  success  factors  for  the  EU  challenge  `Unleashing  the 
flexibility potential of energy uses via digitalized energy-consuming appliances and services´
 ................................................................................................................................ 27 

Table 12: Summary of key barriers and success factors for ‘Mainstreaming optimal energy uses via 
digitalized energy-consuming appliances and services’..................................................... 29 

Table 13: Summary of key barriers and success factors for ‘Digitalize the buildings renovation supply 
chain’ ........................................................................................................................ 30 

Table 14: Summary of key barriers and success factors for ‘Digitalize data collection of information 
about the building stock across Europe’ ......................................................................... 31 

Table  15:  Summary  of  key  barriers  and  success  factors  for  ‘Develop  integrated  approaches 
maximizing the synergies between energy efficiency and renewable energy at the district level’
 ................................................................................................................................ 33 

Table 16: Summary of key barriers and  success  factors for  ‘Streamline and aggregate renovation 
solutions and processes at the neighborhood level’.......................................................... 34 

Table  17:  Summary  of  key  barriers  and  success  factors  for  ‘Develop  comprehensive  (sub)urban 
strategies  combining  energy  and  carbon  efficiency  of  the  building  stock  with  sustainable 
solutions for growth and improvement of citizens’ wellbeing’ ............................................ 35 

Table 18: Summary of key barriers and success factors for ‘Create an enabling framework for deep 
renovations that are not cost-effective’ .......................................................................... 38 

Table 19: Summary of key barriers and success factors for the EU challenge “Trigger acceptance and 
behavioral change of building owners and occupants about deep energy renovations” ......... 39 

Table  20:  Summary  of  key  barriers  and  success  factors  for  ‘Accelerate  the  market  penetration  of 
innovative solutions for deep renovations’ ...................................................................... 40 

Table 21: Summary of key barriers and success factors for ‘Achieve deep energy renovations in an 
heterogenous building stock with mixed ownership’ ......................................................... 41 

 
 
Annex I: Scoping and key challenges 

Table 22: Summary of key barriers and success factors for ‘Unlocking financing for renovations for 
the end-users’ ............................................................................................................ 45 

Table  23:  Summary  of  key  barriers  and  success  factors  for  ‘Financing  building  renovations  in  the 
presence of market failures’ ......................................................................................... 47 

Table 24: Summary of key barriers and success factors for ‘Mobilising sustainable investment and 
de-risking energy efficiency investment’ ........................................................................ 49 

Table 25: Summary of key barriers and success factors for ‘Designing sustainable buildings taking 
into account the lifecycle of materials’ ........................................................................... 52 

Table 26: Summary of key barriers and success factors for the EU challenge `Foster new technologies 
and business models enabling reuse and recycling of building materials and components’ .... 53 

Table  27:  Summary  of  key  barriers  and  success  factors  for  ‘the  EU  challenge  “Apply  technical 
adaptation measures that have limited negative side-effects’ ........................................... 55 

Table 28: Summary of key barriers and success factors for ‘Increase awareness and implementation 
of nature-based solutions’ ............................................................................................ 57 

Table 29: Summary of key barriers and success factors for the EU challenge ‘Integration of health, 
wellbeing and comfort aspects in legislation and policy instruments associated to renovation’
 ................................................................................................................................ 59 

Table  30:  Summary  of  key  barriers  and  success  factors  for  the  EU  challenge  ‘Enforce  existing 
provisions in support of the Indoor Environmental Quality’ ............................................... 60 

Table 31: Summary of key barriers and success factors for the EU challenge ‘Quantification of health 
and  wellbeing  benefits  from  building  renovations  and  integration  in  the  cost-optimal 
methodology to boost the renovation rate’ ..................................................................... 61 

 
 
 
Annex I: Scoping and key challenges 

ACTIVITY 1.1.: SCREENING OF AREAS 

1. Introduction and methodology 

The amending Energy Performance of Buildings Directive1 (EPBD) introduces new elements 
and  provisions  that  go  beyond  energy  efficiency  in  buildings  and  are  relevant  to  other 
related  ‘strategic  areas’.  In  its  call  for  tender,  the  Directorate-General  for  Energy  (DG 
Energy) identified these areas as: 

1.  Clean and sustainable mobility  
2.  Digital technology 
3.  District approaches 
4.  Engaging transformation and phasing out inefficient buildings 
5.  Financing renovation 
6.  Built environment sustainability and adaptation to climate change 
7.  Health and well-being 

The objective with Activity 1.1 was to check whether the seven strategic areas listed above 
are complete, or if the revised EPBD has a significant impact also on any additional strategic 
areas not included on the list above presented above.  

To screen for potential additional areas, the Consortium prioritised reviewing EU documents 
relevant  to  the  building  sector,  released  after  the  publication  of  the  call  for  tender,  to 
ensure that any new element was included.  

The  key  findings  of  the  screening  are  presented  in  section  2,  and  suggestion  of  how  to 
address the gaps are presented in section 3. 

2. Screening of areas 

Under the Clean Energy for  all Europeans package, the EPBD  was  revised and its scope 
enlarged to cover new areas related to energy performance of buildings, for example, e-
mobility and smartness of buildings. In addition, the EU long term vision for a prosperous, 
modern and competitive climate neutral economy2, made clear that reducing emissions in 
the building sector is crucial for climate neutrality and that an integrated approach built on 
interactions and synergies across different areas is needed. 

Following these developments, seven strategic areas were identified to be researched as 
part of this ‘Lessons Learned’ project. This research aims to distil best practice and identify 
promising integrated approaches to renovating and modernising buildings. To ensure the 
research has a solid grounding, our first task was to investigate whether the seven strategic 
areas are exhaustive or if there are possible gaps and scope to add more areas. 

A new European Commission took office on 1 December 2020, after the call for tender was 
published. The new Commission has new priorities that were not established when the call 
for tender was drafted. To make sure the Lessons Learned project remains relevant and 
can contribute to the new Commission’s objectives, the Consortium decided to check for 
missing strategic areas by focusing on official EU documents relevant to the building sector 
that  the  new  Commission  had  adopted.  These  are  detailed  below.  We  have  only  listed 

1  Directive  (EU)  2018/844  of  the  European  Parliament  and of  the  Council  of  30 May 2018  amending Directive 

2010/31/EU on the energy performance of buildings and Directive 2012/27/EU on energy efficiency. 

2  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions. A Clean Planet for all: A European strategic long-term 
vision for a prosperous, modern, competitive and climate neutral economy, COM(2018) 773 final. 

1 

 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

recent documents, although our scanning was  more extensive, and older documents did 
feed into our work.  

The Commission Recommendation on building modernisation3, which offers guidelines on 
implementing the EPBD, was also published after the call for tender. We also reviewed it 
to assess whether new strategic areas should be added to the existing seven (see below). 

While  we  have  not  listed  the  first  Commission  Recommendation  on  building  renovation4  
below, it is another key EU official document we scanned. 

2.1. European Green Deal 

The  European  Green  Deal  (EGD)5  is  one  of  the  new  European  Commission’s  flagship 
initiatives. Its key objectives are to ensure the EU can tackle climate and environmental 
challenges, while ensuring a prosperous and fair society that protects the health and well-
being  of  its  citizens.  In  addition  to  having  a  section  devoted  to  buildings,  the  EGD  has 
several objectives that are clearly linked and have an impact on building renovations. 

The table below lists selected EGD priority areas, describes how these impact on building 
renovations,  and  indicates  whether  they  are  already  covered  under  the  seven  strategic 
areas.  

EGD SELECTED 
PRIORITIES 
Increasing the EU’s 
climate ambition for 2030 
and 2050. 

IMPACT ON BUILDING 
RENOVATIONS 
EU climate neutrality 
objective will require a 
climate-neutral building 
stock. 

Supplying clean, 
affordable and secure 
energy. 

Mobilising industry for a 
clean and circular 
economy. 
Building and renovating 
in an energy- and 
resource-efficient way. 

EU strategy on adaptation to 
climate change is likely to 
address climate adaptation in 
the building sector. 
Decarbonisation of the 
energy system mainly 
through renewable energy 
will require increased 
penetration of renewables in 
the building sector. 
Reducing energy poverty. 

Smart infrastructure enabling 
sector integration.  
Achieving circular economy 
in all sectors, including the 
construction sector. 
Engaging in a ‘renovation 
wave’ of public and private 
buildings. 
Circularity of building 
material, including through a 

COVERED/NOT COVERED  

Actions and measures in all 
strategic areas contribute 
to achievement of this 
overall long-term objective. 

Covered by strategic area 
6. 

Not explicitly covered in 
the strategic areas but 
already addressed under 
the EPBD (Annex I), and 
considered as a cross-
cutting issue. 
Covered by strategic areas 
5 and 7. 
Covered by strategic area 
2. 
Covered by strategic area 
6. 

Covered by strategic area 
4. 

Covered by strategic area 
6. 

3 Commission Recommendation (EU) 2019/1019 of 7 June 2019 on building modernisation. 
4 Commission Recommendation (EU) 2019/786 of 8 May 2019 on building renovation. 
5  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions. The European Green Deal, COM(2019) 640 final. 

2 

 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

Accelerating the shift to 
sustainable and smart 
mobility. 

Pursuing green finance 
and investment and 
ensuring a just transition. 

Mobilising research and 
fostering innovation. 

Activating education and 
training. 

revision of the Construction 
Products Regulation. 
Automated and connected 
multimodal mobility. 
Measures to address 
emissions, urban congestion, 
and improved public 
transport. 
Ensuring investment to 
finance the clean transition, 
including through a 
Sustainable Europe 
Investment Plan. 
New technologies, 
sustainable solutions and 
disruptive innovation are 
critical to achieve the 
objectives of the EGD. 
Re-skilling and upskilling of 
workers to participate in the 
job market during the energy 
transition. 

Covered by strategic area 
1. 
Covered by strategic area 
1. 

Covered by strategic area 
5. 

Not explicitly covered in 
the strategic areas, but 
research and innovation is 
a cross-cutting issue. 

Not explicitly covered in 
the strategic areas, but it is 
a cross-cutting issue. 

Table 1: EGD’s relevant priority areas and how they are addressed in the project 

2.2 The Sustainable Europe Investment Plan 

On  14  January  2020,  the  European  Commission  presented  the  European  Green  Deal 
Investment Plan, also referred to as the Sustainable Europe Investment Plan (SEIP)6. This 
is the investment pillar of the Green Deal. The SEIP acknowledges that the transition to a 
climate-neutral  and  sustainable  economy  will  require  significant  investment.  To  achieve 
the EU’s 2030 climate and energy targets, it estimates that an additional EUR 260 billion 
per year is needed.  

The table below lists selected SEIP priority areas, describes how these impact on building 
renovations,  and  indicates  whether  they  are  already  covered  under  the  seven  strategic 
areas.  

SEIP SELECTED 
PRIORITIES 

IMPACT ON BUILDING 
RENOVATIONS 

COVERED/NOT COVERED  

Mobilising sustainable 
investment from all 
sources. 

Aid to improve energy 
efficiency for buildings. 

The EU budget and EU funds 
will increasingly finance 
activities that contribute to 
climate neutrality and some 
of these resources will also 
be accessible for building 
renovations. 
Member States will have 
more flexibility to support 
upgrades that address both 
the energy efficiency of 

Covered by strategic area 
5. 

Covered by strategic area 
5. 

6  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions. Sustainable Europe Investment Plan (European Green 
Deal Investment Plan), 14 January 2020, COM(2020) 21 final. 

3 

 
 
 
  
 
 
 
Annex I: Scoping and key challenges 

buildings and invest in 
renewable energy generation 
for self-consumption. 

Table 2: SEIP’s relevant priority areas and how they are addressed in the project 

2.3 Circular Economy Action Plan 

On  11  March  2020,  the  European  Commission  released  a  new  Circular  Economy  Action 
Plan7  (CEAP).  This  is  one  of  the  building  blocks  of  the  European  Green  Deal  as  it  will 
contribute  to  putting  the  EU’s  economy  on  the  path  to  becoming  fully  resource-efficient 
and circular. Making sure circular economy principles and resource efficiency are applied 
to buildings and the construction sector is crucial to curb emissions and resource use. 

The table below lists selected CEAP priority areas, describes how these impact on building 
renovations,  and  indicates  whether  they  are  already  covered  under  the  seven  strategic 
areas.  

CEAP SELECTED 
PRIORITIES 

IMPACT ON BUILDING 
RENOVATIONS 

COVERED/NOT COVERED  

Construction and 
buildings. 

Addressing the sustainability 
performance of construction 
products. 

Promoting measures to 
improve the durability and 
adaptability of built assets in 
line with the circular 
economy principles for 
building design. 

Covered by strategic area 
6. 

Covered by strategic area 
6. 

Table 3: CEAP’s relevant priority areas and how they are addressed in the project 

2.4 A New Industrial Strategy for Europe 

On  10  March  2020,  the  European  Commission  published  a  New  Industrial  Strategy  for 
Europe8.  It  aims  to  support  EU  industry  to  remain  globally  competitive  and  lead  on  the 
transitions towards climate neutrality and digital leadership. 

The  table  below  lists  selected  priority  areas  in  the  communication,  describes  how  these 
impact on building renovations, and indicates whether they are already covered under the 
seven strategic areas.  

NEW INDUSTRIAL 
STRATEGY SELECTED 
PRIORITIES 

IMPACT ON BUILDING 
RENOVATIONS 

COVERED/NOT COVERED  

7  Communication  from  the Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions. A New Circular Economy Action Plan For a Cleaner and 
More Competitive Europe, COM(2020) 98 final. 

8  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions. A New Industrial Strategy for Europe, 10 March 2020, 
COM(2020) 102 final. 

4 

 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

Supporting industry 
towards climate 
neutrality. 

Embedding a spirit of 
industrial innovation. 

Skilling and reskilling. 

Addressing the sustainability 
of construction products and 
improving the energy 
efficiency and environmental 
performance of built assets. 
Scaling up innovative ideas, 
which could mean developing 
strategies to foster 
industrialised energy 
renovations. 
Finding the right skills for the 
digital and ecological 
transition. 

Covered by strategic area 
6. 

Covered by strategic area 
4. 

Not explicitly covered in 
the strategic areas, but 
improving workforce skills 
is a cross-cutting issue. 

Table 4: New Industrial Strategy’s relevant priority areas and how they are addressed in 
the project 

2.5 Shaping Europe's digital future 

On  19  February  2020,  the  European  Commission  published  a  new  communication  on 
Shaping  Europe’s  digital  future9.  It  aims  to  ensure  that  digital  transformation  benefits 
people, supports a competitive economy and enables an open and sustainable society. 

The  table  below  lists  selected  priority  areas  in  the  communication,  describes  how  these 
impact on building renovations, and indicates whether they are already covered under the 
seven strategic areas.  

SHAPING EUROPE’S 
DIGITAL FUTURE 
SELECTED PRIORITIES 
Technology that works 
for people. 

IMPACT ON BUILDING 
RENOVATIONS 

Connectivity, including 
investing in smart energy 
infrastructure. 

Improving digital skills. 

A fair and competitive 
economy. 

An open, democratic and 
sustainable society. 

Data needs to be widely and 
easily available, easily 
accessible, and simple to use 
and process. This could also 
include improving the 
collection and availability of 
building data. 
Digital tools as powerful 
enablers for the sustainability 
transition and supporting the 
decarbonisation of all 
sectors. 

COVERED/NOT COVERED  

Covered by strategic area 
2. 

Not explicitly covered in 
the strategic areas but 
improving digital skills is a 
cross-cutting issue and 
digitalisation is already in 
the scope of the EPBD. 
Covered by strategic area 
2. 

Covered by strategic area 
2. 

9  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social  Committee  and  the  Committee  of  the  Regions.  Shaping  Europe’s  digital  future,  19  February  2020, 
COM(2020) 67 final. 

5 

 
 
 
 
 
Annex I: Scoping and key challenges 

Table  5:  Shaping  Europe’s  digital  future’s  relevant  priority  areas  and  how  they  are 
addressed in the project 

2.6 Commission Recommendation on building modernisation 

On  7  June  2019,  the  European  Commission  published  its  second  recommendation  to 
support Member States to implement the EPBD10. It provides guidelines for implementing 
the  provisions  of  the  EPBD  in  several  areas,  including  technical  building  systems  and 
electromobility. 

These areas are in the scope of the EPBD and are covered by the strategic areas selected 
for the study, as shown below.  

COVERED/NOT COVERED  

Covered by strategic areas 
2 and 4. 

Covered by strategic area 
1. 
Covered by strategic area 3 
and 4 (role of renewables). 

COM. RECOMMENDATION 
SELECTED PRIORITIES 
Technical building 
systems. 

Electromobility.  

Primary Energy Factors 
(PEFs). 

IMPACT ON BUILDING 
RENOVATIONS 
New requirements related to 
the installation of self-
regulating devices and 
building automation and 
control systems in buildings 
that meet specific conditions. 
Charging requirements in 
buildings. 
Increasing transparency in 
calculating PEFs; may in the 
long-term increase 
comparability of energy 
performance calculation and 
energy performance 
certificates (EPC); helps to 
address the role of both the 
building envelope and on-
site/off-site renewable 
energy sources. 

Table 6: Second Commission Recommendation on EPBD implementation’s relevant priority 
areas and how they are addressed in the project 

3. Addressing gaps  

Our  assessment  confirms  that  the  seven  strategic  areas  listed  in  the  call  for  tender 
appropriately cover the key areas with a crucial impact on building renovations.  

However, after an in-depth scan of relevant communications issued by the new European 
Commission, we would like to highlight the following issues: 

1.  Renewable energy: To ensure the EU becomes a climate-neutral economy by 

2050, renewable energy, both in electricity and in heating and cooling, must be 
mainstreamed. 

2.  Skilling and re-skilling the workforce: Improving the skills of the construction 
workforce in energy efficient renovation and digitalisation is crucial for the 

10 Commission Recommendation (EU) 2019/1019 of 7 June 2019 on building modernisation. 

6 

 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

decarbonisation of the building sector. It is also important in light of general 
workforce shortages in sectors related to renovation in some Member States. 

3.  Research and innovation: New technologies and disruptive innovation can 

contribute to and enable building renovations. 

As these three areas are cross-cutting, the Consortium does not suggest adding them to 
the  seven  strategic  areas.  Instead,  we  recommend  mainstreaming  and  addressing  the 
three across the relevant existing strategic areas. 

We will look at renewable energy penetration in the following strategic areas: 

•  Clean and sustainable mobility: The research will explore sector coupling between 

buildings and transport, including how this can maximise renewable energy 
penetration. 

•  District approaches: The research will highlight best practice that facilitates joint 

planning of energy efficiency and renewable energy at the local level. 
•  Engaging transformation: The research will address how renewable heat in 

buildings can contribute to the decarbonisation of the EU’s building stock. 

We will look at skilling and re-skilling of the workforce in: 

•  Digitalisation: The research will explore how the building supply chain can benefit 
from digitalisation and investigate best practice to help the workforce acquire 
digital skills.  

•  Engaging transformation: The research will highlight best practice to improve the 

workforce’s qualifications in relation to innovative renovation technologies. 

Research and innovation can in principle be considered in all strategic areas. Therefore, as 
the overall goal of this project is to distil best practice, we will make sure to highlight best 
practice  that  involves  innovative  practices,  including  innovative  business  models  and 
financing tools. 

4. Conclusions 

Activity 1.1 of the project aimed to identify possible gaps in the seven strategic areas listed 
in the call for tender. To ensure that the Lessons Learned project is useful and matches 
the agenda of the new European Commission, the consortium decided to screen  the von 
der Leyen Commission’s newly published initiatives to identify possible gaps. We identified 
renewable energy penetration, skilling the workforce and research and innovation as areas 
that could be further highlighted in the description of the seven strategic areas. However, 
as  these  three  areas  are  cross-cutting,  the  Consortium  has  proposed  to  address  them 
within  the  relevant  existing  strategic  areas  to  ensure  they  are  well  covered  without 
substantially changing the project architecture.  

7 

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
Annex I: Scoping and key challenges 

ACTIVITY 1.2: STRATEGIC AREAS: SCOPE CLARIFICATION 

1. Introduction and methodology  

The amending Energy Performance of Buildings Directive (EPBD) introduces a series of new 
elements and provisions that go beyond energy efficiency in buildings strictly speaking and 
are relevant for other related areas. Those are called “Strategic areas” and were identified 
by DG Energy in its call for tender as follow: 

1. Clean and sustainable mobility  
2. Digital technology 
3. District approaches 
4. Engaging transformation and phasing out inefficient buildings 
5. Financing renovation 
6. Built environment sustainability and adaptation to climate change 
7. Health and well-being 

The  objective  of  Activity  1.2  was  to  clarify  the  scope  of  the  seven  strategic  areas,  by 
summarising  the  EU’s  goals  and  enabling  framework  for  each  area,  describing  the  key 
trends and drivers in each area, and examining the interactions between the areas. 

To  do  this,  the  Consortium  reviewed  the  relevant  EU  legislation  and  initiatives.  We  also 
reviewed at least three recent and highly regarded reports for each area. The list of the 
reports we reviewed can be found in the bibliography. We used the same reports to put 
together the key EU challenges (Activity 1.3). 

2. Clarifying the scope of each strategic area 

The call for tender identified seven strategic areas and provided a short description of each. 
Below we give a more in-depth description of each area. We provide information on the 
relevant EU framework, key trends and drivers, and how policy and measures in the area 
contribute to achieving the overall objectives for the building sector, particularly the EPBD 
requirement for Member States to adopt long-term renovation strategies to achieve highly 
efficient and decarbonised building stock by 2050 (Art.2a). 

2.1 Clean and sustainable mobility  

Overview of strategic area:  The transport sector is a large and  still  increasing source of 
greenhouse gas (GHG) emissions and air pollutants. Car- and lorry-based mobility also has 
negative impacts on safety, space distribution and quality of life. Better urban design and 
planning  can  contribute  to  more  sustainable  transport  options,  including  by  helping  to 
reduce car travel, shortening daily travel distances, and ensuring that new settlements are 
public 
facilitate  more  sustainable 
transportation  by,  for  example,  providing  charging  infrastructure  for  electric  vehicles  or 
bike parking, including for cargo bikes.  

transport-oriented.  Building  design  can  also 

Key trends and drivers: 

• 

Increasing GHG emissions and worsening air pollution, particularly in cities, are a 
crucial driver for sustainable mobility. 

•  Transport volumes are  rising throughout the EU, with fossil fuel-based motorised 
road transport driving most of this increase. The rise is partly the result of further 
globalisation: both people and products are travelling ever longer distances.  

•  Advances  in  battery  technology  will  increase  the  penetration  of  electric  vehicles. 
This will require fast adaptation of urban spaces and buildings to support charging 
infrastructure. Electromobility will cut emissions and air pollutants but will not solve 
congestion and space allocation problems.  

8 

 
 
 
 
 
Annex I: Scoping and key challenges 

• 

Increasing urbanisation is exacerbating problems including poorly functioning urban 
transport systems, traffic congestion and longer commuting times. 

•  The need to optimise the scarce space in cities underlines the benefits of boosting 
public  transport,  cycling,  cargo  bikes,  electric  scooters,  car  sharing,  and  walking 
compared to private car use and ownership. 

•  Advances  in  digital  technology,  such  as  video  conferencing,  shared  mobility  and 
automation,  will  reduce  the  need  for  transport.  Digitalisation  will  also  allow  the 
connection of different mobility options and make them more efficient. 

Description  of  EU  framework:  The  EU  approach  to  addressing  transport’s  climate  and 
environmental impacts is based on improving efficiency of vehicles, using alternative fuels, 
and shifting to sustainable means of transport and new mobility patterns.  

When it comes to the link between transport policy and buildings, the most relevant policies 
and initiatives are listed below: 

•  The EPBD sets minimum requirements for charging infrastructure in car parks over 
a certain size, plus requirements for minimum infrastructure in smaller buildings. 
•  The Directive on alternative fuels infrastructure11 establishes a common framework 
of  measures  for  the  deployment  of  alternative  fuels  infrastructure  in  the  EU, 
including recharging points for electric vehicles.  

•  The  Urban  Mobility  Package12  provides  guidance  and  financial  support  for 
sustainable  mobility  in  urban  areas.  It  also  promotes  sustainable  urban  mobility 
plans,  which  should  embed  action  on  mobility  into  a  wider  urban  and  territorial 
strategy.  

•  The EU provides financial support to local governments, researchers and companies 
mainly through the European Regional Development Fund, the Cohesion Fund, the 
Connecting Europe Facility and Horizon 2020.  

Impact on overall targets for the EU building sector: Sustainable mobility has a moderate 
impact  on  the  EPBD’s  key  objectives  such  as  achieving  a  highly  energy-efficient  and 
decarbonised  building  stock  by  2050.  On  the  other  hand,  the  relevance  of  buildings  for 
shifting  to  clean  mobility  is  more  pronounced.  This  is  because  buildings,  including  their 
location and urban planning more broadly, and their ability to support electromobility, can 
help shift towards sustainable mobility. 

2.2 Digital technology 

Overview  of  strategic  area:  Digital  technologies  can  be  used  across  the  life  cycle  of 
buildings, from design  and construction to  people using buildings. Digitalisation is a key 
enabler of the decarbonisation of building stock. Firstly, it has great potential to increase 
the quality and scalability of energy efficiency solutions, with optimal design (for example, 
building  information  modelling,  drones  and  3D  printing),  execution  (for  example,  digital 
collaboration  platforms),  and  use  of  buildings  (for  example,  automated  management 
systems, controllable devices and smart appliances, and data collection). Secondly, it gives 
building users smart and flexible energy services,  allowing the development of demand-
side  management  strategies  that  help  further  integrate  variable  and  decentralised 
renewable energy sources into the energy system.  

Key trends and drivers: 

11 Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the deployment of 

alternative fuels infrastructure. 

12 

https://ec.europa.eu/transport/themes/clean-transport-urban-transport/urban-mobility/urban-mobility-

package_en 

9 

 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

•  The  Internet  of  Things  has  seen  a  general  boom,  with  an  increasing  number  of 
appliances and services connected to the Internet. This allows remote management, 
including in the building sector. 

•  Many  cities  have  developed  local  energy  plans  with  the  aim,  among  others,  of 
organising energy supply in a smart and sustainable, yet secure, way, for example 
by creating smart grids. 

•  Growing integration of renewables into the system means matching production with 
consumption  cannot  be  done  solely  on  the  production  side.  The  demand  side  is 
increasingly contributing to the flexibility effort. 

Description of EU framework:  

•  The  EPBD  touches  on  areas  related  to  digitalisation.  For  example,  it  mentions 
creating smart readiness indicators to  rate the  readiness  of a building to interact 
with the grid and to adapt its operation to the occupants’ needs (Article 8 and Annex 
Ia). 

•  The communication on Shaping Europe’s digital future13 highlights that digital tools 
are  powerful  enablers  in  transitioning  to  sustainability  and  can  support  the 
decarbonisation of all sectors, including the building sector.  

•  Data  on  energy  consumption  and  production,  including  data  on  the  users  of 
buildings, are private. Therefore, they should be processed in compliance with the 
General Data Protection Regulation14.  

•  The Commission’s communication on a European strategy for data15 details its aim 
to create a single market for EU data. It also announced the creation of a ‘Common 
European energy data space’ to promote availability and sharing of data to support 
the  energy  system’s  decarbonisation,  while  maintaining  a  customer-centric 
approach.  

•  The  EU  Cybersecurity  Act16  establishes  an  EU-wide  cybersecurity  certification 
framework for digital products, services and processes. It is expected to enhance 
citizens’  trust  when  it  comes  to  installing  digital  solutions  in  their  homes  and 
provides  a  competitive  EU-wide  framework  for  providers  to  make  implementing 
solutions easier. 

Impact on overall targets for the EU building sector: 

•  Digitalisation helps optimise energy use, reduce energy bills and open the way for 
new  business  models  which  reap  the  potential  of  digital  technologies  to  facilitate 
the low-carbon transition. 

•  Digitalisation is a key enabler for harvesting buildings’ flexibility, which allows the 

• 

integration of more low-carbon variable energy sources.  
Industrialised solutions enabled by digital technologies will help reduce the waste 
generated by the renovation sector. 

•  Digitalisation  in  the  building  sector  also  allows  better  access  to  and  collection  of 

relevant data, including energy data.  

13 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions,. Shaping Europe’s digital future. COM(2020) 67 final. 
14 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of 
natural persons with regard to the processing of personal data and on the free movement of such data, and 
repealing Directive 95/46/EC (General Data Protection Regulation). 

15 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social  Committee  and  the  Committee  of  the  Regions.  A  European  strategy  for  data,  19  February  2020 
COM(2020) 66 final. 

16 Regulation (EU) 2019/881 of the European Parliament and of the Council of 17 April 2019 on ENISA (the EU 
Agency for Cybersecurity) and on information and communications technology cybersecurity certification and 
repealing Regulation (EU) No 526/2013 (Cybersecurity Act). 

10 

 
 
 
 
 
Annex I: Scoping and key challenges 

2.3 District approaches 

Overview of strategic area: Building renovations can be planned and organised by adopting 
a comprehensive approach that aims  to  renovate not  only single buildings, but rather a 
district or neighbourhood all at the same time. Renovations at the district level can lead to 
potentially significant cost savings through economy of scale and smart logistics. They can 
also  be  more  attractive  to  investors  thanks  to  project  aggregation  and  distributed  risk 
portfolios. Moreover, this approach fosters synergies between energy efficiency and other 
transformation  in  the  district,  including  development  of  local  renewable  energy  sources 
and  urban  development  strategies.  District  approaches  have  the  potential  to  lead  to 
optimal solutions at macro level, combining energy  efficiency with multiple benefits and 
ensuring consistent sustainable development of cities and territories.  

Key trends and drivers: 

• 

Increasing  citizen  participation  and  emerging  citizen-centric  strategies  maximise 
the acceptance of (local) policy objectives and will help to trigger the planification 
of renovation projects at the neighbourhood level. 

•  The challenge of reaching high energy efficiency for certain buildings combined with 
the  continuous  penetration  of  renewable  energy  technologies  fosters  increasing 
joint  consideration  of  energy  efficiency  and  renewable  energies  to  reach  carbon 
neutrality  in  a  smart  way.  District  approaches  contribute  to  maximising  the 
synergies  between  energy  efficiency  and  renewable  energy,  taking  advantage  of 
the potential of local renewable energy sources. 
Industrialisation  and  streamlining  of  renovation  processes  and  solutions  need  to 
become mainstream, with the expected volume, quality and cost thresholds. District 
approaches can trigger projects of the required size to unlock innovations. 

• 

Description of EU framework:  

• 

In  the  next  review  of  the  EPBD,  Article  19  requires  the  European  Commission  to 
“examine  in  what  manner  Member  States  could  apply  integrated  district  or 
neighbourhood  approaches  in  Union  building  and  energy  efficiency  policy,  while 
ensuring that each building meets the minimum energy performance requirements, 
for  example  by  means  of  overall  renovation  schemes  applying  to  a  number  of 
buildings in a spatial context instead of a single building”.  

•  The European Green Deal17, particularly the ‘renovation wave’ initiative, mentions 
the need to better organise renovation efforts into larger blocks to benefit from 
better financing conditions and economies of scale. 

•  The Renewable Energy Directive18 introduces the right for individuals to self-

generate, consume, store and sell excess renewable electricity to the grid at least 
at the market value. It also introduces the concept of the ‘renewable energy 
community’. These communities are entitled to produce, consume, store and sell 
renewable energy, including through renewable power purchase agreements. 
These provisions create the enabling conditions and legal rights to produce and 
consume renewables at the district level. 

•  The new European Union Framework Programme for Research and Innovation, 
Horizon Europe19, which will run from 2021 to 2027, has ‘climate-neutral and 
smart cities’ as one of its core missions. This clearly shows the need to identify 
workable approaches and solutions to decarbonise cities, moving beyond the 
approach of reducing energy and emissions only at the building level. 

17 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions. The European Green Deal, COM(2019) 640 final. 
18 Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion 

of the use of energy from renewable sources. 

19 https://ec.europa.eu/info/horizon-europe-next-research-and-innovation-framework-programme_en 

11 

 
 
 
 
 
Annex I: Scoping and key challenges 

Impact  on  overall  targets  for  the  EU  building  sector:  District  approaches  to  renovation 
directly contribute to achieving a highly energy-efficient and decarbonised building stock 
by  accelerating  renovation  initiatives  through  unlocking  important  renovation  volumes. 
District  approaches  make  it  possible  to  seize  new  renovation  opportunities  that,  for 
financial and technological reasons, may not be available for small-scale projects.  

2.4 Engaging transformation and phasing out inefficient buildings 

Overview of strategic area: To ensure building stock is fully decarbonised, it is important 
to  develop  processes  that  fully  engage  end-users  and  consider  occupants’  needs.  Going 
beyond providing just technical solutions and engaging consumers in driving change is the 
only way to create transformative change. This includes supporting consumers with tailored 
advice for renovations through one-stop-shops or building renovations passports. 

In addition, a dedicated framework is necessary to improve the worst performing buildings, 
which  are  often  left  unrenovated  because  of  the  market,  regulatory  failures  and  other 
barriers.  Setting  mandatory  minimum  performance  requirements  at  a  transaction  point, 
such  as  sale  or  rental,  can  have  a  significant  impact  on  increasing  the  rate  of  building 
renovation, as owners and landlords are compelled to invest in upgrading their properties, 
shifting  poorly  performing  buildings  towards  better  performance.  Mandatory  minimum 
performance  requirements  are  also  one  of  the  most  effective  means  for  tackling  split 
incentives  and  related  barriers  to  energy  efficiency  investments  in  multi-apartment 
buildings  in  the  EU. Any  building  policy  needs  to  be  well-tailored  to  specific  building 
segments/building  types.  For  example,  heritage  buildings  cannot  easily  fulfil  all  deep 
energy  renovation  requirements.  To  reflect  their  heritage  value,  they  are  often  exempt 
under current building policies. 

Key trends and drivers: 

•  Non-energy  considerations  are  increasingly  driving  building  renovations,  such  as 
improving  comfort  and  well-being  and  reducing  energy  poverty.  There  is  also 
increasing recognition that renovations  can boost the construction sector and  are 
an opportunity to support SMEs and local jobs. 

•  Digitalisation plays a key part in innovative approaches to building renovations with 
citizens at their centre. For example, digitalisation enables industrialised renovation 
processes that reduce renovation hassle for occupants of buildings. It also enables 
the  collection  of  building  data  so  that  renovation  measures  can  to  be  tailored  to 
building occupants.  

•  Citizens are increasingly aware  of energy and  are becoming active players in the 
energy  system  (prosumers).  This  may  help  address  non-market  barriers to 
renovations, such as lack of information, and can influence behavioural change.  

Description of EU framework: 

•  The EPBD is the key legislation setting rules for improving energy performance of 
buildings in the EU. It includes the long-term objective for Member States to achieve 
a highly energy-efficient and decarbonised building stock by 2050, and facilitate the 
cost-effective transformation of existing buildings into nearly zero-energy buildings. 
It  also  requires  Member  States  to  put  in  place  policies  and  actions  to  target  the 
worst performing segments of their national building stock. 

•  The Energy Efficiency Directive20 requires that when Member States design policy 
measures  to  fulfil  their  obligations  under  Article  7  (‘Energy  savings  obligations’), 
they  must  prioritise  implementing  a  certain  share  of  measures  in  ‘vulnerable 
households’, including those affected by energy poverty and, where appropriate, in 
social housing. 

20  Directive  (EU)  2018/2002  of  the  European  Parliament  and  of  the  Council  of  11  December  2018  amending 

Directive 2012/27/EU on energy efficiency. 

12 

 
 
 
  
 
 
Annex I: Scoping and key challenges 

Impact on overall targets for the EU building sector: This strategic area is at the core of 
achieving a decarbonised building stock in the EU. 

2.5. Financing renovation 

Overview  of  strategic  area:  Availability  of  financing  and  appropriate  financing  tools  are 
essential to increase the rate and depth of building renovations. Public finance alone cannot 
support this effort and must be used to leverage additional private investment. Innovative 
financing  schemes  and  business  models  are  emerging  to  maximise  the  effectiveness  of 
funds,  as  well  as  to  target  specific  market  failures  for  renovations  or  more  vulnerable 
groups of citizens.  

Key trends and drivers: 

•  As public funds are limited, it is increasingly necessary to unlock private resources 
to finance building renovations. To do so, public funds are increasingly used as a 
guarantee to reduce the risk for private investors. The use of grants is decreasing 
and mainly used to target vulnerable consumers. 
Innovative financial mechanisms for building renovations are emerging, including 
on-tax, on-bill financing and green bonds. 

• 

•  The development of technical assistance to create a pipeline of bankable projects 

is crucial to mobilise financing.  

Description of EU framework:  

•  The EPBD requires Member States to adopt long-term renovation strategies to make 
their  building  stock  highly  efficient  and  decarbonised  by  2050.  A  solid  financial 
component  must  underpin  these  to  ensure  the  mobilisation  of  investment  for 
renovations.  

•  The Smart Finance for Smart Buildings Initiative aims to mobilise private investment 
in building renovations by using EU resources as a guarantee, thus helping de-risk 
investments in the building sector. 

•  European  Local  ENergy  Assistance  (ELENA)21,  implemented  by  the  European 
Investment  Bank  (EIB),  provides  technical  assistance  to  the  public  and  private 
sector for energy efficiency and renewable energy investments in buildings.  

•  Several  EU  funds  can  support  building  renovations,  including  the  Cohesion  Fund 
and  the  European  Regional  Development  Fund.  Horizon  2020,  the  biggest  EU 
research  and  innovation  programme,  also  supports  energy-efficient  technologies 
and solutions for buildings, including heating and cooling. 

•  Alongside its new energy lending policy22, the EIB launched the European Initiative 
for  Building  Renovations  to  support  new  ways  to  attract  finance  for  building 
retrofits. 

•  The  proposed  European  recovery  package  presents  considerable  new  financing 
opportunities  to  accelerate  the  decarbonisation  of  building  stock.  Particularly 
significant are the enhanced InvestEU and the possibility of Member States being 
able to use funds from the Recovery and Resilience Facility for building renovations, 
in line with identified priorities under the European Semester and National Energy 
and Climate Plans.   

Impact on overall targets for the EU building sector: The availability of financing is a pre-
requisite to carry out building renovations. The more resources, and the more accessible 
they are to target specific needs, the quicker the decarbonisation of the EU building stock 
will happen. 

21 https://www.eib.org/en/products/advising/elena/index.htm 
22 EIB energy lending policy, available at https://www.eib.org/en/publications/eib-energy-lending-policy.htm# 

13 

 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

2.6 Built environment sustainability and adaptation to climate change 

2.6.a BUILT ENVIRONMMENT SUSTAINABILITY  

Overview  of  strategic  area:  As  building  stock  will  undergo  substantial  renovation  in  the 
coming years, material use, and embodied emissions, are set to increase (materials and 
construction  already  account  for  around  15%  of  total  lifecycle  CO2  emissions  from  EU 
buildings). In a whole lifecycle approach based on a circular economy, a low carbon building 
optimises the use of resources and so limits carbon emissions during construction, use and 
end-of-life.  Building  circularity  depends  on  building  design,  material  choice  and 
composition, and transparent documentation of building parts. Additional circular economy 
measures will also be key to keep emissions in check, such as extending building lifetimes/ 
conservation,  reducing  construction  and  demolition  waste,  reusing  structural  building 
components, secondary material use and cement recycling.  

Key trends and drivers:  

•  Urbanisation,  population  growth  and  increasing  per  capita  floor  space  are 
contributing to increases in building space, land use for construction purposes and 
the amount of construction materials used, with associated embodied emissions.  

•  Technological  and  business  model  innovation  supports  the  application  of  circular 
economy  principles  in  the  building  sector,  including,  for  example,  the  use  of 
lightweight alternative and secondary materials.  

Description of EU framework: The EPBD only addresses reducing buildings’ energy use and 
emissions  during  its  use  phase,  not  its  whole  lifecycle.  However,  other  legislation  and 
initiatives cover this, particularly:  

•  The new Circular Economy Action Plan23 recognises that applying circular economy 
principles and resource efficiency to buildings and the construction sector is crucial 
to curb emissions and resource use. It also announced that in 2021 the Commission 
will launch a new Strategy for a Sustainable Built Environment. 

•  The  Waste  Framework  Directive24  stipulates  that  Member  States  should  take 
measures to reuse, recycle or recover at least 70% of non-hazardous construction 
and demolition waste by 2020. 

•  Level(s)’25  guide  to  a  new  reporting  framework  for  sustainability  performance  of 
buildings includes indicators for circularity (for example, lifespan and deconstruction 
materials available for recycling) and for GHG emissions along buildings’ lifecycles. 

Impact  on  overall  targets  for  the  EU  building  sector:  EU  targets  for  the  building  sector 
focus principally on reducing energy use and emissions in the use-phase of buildings.  
From  a  circular  economy  perspective,  there  may  be  (i)  synergies  and  (ii)  trade-offs 
between materials and energy efficiency because on one hand (i) circular design can help 
reduce energy needs, but on the other (ii) components that improve energy efficiency can 
also increase material use and thus embodied emissions. 

2.6.b ADAPTATION 

Overview  of  strategic  area:  Buildings  are  long-lasting  assets  that  rarely  undergo 
renovations.  That’s  why  when  a  retrofit  takes  place  it  should  also  make  buildings  more 
resilient  to  the  effects  of  climate  change.  The  main  climate  hazards  buildings  face  are 
extreme precipitation, heatwaves, heavy snowfall and rising sea levels. These will affect 

23 Communication from the Commission to the European Parliament, the Council, the European  Economic and 
Social Committee and the Committee of the Regions. A new Circular Economy Action Plan For a cleaner and 
more competitive Europe, COM(2020) 98 final. 

24  Directive  2008/98/EC  of  the  European  Parliament  and  of  the  Council  of  19  November  2008  on  waste  and 

repealing certain Directives. 

25 https://ec.europa.eu/environment/eussd/buildings.htm 

14 

 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

buildings  differently  depending  on  their  design  and  location.  Adaptation  solutions  for 
buildings focus on technical measures such as shading devices, planning adjustments such 
as building design and orientation, and nature-based solutions such as green roofs, walls 
or facades, which can regulate temperature variability as well as buffer precipitation peaks. 
It should also be noted that technologies installed in buildings to reduce emissions can be 
vulnerable to climate impacts. For example, solar PV are vulnerable to extreme  weather 
events  such as hail and  high-speed winds. It is worth assessing the possible impacts of 
climate change on these technologies and identifying adaptation options. 

Key trends and drivers: 

• 

• 

Increasing  urbanisation  and  population  are  boosting  construction  and  the 
replacement  of  green  spaces  with  hard,  impermeable  surfaces.  Expanding  urban 
sprawl is also pushing settlements into at-risk, flood-prone areas.  
Increasing  concerns  and  awareness  about  climate  risks  are  driving  a  shift  from 
solely  focusing  on  building  materials  and  energy  performance  to  mainstreaming 
green  solutions  that  can  simultaneously  contribute  to  adaptation,  mitigation, 
biodiversity conservation, and health and well-being.  

•  The insurance sector is likely to play an important role in mainstreaming climate-
resilient buildings. Innovative insurance products can help prevent damage but can 
also contribute to better reconstruction after extreme weather (‘build back better’). 

Description of EU framework:  

•  The  EU  Adaptation  Strategy26  refers  to  buildings  in  its  accompanying  document 
‘Adapting  infrastructure  to  climate  change27’.  It  recommends  considering  climate 
resilience in EU infrastructure investment policies and in construction standards. 
•  The Green Paper on the insurance of natural and man-made disasters28 highlights 
that  insurance  can  play  a  role,  together  with  building  restrictions,  in  managing 
damage to buildings caused by extreme weather events. 

Impact  on  overall  targets  for  the  EU  building  sector:  The  area  of  adaptation  to  climate 
change has limited impact on the EPBD’s targets. However, passive solutions and energy 
efficiency measures are becoming increasingly important given the likely increase in energy 
consumption to cool buildings during more frequent and extreme weather events such as 
heatwaves. 

2.7 Health and well-being  

Overview of strategic area: People spend about 90% of their time indoors, so the indoor 
environment has a significant effect on their health and well-being29. Many scientific studies 
show indoor environmental quality (IEQ) plays a crucial role in ensuring quality of life and 
general health and well-being30. The major determinants of IEQ are indoor air quality, and 
thermal,  acoustic  and  lighting  comfort.  As  well  as  improving  IEQ,  energy  efficiency  also 
helps reduce the use of fossil fuels, improving air quality31. Reducing energy consumption 
through  building  renovations  also  reduces  energy  poverty.  Finally,  energy  efficiency 

26 The EU Adaptation Strategy is currently under revision. The revised strategy is expected to be published by 

late 2020 or early 2021. 

27 Commission Staff Working Document ‘Adapting infrastructure to climate change’, accompanying the document 
Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social  Committee  and  the  Committee  of  the  Regions.  An  EU  Strategy  on  adaptation  to  climate  change, 
SWD/2013/0137 Final. 

28 Green Paper on the insurance of natural and man-made disasters, COM(2013) 213 final. 
29 World Health Organization, 2012. Burden of disease from Household Air Pollution for 2012.  
30 Al horr et al., 2016. Impact of indoor environmental quality on occupant well-being and comfort: A review of 

the literature, International Journal of Sustainable Built Environment, 2016, 5 1 11 

31  Environmental  Protection  Agency.  Indoor  Air  Quality  (IAQ),  Health,  Energy  Efficiency  and  Climate  Change 
(Available at: https://www.epa.gov/indoor-air-quality-iaq/health-energy-efficiency-and-climate-change)  

15 

 
 
 
 
 
 
Annex I: Scoping and key challenges 

renovations coupled with the elimination of accessibility barriers are also associated with 
increased well-being. 

Key trends and drivers: 

•  The  need  to  decarbonise  the  building  sector  should  lead  to  increased  renovation 
rates. This will have a positive effect on the health and well-being of occupants. 
•  Existing  sustainable  building  certification  systems  such  as  DGNB32,  LEED33, 
BREEAM34, Home Performance Index35 and WELL36, support health and well-being 
at different levels, favouring the indoor environment, ecology, sociocultural aspects, 
active and healthy lifestyles and safety. 

Description of EU framework:  

•  Article  2a  of  the  EPBD  requires  Member  States  to  incorporate  in  their  long-term 
renovation  strategy  an  evidence-based  estimate  of  expected  energy  savings  and 
wider benefits, such as those related to health, safety and air quality.  

•  The  Commission  Recommendation  on  building  renovation37  clearly  mentions  that 
measures  to  address  energy  performance  can  contribute  to  creating  a  healthy 
indoor quality environment. It spells out some of the wider benefits related to health 
and  well-being  such  as  lower  illness  and  health  costs,  and  greater  labour 
productivity from better working and living conditions. 

•  The Directive on the accessibility requirements for products and services38 aims to 
improve the functioning of the internal market for accessible products and services, 
including in the built environment. 

•  The EC framework  for  sustainable buildings  –  Level(s) – aims to unite the  whole 
sector value chain around a common European language for better environmental 
performance of buildings, which takes into account wider aspects impacting health 
and well-being.  

Impact on overall targets for the EU building sector: Increases in renovations motivated 
by improving health and well-being of EU citizens, including reducing energy poverty, can 
lead  to  an 
in  overall  building  renovations,  therefore  supporting  the 
decarbonisation of the sector.  

increase 

3. Interactions between strategic areas 

The seven strategic areas have interconnections and interactions: a policy measure in one 
area  may  have  impacts  on  another.  For  example,  policies  to  renovate  buildings  using  a 
district approach can contribute to retrofitting the worst performing buildings (‘Engaging 
transformation and phasing out inefficient buildings’); have a positive effect on sustainable 
mobility through better urban planning (‘Clean and sustainable mobility’); and contribute 
to  making  buildings  resilient  to  climate  change  (‘Built  environment  sustainability  and 
adaptation to climate change’). 

The table below gives an overview of the key interactions between strategic areas. 

32 https://www.dgnb.de/en/ 
33 https://www.usgbc.org/leed 
34  https://www.breeam.com/engage/research-and-development/consultation-engagement/active-design-and-

breeam/ 

35 http://homeperformanceindex.ie/ 
36 https://www.wellcertified.com/ 
37 Commission Recommendation (EU) 2019/786 of 8 May 2019 on building renovation. 
38 Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility 

requirements for products and services. 

16 

 
 
 
 
 
 
Annex I: Scoping and key challenges 

Clean & 
sustainable 
mobility 

Digital 
technology 

District 
approach 

Engaging 
transformation 

Financing 
renovation 

Sustainability 
& adaptation 
to climate 
change 

Health and well-
being 

Clean & 
sustainable 
mobility 

Digital 
technology 

District 
approach 

Digital 
technologies 
are crucial to 
distribute the 
load impact of 
EV charging 
over time and 
to account for 
signals such as 
price or 
availability of 
locally 
produced 
energy. 

District 
approaches can 
have a positive 
effect on 
sustainable 
mobility 
through better 
urban planning. 

Clean and 
sustainable 
mobility planning 
takes place at 
city or district 
level. 

Clean and 
sustainable mobility 
measures, for 
example e-mobility 
chargers, can be a 
trigger for building 
renovations. 

Digital 
technologies are 
an enabling tool 
for energy 
communities. 

Digital technologies 
enable industrialised 
renovation 
processes and 
enable the collection 
of buildings data 
that is the starting 
point to tailor 
renovation 
measures. They also 
provide consumers 
with information, for 
example on real-
time energy 
consumption. Data 
security is important 
to gain trust. 

Digital 
technologies 
make 
monitoring the 
performance of 
renovation 
measures 
possible, which 
is necessary to 
attract 
investment in 
building 
renovations. 

Digital 
technologies/ 
Building 
Information 
Modelling enhance 
data availability 
(for example on 
materials) and 
thus facilitate 
circular 
approaches to 
building 
construction and 
renovation.  

District approaches 
can contribute to 
engaging consumers 
and retrofitting the 
worst performing 
buildings in the 
district. 

District 
approaches can 
help aggregate 
renovation 
opportunities 
and support 
economies of 
scale. 

District 
approaches can 
contribute to 
making buildings 
resilient to climate 
change. 

Clean and sustainable 
mobility measures 
contribute to reducing air 
pollution, including 
reduction of indoor air 
pollution.  

Digital technologies can 
help monitor health and 
well-being benefits and 
should help with 
recognising and reacting 
to occupants’ needs in 
terms of comfort, health 
and IAQ. 

District approaches may 
improve social cohesion. 

17 

 
 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

Clean & 
sustainable 
mobility 

Digital 
technology 

District 
approach 

Engaging 
transformation 

Financing 
renovation 

Sustainability 
& adaptation 
to climate 
change 

Health and well-
being 

Engaging 
transformation 

Building 
renovation can 
be the trigger 
to install 
electro-mobility 
infrastructure 
in buildings or 
to create 
spaces for 
softer mobility 
options, 
including bikes. 

Building 
renovation at 
scale will 
increase the 
demand for and 
application of 
digital 
technologies to 
speed up 
processes and 
offer tailored 
solutions. 

While 
transformation 
may be achieved 
faster when 
approached 
district by 
district, it may 
also complicate 
processes (for 
example, 
coordination with 
more 
stakeholders). 

Buildings renovations 
improve comfort and well-
being of building 
occupants. 

Building 
renovation can 
only be done at 
scale when 
there are 
available and 
accessible 
financing tools 
and business 
models. 

Buildings 
renovations can be 
carried out in line 
with circular 
economy 
principles and can 
also be an 
occasion to make 
buildings resilient 
to climate impacts. 

Financing 
renovation 

Sustainability 
& adaptation 
to climate 
change 

Financing 
schemes require 
calculation of, 
for example, 
performance and 
payback times. 
This information 
can be better 
gathered with 
digital 
technologies. 

Financing 
renovations 
based on project 
aggregation is an 
enabling 
condition for 
retrofitting 
buildings using a 
district approach. 

Financing 
renovations though 
appropriate tools 
and business models 
is the key enabling 
condition to make 
refurbishments 
happen on the 
ground. 

Financing certain 
mitigation 
technologies may 
have adverse 
effects from an 
adaptation 
viewpoint. 

Circular economy 
and adaptation 
technologies and 
processes can be 
applied by using 
a district 
approach. 

Considering wider 
sustainability 
aspects may 
encourage 
renovation but also 
hamper its 
implementation due 
to additional 

Circular 
economy and 
adaptation 
technologies and 
processes need 
the support of 
business models 

Improving sustainability 
of the built environment 
and climate adaptation 
measures can contribute 
to the health and well-
being of building 
occupants. 

18 

 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

Clean & 
sustainable 
mobility 

Digital 
technology 

District 
approach 

Engaging 
transformation 

Financing 
renovation 

Sustainability 
& adaptation 
to climate 
change 

Health and well-
being 

Health and 
well-being 

regulatory 
complexity. 

to become 
mainstream. 

Health and well-
being considerations 
can become a 
driving force for 
building renovations. 

Health, well-being 
and comfort 
considerations can 
be a trigger to 
improve buildings’ 
climate resilience. 

When health 
and well-being 
benefits are fully 
considered and 
monetised, 
financing tools 
and business 
models for 
renovations 
become more 
valuable. 

Health and well-
being 
considerations 
can become a 
trigger for 
building 
renovations at 
district level as 
they would allow 
the exploitation 
of synergies with 
other areas, 
including clean 
and sustainable 
mobility. 

Table 7: Key interactions between strategic areas

19 

 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

ACTIVITY 1.3: KEY EU CHALLENGES 

1. Introduction and methodology  

The objective with Activity 1.3 was, for each strategic area, to identify the key challenges 
at the EU level to achieving net-zero GHG emissions by 2050 in a socially fair, cost-efficient 
way.  

Below we present the  key barriers  and main factors for success in tables.  These will be 
used as a basis for the policy assessment that is carried out in Tasks 2 and 3. 

2. Key EU challenges  

2.1 Key EU challenges in the ‘Clean and sustainable mobility’ strategic 

area 

1) Creating sustainable city layouts 

The dominance of the car as the prime mode of individual mobility is not just the result of 
technological developments in car manufacturing, but also urban and spatial planning. City 
planners  have  enabled  increasing  car  use  by  planning  cities  and  regions  around  it,  by 
building the required road and parking infrastructure – at the expense of other options – 
and by establishing and enforcing a set of rules that gives cars priority over other transport 
modes.  It  is  a  key  challenge  to  overcome  this  post-war  paradigm  in  city  planning  and 
replace it with a model that puts sustainable options such as walking, cycling and electric 
vehicles at the  centre.  Getting citizens to accept  new types of mobility  is a key  concern 
given  most  are  used  to  individual  ownership  and  use  of  cars.  In  dense  agglomerations, 
some existing infrastructure, particularly roads and car parking, will need to make way for 
new infrastructure. New approaches have to be socially balanced. They have to take into 
account the needs of disadvantaged groups and require convenient alternative transport 
options. They should be debated and explained extensively.  

2) Making buildings ready for e-mobility39 

Analysis of potential decarbonisation pathways shows that electrifying transport is one of 
the most promising avenues for reducing GHG  emissions from individual mobility. While 
electric  vehicles  remain  a  niche  technology  in  most  Member  States,  growth  rates  are 
pointing towards a considerable increase over the next decade. 

Providing  charging  infrastructure  is  a  key  challenge  to  electrifying  the  transport  sector. 
Buildings  can  support  this  by  ensuring  renovations  are  a  trigger  for  installing  charging 
points, not only for electric cars but also for electric bikes and scooters. It is also important 
to consider other barriers, like lack of easily available charging points for people in multi-
apartment  buildings.  Similarly,  the  lack  of  adequate  infrastructure  such  as  garages  for 
bikes, including cargo bikes, is an additional barrier to developing softer mobility options. 

3) Increasing joint investment in buildings and mobility 

An overarching challenge in the interplay between mobility and buildings is finance. Rising 
rents and property prices are a widespread social concern in European cities. Adding further 
costs  to  build  new  or  refurbish  dwellings  to  facilitate  and  promote  sustainable  mobility 
options can therefore become a social concern. Smart financing and support instruments 

39  Electric  mobility  (e-mobility)  refers  to  different  types  of  electrified  vehicles,  including  electric  cars,  electric 

bikes, electric scooters and electric motorcycles. 

20 

 
 
Annex I: Scoping and key challenges 

are  key  to  developing  infrastructure  for  sustainable  mobility  while  protecting  social 
cohesion.40  

The  following  tables  summarise  key  barriers  and  success  factors  for  each  of  the  EU 
challenges above. 

40 See for example, Tomassini et al. (2016). EU financial support to sustainable urban mobility and to the use of 

alternative fuels in EU urban areas. 

21 

 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 1: Creating sustainable city layouts 

LEVEL OF 
IMPLEMEN-
TATION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/
LEGAL 

Developers focus on 
value of property 
above all other 
considerations. 

BARRIERS  There is little 
coordination 
between the 
different 
governance 
levels on 
mobility 
infrastructure 
development. 

SUCCESS 
FACTORS 

Integrated 
planning 
processes with 
participation 
of all relevant 
governance 
levels. 

Incentives for 
sustainable mobility 
infrastructure and 
disincentives for 
private car 
ownership. 

Local policymakers 
do not have legal 
tools to enforce rules 
on sustainable city 
layouts if developers 
do not agree. 

Local policymakers 
often lack skills to 
plan adequate 
sustainable transport 
infrastructure.  

Dedicated legal 
provisions 
encouraging 
sustainable city 
layout. 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Citizens may 
initially oppose a 
layout prioritising 
walking, biking 
and shared 
transport options 
over private 
cars. 

Highlighting  
co-benefit. 

Pilot projects, 
even when 
limited in time, 
can help to 
overcome 
opposition. 

Table 8: Summary of key barriers and success factors for ‘Creating sustainable city layouts’ 

22 

 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 2: Readying buildings for e-mobility 

LEVEL OF 
IMPLEMENTATION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

BARRIERS 

SUCCESS 
FACTORS 

Low demand for 
charging 
infrastructure. 

Uncertainty about 
mechanism to bill 
costs of charging. 

Uncertainty about 
future standards 
for charging 
devices. 

Economic incentives 
for electric vehicles 
create demand for 
charging 
infrastructure in 
buildings. 

Innovative financing 
schemes or service 
solutions. 

Giving cities a clear 
target to make e-
mobility the norm, 
supported by 
extensive and 
complementary 
support measures.  

Rising housing 
costs are a 
growing social 
concern in 
many Member 
States. 

Increasing 
demand from 
first adopters 
of electric 
vehicles. 

Table 9: Summary of key barriers and success factors for the EU challenge “Making buildings ready for e-mobility 

23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 3: Increasing joint investment in buildings and mobility 

BARRIERS 

LEVEL OF 
IMPLEMENTA-
TION  

Infrastructure 
decisions for 
neighbourhood-
based mobility are 
made at local 
level. 

Municipalities often 
face budget 
restrictions. 

Lack of finance 
expertise in 
municipalities to 
explore innovative 
finance models. 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

SUCCESS 
FACTORS 

Partnerships 
between 
government levels 
to leverage EU or 
national resources 
for local 
investment. 

Availability of 
smart financing 
support tailored to 
the needs of 
municipalities. 

Table 10: Summary of key barriers and success factors for ‘Increasing joint investment in buildings and mobility’

24 

Increasing 
housing costs. 

Municipalities 
may face 
resistance when 
demanding that 
developers install 
sustainable 
mobility 
infrastructure. 

Support and 
demand from 
citizens for clean 
mobility 
solutions. 

 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

2.2 Key EU challenges in the ‘Digital technology’ strategic area  

1)  Unleashing  the  flexibility  potential  of  energy  uses  via  digitalized  energy-
consuming appliances and services 

Integrating distributed energy sources at low voltage level poses a challenge as grids were 
not  initially  designed  to  host  bidirectional  energy  flows.  In  addition,  the  lack  of  a  clear 
framework and high equipment costs might hamper self-consumption of locally produced 
renewable energy. While flexibility services exist for larger energy consumers (such in the 
industry or services sectors), flexibility at the level of residential buildings is less organised. 
Digitisation is a key enabler of energy uses/consumption patterns that adapt to variable 
production sources to balance consumption with production. The key challenge is to harvest 
small-scale  flexibility  and  organise  its  use  in  ways  that  1)  foster  local  consumption  of 
decentralised and variable energy sources, including at the scale of one/several buildings 
(energy  communities),  and  2)  support  the  global  energy  system  with  flexible  energy 
consumption patterns. This will prevent decarbonisation of the energy system significantly 
increasing energy system costs.  

2)  Mainstreaming  optimal  energy  uses  via  digitalized  energy-consuming 
appliances and services 

failures  that  could 

Optimising  energy  use  through  digitalisation  helps  reap  the  full  benefits  of  deep 
renovations;  self-regulating  devices  limit  unnecessary  energy  use  and  help  address 
technical 
lead  to  additional  energy  consumption.  However, 
mainstreaming  digitalisation  techniques  to  enable  smart  buildings  is  hampered  by  split 
incentives (building owners who do not occupy their buildings have no direct incentive to 
increase  energy  performance  by  installing  self-regulating  devices)  and  the  cost  of 
digitalisation for building technical systems. 

3) Digitalize the buildings renovation supply chain  

The  whole  building  supply  chain  can  benefit  from  digitalisation,  for  example  by  using 
Building Information Modelling. This eases interactions between contractors, spots design 
problems and optimises management of the building during its lifecycle, ultimately helping 
to  reduce  its  energy  consumption.  However,  there  are  many  barriers  to  making  these 
benefits a reality, such as the large variety of small-scale contractors, the lack of standards 
and skilled workers to digitise the sector, and the costs of software acquisition and training. 

4) Digitalize data collection of information about the building stock across Europe 

There  is  an  increasing  amount  of  data  available  on  building  energy  use  and  building 
occupants’ energy consumption patterns. Collecting these data and making them available 
in a transparent way would be useful both for policymaking and to support the creation of 
innovative energy service and business models. To this end, the key challenge is to create 
a  framework  that  systematises  data  collection  by  allowing  the  integration  of  data  from 
different  sources  (for  example,  smart  meters  and  energy  performance  certificate 
repositories), and the automation of the process with minimal or no manual intervention. 
Any digitalisation of data collection should be compliant with data protection regulations, 
with data kept securely.41  

41  Challenge  expressed  by  the  Commission  in  its  H2020  call  ‘European  building  stock  data  4.0’.  Available  at: 
https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/opportunities/topic-details/lc-sc3-
b4e-7-2020, last accessed 26 February 2020. 

25 

 
 
Annex I: Scoping and key challenges 

The  following  tables  summarise  key  barriers  and  success  factors  for  each  of  the  EU 
challenges above. 

26 

 
Annex I: Scoping and key challenges 

EU CHALLENGE 1: Unleashing the flexibility potential of energy uses via digitalized energy-consuming appliances and 
services 

LEVEL OF 
IMPLEMEN-
TATION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/
LEGAL 

TECHNOLOGICAL  

SOCIAL  

ECOLOGICAL 

BARRIERS  Low 

digitisation 
of Europe 
compared to 
other 
economies.42 

SUCCESS 
FACTORS 

Cost of installing 
regulating 
devices that 
adapt 
consumption to 
an external 
signal. 
Split-incentive 
dilemma. 
Purchase cost of 
smart 
appliances. 
Incentivising the 
installation of 
regulation 
devices and the 
purchase of 
smart 
appliances. 

Lack of clearly 
defined roles on who 
should operate 
flexibility. 
Cyber security, 
protection of 
consumer data. 
Lack of a clear 
legislative framework 
on energy 
communities/self-
consumption. 
Clear market 
framework with 
defined roles. 
Definition of a clear 
framework for energy 
communities/self-
consumption. 

Buildings are the 
least digitised sector 
in Europe. 
Diversity of 
interfaces and 
communication 
protocols. 
No time-of-use 
signals ready to be 
used yet. 

Resistance to 
change. 
Fear of loss of 
comfort and control. 
Data privacy. 
Lack of skilled 
workers. 
Weak understanding 
from occupants. 

Specific 
resources 
needed (rare 
materials) for 
IT devices. 
Connected 
appliances 
have higher 
energy 
consumption. 

Inclusion of EV 
charging stations. 
Standardisation of 
communication 
protocols. 

Raising awareness of 
building users. 
EU programmes 
incorporating these 
skills into 
education/training. 

Table  11:  Summary  of  key  barriers  and  success  factors  for  the  EU  challenge  `Unleashing  the  flexibility  potential  of  energy  uses  via 
digitalized energy-consuming appliances and services´ 

42 https://www.mckinsey.com/business-functions/mckinsey-digital/our-insights/digital-europe-realizing-the-continents-potential 

27 

 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 2: Mainstreaming optimal energy uses via digitalized energy-consuming appliances and services 

LEVEL OF 
IMPLEMENTA-
TION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Cost of 
installing 
regulating 
devices. 

Low 
replacement 
cycles. 

Split-incentive 
dilemma. 

Adequate 
incentives to 
foster the 
development of 
smart regulated 
systems. 

BARRIERS 

SUCCESS 
FACTORS 

Replacement of old 
systems 
encouraged. 

EU framework 
(EPDB) for the 
deployment of 
BAMS. 

The Digital Europe 
Programme 
intends to ensure 
wide use of digital 
technologies 
across the 

SUCCESS 
FACTORS 

Cyber security, 
protection of 
consumer data. 

Buildings are the 
least digitised 
sector in Europe. 

Invisibility of 
energy consumption 
leads to significant 
energy volumes 
being consumed 
unnecessarily. 

Weak 
understanding of 
the systems by 
the occupants. 

Lack of skilled 
workers. 

Specific 
resources 
needed (rare 
materials) for 
IT devices. 

Connected 
appliances 
have higher 
energy 
consumption. 

Increasing 
awareness. 

EU programmes 
incorporating 
these skills into 
education/training
. 

28 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 2: Mainstreaming optimal energy uses via digitalized energy-consuming appliances and services 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

LEVEL OF 
IMPLEMENTA-
TION  

economy and 
society.43 

Table 12: Summary of key barriers and success factors for ‘Mainstreaming optimal energy uses via digitalized energy-consuming appliances 
and services’ 

EU CHALLENGE 3: Digitalize the buildings renovation supply chain 

LEVEL OF 
IMPLEMENTA-
TION  

BARRIERS  The construction 

value chain is very 
fragmented and has 
different needs, 
depending on the 
size of companies. 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Cost of software 
acquisition and 
training 
employees/worker
s, especially for 
smaller structures. 

Lack of national 
standards. 

Cyber security, 
protection of 
consumer data. 

Buildings are the 
least digitised 
sector in Europe. 

Lack of skilled 
workers. 

Coordination 
between 
various actors/ 
contractors. 

Variety of small 
actors. 

Lack of 
awareness. 

43 https://ec.europa.eu/digital-single-market/en/news/digital-europe-programme-proposed-eu92-billion-funding-2021-2027 

29 

 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 3: Digitalize the buildings renovation supply chain 

SUCCESS 
FACTORS 

LEVEL OF 
IMPLEMENTA-
TION  

The Digital Europe 
Programme intends 
to ensure wide use 
of digital 
technologies across 
the economy and 
society.44 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Financial support 
for digitalisation. 

Harmonisation of 
standards. 

EU programmes 
incorporating 
these skills into 
education/traini
ng. 

Leadership 
from the 
master of 
works. 

Increasing 
awareness. 

Table 13: Summary of key barriers and success factors for ‘Digitalize the buildings renovation supply chain’ 

EU CHALLENGE 4: Digitalize data collection of information about the building stock across Europe 

LEVEL OF 
IMPLEMENTA-
TION  

BARRIERS 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Cost of collecting 
data. 

Data privacy. 

Cyber security.  

Lack of quality data 
on the building 
stock. 

Data privacy. 

44 https://ec.europa.eu/digital-single-market/en/news/digital-europe-programme-proposed-eu92-billion-funding-2021-2027 

30 

 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

SUCCESS 
FACTORS 

Showcasing 
innovative energy 
services, new 
business models 
and financing 
schemes based on 
digitised collection 
of buildings data. 

Deployment of 
energy performance 
certificates. 

Deployment of 
building renovations 
passports and 
digital logbooks. 

Local authorities 
contributing to data 
collection. 

Lack of 
standardisation. 

Integration of data 
from multiple 
sources. 

Need for manual 
input. 

Standardisation of 
data. 

Policies aiming 
to detect 
energy 
poverty 
situations that 
require data 
collection 

Enhanced 
consumer 
information. 

Table 14: Summary of key barriers and success factors for ‘Digitalize data collection of information about the building stock across Europe’

31 

 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

2.3 Key EU challenges in the ‘District approaches’ strategic area 

1)  Develop  integrated  approaches  maximizing  the  synergies  between  energy 
efficiency and renewable energy at the district level 

Energy  efficiency  and  renewables  measures  are  not  often  planned  together.  A  key 
challenge is to start developing integrated approaches, particularly at the district level, to 
find  an  optimal  combination  between  the  two  and  ensure  the  potential  of  both  is 
maximised.  Optimal  renewable  energy  solutions  are  more  likely  to  be  found  when  solar 
energy, ground heat, storage etc. are designed on a district level45. Developing solutions 
at the district level is the only way to ensure building-specific measures to improve energy 
efficiency affect the entire residential district and its energy production46. Furthermore, if 
strategic decisions about supply and demand of available (heat) resources are made at a 
higher level of governance (regional and local), this would also guide decisions on viable 
options at neighbourhood or district level47. 

2)  Streamline  and  aggregate  renovation  solutions  and  processes  at  the 
neighborhood level  

Buildings  in  residential  districts  typically  have  common  characteristics,  requiring  similar 
renovation solutions. However, very often renovation opportunities are not aggregated at 
the district level. A key challenge is to identify and capture opportunities for standardization 
and aggregation at the district level. This will help speed up renovation, provide economies 
of  scale  and  foster  quality  by  giving  opportunities  to  draw  learnings  as  renovations  are 
replicated from one site to others. Using prefabricated renovation solutions, and developing 
lean and integrated renovation processes, practices and services, can support this. 

3) Develop comprehensive (sub)urban strategies combining energy and carbon 
efficiency  of  the  building  stock  with  sustainable  solutions  for  growth  and 
improvement of citizens’ wellbeing  

Growing populations and evolving living and mobility patterns may lead to an unsustainable 
urban exodus. A key challenge is to embed building energy renovation into global territory 
planning strategies. Planning renovation and infill strategies at the district level maximises 
benefits and increases positive synergies. To cover  the growing need for buildings while 
preventing urban sprawl and limiting the environmental impact of new construction, infill 
projects in existing urban and sub-urban districts and reusing existing urban infrastructure 
should  be  prioritised48.  This  is  also  a  potential  way  to  finance  energy  refurbishment  of 
buildings. District planning is also an opportunity to rethink mobility needs and  solutions 
and put in place sustainable solutions. 

The  following  tables  summarise  key  barriers  and  success  factors  for  each  of  the  EU 
challenges above.

45  T.  Häkkinen  (2018),  District-scale  energy  refurbishment  helps  to  achieve  low-carbon  targets,  available  at: 
https://vttblog.com/2018/09/14/district-scale-energy-refurbishment-helps-to-achieve-low-carbon-targets/, 
(last accessed 26 February 2020). 

46 S. Pahio (2015), It is more sensible to renovate entire residential districts than individual buildings, available 
https://vttblog.com/2015/11/19/it-is-more-sensible-to-renovate-entire-residential-districts-than-

at: 
individual-buildings/ (last accessed 26 February 2020). 

47 H. Vandevyvere, G. Reynders, R. Baeten, I. De Jaeger, Y. Ma (2019),  The trade-off between urban building 
stock retrofit, local renewable energy production and the roll-out of 4G district heating networks, available 
(last  accessed  27 
at:  https://www.energyville.be/sites/energyville/files/position_paper_per_blad.pdf 
February 2020). 

48  T.  Häkkinen  (2018),  District-scale  energy  refurbishment  helps  to  achieve  low-carbon  targets,  available  at: 
https://vttblog.com/2018/09/14/district-scale-energy-refurbishment-helps-to-achieve-low-carbon-targets/, 
(last accessed 26 February 2020). 

32 

 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 1: Develop integrated approaches maximizing the synergies between energy efficiency and renewable 
energy at the district level 

LEVEL OF 
IMPLEMENTA-
TION 

BARRIERS  National 

SUCCESS 
FACTORS 

objectives and 
policies do not 
always facilitate 
an integrated 
approach to 
energy efficiency 
and renewable 
energy. 

Mapping of zones 
at the local level 
with potential for 
specific 
technologies (for 
example, heat 
capacity 
mapping). 

Creating 
renovation 
platforms at local 
level 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLO-
GICAL 

SOCIAL 

ECOLOGICAL 

Large-scale 
innovative 
systems are not 
cost-effective 
from the 
beginning. 

Optimal technologies 
identified can be 
available on the 
market but still 
difficult to implement 
because the legal 
framework is not 
supportive. 

Implementation 
of technological 
solutions at large 
scale offers cost 
reduction 
potential. 

Incentive measures 
and policies. 

Financial measures 
supporting new 
technologies to make 
them attractive. 

Lack of 
sufficiently 
skilled 
professionals at 
the local level. 

Matching training 
and education 
with the skills 
needed in the 
market.  

Skilled and 
qualified 
professionals. 

Large-scale 
initiatives leading 
to development 
of local 
renewable 
energy potential, 
otherwise 
unexploitable at 
smaller scale.  

Table  15:  Summary  of  key  barriers  and  success  factors  for  ‘Develop  integrated  approaches  maximizing  the  synergies  between  energy 
efficiency and renewable energy at the district level’ 

33 

 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 2: Streamline and aggregate renovation solutions and processes at the neighborhood level 

LEVEL OF 
IMPLEMENTA-
TION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Administrative 
burden to realise 
solutions at national 
level (for example, 
tax law and PV 
support regulation). 

Supporting the 
creation of 
renovation 
facilitators. 

Project aggregation 
is complex and 
time-consuming. 

Prefabricated 
renovation 
solutions. 

Developing 
standardised 
renovation 
processes, practices 
and services. 

Disagreement of 
some owners to start 
district-scale 
projects. 

Lack of skilled 
professionals at local 
level. 

Match training and 
education with the 
skills needed in the 
market. 

Including citizens in 
project conception. 

Availability of skilled 
professionals. 

BARRIERS  Lack of national 

strategy to 
coordinate 
different 
independent 
initiatives. 

SUCCESS 
FACTORS 

Tools to identify 
local potentials or 
district with 
standardisation 
potential.  

Tools to secure an 
identified 
renovation volume 
with great 
potential for 
district approach. 

Creating 
renovation 
platforms at local 
level. 

Finance 
support for 
renovation.  

Tools to 
support the 
creation of 
economy of 
scale (such as 
group 
procurement, 
joint ventures 
in procuring 
design, 
construction 
and other 
services). 

Table  16:  Summary  of  key  barriers  and  success  factors  for  ‘Streamline  and  aggregate  renovation  solutions  and  processes  at  the 
neighborhood level’ 

34 

 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 3: Develop comprehensive (sub)urban strategies combining energy and carbon efficiency of the 
building stock with sustainable solutions for growth and improvement of citizens’ wellbeing 

LEVEL OF 
IMPLEMENTA-
TION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE
/LEGAL 

BARRIERS  Lack of 

integrated 
approaches to 
urban planning.  

Public 
administration 
departments often 
work in silos. 

SUCCESS 
FACTORS 

Combining 
building 
renovations at 
the district level 
with investment 
in sustainable 
mobility. 

Institutional and 
legal obstacles 
related to town 
planning and 
building permission 
practices. 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Lack of sufficient 
skilled 
professionals in 
public 
authorities. 

Tools to identify 
local potential for 
infill projects. 

Including citizens 
in project 
conception. 

Integrated 
strategy leads to 
optimal 
renovation of the 
district, including 
integrating green 
areas. 

Table 17: Summary of key barriers and success factors for  ‘Develop comprehensive (sub)urban strategies combining energy and carbon 
efficiency of the building stock with sustainable solutions for growth and improvement of citizens’ wellbeing’ 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

2.4 Key EU challenges in the ‘Engaging transformation and phasing out 

inefficient buildings’ strategic area 

1) Create an enabling framework for deep renovations that are not cost-effective  

Deep building retrofits are not always cost-effective under current calculation methods. A 
contributing factor is that non-energy benefits of renovations are difficult to monetise and 
account  for.  The  challenge  is  to  create  an  enabling  framework  to  make  those  non- 
economical renovations, or those with a very long payback period, happen, and to advance 
approaches that take into account wider benefits.  

2) Trigger acceptance and behavioral change of building owners and occupants 
about deep energy renovations  

Consumer  demand  for  deep  energy  renovations  is  key  to  kick-starting  the  renovation 
market. When citizens actively demand and carry out deep renovations in their homes, the 
renovation rate will start increasing.  To make this happen, deep renovations need to be 
made desirable and accessible to citizens, for example, by becoming affordable and easy 
to carry out. Thus, the challenge is to understand individual consumer needs and match 
those  to  the  renovation  solutions  in  a  market  currently  driven  by  offers  that  do  not 
necessarily reflect long-term targets or individual circumstances.  Solutions could include 
providing tailored advice and support for renovations, as well as clear explanations (and 
quantifications) of the non-energy related benefits of renovations. 

Another  issue  is  ensuring  building  occupants  can  operate  their  homes  efficiently.  For 
example, they should be aware of the energy they consume, and know how to use heating 
equipment and ventilation systems efficiently. The challenge is to find solutions that, for 
example,  make  alternatives  more  attractive,  change  people’s  default  settings  and 
behaviour, and increase automation.  

3) Accelerate the market penetration of innovative solutions for deep renovations  

To increase the rate of deep energy renovations, innovative solutions must emerge from 
the  niche  market  and  become  mainstream.  The  construction  sector  is  one  of  the  least 
innovative  of  all  sectors.  In  recent  years,  the  construction  sector  –  from  planning  to 
operation – has been profitable with its existing approaches, so investing in innovation has 
not been a priority. 

Policies and measures are needed to encourage new business models. These could include 
mainstreaming energy performance contracting for different user  groups, and promoting 
innovative solutions to industrialise renovations, for example by using more prefabricated 
modules or plug-and-play solutions for suitable building types. In addition, better training 
is needed for the construction sector’s workforce, so they are able to deliver good quality 
renovations using state-of-the-art technologies.  

4) Achieve deep energy renovations in a heterogenous building stock with mixed 
ownership  

Building typologies vary considerably across the EU and so does the ownership tenure of 
buildings. It is very difficult to address this diversity with one-size-fits-all measures. It is 
difficult to set up specific incentives and initiatives to target specific building segments and 
population  groups  in  a  consistent  way,  making  sure  that  target  groups  and  long-term 
targets  are  addressed  properly  and  progress  is  tracked  in  fragmented  markets.  To 
overcome this challenge, measures to address heterogenous interests (for  example, the 
split-incentive  dilemma)  in  combination  with  a  consistent  monitoring  approach  may  be 
helpful. 

36 

 
Annex I: Scoping and key challenges 

The  following  tables  summarise  key  barriers  and  success  factors  for  each  of  the  EU 
challenges above. 

37 

 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 1: Create an enabling framework for deep renovations that are not cost-effective 

LEVEL OF 
IMPLEMENTA-
TION  

BARRIERS  Misalignment 

between different 
governance levels 
on renovation 
strategies. 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Definition of cost-
effectiveness/ 
application of 
economic viability 
principle. 

Deep renovations have 
a long pay-back time. 

Low energy prices. 

High up-front costs for 
deep renovations. 

Difficult to aggregate 
small projects. 

Split-incentive 
dilemma. 

Lack of 
digitalisation in the 
construction sector. 

Lack of 
qualified work 
force. 

Aggregation and 
standardisation of 
solutions not 
mainstreamed yet. 

Lack of 
awareness 
about health 
and well-being 
benefits of 
renovated 
buildings. 

SUCCESS 
FACTORS 

EU policy-making 
as stimulus for 
national action. 

Reforming definition of 
cost-effectiveness, to 
include wider benefits. 

Policy instruments 
designed in view of 
long-term objectives. 

Prefabricated 
renovation 
solutions. 

Stepping up funds for 
deep renovation. 

Standardised energy 
performance 
contracts. 

Table 18: Summary of key barriers and success factors for ‘Create an enabling framework for deep renovations that are not cost-effective’ 

38 

 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 2: Trigger acceptance and behavioral change of building owners and occupants about deep energy 
renovations 

LEVEL OF 
IMPLEMENTATION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

BARRIERS 

Incentives set at 
supranational or 
national level need 
to target citizens in 
their specific 
surroundings. 

Low energy 
prices. 

Market failure, 
split-incentive 
dilemma. 

SUCCESS 
FACTORS 

Support from local 
authorities for 
renovations.  

Targeted financial 
incentives.  

One-stop-shop 
solutions. 

Tailored advice for 
renovations. 

Lack of 
understanding of 
renovation 
technologies and 
processes. 

Lack of 
understanding 
of non-energy 
benefits of 
renovations.  

Participation 
in renovation 
decision-
making 

Digital solutions 
give feedback to 
consumers. 

‘Ownership’ of 
technological 
solutions 
(prosuming). 

Table 19: Summary of key barriers and success factors for the EU challenge “Trigger acceptance and behavioral change of building owners 
and occupants about deep energy renovations” 

39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 3: Accelerate the market penetration of innovative solutions for deep renovations 

LEVEL OF 
IMPLEMENTA-
TION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL  

SOCIAL  

ECOLOGICAL 

BARRIERS 

Lack of appropriate 
business models. 

Long permit 
procedure. 

SUCCESS 
FACTORS 

Performance-based 
requirements to 
trickle down the 
renovation supply 
chain. 

Standardised 
approaches to 
facilitate permit 
procedures. 

Difficult to 
address 
mixed-
ownership 
structures of 
buildings. 

Lack of understand-ding 
of renovation 
technologies and 
processes. 

Adaptable modules for 
new builds and 
renovation. 

Lack of individualisation 
of possible solutions.  

Support for innovative 
technologies, such as 
prefabricated facades, 
plug-and-play solutions 
and energy modules. 

Aggregation of deep 
renovation projects at 
district level. 

Performance 
criteria 
beyond 
energy 
requirements 
(for example, 
circularity, 
materials, 
climate 
resilience). 

Table 20: Summary of key barriers and success factors for ‘Accelerate the market penetration of innovative solutions for deep renovations’ 

40 

 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 4: Achieve deep energy renovations in a heterogenous building stock with mixed ownership 

LEVEL OF 
IMPLEMENTATION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

BARRIERS  Misalignment 

between different 
governance levels 
on renovation 
strategies. 

Lack of targeted 
financial support. 

Long payback periods 
for renovation. 

Decision-making 
process for building 
renovations in multi-
family buildings. 

Lack of good data 
about the building 
stock. 

Split-incentive 
dilemma. 

SUCCESS 
FACTORS 

Local support 
schemes 
accompanied by 
planning processes 
that take into 
account social 
cohesion and district 
approaches. 

Targeted financial 
incentives for specific 
building types and 
ownership tenure. 

Tailored advice to 
buildings’ owners 

Streamlining 
procedures, decisions 
not requiring 
unanimity or very 
high majorities in 
multi-family 
buildings. 

Co-benefits 
including 
social 
cohesion.  

Table 21: Summary of key barriers and success factors for ‘Achieve deep energy renovations in an heterogenous building stock with mixed 
ownership’

41 

 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

2.5 Key EU challenges in the ‘Financing renovation’ strategic area 

1) Unlocking financing for renovations for the end-users 

To  increase  renovation  rates,  there  is  a  clear  need  to  create  mechanisms  and  support 
programmes  with  the  financing  capacity  to  stimulate  investments,  including  to  target 
buildings occupied by the most vulnerable consumers. 

To  achieve  lower-cost  financing  and  better  access  for  tenants  and  occupants,  the 
creditworthiness  and  security  of  repayments  for  energy  efficiency  retrofits  must  be 
improved. Building occupants are the most engaged stakeholders. However they are also 
the least likely to engage in building renovation unless they own their home. 

Many  end-users  also  lack  available  funds  to  carry  out  renovations.  Banks  and  energy 
suppliers  involved  in  supplying  energy-efficient  retrofit  solutions  to  their  individual  and 
commercial customers could offer more profitable products to their customers. 

Investment from the public sector is also necessary to overcome key challenges. Member 
States should implement and design effective mechanisms that allow all users to carry out 
renovations  at  a  reasonable  cost.  These  should  take  the  difficulties  they  may  face  into 
consideration (for example, lack of funds and high upfront costs).  

2) Financing building renovations in the presence of market failures 

Adequate financial instruments to overcome market failures are of central importance to 
achieve  and  sustain  higher  deep  renovation  rates.  Market  failures  are  understood  as  a 
range of problems that tend to delay the transformation of building stock and the tapping 
of  cost-effective  energy  savings  potential.  They  may  include  lack  of  understanding  of 
energy use in buildings and potential savings resulting from renovations; lack of attractive 
financial  products;  high  upfront  costs  of  renovation  and  their  long  payback  period;  low 
energy  prices  negatively  affecting  payback  of  energy  savings  measures;  limited 
information and data availability about the building stock; limited uptake of efficient and 
smart technologies; and split incentives. 

Adequate  financial  instruments  to  overcome  market  failures,  a  sufficient  workforce  with 
the right skills, and affordability for all citizens are very important if the EU is to achieve 
and sustain higher renovation rates. 

3) Mobilising sustainable investment and de-risking energy efficiency investment  

Lack of evidence on the performance of energy efficiency investments in buildings makes 
financial risk harder to assess and mobilisation of both public and private investments more 
difficult. On one hand, suitable platforms for dialogue and exchange of good practice, which 
promote the provision of reliable, comparable and verifiable information, are needed to de-
risk energy efficiency investments and engage stakeholders. On the other hand, there is a 
lack  of  standard  financial  approaches  for  building  renovations,  such  as  agreed  protocols 
and benchmarking rules for private capital investment, and ‘ready to use’ financial products 
that would facilitate de-risking of investments. 

Risks related to energy efficiency investments can fall under five categories: economic and 
financial,  behavioural  and  operational,  measurement  and  verification,  contextual  and 
technology,  and  regulatory.  The  factors  that  determine  how  risks/barriers  can  be 
categorised  and  solved  range  from  market-specific  (for  example,  lack  of  appropriate 
financing  vehicles  or  debt  instruments,  regulatory  risks,  volatile  energy  prices)  and 
investor-specific (for example, risk aversion, behavioural bias, perceived lack of collateral), 
to  project-specific  barriers  (for  example,  high  initial  costs,  long  payback  periods, 
uncertainty of technology). 

42 

 
Annex I: Scoping and key challenges 

The  following  tables  summarise  key  barriers  and  success  factors  for  each  of  the  EU 
challenges above.

43 

 
Annex I: Scoping and key challenges 

EU CHALLENGE 1:  Unlocking financing for renovations for the end-users 

LEVEL OF 
IMPLEMENTA-
TION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Lack of a harmonised 
definition and 
measure of energy 
poverty across the 
EU. 

Inefficient energy 
performance of 
buildings (thermal 
insulation, heating 
systems and 
equipment) lead to 
an increase in 
energy bills. 

BARRIERS  Difficulties in 

channelling EU 
and national 
funds to local 
renovation 
projects. 

True costs of CO2 
emissions are 
not reflected in 
market prices. 

Lack of available 
funds for energy 
efficiency 
renovations. 

Split-incentive 
dilemma. 

Arrears on utility 
bills. 

High upfront 
costs of 
renovation and 
long payback. 

Lower energy 
prices (natural gas 
vs electricity) and 
lower capital costs 
(gas boilers tend 
to be less 
expensive in most 
countries than 
heat pumps) mean 
higher 
performance 
equipment may 
barely break even 
on a lifecycle 
basis. 

Higher property 
value, which can 
lead to higher 
rents. 

Households that 
struggle to pay 
the bills. 

Lack of 
understanding of 
energy use and 
potential 
savings. 

Limited 
information on 
the effectiveness 
of currently 
available 
financial support 
mechanisms. 

SUCCESS 
FACTORS 

SUCCESS 
FACTORS 

Ensuring that 
local authorities 
are able to 
apply for EU 
and national 
funds and can 

Energy tariffs. 

Boosting 
effective use of 
financial tools, 
such as tax 
incentives, and 

Integrated national 
action plans. 

Better monitoring 
and sharing of best 
practices. 

Determining the 
worst-performing 
segment by setting 
a specific threshold. 

Education and 
awareness tools, 
training and 
capacity-
building.  

Increasing 
awareness of 
alternative and 
more efficient 
technologies. 

44 

 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 1:  Unlocking financing for renovations for the end-users 

LEVEL OF 
IMPLEMENTA-
TION  

channel them 
to the best local 
projects. 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Improving policy 
regulations and 
market signals 
related to energy 
efficiency and CO2 
emissions in the 
building sector. 

linking them with 
R&D activities to 
reduce the cost 
of more efficient 
equipment. 

Incentives to 
owners or 
tenants through 
subsidies and 
financial 
mechanisms. 

Investing in 
reskilling and 
upskilling of the 
workforce. 

Reliable, 
comparable and 
verifiable 
information.  

Cross-sectoral 
measures that 
ensure nobody is 
left behind. 

Adoption of 
social policy 
measures.  

Table 22: Summary of key barriers and success factors for ‘Unlocking financing for renovations for the end-users’ 

45 

 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 2: Financing building renovations in the presence of market failures 

LEVEL OF 
IMPLEMEN-
TATION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

BARRIERS 

SUCCESS 
FACTORS 

Lack of consistent 
and comparative 
information. 

Lack of attractive 
financing 
products. 

High upfront costs 
of renovation and 
long payback. 

Stranded assets.  

Benefits are in the 
form of savings 
rather than 
revenues. 

Split-incentive 
dilemma.  

Better targeted 
subsidies. 

Mobilisation of 
public funding to 
leverage 
additional private 

Limited consideration 
of benefits due to 
energy renovation in 
lending decision 
criteria. 

Limited uptake of 
available funds to 
finance efficient and 
smart technologies. 

Limited 
information on 
the 
effectiveness of 
currently 
available 
financial 
support 
mechanisms. 

Lack of 
understanding 
of potential 
energy savings 
and other 
benefits.  

Lower energy 
prices (natural 
gas vs 
electricity) and 
lower capital 
costs (gas boilers 
tend to be less 
expensive in 
most countries 
than heat 
pumps) mean 
higher 
performance 
heat pumps may 
barely break 
even on a 
lifecycle basis. 
Therefore, 
buildings remain 
carbon-intense 
energy vectors.  

Policies and measures 
to stimulate cost-
effective deep 
renovations of 
buildings. 

Achieving high 
energy efficiency 
through optimal 
operation of 
buildings and 
facilitating 
maintenance of 

Reliable, 
comparable and 
verifiable 
information. 

Fuel poverty 
alleviation. 

46 

 
 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 2: Financing building renovations in the presence of market failures 

LEVEL OF 
IMPLEMEN-
TATION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Long-term policy 
signals. 

technical building 
systems. 

SUCCESS 
FACTORS 

sector investment 
and address 
market failures. 

Innovative 
schemes such as 
energy services 
companies 
(ESCOs) or on-bill 
and on-tax 
mechanisms. 

Public authorities, 
including the EU 
institutions, leading by 
example and ensuring 
that their procurement 
is green, providing 
evidence of 
advantages.  

Digital 
transformation.  

Improving the 
availability of 
information to the 
public and other 
actors when making 
purchasing 
decisions, such as 
labelling 
programmes.  

Risk-sharing 
instruments such 
as loans, 
guarantees and 
technical 
assistance 

Improving policy 
regulations and 
market signals related 
to energy efficiency 
and CO2 emissions in 
the building sector. 

Table 23: Summary of key barriers and success factors for ‘Financing building renovations in the presence of market failures’ 

47 

 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 3: Mobilising sustainable investment and de-risking energy efficiency investment 

LEVEL OF 
IMPLEMEN-
TATION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLO-
GICAL  

SOCIAL  

ECOLOGICAL 

Stranded assets.  Financial risk 

perception.  

Limited access 
to equal 
finance for 
end-users. 

Lack of 
definition of 
'green assets’ 
(EU 
taxonomy) 

BARRIERS 

Lack of large-scale 
structured 
collaboration 
between 
stakeholders across 
the value chain. 

Lack of standard 
financial approaches 
for building 
renovation. 

True costs of CO2 emissions 
are not reflected in market 
prices. 

Lack of access to reliable, 
comparable and verifiable 
information. 

High upfront costs of 
renovation and long payback. 

Retrofits do not produce 
direct income streams; rather 
they create avoided costs.  

Lack of attractive financing 
products. 

Small-size investments which 
increase implementation 
costs and reduce bankability. 

SUCCESS 
FACTORS 

Transversal 
measures 
that ensure 
nobody is 
left behind. 

Using economic tools, such as 
a carbon tax, to improve 
pricing dynamics for clean 
energy solutions. 

Higher property values, rental 
incomes, lower tenant 
turnover and the ability to 
attract grants or subsidies. 

Setting of ambitious 
and clear milestones 
within long-term 
renovation strategies 
is key to reducing 
investor risks and 
uncertainties, and 
engaging 

Building 
renovation 
passports are an 
example of a 
measure Member 
States can use to 
support targeted 
cost-effective 
renovation and 

Reliable, 
comparable 
and verifiable 
information. 

48 

 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 3: Mobilising sustainable investment and de-risking energy efficiency investment 

LEVEL OF 
IMPLEMEN-
TATION  

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLO-
GICAL  

SOCIAL  

ECOLOGICAL 

SUCCESS 
FACTORS 

Key financial mechanisms to 
be promoted include tax-
related measures (tax 
incentives and credits on 
income, property and energy 
tax), on-bill financing, 
mortgages for energy 
efficiency, green bonds, 
grants and market-based 
instruments. 

Innovative financing schemes 
under InvestEU, the 
European Bank for 
Reconstruction and 
Development, the European 
Investment Bank and 
structural funds such as the 
European Structural and 
Investment Fund and 
European Social Fund. 

stakeholders and 
business. 

staged deep 
renovation. 

Smart 
infrastructure 
and digital 
transformation. 

Screening and 
benchmarking green 
budgeting practices, 
enabling buyers to 
make more 
sustainable decisions.  

Public authorities 
leading by example 
and ensuring their 
procurement is 
green. 

Changing risk 
perception of 
financers and 
investors. 

Clear long-term 
signals for private 
sector investment. 

Table 24: Summary of key barriers and success factors for ‘Mobilising sustainable investment and de-risking energy efficiency investment’

49 

 
 
Annex I: Scoping and key challenges 

2.6  Key  EU  challenges  in  the  ‘Built  environment  sustainability  and 

adaptation to climate change’ strategic area 

1) Designing sustainable buildings taking into account the lifecycle of materials  

Today’s  commercial  and  residential  buildings  are  rarely  designed  for  extended  use,  for 
accommodating  different  kinds  of  building  uses  through  modularity,  or  for  reuse  and 
recycling  during  deconstruction.  Therefore,  buildings  end  up  being  deconstructed  before 
their functional end-of-life, leading to large quantities of construction and demolition waste. 
This  is  rarely  used  for  new  buildings  and  so  does  not  reduce  the  need  for  new,  virgin 
construction materials. 

Producing  construction  materials  is  associated  with  significant  GHG  emissions.  More 
circular building design can help lower emissions by slowing down and reducing the need 
for  new  construction  materials.  Key  challenges  are  to  integrate  circularity  into  existing 
design  education  and  practices  as  well  as  into  building  owners’  and  investors’  decision-
making. This requires coordination, dialogue and efforts across buildings’ value chains. 

2) Fostering reuse and recycling of building materials and components 

The  low  prices  of  virgin  construction  materials  and  low  value  of  end-of-life  materials 
disincentivise deconstruction practices oriented towards reuse and recycling. This reduces 
the availability and use of secondary construction materials. Given this low demand, a key 
challenges is to step up research and development in the sector to ensure better quality 
and higher performing secondary materials. 

Another key challenge is to increase acceptance of and demand for secondary construction 
materials. Building designers, construction material manufacturers, architects and building 
owners still have many reservations about using secondary materials. There may also be 
uncertainty about their performance, which can lead to problems with building warranties. 

3) Apply technical adaptation measures that have limited negative side-effects  

Technical  adaptation  measures  can  be  divided  between  (1)  measures  connected  to 
buildings’ position and orientation and (2) measures directly applied in buildings, such as 
air-conditioning, shading systems and rainwater harvesting. A key challenge is to ensure 
that  both  types  of  measures  are  taken  into  account  from  the  very  early  stages  of  the 
building design and construction process. 

A  second  key  challenge  is  that  many  technical  adaption  measures  have  negative 
environmental  side  effects,  such  as  increasing  energy  demand  (especially  true  for  air-
conditioning).  To  avoid  major  trade-offs  it  is  important  to  promote  measures  with  low 
negative  side  effects,  for  example  energy-efficient  measures  such  as  passive  cooling 
systems (shading systems, passive cooling walls). Climate-resilient approaches promoted 
through  building  codes  or  (private  or  public)  financial  instruments  should  aim  to  reduce 
the negative side effects. It should also be noted that technologies installed in buildings to 
reduce emissions can be vulnerable to climate impacts. 

4) Increase awareness and implementation of nature-based solutions  

Nature-based  solutions  in,  on  and  around  buildings  increase  climate  resilience  and  offer 
additional co-benefits such as improving air quality, protecting biodiversity, reducing urban 
heat island effects, contributing to stormwater management and extending the life of roof 
membranes. A key challenge is the lack of awareness of nature-based solutions and their 
multifunctional potential and ability to deliver diverse benefits. This is worsened by a lack 
of  technical  expertise  and  by  the  absence  of  a  specific  legal  framework,  including 
standards, requirements and financial support/incentives (particularly targeting the private 

50 

 
Annex I: Scoping and key challenges 

sector).  These  factors  limit  the  uptake  of  nature-based  solutions  and  the  willingness  of 
decision-makers and other stakeholders to choose green over the more established ‘grey 
infrastructure’ status quo solutions. 

The  following  tables  summarise  key  barriers  and  success  factors  for  each  of  the  EU 
challenges above. 

51 

 
Annex I: Scoping and key challenges 

EU CHALLENGE 1: Designing sustainable buildings taking into account the lifecycle of materials 

LEVEL OF 
IMPLEMENTA-
TION  

BARRIERS  EU-wide, 

national and 
regional 
coordination is 
mostly 
insufficient. 

SUCCESS 
FACTORS 

Regional or 
national 
coordination 
supporting pilot 
cases. 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Cheap virgin 
construction materials. 

Lower value of end-of-
life materials. 

High(er) investment 
costs and insufficient 
market mechanisms to 
aid circular design, 
reuse and recycling. 

Raising prices for virgin 
materials. 

Providing financial 
support. 

Lack of legal 
requirements to 
foster CE principles. 

Warranty issues 
around using reused 
materials. 

Limited access to 
sufficient quantity 
and quality of 
secondary 
materials. 

Lack of effective 
separate collection 
and recovery 
infrastructure. 

Providing guidelines 
on the use of Green 
Public Procurement 
for circular buildings. 

Availability of 
alternative and 
applicable new/pilot 
technologies. 

- 

Insufficient 
coordination 
among value 
chain actors. 

Low 
acceptance 
of secondary 
materials. 

Circular 
buildings 
fostering 
employment 
and design 
for health. 

Avoiding sites 
for 
construction 
mineral 
extraction. 

Table 25: Summary of key barriers and success factors for ‘Designing sustainable buildings taking into account the lifecycle of materials’ 

52 

 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 2: Foster new technologies and business models enabling reuse and recycling of building materials and 
components 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE
/LEGAL 

TECHNOLOGICAL  

SOCIAL  

ECOLOGI-
CAL 

BARRIERS 

LEVEL OF 
IMPLEMENTA-
TION  

Intra-sectoral and 
value chain 
coordination 
insufficient. 

Cheap virgin construction 
materials. 

Low value of end-of-life 
materials. 

High investment costs 
and insufficient market 
mechanisms to aid reuse 
and recycling. 

Lack of legal 
requirements to 
foster 
reuse/recycling. 

Warranty issues 
around using 
reused materials. 

Immature 
technologies for 
sorting and recycling 
(parts of) 
construction and 
demolition waste. 

Limited access to 
sufficient quantity 
and quality of 
secondary materials.  

Lack of effective 
separate collection 
and recovery 
infrastructure. 

Lack of data to label 
and trace material. 

Availability of 
alternative and 
applicable new/pilot 
technologies. 

Low 
acceptance 
of secondary 
materials. 

Reuse and 
recycling 
more job 
intense than 
virgin 
extraction. 

Avoiding 
sites for 
constructio
n mineral 
extraction. 

SUCCESS 
FACTORS 

Intra-sectoral and 
value chain 
coordination 
supporting 
marketable pilot 
cases. 

Raising prices for virgin 
materials. 

Emerging business 
opportunities, for 
example due to Green 
Public Procurement. 

Providing guidelines 
on the use of Green 
Public Procurement 
for circular 
buildings. 

Table 26: Summary of key barriers and success factors for the EU challenge `Foster new technologies and business models enabling reuse 
and recycling of building materials and components’  

53 

 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 3: Apply technical adaptation measures that have limited negative side effects 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE
/ LEGAL 

TECHNOLOGI-
CAL  

SOCIAL  

ECOLOGICAL 

BARRIERS 

LEVEL OF 
IMPLEMENTA-
TION  

Insufficient 
cooperation 
between the 
different 
governance 
levels, especially 
down to local 
level. 

Standardisation 
organisations not 
actively involved 
(especially with 
private 
organisations). 

SUCCESS 
FACTORS 

Increasing 
coordination 
across 
governance levels 
and sectors, 
including private 
actors. 

Large number of 
buildings are in 
private ownership – 
private owners need 
incentives to make 
climate resilience-
related investments; 
partial measures 
which would be 
cheaper to implement 
during the building 
process are shifted to 
use phase.  

Additional costs, 
especially for energy-
efficient solutions (for 
example cooling). 

Cities developing 
clear requirements for 
buildings in certain 
areas during official 
approval processes 
(for example, passive 
cooling, flood 
protection); 
Guidelines could 
support cities. 

For water re-use, 
high water 
quality is 
necessary. 

Awareness is 
still low due to 
local specific 
risk situations 
(elevations, 
etc.). 

Additional 
cooling 
measures can 
link to 
increased 
energy use. 

In some Member 
States requirements 
for reuse of water 
are not regulated. 
Therefore, measures 
cannot be 
implemented. 

Climate impacts not 
integrated into 
building codes.   

Establishing legal 
requirements for 
water reuse. 

Guidelines on legal 
requirements for 
water reuse. 

Identifying clear 
categories 
showing which 
types of water 
can be used for 
which purposes. 

Acceptance is 
low for a 
number of 
measures 
(negative 
impacts for 
the buildings 
are expected). 

Local-specific 
risk mapping 
being 
available to 
inform 
building 
owners about 
risk of 
extreme 
events. 

Legal 
requirement for 
energy-efficient 
solutions (for 
example, 
passive 
cooling). 

54 

 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 3: Apply technical adaptation measures that have limited negative side effects 

SUCCESS 
FACTORS 

LEVEL OF 
IMPLEMENTA-
TION  

Standardisation 
organisations are 
key players and 
are actively 
involved in 
decision-making 
processes. 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE
/ LEGAL 

TECHNOLOGI-
CAL  

SOCIAL  

ECOLOGICAL 

Further financing 
possibilities; also for 
innovative solutions 
(for long-term testing 
of technologies, etc.).  

Insurance could set 
financial incentives, 
for example, reduced 
premiums for climate-
resilient buildings. 

Awareness 
and 
acceptance 
raising by 
pilots and 
best-practice 
examples. 

Table  27:  Summary  of  key  barriers  and  success  factors  for  ‘the  EU  challenge  “Apply  technical  adaptation  measures  that  have  limited 
negative side-effects’ 

EU CHALLENGE 4: Increase awareness and implementation of nature-based solutions 

LEVEL OF 
IMPLEMENTATION  

ECONOMIC 
/FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

BARRIERS 

Effectiveness 
requires site-specific 
and locally catered 
design, 
necessitating higher 
consultancy costs 
than for standard 
materials.  

Scattered evidence, 
which often lacks 
long-term cost 
effectiveness data. 

High initial 
construction costs; 
ongoing maintenance 
costs. 

Lack of government 
incentives, 
legislation and 
standards for green 
roofs/facades on new 
buildings or conflicts 
with existing 
regulations. 

Lack of technical 
know-how 
(necessitating 
potentially 
expensive 
consultants). 

Low 
acceptance 
compared to 
traditional 
‘grey’ 
infrastructure 
solutions. 

Designing 
locally 
adapted 
nature-based 
solutions to 
thrive in 
climate 
conditions, 
while offering 

55 

 
 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 4: Increase awareness and implementation of nature-based solutions 

LEVEL OF 
IMPLEMENTATION  

ECONOMIC 
/FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

BARRIERS  Competition for use 
of facades/roofs (for 
example for 
electricity 
generation/ 
signage/advertising/ 
media facades). 

Lack of integration 
across sectoral 
policies, to which 
green buildings could 
contribute. 

Biophysical 
barriers (not all 
buildings are 
suitable for green 
roofs/retrofitting). 

Loss of insurance: 
some insurance 
companies do not 
want to cover 
potential damage to 
buildings that have 
made structural 
changes, like 
installing green 
roofs. 

High cost of 
retrofitting compared 
to building new green 
roofs.  

Lack of trust in and 
high scepticism about 
economic data 
regarding green roofs 
and facades. 

High perceived costs 
and financial risks of 
green facades/roofs 
compared to 
considered benefits. 

Securing long-term 
funding for 
maintenance. 

biodiversity 
co-benefits. 

Lack of 
knowledge, 
education, 
and 
awareness 
related to 
potential of 
green 
buildings 
(leading to 
low support 
from local 
authorities 
and the 
public). 

High path 
dependency 
in public 
institutions 
and hesitation 
to embrace 
innovation 
and/or accept 
risk 

SUCCESS 
FACTORS 

Producing local 
guidelines and 
creating 

Targeted awareness-
raising and 

Establishing a tax 
differentiation 
system (for example, 

Development of 
technical guides 

Informational 
campaigns to 
increase 

Utilising 
expert 
knowledge to 

56 

 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 4: Increase awareness and implementation of nature-based solutions 

LEVEL OF 
IMPLEMENTATION  

ECONOMIC 
/FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

SUCCESS 
FACTORS 

Information-sharing 
platform for 
exchange. 

Providing subsidies 
or tax breaks for 
pursuing green 
buildings. 

Information-sharing 
campaigns. 

Changing legislation, 
regulations, 
standards and 
planning guidelines. 

Government financial 
support for 
construction costs of 
green roofs. 

Sharing of evidence 
on costs and benefits, 
ideally stemming 
from local examples. 

reducing water taxes 
for homeowners with 
green roofs; or 
levying stormwater 
management 
charges on 
impervious surfaces) 

Legal requirement 
for green roofs (for 
example on new 
developments 
fulfilling certain size 
criteria, for city-
owned buildings, 
etc.). 

Supporting 
programmes to 
address code and 
zoning obstacles. 

Fostering 
exchange with 
successful case 
studies. 

Awareness 
and highlight 
effective case 
studies and 
diverse co-
benefits. 

optimise 
design, 
ensuring the 
delivery of 
primary and 
co-benefits. 

Supporting 
demonstration 
projects and 
providing 
publicly 
accessible 
data on costs 
vs benefits.  

Promoting 
partnerships 
and 
collaborative 
design 
processes. 

Table 28: Summary of key barriers and success factors for ‘Increase awareness and implementation of nature-based solutions’

57 

 
 
 
 
 
Annex I: Scoping and key challenges 

2.7 Key EU challenges in the ‘Health and well-being’ strategic area 

1) Integration of health, wellbeing and comfort aspects in legislation and policy 
instruments associated to renovations  

Improving  building  occupants’  health  and  well-being  can  be  one  of  the  most  important 
drivers  for  renovations.  But  health  and  well-being  are  often  overlooked.  Until  recently, 
regulatory  and  legislative  measures  have  failed  to  fully  integrate  health  and  well-being 
considerations  into  building  legislation.  Despite  the  identified  impacts  of  the  indoor 
environment  on  occupants’  health,  it  is  often  a  challenging  and  complex  procedure  to 
isolate  and  quantify  the  benefits  of  health,  well-being,  comfort  and  productivity  from 
building renovation. In addition, the lack of synergy and interdisciplinarity between working 
groups on public health and  the building sector has been a crucial barrier  in integrating 
these aspects in legislation. 

The  revised  EPBD  heads  in  the  right  direction  by  including  elements  related  to  health, 
comfort  and  air  quality.  However,  it  falls  short  on  information  about  how  to  achieve 
satisfactory indoor environmental conditions.  

2)  Enforce  existing  provisions  in  support  of  the  Indoor  Environmental  Quality 
(IEQ) 

Despite the existence of EN and ISO standards for indoor environments, there is a lack of 
harmonised design criteria and IEQ requirements at EU level. This makes it impossible to 
take a systematic approach to comparing outcomes across all Member States. Even though 
several EU projects49 examine tools through which health and well-being can be integrated 
into  regulatory  tools,  there  is  no  formal  and  standardised  approach  to  systematise  this 
process. In addition, slow implementation and poor compliance at Member State level and 
the lack of experts able to combine knowledge on IEQ, health and well-being with energy 
efficiency  expertise,  leads  to  further  barriers  to  enforcing  existing  provisions  on  IEQ. 
Another  related  challenge  is  the  time-consuming  and  costly  procedure  to  monitor  the 
indoor environment in buildings. 

3) Quantification of health and wellbeing benefits from building renovations and 
integration in the cost-optimal methodology to boost the renovation rate  

Isolation  of  health  and  well-being  benefits  from  renovation  is  challenging  and  complex. 
Several approaches have been developed to quantify the expected reductions in building-
related  illnesses  and  estimate  the  associated  health  benefits  from  building  renovations. 
Although these approaches do not use a common calculation framework, they can be used 
as  a  baseline  to  develop  a  more  complete  and  structured  method.  The  lack  of 
interdisciplinarity  between  working  groups  in  public  health  and  the  building  sectors  is 
another  barrier  to  the  quantification  of  tangible  and  intangible  health  and  well-being 
benefits from building renovations.  

The  following  tables  summarise  key  barriers  and  success  factors  for  each  of  the  EU 
challenges above. 

49 https://x-tendo.eu/ 

58 

 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 1: Integration of health, wellbeing and comfort aspects in legislation and policy instruments associated to 
renovation 

LEVEL OF 
IMPLEMENTA-
TION  

BARRIERS  EPBD does not 

sufficiently include 
provisions on how 
health, comfort 
and air quality can 
be achieved 

Addition of 
elements on 
health, comfort 
and air quality in 
legislation. 

SUCCESS 
FACTORS 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/
LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGICAL 

Macro-economic impact 
understudied. 

Lack of standardised 
IEQ-related 
requirements. 

Lack of longitudinal 
studies in Member 
States. 

Lack of cost-optimised 
solutions to improve 
IEQ. 

More macro-economic 
studies on multiple 
benefits. 

Increased investment in 
technical know-how.  

Setting up 
mandatory 
requirements in 
building regulations 
and public policy 
instruments. 

Supporting 
research projects 
with field studies 
evaluating multiple 
benefits. 

Lack of 
awareness 
about 
benefits for 
citizens and 
professional
s. 
Awareness 
campaigns, 
education 
and training 
programmes
. 

Table  29:  Summary  of  key  barriers  and  success  factors  for  the  EU  challenge  ‘Integration  of  health,  wellbeing  and  comfort  aspects  in 
legislation and policy instruments associated to renovation’ 

59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 2: Enforce existing provisions in support of the Indoor Environmental Quality 

LEVEL OF 
IMPLEMENTA-
TION  

BARRIERS  Lack of systematic 

way of involving 
and documenting 
IEQ in existing 
provisions. 

SUCCESS 
FACTORS 

EN and ISO 
standards for 
setting up the 
criteria exist. 

A number of EU 
projects examine 
tools through 
which health and 
well-being can be 
integrated. 

ECONOMIC/ 
FINANCIAL 

ADMINISTRATIVE/ 
LEGAL 

TECHNOLOGICAL  

SOCIAL  

ECOLOGI-
CAL 

Lack of support from 
value chain actors to 
boost the 
development for 
larger economic 
impact. 

Time-consuming and 
costly procedure to 
monitor IEQ. 

No dedicated financial 
incentives or grants to 
improve IEQ in 
buildings. 

Reduction of high 
costs of monitoring 
equipment, software 
and training of 
professionals. 

Extension of existing 
schemes for energy 
efficiency to IEQ. 

Lack of harmonised 
calculation 
methodology and IEQ 
requirements at EU 
level.  

Experts involved in 
existing provisions to 
support IEQ are not 
trained beyond 
energy efficiency 
matters (lack of 
skills). 

Resistance of 
building 
occupants. 

Lack of social 
awareness. 

IEQ-focused 
programmes in 
existing EU initiatives 
such as BUILDUP 
Skills. 

Improving 
public health 
thanks to 
healthier 
indoor 
environments.  

Table  30:  Summary  of  key  barriers  and  success  factors  for  the  EU  challenge  ‘Enforce  existing  provisions  in  support  of  the  Indoor 
Environmental Quality’ 

60 

 
 
 
 
 
 
 
 
Annex I: Scoping and key challenges 

EU CHALLENGE 3: Quantification of health and wellbeing benefits from building renovations and integration in the cost-
optimal methodology to boost the renovation rate   

LEVEL OF 
IMPLEMENTA-
TION  

BARRIERS  No standardised 
methodology for 
quantifying health 
and well-being 
benefits from 
renovation. 

SUCCESS 
FACTORS 

Methods exists 
that quantify the 
expected 
reductions in 
building-related 
illnesses and 
estimate the 
associated health 
benefits. 

ECONOMIC/ 
FINANCIAL 

ADMINISTRA-
TIVE/LEGAL 

TECHNOLOGICAL   SOCIAL  

ECOLOGI-
CAL 

The macro-economic 
impact of energy poverty 
on health and well-being 
is understudied. 

Difficult to translate non-
tangible benefits into 
monetary values or 
integrate them as 
financial offsets in 
renovation planning. 

More and more funding 
opportunities exist 
supporting the 
quantification and 
monetisation of multiple 
benefits from building 
retrofits. 

Financial gains from 
increased productivity, 
lower absenteeism and 
reduced healthcare. 

Lack of longitudinal 
studies across 
different building 
typologies on 
quantification of 
health and well-
being benefits. 

Insufficient 
interdisciplinarity 
between public 
health and 
building sector. 

Reduction of sick 
days. 

Increased 
productivity. 

Reduced 
employee 
turnover. 

Initiatives to create 
new databases from 
Member States. 

The existing 
methods for 
quantifying benefits 
can be used as a 
baseline for 
developing a more 
complete and 
standardised 
approach. 

Table 31: Summary of key barriers and success factors for the EU challenge ‘Quantification of health and wellbeing benefits from building 
renovations and integration in the cost-optimal methodology to boost the renovation rate’

61 

 
 
 
 
 
 
 
  
 
 
 
BIBLIOGRAPHY 

The bibliography lists the literature we used to carry out the analysis and the relevant EU 
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Tomassini et al. (2016), EU financial support to sustainable urban mobility and to the use 
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Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 
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2. Digital technology 

Literature  

Baldini et al. (2019), Digital Transformation in Transport, Construction, Energy, 
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Borsboom-van Beurden et al. (2017), Smart City Guidance Package for Integrated 
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IEA (2018), Review of applied and tested control possibilities for energy flexibility in 
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Vito et al. (2018), Support for setting up a smart readiness indicator for buildings and 
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62 

 
 
EU legislation and documents 

Communication from the Commission to the European Parliament, the Council, the 
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Europe’s digital future, COM(2020) 67 final. 

Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions. A 
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European Commission (2019), Supporting digitalisation of the construction sector and 
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on the free movement of such data, and repealing Directive 95/46/EC (General Data 
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3. District approaches 

Literature  

Block & Baugniet (2019), L’actualité réglementaire dans le domaine du solaire 
photovoltaïque et du stockage énergétique en Wallonie, presentation February 2019. 
Available at: 
http://guider.be/custom/domain_1/image_files/Formation/PV2019/1_EF4_Actualite_regl
ementaire_Guy_Block_2019.pdf (last accessed 30 March 2020). 

German Federal Ministry for Economic Affairs and Energy (2015), Energy Efficiency 
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IEA and EBC (2019), Cost-effective Building Renovation at District Level Combining 
Energy Efficiency & Renewables, Annex 75.  

Pahio, 2015. It is more sensible to renovate entire residential districts than individual 
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meer CO2 reductie kunnen opleveren, Stroomversnelling, April 2019. Available at: 
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(last accessed 30 March 2020). 

Schlitzberger et al. (2018), Kurzgutachten zur Aktualisierung und Fortschreibung der 
vorliegenden Wirtschaftlichkeitsuntersuchung sowie zu Flexibilisierungsoptionen, Bericht 
für das BMWi, April 2018. 

Vandevyvere et al. (2019), The trade-off between urban building stock retrofit, local 
renewable energy production and the roll-out of 4G district heating networks. Available at 
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accessed 27 February 2020). 

63 

 
 
 
EU legislation and documents 

Regulation (EU) 347/2013 of the European Parliament and of the Council of 17 April 2013 
on guidelines for trans-European energy infrastructure. 

4. Engaging transformation and phasing out inefficient buildings 

Literature  

ECN (2017), De derde succesfactor ontrafeld. Available at: 
https://projecten.topsectorenergie.nl/storage/app/uploads/public/5cc/c3d/a2d/5ccc3da2
dbcb7404142547.pdf (last accessed 30 March 2020) 

Esser et al. (2019), Comprehensive study of building energy renovation activities and the 
uptake of nearly zero-energy buildings in the EU, Final report by IPSOS and Navigant for 
the European Commission. 

German Federal Ministry for Economic Affairs and Energy (2017), Green Paper on Energy 
Efficiency. 

IPOS (2018), Uncover the underlying motivations and barriers for energy efficient 
renovations.  

Irish Green Building Council (2019), Overcoming the split incentive barrier in the private 
rental market, International Case Studies. 

The Leeuwarden Declaration (2018), Adaptive re-use of the built heritage: Preserving 
and enhancing the values of our built heritage for future generations, Built Heritage 
Conference. 

EU legislation and documents 

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’, SWD(2016) 415. 

5. Financing renovation 

Literature  

IEA (2019), Perspectives for the clean energy transition. The critical role of buildings. 

Energy Efficiency Financial Institutions Group (2015), Final report covering buildings, 
industry and SMEs. 

European Construction Sector Observatory (2018), Stimulating favourable investment 
conditions, Analytical report. 

European Parliament (2016), Boosting Building Renovation: What Potential and Value for 
Europe? Study for the ITRE Committee. Available at: 
https://www.europarl.europa.eu/RegData/etudes/STUD/2016/587326/IPOL_STU%28201
6%29587326_EN.pdf (last accessed 29 May 2020). 

EIB (2019), EIB energy lending policy, Supporting the energy transformation. Available 
at: https://www.eib.org/attachments/strategies/eib_energy_lending_policy_en.pdf (last 
accessed 30 March 2020). 

Joint Research Centre (2016), Synthesis report on the assessment of Member States’ 
building renovation strategies. 

EU legislation and documents 

European Commission (2014), Technical Guidance, Financing the energy renovation of 
buildings with Cohesion Policy, Final Report prepared for EC DG Energy. 

64 

 
 
6. Built environment sustainability and adaptation to climate change 

Literature  

BAMB (2019), Framework for policies, regulations and standards. Buildings as Material 
Banks (BAMB) project.  

CLIC Project (2020), Circular Models Leveraging Investments in Cultural Heritage 
Adaptive Reuse. Available at: https://www.clicproject.eu/about/ (last accessed 30 March 
2020). 

Ebinger & Vergara (2011), Climate Impacts on Energy Systems, Key Issues for Energy 
Sector Adaptation, World Bank Study. 

Ellen MacArthur Foundation (2014), Towards the circular economy Vol. 3: Accelerating 
the scale-up across global supply chains. 

Green Alliance (2015), Unemployment and the circular economy in Europe: a study of 
opportunities in Italy, Poland and Germany. London, December 2015. 

Hertwich et al. (2019), Material efficiency strategies to reducing greenhouse gas 
emissions associated with buildings, vehicles, and electronics – a review. Environmental 
Research Letters 14. 

Le Den et al. (2017), Insurance of weather and climate related disaster risk: Inventory 
and analysis of mechanisms to support damage prevention in the EU.  

Material Economics (2018), The Circular Economy: a Powerful Force for Climate 
Mitigation, Transformative innovation for prosperous and low-carbon industry. 

Menzies (2011), Embodied energy considerations for existing buildings, Historic Scotland 
Technical Paper 13, Heriot-Watt University, Edinburgh. 

Nußholz et al. (2019), Circular building materials: Carbon saving potential and the role of 
business model innovation and public policy. Resources, Conservation and Recycling. 

Urban agenda partnership on circular economy (2019), Handbook on sustainable & 
circular re-use of spaces & buildings. 

EU legislation and documents 

Commission Staff Working Document ‘Adapting infrastructure to climate change’, 
accompanying the document Communication from the Commission to the European 
Parliament, the Council, the European Economic and Social Committee and the 
Committee of the Regions. An EU Strategy on adaptation to climate change, 
SWD/2013/0137 Final. 

Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions. A new 
Circular Economy Action Plan for a cleaner and more competitive Europe, COM(2020) 98 
final. 

Directive 2008/98/EC of the European Parliament and of the Council of 19 November 
2008 on waste and repealing certain Directives.  

Green Paper on the insurance of natural and man-made disasters, COM(2013) 213 final. 

European Commission (2019), LEVEL(S) – Taking action on the TOTAL impact of the 
construction sector, available at: https://ec.europa.eu/environment/eussd/buildings.htm 
(last accessed 30 March 2020).  

European Commission (2020), Circular Economy Principles for Buildings Design. 

65 

 
 
 
7. Health and well-being 

Literature  

Al Horr et al. (2016), Impact of indoor environmental quality on occupant well-being and 
comfort: A review of the literature, International Journal of Sustainable Built 
Environment. 

BPIE (2018), The inner value of a building – Linking indoor environmental quality and 
energy performance in building regulation. 

Dodd et al. (2017), Level(s) – A common EU framework of core sustainability indicators 
for office and residential buildings: Parts 1 and 2: Introduction to Level(s) and how it 
works, JRC Science for Policy Report, Publications Office of the European Union. 

Environmental Protection Agency (2017), Indoor Air Quality (IAQ), Health, Energy 
Efficiency and Climate Change. 

Joint Research Centre (2017), Promoting healthy and highly energy performing buildings 
in the European Union. 

World Health Organization (2012), Burden of disease from Household Air Pollution for 
2012.  

EU legislation and documents 

Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 
on the accessibility requirements for products and services. 

8. EU legislation and documents relevant across strategic areas 

Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions. The 
European Green Deal, COM(2019) 640 final. 

Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions. A Clean 
Planet for all: A European strategic long-term vision for a prosperous, modern, 
competitive and climate neutral economy, COM(2018) 773 final. 

Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions. 
Sustainable Europe Investment Plan (European Green Deal Investment Plan), 14 January 
2020, COM(2020) 21 final. 

Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions. A New 
Industrial Strategy for Europe, 10 March 2020, COM(2020) 102 final. 

Commission Recommendation (EU) 2019/786 of 8 May 2019 on building renovation. 

Commission Recommendation (EU) 2019/1019 of 7 June 2019 on building modernisation. 

Directive (EU) 2018/844 of the European Parliament and of the Council of 30 May 2018 
amending Directive 2010/31/EU on the energy performance of buildings and Directive 
2012/27/EU on energy efficiency. 

Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 
2018 amending Directive 2012/27/EU on energy efficiency. 

Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 
2018 on the promotion of the use of energy from renewable source

66 

 
 
 
 
 
 
Lessons learned to inform 
integrated approaches for the 
renovation and modernisation 
of the built environment 

Annex II: Factsheets and lessons learned 

ENER/C3/2019-468/03 

Written by:  
Buildings Performance Institute Europe ASBL (BPIE), 
CLIMACT SA,  
Creara Consultores SL, and  
Ecologic Institute 

December 2020 

 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

CONTENTS 

Built environment sustainability and adaptation to climate change - Factsheet . 1 

1.1 Introduction ................................................................................................. 3 

1.2 Built environment and adaptation ................................................................... 3 

1.3 Provisions to address key challenges ............................................................... 5 

1.4 Effectiveness of the policy landscape to address key challenges.......................... 7 

1.5 Highlighting good practice examples ............................................................. 12 

1.6 Concluding assessment ............................................................................... 17 

Clean and sustainable mobility – Factsheet ...................................................... 22 

2.1 Introduction ............................................................................................... 23 

2.2 Clean and sustainable mobility ..................................................................... 23 

2.3 Provisions to address key challenges ............................................................. 24 

2.4  Effectiveness  of  the  policy  landscape  to  address  key  challenges  -  overview  and 
description ...................................................................................................... 27 

2.5 Highlighting good practice examples ............................................................. 31 

2.6 Concluding assessment ............................................................................... 33 

Digital technologies for energy efficiency and renovation – Factsheet ............. 36 

3.1 Introduction ............................................................................................... 37 

3.2 Digital technology ....................................................................................... 37 

3.3 Provisions to address key challenges ............................................................. 38 

3.4 Effectiveness of the policy landscape to address key challenges........................ 42 

3.5 Highlighting good practice examples ............................................................. 47 

3.6 Concluding assessment ............................................................................... 50 

District approach – Factsheet ........................................................................... 52 

4.1 Introduction ............................................................................................... 53 

4.2 District approach ........................................................................................ 53 

4.3 Provisions to address key challenges ............................................................. 54 

4.4  Effectiveness  of  the  policy  landscape  to  address  key  challenges  -  overview  and 
description ...................................................................................................... 57 

4.5 Highlighting good practice examples ............................................................. 63 

4.6 Concluding assessment ............................................................................... 71 

Engaging transformation and phasing out inefficient buildings –Factsheet ...... 76 

5.1 Introduction ............................................................................................... 77 

5.2 Engaging transformation and phasing out inefficient buildings .......................... 77 

5.3 Provisions to address key challenges ............................................................. 77 

 
Annex II: Factsheets and lessons learned 

5.4 Overall assessment for effectiveness - overview and description ....................... 83 

5.5 Highlighting good practice examples ............................................................. 92 

5.6 Concluding assessment ............................................................................... 95 

Financing renovation – Factsheet ..................................................................... 97 

6.1 Introduction ............................................................................................... 98 

6.2 Financing renovation ................................................................................... 98 

6.3 Provisions to address key challenges ............................................................. 99 

6.4  Effectiveness  of  the  policy  landscape  to  address  key  challenges  –  overview  and 
description .................................................................................................... 103 

6.5 Highlighting good practice examples ........................................................... 109 

6.6 Concluding assessment ............................................................................. 112 

Health and wellbeing - Factsheet ......................................................................... 115 

7.1 Introduction ............................................................................................. 116 

7.2 Health and wellbeing ................................................................................. 116 

7.3 Provisions to address key challenges ........................................................... 117 

7.4  Effectiveness  of  the  policy  landscape  to  address  key  challenges  –  overview  and 
description .................................................................................................... 125 

7.5 Highlighting good practice examples ........................................................... 130 

7.6 Concluding assessment ............................................................................. 133 

Orno 

 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

vation 

Built environment sustainability and adaptation to 
climate change - Factsheet 

Authors: Martin Hirschnitz-Garbers, Jenny Tröltzsch, McKenna Davis (Ecologic Institute) 

September 2020 

Tender N° ENER/C3/2019-468/03 

    1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

    2 

 
 
 
 
 
Annex II: Factsheets and lessons learned 

1.1 Introduction 

This  factsheet  provides  an  overview  of  how  different  policy  instruments  and  selected 

private initiatives can help to achieve European objectives and effectively address key EU 

challenges in the strategic area of built environment and adaptation. The findings draw 

upon  a  policy  screening  for  15  EU  Member  States,  3  non-EU  countries  and  5  European 

regions covering broadly the climatic zones of the EU. In addition, the factsheet draws on 

additional  information  provided  by  external  experts  as  well  as  on  the  long-standing 

expertise of the authors, meaning policy examples going beyond the researched country 

and region cases are occasionally added. The concluding assessment draws on the findings 

and detailed analysis of the good practice cases as well as on the in-house expertise of 

the partners.  

1.2 Built environment and adaptation 

This  area  encompasses  policies  and  measures  on  the  built  environment  relating  to  a 

circular economy as well as to climate adaptation and nature-based solutions. 

In the EU, the construction industry and building sector is a major user of materials, with 

buildings accounting for roughly for two-thirds of cement use, more than a third of steel, 
a  quarter  of  aluminium,  and  almost  a  fifth  of  plastics.1  When  including  further  building 
materials, such as bricks, gypsum, lime and copper, Europe’s buildings account for roughly 

1.6 million tonnes of material use per year. Europe’s building stock is expected to slowly 
expand due to continuing trends of urbanisation and increasing per capita floor space.2 In 
addition,  most  post-war  buildings  in  European  Member  States  will  require  substantial 

renovation or replacement in the coming years and decades, not least in relation to energy 
efficiency standards.3, 4 Therefore, the sector’s material use is expected to increase.  

This  has  consequences  for  CO2  emissions  associated  with  the  buildings  sector  because 

“[…] around 15% of total lifecycle CO2 emissions from EU buildings today are attributable 
to  materials  and  construction”.5  Producing  these  building  materials  is  responsible  for 
approximately 250 million tonnes (Mt) of CO2 emissions annually, of which cement, steel, 

aluminium and plastics production account for almost 80%. In a whole lifecycle approach 

based  on a circular  economy, a low-carbon building optimises the use of  resources and 

thereby limits carbon emissions during construction, use and end-of-life. Circular economy 

measures in the buildings sector, such as extending building lifetimes, reusing structural 

building  components,  increasing  secondary  material  use,  and  cement  recycling,  could 

reduce emissions by 80 Mt CO2 a year by 2050. Benefits from increasing circularity in the 

building sector for carbon savings also form part of the ‘Circular Economy Principles for 

Building Design’, which the European Commission together with a wide set of stakeholders 

from  the  construction  industry  developed  between  2016  and  2019.  The  principles 

1 Material Economics (2018). The circular economy – a powerful force for climate mitigation. Transformative 
innovation for prosperous and low-carbon industry. Stockholm, Sweden. Unless otherwise stated, statistics in 
this and the following paragraph are taken from this report. 
2 BPIE (2011). Europe’s Buildings under the Microscope. A country-by-country review of the energy 
performance of buildings. Buildings Performance Institute Europe (BPIE),  
3 Ibid. 
4 
https://ec.europa.eu/energy/eu-buildings-factsheets_en?redir=1, accessed 16 June 2020. 
5 Material Economics 2018; p.144 

update:  May 

Commission 

Factsheets. 

European 

Building 

(2020). 

Last 

EU 

2020. 

    3 

 
 
 
 
 
Annex II: Factsheets and lessons learned 

encompass  general  and  target-group-specific  principles  for  increasing  circularity  in  the 

building sector, which encompass fostering durability and adaptability of buildings as well 
as reducing waste and facilitating high-quality waste management.6 

European cities are facing mounting pressures from increasing urbanization, compounded 

by climate hazards such as extreme precipitation, heatwaves, heavy snowfall and rising 

sea levels. Adaptation measures to increase urban resilience to withstand climate hazards 

can take the form of technical measures (such as shading devices or planning adjustments 

such  as  building  design  and  orientation)  as  well  as  nature-based  solutions  (e.g.  green 

roofs, walls or facades that can regulate temperature variability and buffer precipitation 

peaks).  Both  types  of  measures  are  essential  to  incorporate  climate  impacts  within  the 

building sector. Nature-based solutions in combination with buildings also offer co-benefits 

such as improving air quality, biodiversity, local food production, and aesthetic appeal as 

well as reducing urban heat island effects, contributing to stormwater management and 
extending the life of the roof membrane.7, 8 

Against this background it is essential to foster (1) circular building design, (2) re-use of 

building  materials  to  use  construction  materials  with  low  embodied  carbon,  and  (3) 

sustainable adaptation in the urban environment for increased climate resilience. In order 

to successfully do so, key challenges need to be tackled: 

1)  Design  sustainable  buildings  taking  into  account  the  lifecycle  of  materials: 

Today’s commercial and residential buildings are rarely designed for extended use life or 

for  re-use  and  recycling  during  deconstruction.  Therefore,  buildings  end  up  being 

deconstructed before their functional end-of-life and large quantities of construction and 

demolition waste (CDW) arise, containing embodied carbon.  

2) Foster reuse and recycling of building materials and components: Low prices of 

virgin  construction  materials  and  low  value  of  end-of-life  materials  discourage 

deconstruction  practices  oriented  towards  re-use  and  recycling.  This  reduces  the 

availability and use of secondary construction materials.  

3) Apply technical adaptation measures that have limited negative side effects: 

One  key  challenge  is  to  increase  incentives  for  implementing  technical  adaptation 

measures and thus their uptake in buildings and the built environment. Different available 

measures  have  environmental  trade-offs,  e.g.  increasing  energy  and  water  demand. 

Climate-resilient approaches should aim for low negative side-effects. 

4)  Increase  awareness  and  implementation  of  nature-based  solutions:  A  key 

challenge  is  the  lack  of  awareness  of  nature-based  solutions  and  their  ability  to  deliver 

diverse benefits. This is compounded by a lack of technical expertise and a largely absent 

legal  framework  of  standards,  requirements  or  financial  support/incentives  to  increase 
implementation and secure long-term funding for maintenance costs.9  

6 European Commission (no publication date). Circular Economy - Principles for Building Design. 
https://ec.europa.eu/docsroom/documents/39984, accessed 4 August 2020.  
7 COM (2013). Adapting infrastructure to climate change. Commission Staff Working Document, SWD(2013) 
137 final, Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF 
THE REGIONS: An EU Strategy on adaptation to climate change. 
8 Kabisch, C., Stadler, J., Korn, H., Bonn, A. (2016): Nature-based solutions to climate change mitigation and 
adaptation in urban areas. BfN-Skripten 446. 
9 COM, 2013. 

    4 

 
 
 
 
 
Annex II: Factsheets and lessons learned 

Policy can help tackle these key challenges. In the following sections of this factsheet, we 

provide: 

•  An  overview  and  brief  analysis  of  relevant  provisions  implemented  in  different 

countries that address the above key challenges; 

•  A cursory overall assessment of the effectiveness of different national provisions; 

and 

•  Highlights of good practice examples. 

1.3 Provisions to address key challenges  

This section gives an overview of the policies considered to be most successful at tackling 

key  challenges  in  the  area  of  built  environment  adaptation.  To  operationalise  the 

challenges  and  allow  for  quantitative  estimations  on  selected  aspects,  the  country 

screening  looked  for  provisions  including  material  information  and  passports,  increased 

use of secondary materials in buildings and adaptation measures in building codes:  

•  Material information and passports: material passports, building logbooks and other 
approaches  increase  transparency  and  provide  information  along  a  building’s 

lifecycle on construction materials and building components used. This facilitates the 

re-use of building parts and deconstruction for recycling of construction materials, 

fostering a circular built environment. They help building stocks to be  viewed and 
used as ‘material banks.’10 
Increased use of secondary materials in buildings: provisions, incentives and quotas 

• 

(mandatory or voluntary) can increase demand for and use of secondary construction 

materials (e.g. recycled cement) in buildings, by facilitating or rewarding their use 

or setting a certain share of secondary materials to be used in a building or building 

components. 

• 

Adaptation measures in building codes: climate impacts (especially extreme events 

e.g.  storms,  flooding,  heatwaves)  can  be  integrated  in  requirements  for  buildings 

and the built environment. Approaches should support increased climate resilience 

of buildings and define recommendations and requirements for e.g. energy-efficient 

air conditioning or flood protection of buildings (e.g. check valves). 

Figure 1 provides an overview  of the policy  screening. Since countries vary in  size, the 

number of provisions does not necessarily reflect the effectiveness of the policy mix. While 

the  number  of  provisions  found  may  give  an  indication  of  the  breadth  and  diversity  of 

approaches, it should not be taken as the sole indicator for how effective the provisions 

are  for  tackling  key  challenges.  One  well-designed  policy  instruments  may  be  more 

effective  than  a  multitude  of  less  adequate  instruments.  Therefore,  an  additional 

qualitative discussion as well as insights from the good practice analysis  are provided in 

the remaining parts of the paper. 

10 The EU research project ‘Buildings As Material Banks’ (BAMB) investigated enablers for shifting to a circular 
built  environment.  URL:  https://www.bamb2020.eu/topics/circular-built-environement/,  accessed  4  August 
2020. 

    5 

 
 
 
 
 
Annex II: Factsheets and lessons learned 

s
n
o
i
s
i
v
o
r
p

f
o

r
e
b
m
u
N

18

16

14

12

10

8

6

4

2

0

Material information and passports

Increased secondary material use

Adaptation measures in building codes

Figure 1 - Key aspects of the built environment and adaptation per country 

6 

 
 
 
 
Annex II: Factsheets and lessons learned 

1.4 Effectiveness of the policy landscape to address key challenges  

This section presents an assessment of the overall policy landscape that a previous country 

screening  identified  as  relevant  for  the  covered  countries  and  regions.  The  assessment 

takes into account the diversity of instruments (regulation, pricing, support, information 

etc.), whether there are particularly interesting and innovative instruments, and whether 

the instruments identified together seem to be adequate to address the given challenges. 

The overview tables are followed by a discussion of policy instruments.  

In this context, the classification in Table 1 and Table 2 should be interpreted as follows: 

  Good  policy  landscape  with  at  least  one  innovative  instrument  targeting  built-

environment adaptation 

  Adequate  policy  landscape  with  instruments  that  could  in  the  future  better 

integrate built-environment adaptation in building renovation policies 

  Inadequate policy landscape, with no instruments identified in relation to the given 

challenges 

Not conclusive 

Table 1 – Legislative policies 

Built Environment and Adaptation – LEGISLATIVE POLICIES 

KEY CHALLENGES 

Designing 

Fostering 

Apply 

technical 

Increase 

sustainable 

reuse 

and 

adaptation 

awareness  and 

buildings  taking 

recycling 

of 

measures 

that 

implementation 

into  account  the 

building 

have 

limited 

of 

nature-

lifecycle 

of 

materials  and 

negative 

side-

based solutions 

materials 

components 

effects 

Belgium 

Croatia 

Denmark 

France 

Germany 

Greece 

Ireland 

Italy 

Lithuania 

Netherlands 

Poland 

Portugal 

Romania 

Spain 

Sweden 

UK 

Norway 

USA 

7 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Table 2 – Non-legislative policies 

Built Environment and Adaptation – NON-LEGISLATIVE POLICIES 

KEY CHALLENGES 

Designing 

sustainable 

Fostering  reuse 

Apply 

Increase 

and recycling of 

technical 

awareness  and 

buildings 

taking 

building 

adaptation 

implementation 

into  account  the 

materials  and 

measures  that 

of nature-based 

lifecycle 

materials 

of 

components 

have 

limited 

solutions 

negative  side-

effects 

Andalusia 

Tirol 

BW 

Silesia 

Umea 

Belgium 

Croatia 

Denmark 

France 

Germany 

Greece 

Ireland 

Italy 

Lithuania 

Netherlands 

Poland 

Portugal 

Romania 

Spain 

Sweden 

UK 

Norway 

USA 

Andalusia 

Tirol 

BW 

Silesia 

Umea 

1) Design sustainable buildings taking into account the lifecycle of materials  

As the production of construction materials is associated with significant greenhouse gas 

(GHG) emissions, more circular building design can help slow down and reduce the need 

for  new  construction  materials,  and  help  achieve  emissions  reductions.  Related  key 

challenges are to integrate circularity into existing architectural and engineering education 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

and practices as well as into building owners’ and investors’ decision-making routines. This 

requires coordination, dialogue and efforts across building value chains. 

Country research shows a diversity of approaches that aim to foster sustainable building 

design and promote a lifecycle perspective regarding environmental impacts of materials 

used in construction. Across the differing provisions found at national and regional level, 

common efforts encompass:  

• 

Increasing  the  transparency  of  building  material  use  via  the  use  of  material 

passports  and  building  logbooks  (e.g.  the  manual  for  future-oriented  building 

projects (GRO) of the Facility Company of the Flemish government in Belgium, the 

Circle  House  Lab  in  Denmark  and  the  Dutch  material  passport  public  platform 

Madaster),  standards,  manuals  and  product  declarations  following  lifecycle 

thinking,  all  of  which  facilitate  public  procurement  and  implementation  of  pilot 

projects.  Furthermore,  some  countries  and  regions  have  put  in  place  legal  acts 

promoting  climate  protection  that  stipulate  applying  lifecycle  thinking  and 

considering  lifecycle  costs  in  public  procurement  (e.g.  section  13  in  the  Federal 

Climate Protection Act in Germany and section 7 in the Law for the promotion of 

climate protection in the German region of Baden-Württemberg).  

•  Encouraging circularity and long building lifetime in the planning of new buildings, 
e.g.  by  adopting  legislation  that  stipulates  design  for  longevity  and  disassembly 

legislation  (a  relevant  example  is  the  Decision  promulgating  the  Building  Act  in 

Croatia),  and  improving  information  flows  along  with  building  projects  through 

building  information  modelling  (e.g.  the  Belgian  Tool  to  Optimise  the  Total 

Environmental impact of Materials (TOTEM) and provisions in the National Action 

Plan for Construction Waste 2017 -2020 of Norway). 

•  Funding, research and development as well as the implementation of pilot projects 
for  circular  building  design  and  reductions  in  resource  use  (e.g.  the  “Circular 

Construction  Challenge”  launched  by  the  Danish  philanthropic  association 

Realdania) to inspire replication or development of pilot projects elsewhere. 

For  some  countries  and  regions,  the  country  research  yielded  no  or  only  very  few 

provisions  for  tackling  the  key  challenges.  In  such  cases,  based  on  the  available 

information from country research, the policy landscape was considered not conclusive to 

undertake an assessment (e.g. for the two  circular economy-related key challenges this 

applies  to  Andalusia,  Romania  and  Lithuania,  and  for  legislative  provisions  to  Denmark 

and France as well as to the Alpine, Andalusia, Silesia and (partially) Baden-Württemberg 

regions). 

2) Fostering reuse and recycling of building materials and components 

Given low demand for secondary construction materials, one of the key challenges is to 

step up further research and development in the sector to ensure better performing, good 

quality  secondary  materials.  Furthermore,  as  building  designers,  construction  material 

manufacturers,  architects and building owners  still have many reservations  about using 

secondary materials (also because of uncertainty about their performance, which can 

create problems in relation to the building warranty), another key challenge is to increase 

acceptance of and demand for secondary construction materials. 

Country research shows a diversity of approaches that aim to foster reuse and recycling 

of  building  materials  and  components.  Although  differing  in  their  approaches,  the 

provisions identified as relevant have in common the promotion of:  

9 

Annex II: Factsheets and lessons learned 

•  Use of recycled content and hence of secondary raw materials in buildings 
•  Circularity in the renovation and reuse of abandoned materials and/or abandoned 

buildings  

•  Reductions in the amount of construction waste. 

Relevant approaches encompass national plans, legislation and standards that foster and 

stipulate  the  use  of  secondary  materials  in  buildings,  in  many  cases  referring  to 

environmental product declarations (e.g. the Sustainable construction evaluation system 

for  federal  buildings  in  Germany).  Relevant  national  plans  include,  for  instance,  the 

government-wide  programme  for  a  circular  economy  in  the  Netherlands  by  2050,  the 

Portuguese  Integrated  National  Energy  and  Climate  Plan  2021-2030  and  the  Swedish 

National  Waste  Management  Plan.  Regarding  legislation,  relevant  examples  include  the 

Decision promulgating the Building Act in Croatia, the German Circular Economy Act and 

the Polish Regulation of the Minister of the Environment on recycling levels, preparation 

for  reuse  and  recovery  by  other  methods  of  certain  municipal  waste  fractions.  For 

standards,  e.g.  the  Italian  Decree  no.  186  is  a  relevant  example,  which  implements  a 

standard for the identification of non-hazardous waste for recovery requiring a series of 

practices to be followed for the recycling and reuse of materials from the construction site, 

with  details  including  the  percentage  of  recycling  allowed  for  new  materials.  Several 

countries  have  implemented  provisions  that  foster  the  consideration  of  environmental 

criteria  in  public  procurement,  which  make  having  environmental  information  available 

increasingly  important  in  procurement  decisions  (e.g.  in  Belgium,  Croatia,  Germany, 

Greece, Italy, the Netherlands, Norway).  

New  routines  and  guidelines  to  facilitate  the  reuse  of  building  materials  or  components 

include pre-demolition inventories as recommended in the EU Construction and Demolition 

(C&D) Waste Protocol and Guidelines. Such inventories (e.g. a proposal for supervision of 

the dismantling of buildings and recover deconstruction waste in the Brussels region, in 

Belgium) oblige applicants for demolition permits to draw up a pre-demolition inventory 

to list the different waste streams produced on the site and provide a management system, 

thus encouraging recycling and reuse through better knowledge of the waste produced. In 

addition, some countries (e.g. Belgium and Croatia) put in place requirements for selective 

deconstruction,  requiring  dismantling  operations  to  be  organised  so  that  reusable 

elements  are  effectively  dismantled  and  recovered  for  introduction  into  a  reuse  chain. 

However,  systematic  planning  including  waste  management  during  the  renovation 

process, as recommended in the EU C&D Waste Protocol, is not yet common practice. 

In addition, provisions found for some countries yielded approaches that discourage the 

use of primary construction minerals,  e.g.  via a charge  on aggregate  (sand, gravel and 

limestone) extraction in the UK (aggregates levy) or a prohibition of setting up a technical 

landfill for most construction and demolition waste in the Belgian region Wallonia. 

Furthermore,  information  and  labelling  also  help  foster  increased  use  of  secondary 

materials in buildings. For example, the Italian brand 'Plastic second life', an environmental 

product  certification  system  dedicated  to  materials  and  products  obtained  from  the 

recycling of plastic waste, certifies the recycled content and  traceability in products. For 

some  countries  and  regions,  the  country  research  yielded  no  or  very  few  provisions  to 

tackle  these  key  challenges.  In  such  cases,  based  on  the  available  information  from 

country research the policy landscape was considered inadequate (e.g. for the two circular 

economy-related key challenges this applies to Andalusia, Lithuania, Romania and Silesia). 

10 

 
 
Annex II: Factsheets and lessons learned 

3) Apply technical adaptation measures that have limited negative side-effects  

The country review highlighted a number of diverse approaches that aim to support the 

application  of  technical  adaptation  measures  to  increase  climate  resilience  of  buildings. 

Although  differing  in  their  approaches,  the  provisions  identified  as  relevant  have  in 

common the promotion of: 

•  Using and collecting rainwater around buildings, e.g. by cisterns, tanks 
•  Sun protection and shading on and in buildings 
•  Efficient water use in and around buildings 
•  Protection against flooding and landslides 
•  Providing information and data on local climate impacts (e.g. flood risk) which can 

be used by municipalities to adjust local approaches. 

Reviewed legislative approaches include grants/funding for the construction of rainwater 

collection  (e.g.  municipalities  within  Germany  and  Baden-Württemberg)  and  sun 

protection  and  shading  measures  (e.g.  Andalucia).  Regulations  are  in  place  to  avoid 

overheating  of  buildings,  e.g.  including  technical  guidelines  (e.g.  Ireland,  Norway). 

Technical regulations also concern protection against flooding and landslides (e.g. Norway) 

and ordinances and technical regulations are in place regarding water conservation and 

the use of water-efficient products within and around buildings (e.g. USA, Sweden). 

Reviewed  non-legislative  measures  include  initiatives  on  providing  and  promoting 

information  and  data  platforms  highlighting  local  climate  impacts  that  can  guide 

municipalities  in  designing  legislative  and  non-legislative  measures  (e.g.  Denmark, 

Ireland,  Norway).  Further  information  platforms  are  promoting  rainwater  collection  for 

private homes (e.g.  Germany). Guidelines and support programmes are  established for 

climate-friendly construction, protection measures on buildings against extreme events, 

passive houses including low energy use for cooling (e.g. Germany and Tirol). Certification 

programmes,  rating  systems  and  labels  for  buildings  include  water  efficiency  as  a 

performance category (e.g. USA). 

Some measures are designed to reduce possible negative side-effects of adaptation, for 

example through technical regulations promoting passive cooling and ventilation to avoid 

additional energy use for air conditioning (e.g. Norway). Conversely, resilience to climate 

change  is  occasionally  built  into  technical  mitigation  measures.  For  example,  the  US 

Department  of  Energy  prepared  a  note  on  recommended  design  specifications  for 

photovoltaic systems to limit hurricane damage. It includes specifications for fasteners but 

also recommend using modules which have a high rating for front and back load. These 

additions to technical regulations and standards for photovoltaic systems might be useful 

in other areas facing high wind speeds. 

For  a  number  of  countries  and  regions,  there  was  not  enough  available  information  to 

undertake an assessment. 

4) Increase awareness and implementation of nature-based solutions  

Country  research  shows  a  diversity  of  approaches  to  increase  awareness  and 

implementation  of  nature-based  solutions.  Although  differing  in  their  approaches,  the 

provisions identified as relevant have in common the promotion of:  

•  Constructing green or ‘productive’ roofs, terraces or vertical walls 
•  Using ecological materials in work on the envelope of buildings 

11 

 
Annex II: Factsheets and lessons learned 

•  Creating open and permeable surfaces to fight against flooding and support water 

management 

•  Research  to  increase  the  evidence  base  and  create  support  for  nature-based 

solutions. 

Relevant legislative approaches encompass grants/subsidies for the construction of green 

or  ‘productive’  roofs  (e.g.  in  Belgium,  Baden  Württemberg  and  Germany)  or  terms, 

conditions and standards (e.g. in Greece, Baden-Württemberg, Germany) that foster and 

stipulate the use and planting of ecological materials in, on or around buildings (sometimes 

as part of broader water management strategies, as in Portland, USA).  

Non-legislative  measures,  which  were  far  more  prevalent  than  legislative  measures, 

include  initiatives  to  encourage  sustainable  architecture,  introduce  permeable  and 

vegetated services in building renovations or reconstructions (e.g. in Belgium, Germany), 

foster  citizen-led  revegetation  projects  in  public  spaces  (Belgium),  increase  knowledge 

and  evidence  on  nature-based  solutions  through  research/pilot  projects  (e.g.  Belgium, 

Greece, Germany, Netherlands), and raise awareness of nature-based solutions as a tool 

for e.g. reducing flood risks (Ireland) or sustainable urban development (Germany).  

the majority of countries and regions, the research yielded no or very few provisions and 

was not considered conclusive to undertake an assessment of the policy landscape. 

1.5 Highlighting good practice examples 

Based on the results of the previous research as well as on expert knowledge, this section 

highlights  selected  good  practice  examples.  Each  example  fulfils  one  or  several  of  the 

following selection criteria: innovation (new mechanism, triggering innovation, scaling up 

innovation), impact (on EU objectives, energy savings, CO2 emissions reduction, potential 

renovation  impact),  ease  of  implementation  (including  transferability,  scalability, 

transaction and administrative costs, budget (in-)dependency, compatibility with existing 

legislative/policy framework) and coverage of diverse jurisdictions and climatic zones.  

1) Built environment 

Country 

Policy 

Croatia 

Building 

(Zakon 

gradnji) 

Act 

o 

Brief description 
•  Article  15  of  the  Building  Act  (most 
recent  version,  in  force  since  28 
December  2019)  stipulates 
that 
designed, 
"buildings  must 
constructed  and  removed  in  such  a 
way that the use of natural resources 
is sustainable, and in particular must 
guarantee the following: 

be 

Source 

Croatian 

Parliament 

o  Reuse  or  recyclability  of  the 
building,  its  materials  and 
parts after removal 
o  Durability of the building 
o  Use 

environmentally 
friendly  raw  materials  and 
secondary  materials 
in 
buildings” 

of 

12 

 
 
Annex II: Factsheets and lessons learned 

•  Such  a 

legal  stipulation  to  use 
secondary  materials  in  construction 
works sets an effective framework to 
foster  circular  design  and  buildings 
and  is  rare  across  the  countries 
analysed.  

Denmark 

Circle 

House 

Lab 

•  Multi-stakeholder  exchange  platform 
and laboratory for experimenting with 
circular  building  solutions  across  the 
and 
industry. 
discoveries from Circle House Lab will 
be  updated  and  shared  on  their 
webpage  and  in  a  cloud  folder,  for 
everyone to access. 

knowledge 

The 

•  The  Circle  House  Lab  aims 

to 
accelerate the transition to a circular 
economy 
in  the  Danish  building 
industry by: 

logbooks 

o  Developing  solutions  and 
standards  such  as  digital 
building 
on 
selective  demolition,  design 
for  disassembly  and  circular 
the 
construction 
building 
to 
demographic fluctuations) 
Providing advice to renew the 
traditional  business  models 
and 
the 
legislation supports recycling 
and circular construction. 

(adapt 
stock 

to  ensure 

that 

o 

•  Tackling  the  key  challenges  requires 
multi-stakeholder  dialogue  along  the 
building value chain. The Circle House 
Lab provides a promising platform for 
such dialogue and for joint progress. 
•  Section  45  “Obligations  of  the  public 
sector”  of  the  Circular  Economy  Act 
obliges,  among  others,  authorities 
and  agencies  to  contribute,  through 
their conduct, including procurement, 
to  promote  a  circular  economy  in 
order  to  conserve  natural  resources 
and  to  ensure  the  protection  of 
human health and the environment in 
the  generation  and  management  of 
waste.  For  this  purpose,  they  shall 
examine  inter  alia  in  procurement 
whether  products  can  be  used,  that 
are  resource-efficient,  low  in  waste, 
and 
repairable, 
recyclable.  

low-polluting 

•  Green  public  procurement  is  a  key 
instrument 
for 
secondary  materials  in  buildings  and 
to build up secondary markets. 

to  push  demand 

•  The  transition  agenda  describes  the 
strategy 
for  achieving  a  circular 
construction  economy  in  2050  and 
contains  specific  recommendations 

Germany 

Circular 

Economy 

Act 

(Kreislaufwirt-

schaftsgesetz 

KrWG) 

The 

Transition 

Netherlands 

Agenda Circular 

Construction 

BloxHub 

BMU 

Transition 

Agenda 

Circular 

13 

Annex II: Factsheets and lessons learned 

Economy 

(Transitie-

Agenda 

Circulaire 

Bouweconomie) 

Spain 

Demolition 

Waste  National 

Plan 

for 

the 

period  2016  – 

2022 

(Plan 

Estatal  Marco 

de  Gestión  de 

Residuos 

'PEMAR'  2016-

2022) 

UK 

Aggregates levy 

for  the  period  2018-2021.  It  was 
drawn  up  by  a  transition  team  of 
experts  from  science,  government 
and  market  parties.  The  agenda 
recommends that: 

Construction 

Economy 

o  A  decision  on  the  use  of  a 
materials  passport  is  made 
by 2020 

o  All  government  procurement 
must be circular by 2030 
o  Circular  construction  should 
integral  part  of 

be  an 
education by 2021 

o  Circularity  is  introduced  in 

building codes. 

• 

circular  design 

Integrating 
into 
building  codes  and  education  of 
building professionals promises long-
term  effects  towards  making  circular 
buildings the new default. 

•  The  national  plan  aims  to  reduce 
resource  use,  increase  the  recycling 
rate and improve resource efficiency. 
The  plan  has  a  specific  chapter 
targeting  construction  waste  and 
to  promote 
demolition 
actions for reutilisation and recycling 
of  construction  material  to  ensure 
that  Spain  complies  with  legal  EU 
objectives.  

in  order 

•  The  plan  pursues  a  diversity  of 
objectives  and  suggests  an  effective 
policy mix of, inter alia: 

o  Research,  development  and 
the 
regarding 
innovation 
durability 
recycling 
and 
possibility of materials, which 
will play an important role in 
achieving 
recycling 
EU 
targets 
Increasing  taxes  (economic 
disincentives)  

o 

o  Encouraging 

the  use  of 

sustainable products.  

•  The  aggregates  levy,  a  tax  on  sand, 
gravel  and  rock  which  has  been  dug 
from  the  ground,  dredged  from  the 
sea in UK waters or imported, charges 
£2 per tonne of sand, gravel or rock.  
•  As  aggregates  are  a  key  building 
material,  increasing  their  prices  by 
taxing  them  provides  incentives  for 
using 
in  addition) 
secondary  materials  from  domestic 
sources for construction projects. 

(instead  or 

Construction 

and 

demolition 

waste 

management 

in Spain 

UK 

government 

14 

 
 
 
Annex II: Factsheets and lessons learned 

2) Adaptation and nature-based solutions 

Country 

Policy 

Germany 

Bundesweite 

Initiativen 

zur 

Stadtgrün  

(Nationwide 

Initiative 

– 

Green  in  the 

City)  

Ireland 

Dublin 

Climate 

Action Plan – 

Nature-

based 

solutions 

The 

City 

Deal 

Netherlan

Klimaatadapt

ds 

atie 

(City 

Deal 

Climate 

Adaptation) 

USA 

City 

of 

Portland 

Green 

Building 

Policy 

Germany  Gräfelfingen 

support 

programme 

for  rainwater 

utilisation 

•  Brief description 
•  The "Green in the City" initiative and the new 
urban  development  support  programme 
"Zukunft Stadtgrün" (Future City Green) focus 
on urban green infrastructure. This means that 
for the first time there is the possibility of an 
area-wide  promotion  of  green  roofs  and 
facades  within  the 
framework  of  urban 
development funding. 

Source 

City 

of 

Stuttgart 

solutions 

•  The Dublin Climate Action Plan, developed by 
the  Dublin  City  Council  in  2019,  includes  a 
for 
chapter  on  nature-based 
adaptation measures. Planned policies include 
pilot projects for green roofs on civic buildings 
(awaiting  funding),  development  of  a  Green 
Infrastructure Strategy for the region (2021), 
increasing flood resilience, e.g. implementing 
sustainable  urban  drainage  guidelines 
in 
council buildings, flood awareness campaigns 
and flood alleviation/ adaptation schemes. 
•  Cooperation  agreement  between  17  public 
partners  and  17  (semi)private  cooperation 
partners  and  the  central  government  to 
implement pilot projects to develop new forms 
of  governance  and  financing  structures  and 
innovative  solutions.  Two  of  four  focus  areas 
concentrate 
area 
development (for public and private parties in 
and 
development, 
management); 
and 
integration  of  nature-based  solutions  and 
ecosystem  services  (to  examine  added  value 
and demonstrate feasibility). 

renovation 
development 

design, 
and 

climate-robust 

on 

•  The  City  of  Portland  implemented  a  Green 
Building Policy in 2001, which was updated in 
2015  with  Resolution  37122.  The  policy 
obligates  new,  occupied  city-owned  buildings 
to  achieve  Leadership 
in  Energy  and 
Environmental Design (LEED) Building Design 
and  Construction  (BD+C)  at  the  Gold  level. 
They should also include eco roofs and storm 
water  management  strategies  and  related 
watershed  enhancement  strategies  in  their 
design  and  provide  adequate  bicycle  parking 
opportunities  (equal  to  25%  of  the  target  in 
the City’s Climate Action Plan).  

•  The municipality of Gräfelfing is promoting the 
construction  of  cisterns  to  collect  and  use 
rainwater for garden irrigation and/or service 
water use. The amount of funding depends on 
the  size  of  the  cistern.  Eligible  to  apply  are 
building  owners  (private  owners,  owners' 
associations),  as  well  as  tenants,  provided 
that  the  landlord's  declaration  of  consent  is 

Dublin City 

Council 

City  Deal 

Klimaatad

aptatie  

City 

of 

Portland 

Municipalit

y 

of 

Gräfelfing 

15 

 
 
Annex II: Factsheets and lessons learned 

(Municipality 

of Gräfelfing) 

Germany 

Information 

• 

available.  The  municipality  of  Gräfelfing 
supports 
rainwater 
the  construction  of 
cisterns,  the  devices 
for  the  supply  of 
rainwater  and  the  necessary  installations  for 
the use of rainwater. 
Information on rainwater use in homes related 
to  financial  support,  advantages,  costs  and 
benefits, basis for calculation. 

platform 

for 

rainwater 

utilisation  in 

homes 

Denmark 

Climate Atlas 

(Klimaatlas) 

Ireland 

Building 

Regulation  - 

Technical 

Guidance 

Part L 2019 

Building 

Control  Act 

(1990) 

Norway 

Building 

Technical 

Regulations 

data 

•  The tool is a nationwide climate atlas based on 
the 
own 
Intergovernmental  Panel  on  Climate  Change 
(IPCC). Data is free and available on the DMI 
website. 

from 

data 

and 

•  The  Climate  Atlas  provide  an  indication  of 
areas  with  particular  risk  of  storm  surge  and 
cloudburst,  and  thus  the  risk  of  flooding  in 
Denmark  in  the  future.  This  tool  gives  the 
climate  data  so  municipalities  can  take  the 
necessary  precautions  and  guard  citizens, 
infrastructure  and  buildings  against 
the 
expected extreme weather in the future. 

•  The  Building  Regulation  on  conservation  of 
fuel  and  energy  includes  regulations  on 
"Limiting Heat Gains" in residential buildings. 
and 
guidance  to  reduce  and  avoid  solar 
overheating  (layout,  solar  shading, 
thermal mass, good ventilation). 

Recommendations 

o  1.3.5.2. 

are 

based 

categorised 

•  The  building  code  prescribes  minimum 
measures that need to be taken in protection 
against  natural  stresses  (e.g.  flooding  and 
landslides).  Requirements  are  linked  to  the 
level  of  risk  in  the  construction  area.  All 
buildings 
on 
functionality. In particular, buildings with high 
public  importance,  like  police  stations,  or 
buildings with vulnerable people, like hospitals 
and  schools,  can  only  be  constructed  in  low-
risk  zones.  Other  buildings  will  get  a  safety 
class  which  defines  the  risk  they  may  be 
exposed  to  in  terms  of  floods.  The  technical 
regulation  also  includes  a  section  on  thermal 
comfort  which  describes  the  recommended 
temperatures, passive measures and opening 
of windows and doors. 

USA 

WaterSense 

program 

•  WaterSense 

is  a  voluntary  partnership 
sponsored by the US Environmental Protection 
Agency  (EPA),  which  labels  water-efficient 
products,  new  homes  and  programmes  and 
provides resources on how to save water. For 

Homeown

ers' 

Associatio

n  Bavaria 

e.V. 

Danish 

Meterologi

cal 

Institute 

(DMI) 

Building 

regulation 

– 

Technical 

guidance 

Norwegian 

Building 

Authority 

US 

Environme

ntal 

Protection 

16 

 
Annex II: Factsheets and lessons learned 

WaterSense  labelled  homes,  the  following 
issues are included: 

o 

leaks, 

criteria: 

service 
Indoor 
pressure, 
delivery, 
hot  water 
plumbing  fixtures,  dishwashers  and 
clothes washers 

Tirol 

Measures 

catalogue: 

Climate-

friendly 

construction 

o  Outdoor  criteria:  landscape  design, 
irrigation system, pools and spas. 

•  The  measures  catalogue  includes  synergy 
measures between climate protection, climate 
change  adaptation  and  living  comfort  (heat 
and cold insulation and ventilation concepts), 
as  well  as  measures  to  adapt  to  a  changed 
natural  hazard  potential  (flood  protection)  
and  ensure  drainage  infrastructure  can  cope 
with increased rainfall. 

Agency 

(EPA) 

Office 

of 

the 

Tirolean 

Provincial 

Governme

nt  Energy 

Tirol 

1.6 Concluding assessment 

Assessment of impact per type of policy instrument 

For the strategic area “built environment and adaptation”, four key challenges have been 

defined:  

1.  Design sustainable buildings taking into account the lifecycle of materials 

2.  Foster reuse and recycling of building material and components 

3.  Apply technical adaptation measures that have limited negative side-effects 

4.  Increase awareness and implementation of nature-based solutions. 

The  country  research  revealed  a  variety  of  provisions  and  approaches  at  national  and 

regional  level  aimed  at  tackling  the  above  challenges.  There  is  a  mix  of  legislative  and 

non-legislative  policies  in  place  to  address  the  first  two  challenges,  but  legislative 

provisions constitute a higher share of provisions relating to the second. The main reason 

seems to be that increasing re-use of building materials and components fits with existing 

national and regional building or waste legislation, while approaches for circular building 

design appear to focus on improved information flows and transparency (for instance via 

building information modelling) as well as funding for research and development and pilot 

projects.  However,  legislative  provisions  also  play  a  role  towards  tackling  the  first  key 

challenge,  for  instance  when  stipulating  design  for  longevity  and  disassembly  or  via 

legislation on climate protection, which fosters the integration of lifecycle thinking for low-

carbon  materials.  Alongside  information  flows  and  lifecycle  thinking,  incentives  play  a 

relevant  role  too.  Environmental  product  declarations  and  labels  on  circular  building 

materials facilitate green public procurement, where they provide proof that environmental 

criteria  are  being  fulfilled  during  procurement.  Linking  incentives  for  green  public 

procurement with disincentives, such as prohibiting landfilling of construction materials or 

charging for extraction of primary aggregates, might form a promising policy mix. Overall, 

country  research  findings  appear  to  be  in  line  with  key  principles  highlighted  by  the 

European Circular Economy Principles for Building Design.  

The identified set of policies constitutes a promising menu to build effective policy mixes 

for  contributing  to  GHG  emission  reductions.  While  regulatory  approaches  –  when 

combined with effective administration, monitoring and enforcement – form an important 

baseline to set conducive framework conditions and motivate compliance, economic and 

17 

Annex II: Factsheets and lessons learned 

fiscal incentives to help create markets and reward circular approaches (or/and penalise 

linear ones) are equally important in order to foster innovation and support “first movers” 

in  more  sustainable  markets.  As  innovation  thrives  where  peer  learning  takes  place, 

providing room for networking and dialogue across the building sector (and its value chain 

stages)  is  essential  to  enshrine  progress  towards  circular  and  low-carbon  buildings  and 

construction  on  the  supply  side.  This  shows  the  interconnectedness  of  different  policy 

instruments: a sound legal basis is needed to provide guidance (e.g. secondary material 

quotas or enshrining in legislation the obligation to monitor and consider embodied carbon 

of different materials in building design and procurement) and sanction non-compliance. 

This in turn helps establish a level playing field across market actors in the building sector. 

At the same time, specific incentive structures can give circular products and services a 

competitive edge. This is likely to function best (or only) if all key players are involved and 

engage in dialogue and joint action based on optimal flows of information. On the demand 

side, information flows, facilitated by credible labels and certification, enable owners and 

purchasers  of  buildings  and  building  services  to  identify  and  opt  for  circular  solutions. 

Adding  financial  incentives  for  making  the  “right”  choices  will  assist  consumers  in 

demanding circular approaches. For incentives  (e.g.  subsidies) to work effectively, they 

need to be accompanied, inter alia, by product declarations and/or labels in order to enable 

public  and  private  procurement  to  clearly  identify  subsidised  products  and  make  use  of 

incentives.  Similarly,  without  regulatory  backing,  incentives  may  face  legal  challenges 

from market players whose products are not subsidised. Therefore, the potential impact 

of individual instruments should be assessed as part of a broader strategic policy mix and 

roadmap that aims to maximise synergies and alleviate trade-offs. 

Regarding  challenge  3,  a  number  of  legislative  and  non-legislative  provisions  are 

established. In most countries a mix of both approaches is in place. Legislative approaches 

include technical regulations focusing on flooding, landslides, water efficiency and thermal 

comfort  within  the  building.  A  good  example  is  the  Building  Technical  Regulation 

established in Norway, which indicates acceptable local risk level according to the function 

of  the  building.  Further  legislation  focuses  on  mandatory  requirements  for  rainwater 

collection.  Grants,  subsidies  or  supporting  programmes  in  some  communities  and 

countries support the implementation of other legislation or are stand-alone instruments. 

The legislative provisions are partially combined with non-legislative approaches such as 

information  platforms,  e.g.  on  rainwater  collection  and  use  for  the  community  in 

Gräfelfing,  or  guidelines  on  implementation  of  climate-friendly  construction,  protection 

against extreme events or sun protection and cooling. Further information platforms and 

data promote climate impact information, which is necessary to indicate local risk levels 

for e.g. flood risk. Negative side-effects are addressed by more general approaches, e.g. 

the  concept  of  passive  houses  which  combine  a  number  of  advantages  including  lower 

energy use for cooling.  

For effective implementation and uptake of technical adaptation measures, a sound mix 

of policies is essential, especially to avoid potential negative side-effects of a number of 

technical adaptation measures. Mandatory technical regulations and building codes could 

have  a  vital  impact  on  increasing  climate  resilience  of  buildings,  including  e.g.  sun-

shading,  flood  protection  and  water  efficiency.  They  should  include  a  focus  on  passive 

houses, passive cooling systems, etc. to limit negative side-effects of increasing energy 

use mainly due to active air conditioning. 

18 

Annex II: Factsheets and lessons learned 

Other  aspects  are  difficult  to  include  in  technical  regulations  as  they  depend  on  the 

individual building’s location and local circumstances. For example, adjusting the direction 

that  windows  and  certain  rooms  face  can  be  an  effective  instrument  to  limit  cooling 

demand,  but  can  only  happen  through  guidance  and  information  for  planning  and 

architecture offices and house builders.  

Certification programmes and labels cover a number of environmental issues such as water 

efficiency  and  reuse,  energy  efficiency  and  waste  management.  They  can  give  positive 

incentives  to  include  these  aspects  in  building  projects.  Some  examples  show  that 

certification  and  label  systems  can  be  included  in  local  regulations  and  then  become 

mandatory for new houses. 

While reducing GHG emissions is not the main objective of technical adaptation measures, 

well-designed  policies  should  aim  to  limit  the  increase  of  GHG  emissions  linked  to 

responses such as active cooling systems. 

Regarding the challenge of nature-based solutions, only a limited number of national and 

regional level  examples were identified. In the case  of Germany, which had the largest 

number of examples, the majority of measures were legislative in nature and concerned 

regional or city-level green roof planning instruments.  A  range of subsidies, grants and 

planning requirements supported the construction of new green roofs and/or facades as 

well as the retrofitting of existing buildings. As responsibility for these policies falls in the 

hands of the regions (Länder), it is not surprising that this is reflected in the assessment. 

Across the remaining countries and regions, only Belgium had a comparably high number 

of measures (15). The lack of measures in the remaining regions/countries can possibly 

be attributed to the  chosen focus  of  research  related to nature-based solutions. As this 

term is relatively new and largely adopted at European but not Member State or regional 

level, robust searches would also need to include similar sectoral terms such as green (and 

blue) infrastructure, ecosystem-based adaptation, natural water retention measures, etc. 

to  gain  a  more  holistic  picture  of  the  legislative  and  non-legislative  measures  being 

implemented. 

Within the last challenge, we focused on increasing awareness with a focus on guidance, 

information platforms and support programmes to increase awareness and knowledge on 

nature-based  solutions.  As  is  well  known,  these  types  of  instruments  have  less  direct, 

more indirect effects on GHG emissions as well as other environmental problems such as 

heat island effects or urban flood events. 

The main target groups for these measures are local public authorities and private and 

public property owners. Measures need to be implemented at local level, as communities 

and  cities  are  mainly  responsible  for  local  planning  processes  and  need  to  be  aware  of 

benefits  including  positive  side-effects  of  nature-based  solutions.  This  also  means  that 

activities at EU level are limited. A major issue is that nature-based solutions are not well 

known;  they  may  be  associated  with  increased  maintenance  costs,  or  there  is  low 

awareness  of  the  the  positive  side-effects,  such  as  improved  air  quality,  recreational 

potential  and  biodiversity.  Providing  information  and  increasing  awareness  is  a  pre-

condition for increasing uptake of local nature-based solutions, which could additionally be 

supported by financial support programmes, grants, etc.  

19 

 
 
Annex II: Factsheets and lessons learned 

Ease of implementation per type of policy instrument  

Whether or not a policy instrument can (more or less) be easily implemented depends on 

several  contextual  factors,  some  of  which  public  policy  can  control  or  influence,  while 

others  are  independent  of  it.  Within  reach  of  public  policy  are  the  capacity  and  will  of 

political actors and administrations to lay down an ambitious legal base towards a circular 

and  low-carbon  built  environment,  and  to  provide  resources  needed  to  implement  and 

monitor this legal base. Regulations therefore constitute a policy instrument that can be 

easily implemented, if a country’s political economy is conducive to passing this kind of 

sustainable legislation. Furthermore, as legislation relating to buildings is in place across 

all EU Member States, good options to anchor circular building approaches already exist 

and make passing such laws easier than if built from scratch. The EU’s Waste Framework 

Directive  stipulates  national  transposition  of  requirements  relating  to  e.g.  reducing 

construction  and  demolition  waste,  so  there  is  existing  political  momentum,  which  can 

open up so-called policy windows in several countries to push for more circular approaches 

in legislation.  

Similarly, financial and fiscal means to incentivise circular approaches, whether  through 

green public procurement (e.g. giving clear guidance and weighting for circularity criteria) 

or  increasing  the  price  for  using  virgin  building  materials,  can  be  promoted  across 

countries where both political will and the public budget allow. But while incentives may 

function relatively independent of context as a policy instrument type, sectoral specificities 

should be borne in mind when designing incentive levels and the purpose that, e.g. tax 

income, is used for. Here, setting up tax recycling schemes that channel tax income back 

to those paying the tax in order to ease their transition to a circular economy can increase 

acceptance and hence ease implementation. As debates on reduction of VAT for certain 

circular products and services at EU level show, changing tax schemes EU-wide is a very 

contentious  issue  affecting  Member  States’  fiscal  sovereignty  and  therefore  requires 

unanimous decisions. Hence, achieving tax agreements at EU level may pose a formidable 

challenge.  But  EU-level  processes,  such  as  the  Green  Deal  and  new  Circular  Economy 

Action Plan, can foster national-level action – e.g. on financial and fiscal incentives – by 

providing guidance on general policy orientation towards circular buildings.  

Setting up or supporting the set-up of networks and dialogue should be within easy reach 

of public policy, either by actively using contacts to establish them under public auspices, 

by providing physical meeting space, or by encouraging and becoming part of processes 

already set up by private actors. At European  level, for instance, the  European Circular 

Economy Stakeholder Platform serves as a network of networks and provides an exchange 

and meeting place for stakeholders (such as public authorities, businesses, trade unions, 

consumers, academia and civil society) to  share and scale up effective solutions at and 

across local, regional and national levels. 

In  general,  while  the  legal  basis  and  incentive  structures  should  be  uniform  and  hence 

apply across a jurisdiction, adapting sub-legal regulations and administrative procedures 

to regional and municipal/local contexts appears essential to increase the effectiveness of 

policy instruments. 

Technical  adaptation  measures  could  be  implemented  via  technical  regulations  and 

building  codes.  These  are  within  the  responsibility  of  national  or  regional  authorities; 

implementation  depends  on  e.g.  capacities,  political  will,  ongoing  policy  processes  and 

momentum (windows of opportunities). Recent weather events in many EU Member States 

mean adaptation policies are currently on the political agenda, with adaptation strategies 

20 

Annex II: Factsheets and lessons learned 

and actions plan being developed or adopted at national, regional and local levels. It should 

be possible to integrate instruments linked to the building sector with these. At EU level, 

the  ongoing  processes  linked  to  the  EU  adaptation  strategy  are  an  opportunity  to 

encourage national adoption of technical regulations on climate-resilient buildings.  

Standards are developed and adopted by standardisation organisations (mainly at national 

or  international  level,  e.g.  ISO,  DIN)  rather  than  by  governments.  The  integration  of 

adaptation therefore depends on awareness and interest within these organisations. One 

way to increase awareness could be to include the topic within national stakeholder and 

network  activities  organised  by  public  authorities  –  in  Germany,  for  example,  national 

stakeholder  dialogues  have  been  held  for  several  years,  including  topics  like 

standardisation for adaptation.  

In general, measures at EU level could support the delivery of information and knowledge 

regarding technical adaptation as well as nature-based solutions. To conserve resources 

and to increase impact, existing adaptation and biodiversity related portals could be used, 

e.g. portals such as the European Environment Agency Climate-ADAPT platform, which is 

used as an information hub for climate change and adaptation.  

However,  increasing  awareness  will  also  require  more  local  or  regional  networks  or 

dialogue processes. Local communities are responsible for planning processes for buildings 

and  their  surroundings:  to  overcome  this  challenge,  existing  city  networks  such  as 

Covenant  of  Majors  for  Climate  and  Energy  or  Climate  Alliance  should  be  used  to  raise 

awareness for adaptation of the built environment and used as multipliers to facilitate the 

initiation and implementation of local processes. 

21 

 
 
 
Annex II: Factsheets and lessons learned 

renovation and modernisation of the 
built environment 
Clean and sustainable mobility – Factsheet  

Author: Katharina Umpfenbach 

September 2020 

Tender N° ENER/C3/2019-468/03 

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

2.1 Introduction 

This  factsheet  provides  an  overview  of  how  different  policy  instruments  and  selected 

private initiatives can help to achieve European objectives and effectively address key EU 

challenges in the strategic area of clean and sustainable mobility. The findings draw 

upon  a  policy  screening  for  15  EU  Member  States,  3  non-EU  countries  and  5  European 

regions covering broadly the climatic zones of the EU. In addition, the factsheet draws on 

additional  information  provided  by  external  experts  as  well  as  on  the  long-standing 

expertise of the authors, meaning policy examples going beyond the researched country 

and region cases are occasionally added. The concluding assessment draws on the findings 

and detailed analysis of the good practice cases as well as on the in-house expertise of 

the partners.  

2.2 Clean and sustainable mobility 

The transport sector is a large and still rising source of greenhouse gas (GHG) emissions 
and  air  pollutants.11  For  transport  to  contribute  fairly  to  the  EU  target  of  cutting  GHG 
emissions by 40% by 2030, drastic changes are required. Car- and lorry-based mobility 

also has negative impacts  on  safety, space distribution and quality  of  life. Better urban 

design  and  planning  can  contribute  to  more  sustainable  transport  options,  including  by 

reducing  car  travel  and  shortening  daily  travel  distances  or  by  ensuring  that  new 

settlements are oriented to facilitate the use of public transport. Building design can also 

facilitate more sustainable transportation modes through, for example, providing charging 

infrastructure for electric vehicles or parking for bikes, including cargo bikes.  

New  buildings  and  developments  in  particular  present  an  opportunity  to  enable  their 

inhabitants to take up and maintain sustainable mobility patterns. They should contribute 

to  reducing  negative  external  impacts  of  transport  rather  than  exacerbating  them  (e.g. 

through increased urban sprawl). Strictly speaking, this strategic area is unlikely to reduce 

emissions of buildings per se. Electric mobility may even increase the electricity demand 

in  buildings  when  residents  charge  their  vehicles  at  home.  At  the  same  time,  electric 

vehicles  can  also  become  a  useful  element  in  a  modern,  intelligently  managed  energy 

system for a building. 

When  aiming  to  harness  the  potential  of  buildings  to  help  shift  mobility  pattern,  key 

challenges are:  

•  Creating a sustainable city layout  
•  Making buildings ready for e-mobility  
•  Securing increasing investments 

Creating a sustainable city layout: Today’s dominance of the car as the prime mode of 

individual  mobility  is  not  only  the  result  of  technological  developments  but  was  also 

enabled by city planners that saw private cars as the dominant mode of transport. A key 

challenge  is  to  overcome  this  post-war  paradigm  and  replace  it  with  a  vision  that  puts 

sustainable  options  such  as  walking,  cycling  and  electric  vehicles  at  the  centre. 

Acceptability for new types of mobility is a key concern given that new infrastructures will 

come  at  some  costs  for  existing  ones,  in  particular  roads  and  parking  for  cars.  New 

11 Eurostat (2019). Smarter, greener, more inclusive? – Indicators to support the Europe 2020 strategy. 

23 

 
 
Annex II: Factsheets and lessons learned 

approaches  have  to  be  socially  balanced;  they  require  convenient  alternative  transport 
options and they should be debated and explained extensively.12  

Making buildings ready for e-mobility: Analysis of potential decarbonisation pathways 

shows that electrification of transport is one of the most promising avenues for reducing 

the GHG emissions arising from individual mobility. While electric vehicles remain a niche 

technology  in  most  EU  member  states,  growth  rates  are  promising.  For  inhabitants  of 

multistorey buildings, the lack of easily available charging points can be a barrier when 

deciding whether to shift from a conventional car to an electric one. Providing for charging 

infrastructure both in and close to buildings is therefore critical to enabling electrification 
of the transport sector.13  

Securing increasing investments: An overarching challenge in the interplay of mobility 

and buildings is finance. Rising rents and property prices are a widespread social concern 

in  European  cities  that,  among  other  effects,  may  lead  to  urban  sprawl.  Any  additional 

increase in investment  required to build new  or  refurbish  existing dwellings to facilitate 

and promote sustainable mobility options can therefore become a social concern. Smart 

financing and support instruments are key to developing the infrastructures for tomorrow’s 
mobility needs while protecting social cohesion.14 

2.3 Provisions to address key challenges 

This section gives an overview of the policies considered to be most successful at tackling 

key challenges in the area of clean mobility. To operationalise the mobility challenge and 

allow for quantitative  estimations on  selected  aspects, the country screening looked  for 

provisions that would implement Article 8 of the Energy Performance of Buildings Directive 

(EPBD) 2018 on e-mobility, along with legislation beyond, urban planning instruments and 

approaches to finance urban planning.  

Figure  1  provides  a  quantitative  analysis  of  those  provisions  identified  in  the  policy 

screening.  Since  countries  vary  in  size,  the  number  of  provisions  does  not  necessarily 

reflect the effectiveness of the policy mix. While the number of provisions found may give 

an indication of the breadth and diversity of approaches, it should not be taken as the sole 

indicator  for  how  effective  the  provisions  are  for  tackling  key  challenges.  One  well-

designed  policy  instruments  may  be  more  effective  than  a  multitude  of  less  adequate 

instruments. Therefore, an additional qualitative discussion as well as  insights from the 

good practice analysis are provided in the remaining parts of the paper. 

Urban planning is a competence assigned to regional and local authorities in virtually all 

Member  States.  National  governments  can  influence  outcomes  to  a  varying  degree  by 

setting out principles or by providing funding, but most decisions are made at sub-national 

level. This makes an EU-wide assessment of provisions that aim at creating a sustainable 

city  layout  particularly  challenging.  Even  within  Member  States  the  variations  between 

measures  can  be  relatively  high.  For  the  search  term  ‘urban  planning’,  the  number  of 

identified  provisions  therefore  reflects  not  so  much  the  absolute  number  of  relevant 

12 Agora Verkehrswende (2017). Transforming transport to ensure tomorrow’s mobility. 
13 Velten, E.K., Stoll, T., Meinecke, L. (2019). Measures for the promotion of electric vehicles. Ecologic Institute, 
Berlin. Commissioned by Greenpeace e.V. 
14 Tomassini, M. et al. (2016). EU financial support to sustainable urban mobility and to the use of alternative 
fuels in EU urban areas. 

24 

 
 
Annex II: Factsheets and lessons learned 

provisions in each country or region, but the extent to which country researchers included 

subnational and local examples in the country data sheet in addition to their main focus 

on national level measures. 

With respect to charging infrastructure for electric vehicles, the picture is somewhat 

clearer. National governments have mostly implemented the obligation included in Article 

8 of EPBD on charging points for electric vehicles and ducting infrastructure (to support 

smart buildings) in national law or plan to do so. Moreover, many countries and regions 

provide financial support for the installation of charging points – a measure that addresses 

both the challenge of making buildings ready for e-mobility and the challenge of securing 

funding for sustainable mobility approaches in the built environment. 

By contrast, the country research provided limited results on funding instruments that 

address  other  issues  of  sustainable  urban  planning.  However,  rather  than  proving  that 

such instruments do not exist, this may reflect the difficulties of capturing such  a multi-

faceted issue through a country screening making use of only a couple of keywords applied 

across all countries and regions under study. 

25 

Annex II: Factsheets and lessons learned 

s
n
o
i
s
i
v
o
r
p

f
o

r
e
b
m
u
N

20
19
18
17
16
15
14
13
12
11
10
9
8
7
6
5
4
3
2
1
0

EPBD requirements

Charging infrastructure legislation

Urban planning

Approach to finance urban planning

Other

Figure 1 – Key aspects of clean and sustainable mobility per country 

26 

  
 
 
Annex II: Factsheets and lessons learned 

2.4 Effectiveness of the policy landscape to  address key challenges  - overview 

and description 

This section presents an assessment of the overall policy landscape that a previous country 

screening  identified  as  relevant  for  the  covered  countries  and  regions.  The  assessment 

takes into account the diversity of instruments (regulation, pricing, support, information 

etc.), whether there are particularly interesting and innovative instruments, and whether 

the instruments identified together seem to be adequate to address the given challenges. 

The overview tables are followed by a discussion of policy instruments.  

In this context, the classification in Table 1 and Table 9 should be interpreted as follows: 

Good  policy  landscape  with  at  least  one  innovative  instrument  targeting  clean 

mobility 

Adequate  policy  landscape  with  instruments  that  could  in  the  future  better 

integrate clean mobility in building renovation policies 

Inadequate  policy  landscape,  with  no  instruments  identified  in  relation  to  the 

given challenges 

Not conclusive 

This chapter provides a deeper analysis of the results of the country research with respect 

to  mobility.  In  particular,  it  provides  more  detail  on  the  types  of  instruments  used  for 

tackling the three key challenges: 1) creating sustainable city layouts, 2) making buildings 

ready for e-mobility, and 3) securing increasing investments. 

Overall,  the  majority  of  instruments  identified  in  the  mobility  area  are  legislative 

measures, portrayed in This section presents an assessment of the overall policy landscape 

that  a  previous  country  screening  identified  as  relevant  for  the  covered  countries  and 

regions.  The  assessment  takes  into  account  the  diversity  of  instruments  (regulation, 

pricing,  support,  information  etc.),  whether  there  are  particularly  interesting  and 

innovative instruments, and whether the instruments identified together seem adequate 

to address the given challenges. The overview tables are followed by a discussion of policy 

instruments.  

The given classification in Table 8 and Table 9 should be interpreted as follows: 

Good policy landscape with at least one innovative instrument targeting financing 

renovation 

Adequate  policy  landscape  with  instruments  that  could  in  the  future  better 

integrate financing in building renovation policies 

Inadequate  policy  landscape,  with  no  instruments  identified  in  relation  to  the 

given challenges 

Not conclusive 

27 

 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Table 8. This clearly results from a research focus on national-level action. At the regional 

and local level, information-based measures, best-practice sharing and support through 

handbooks also play a key role. 

Table 3 – Legislative policies 

Creating a sustainable 
city layout 

Mobility – legislative policies 
KEY CHALLENGES 
Making buildings 
ready for e-
mobility 

Securing 
increasing 
investments 

Belgium 
Croatia 
Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 
Baden-
Württemberg 
Silesia 
Umea 

Belgium 
Croatia 
Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 

Table 4 – Non-legislative policies 

Creating a sustainable 
city layout 

Mobility – non-legislative policies 
KEY CHALLENGES 
Making buildings 
ready for e-
mobility 

Securing 
increasing 
investments 

28 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 
Baden-
Württemberg 
Silesia 
Umea 

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

1) Creating a sustainable city layout 

Urban planning for sustainable cities and neighbourhoods is a complex issue. While local 

authorities  are  central  players  in  charge  of  planning  processes,  decisions  require 

coordination with regional and in some cases national governments and with stakeholders 

including  private  actors  such  as  developers  or  transport  operators.  Moreover,  urban 

planning  for  sustainable  mobility  has  many  dimensions  and  the  importance  of  each 

dimension  always  depends  on  local  conditions.  Key  issues  include,  inter  alia,  mixed 

neighbourhoods that provide room for living, working and shopping so as to reduce the 

need  for  long  daily  trips;  accessibility  and  attractiveness  of  public  transport;  cycling 

infrastructure; management of parking space; availability of charging points  for electric 

vehicles; availability of  convenient car and bike  sharing  options; management  of goods 

deliveries;  and  ease  of  inter-modal  trips,  i.e.  the  change  between  public  transport  and 

cars or bikes within one trip.  

This new vision of a sustainable city layout has been labelled the 15-minute-city. The term 

has  been  used  by  Anne  Hidalgo,  the  mayor  of  Paris,  in  her  re-election  campaign.  It 

describes the goal that each resident can cover all basic needs with a bike or walking trip 

of  15  minutes  or  less.  Basic  needs  include  working,  education,  experiencing  nature, 

shopping, leisure activities like sports, cultural events and social gathering, and medical 

care. The new paradigm has been taken up by the C40 Cities in their agenda for a green 
and just recovery from the Covid-19 pandemic.15  

The country research shows that many countries have overarching plans for green urban 

planning  enshrined  in  legislation  (e.g.  Belgian  regions,  Greece,  Croatia,  Italy,  Ireland, 

Portugal and Poland). Italy for example aims to reduce the need for transport and increase 

the sustainability of each trip by promoting smart working, car sharing, the use of public 

transport and the adoption of efficient vehicles and alternative fuels. Wallonia and Brussels 

in  Belgium  have  developed  innovative  principles  for  planning  new  neighbourhoods  that 

address  the  many  facets  enabling  a  settlement  to  become  sustainable  in  an  integrated 

fashion.  Wallonia  has  also  developed  a  tool  to  design  “peaceful  neighbourhoods”  that 

focuses on parking space management, aiming to  encourage inhabitants to move away 

from the private car. 

While an overarching vision for sustainable transport is crucial, it needs to be combined 

with concrete actions at the local level. The limited scope of the country research does not 

allow a final verdict on whether this is happening in each country. As mentioned above, 

the relevant assessment level is the local municipality. Variations between cities and towns 

are likely to be significant even within countries. We therefore focus on highlighting good 

practices with the potential for replication within countries and in other EU Member States. 

For the particular issue of cycling, the country research reveals that some countries and 

local  authorities  are  implementing  very  concrete  regulations.  For  example,  regulations 

requiring secure bike parking spots for new residential buildings were found in Germany 

(mandated at the regional level, e.g. Baden-Württemberg) and Tirol as well as in Denmark 

and  in  France  where  the  obligation  extends  to  non-residential  buildings  as  well.  Some 

national  or  regional  governments  financially  support  cycling  investments  at  local  level 

15 C40 Mayors (2020). Agenda for a green and just recovery, p. 30. 

30 

 
 
Annex II: Factsheets and lessons learned 

(Baden-Württemberg, Germany). Non-legislative measures include guides on local cycling 

action plans or best practice sharing between local authorities (Baden-Württemberg).  

2) Making buildings ready for e-mobility 

The EPBD requires the installation of charging points in certain public parking spaces and 

sets pre-tubing requirements that allow for subsequent installation of charging points in 

new  or  renovated  residential  buildings  of  a  certain  size  (as  well  as  for  non-residential 

buildings).  Most  countries  under  review  in  this  study  have  already  implemented  this 

regulation or are planning to do so.  

The  country  analysis  also  shows  that  many  national  governments  provide  grants  for 

private actors who install charging infrastructure in buildings and car parks (e.g. Andalusia, 

Baden-Württemberg, Ireland, Italy, Sweden, UK, Tirol) or streets (e.g. Portugal, Germany, 

Poland,  Tirol,  Sweden).  Other  countries  use  tax  rebates  to  support  the  installation  of 

privately owned charging infrastructure (Denmark, Italy). Denmark also offers tax rebates 

on the electricity used for charging electric vehicles at home. The Dutch government offers 

low-rate  loans  for  co-owner  associations  to  finance  the  installation  of  charging 

infrastructure in their building. 

The  Netherlands  has  also  developed  an  interesting  non-legislative  approach  using  local 

cooperation  agreements  between  the  local  government  and  private  sector  to  ensure 

minimum and accessible charging infrastructure in business parks. In  the US, efforts in 

several states are focused on establishing charging points in public buildings.  

Many countries support the roll-out of charging infrastructure by clarifying technical and 

regulatory issues, e.g. relating to the roles of different actors and their interaction as well 

as  rules  on  tariffs  (Portugal),  safety  regulations  (Norway),  enabling  distribution  grid 

operators  to  manage  the  impacts  of  electric  mobility  on  grids  (Flanders,  Belgium)  and 

connection capacity (Poland). France and Norway have established new rules that make it 

easier  for  single  owners  in  collectively  owned  apartment  buildings  to  install  charging 

points. 

Finally, the Nordic countries have established the database NOBIL which provides a map 

of existing charging points and their accessibility, including those charging points in public 

and residential buildings.  

3) Securing increasing investments  

The country researchers have found relatively few examples of financing instruments for 

sustainable redesign of urban areas – beyond fiscal incentives for electromobility charging 

infrastructure.  This  may  in  part  reflect  that  the  issue  is  hard  to  describe  with  a  few 

keywords that can work across all Member States and regions. However, it could also point 

to a lack of suitable ideas on how to tackle these key issues. As the factsheet on district 

approaches shows, district or neighbourhood-level projects have the potential to increase 

the  attractiveness  of  investments  thanks  to  project  aggregation  and  distributed  risk 
portfolios. The larger scope can enable new business models and financing solutions.16 

16 Paiho, S. (2014), Energy-efficient renovation of residential districts, p.58 

31 

 
 
 
 
Annex II: Factsheets and lessons learned 

The  identified  examples  include  a  programme  in  Italy  where  the  national  government 

offers  municipalities  co-funding  for  mobility  projects  that  limit  traffic  and  pollution, 

including  cycling  projects,  walking  initiatives,  car-pooling,  car-sharing,  bike-pooling  and 

bike-sharing, education programmes and road safety, and mobility management schemes 

at universities, schools or other public bodies.  

The German development bank KfW offers loans of up to €150 million per year for model 

projects of so-called “Smart Cities”. The low-interest loans can be used for investments in 

urban  development  and  digitisation.  Specific  measures  include  investments  in  traffic 

relocation, biking, walking and public transport.

2.5 Highlighting good practice examples 

Based on the results of the previous research as well as on expert knowledge, this section 

portrays  selected  good  practice  examples.  Each  example  fulfills  one  or  several  of  the 

following selection criteria: innovation (new mechanism, triggering innovation, scaling up 

innovation), impact (on EU objectives, energy savings, CO2 emission reduction, potential 

renovation  impact),  ease  of  implementation  (including  transferability,  scalability, 

transaction and administrative costs, budget (in-)dependency, compatibility with existing 

legislative/policy framework) and coverage of diverse jurisdiction and climatic zones. 

Country 
Belgium – 
Wallonia & 
Brussels 

Policy 
Establishment 
of multi-modal 
stations called 
“Mobipoles” 

Belgium – 
Wallonia  

Regional 
Mobility 
Strategy 

Brief description 
•  The "mobipoles" will offer various 

services and allow modal exchange 
for people, including car parks, in 
particular car-pooling, secure bicycle 
shelters, bus, tram, new rapid bus 
lines, perfectly connected co-working 
spaces, shared bicycles and cars, 
charging stations, etc. 

•  Mobipoles aim above all to promote 
“smart mobility”, i.e. a system that 
includes both sustainable, efficient 
and innovative solutions and mobility 
behaviours. 

•  The provision is innovative, because 
it enables inter-modal trips on the 
ground, recognising that a shift away 
from the car will only happen if trips 
with other modes of transport are 
convenient for all users (including 
suburban commuters).  

•  Aiming  to  reduce  urban  sprawl,  the 
strategy  prioritises  centrality,  density 
and  diversity  of  activities  in  urban 
planning. Traffic and parking must be 
managed in  such a way as to reduce 
the  space  occupied  by  cars  and  give 
priority  to  public  transport  and  soft 
modes  where  congestion  is  an  issue. 
functions  must  be 
The  mix  of 
privileged.  These  ambitions  require 
coordinating  mobility  strategies  and 
land-use development.  

•  The  action 
concrete 

is  broken  down 

multi-year 

into 
action 

Source 
NECP 
Belgium, 
p.188. 

Stratégie 
Régionale 
de 
Mobilité 
Volet I – 
Mobilité 
des 
personnes 

32 

 
Annex II: Factsheets and lessons learned 

programmes. Mobility issues are to be 
integrated  from  the  design  of  new 
districts  or  new  projects  (pedestrian 
routes  to  public  transport  stops, 
pooling  of  parking  and  deliveries, 
needed  space  for  public  transport 
terminals or depots). 

•  The  provision  is  a  good  practice 
example because it combines a vision 
of 
with  well-defined 
sustainable  urban  planning  with 
concrete action and concrete projects. 
It also allows for regular updates and 
thus policy learning in the process.  
•  Aims to put cities at the forefront of 

principles 

sustainable mobility, creating 
conditions for a paradigm shift in 
urban mobility. Action measures: 
Mobility and Transport Plans (PMT) or 
Action Plans for Sustainable Urban 
Mobility (PAMUS) by municipalities 
with more than 50,000 inhabitants; 
demand management (passengers 
and goods) and urban planning in 
order to reduce the volume and the 
distance of travel; tools to support 
intelligent management of mobility; 
urban design that favours 
pedestrians; inter-municipal 
cooperation. 

•  The strategy is a good practice 

example because it builds on the 
understanding that urban planning 
for sustainable mobility requires a 
paradigm shift which will only be 
successful if it is integrated in all 
dimensions of planning and 
operating. In particular the focus on 
inter-municipality cooperation is key 
for success. 

•  Minimum requirements for the 

establishment of bicycle parking 
facilities when expanding or 
refurbishing existing buildings: 
workplaces/educational institutions: 
0.5 per person; shopping centres: 4 
per 100m2; residential blocks of flats: 
4 per 100m2 

•  The provision is a good practice 

example of a concrete mandatory 
norm that ensures that cycling, as a 
preferred mobility option for 
inhabitants and building users, is fully 
integrated into the building planning 
approach at an early stage. 
•  With this information hub on all 
matters relating to cycling, the 
regional government provides up-to-
date information to its municipalities 
covering the following areas: legal 

NECP 
Portugal 

Cycling 
Embassy 
Denmark 

Ministry 
of 
Transport 

33 

Portugal 

NECP measure 
1.6 on 
Decarbonization 
of cities 

Denmark 

Local 
mandatory 
norms on bike 
parking  

Baden-
Württemberg 

Information 
hub for 
promotion of 
cycling  

Annex II: Factsheets and lessons learned 

Germany 

Low-interest 
loan for 
municipalities 

provisions, financing, guidebooks, 
best practice examples, statistics and 
ideas for communication strategies. 

•  This provision is an example of 

support instruments that national or 
regional governments can use to help 
local municipalities make progress on 
cycling.  

•  Low-interest loan to foster 

KfW 

sustainable development of the 
municipal infrastructure, including 
traffic relocation through cycling, 
walking and public transport 

•  This provision addresses a key hurdle 
for progress at the local level: lack of 
capital for infrastructure investments 
(this is particularly the case in 
municipalities with high debt levels). 
It is another good example of support 
from the national level helping 
municipalities to address sustainable 
mobility. 

2.6 Concluding assessment 

Assessment of impact per type of policy instrument 

For the strategic area “clean and sustainable transport”, three key challenges have been 

defined:  

•  Creating a sustainable city lay-out,  
•  Making buildings ready for e-mobility  
•  Securing increasing investments. 

The country research shows that a variety of provisions exist that address urban planning 

and charging infrastructure for e-mobility. By contrast, it has been more difficult to identify 

provisions  targeting  broader  financing  issues  (rather  than  instruments  focusing  on 

particular  investments  such  as  charging  points  or  cycling  infrastructure).  The  “district 

approach”  strategic  area  highlighted  the  potential  of  neighbourhood  or  district-level 

projects to attract investments more easily thanks to project aggregation and distributed 

risk portfolios. The larger scope can enable new business models and financing solutions 

(see “district approach” factsheet).  

Overall,  the  majority  of  instruments  identified  in  the  mobility  area  are  legislative 

measures. This clearly results from the research focus primarily targeting national-level 

action. On the regional and local level, information-based measures, best-practice sharing 

and support through handbooks also play a key role. 

With  respect  to  the  challenge  of  creating  a  sustainable  city  layout,  the  effectiveness 

assessment faces the challenge that urban planning is a competence assigned to regional 

and local authorities. As a result, national-level measures are mostly supportive or guiding 

while local authorities take the final decisions. This leads to a high variation even within 

Member States, with some cities effectively tackling the sustainable mobility challenge and 

others neglecting the issue.  

34 

Annex II: Factsheets and lessons learned 

The  analysis  does  nonetheless  show  that  ambitious  national  and  regional  governments 

guide  local  action  by  developing  overarching  visions  for  sustainable  urban  areas  and 

setting out key principles such as the need to mix functions, to ensure access to public 

transport, to reduce public space devoted to car traffic and to build attractive cycling and 

walking  infrastructure.  New  paradigms  such  as  the  vision  of  a  15-minute  city  can  help 

build the momentum for local action. Even though overarching visions cannot in and of 

themselves reduce emissions, they have a key function in communicating the goal of single 

measures, some of which, like removing car parking spots, can be unpopular with parts of 

the electorate.  

The most comprehensive approaches combine an overarching vision with concrete actions 

on the different dimensions, e.g. by mandating minimum bike parking spots to be provided 

at new or renovated buildings, providing financial support or limiting car parking spots in 

new buildings. These approaches tackle the problem of multi-level governance head on by 

recognising  that  effectiveness  will  require  strong  vertical  and  horizontal  cooperation 

between national, regional and local governments and among neighbouring municipalities 

or regions. As Wallonia’s strategy shows, an effective approach requires setting up new 

governance  structures  that  allow  for  ongoing  target-setting,  planning,  implementation, 

review and adaptation. Best practice examples also include national or regional funding to 

support local authorities to boost sustainable transport through integrated planning. This 

can take the form of funding for integrated mobility plans or cycling strategies or include 

practical  guides  for  local  authorities  on  legal,  financial  and  technical  questions  of 

implementation.  

Given the complexity of changing city layouts for enabling sustainable mobility, all of the 

actions above are required for substantial change to take place. Taking into account the 

speed that is needed for this transformation due to  the imminent climate crisis and the 

long investment  cycles  in buildings, roads and  other city infrastructure, there is a  clear 

case  for  mandatory  elements,  e.g.  with  respect  to  bike  parking  in  new  or  renovated 

buildings. Such an approach can avoid costly retrofits at a later stage. Moreover, it is itself 

a contribution to paradigm shift since it establishes a “new normal” and forces all planners, 

architects and municipal administrators to familiarise themselves with the infrastructure 

needs for sustainable mobility. 

The picture is more homogenous for the second challenge of making buildings ready for 

e-mobilty. A key reason is that the EPBD sets EU-wide standards in this field which are 

implemented at the national level. In addition, most countries under review here provide 

financial  support  for  private  actors  who  install  charging  points  for  electric  vehicles.  In 

addition, many Member States have put in place provisions that lay down technical and 

regulatory standards for the installation and operation of charging points – a key issue for 

ensuring investment security. The EU-level approach has forced all national governments 

to address the issue and build knowledge and financial capacity for implementation. What 

remains to be seen is how stringently enforcement can be monitored at local level. 

Ease of implementation per type of policy instrument 

The level of awareness of the role of infrastructure in enabling sustainable urban mobility 

varies widely between and within Member States. As a consequence, some instruments 

can be easily implemented in one city, but may be perceived as not feasible in another.  

In the face of such heterogeneity, strategy and planning tools appear particularly useful, 

because they can allow each country, region and municipality to assess its starting point 

35 

Annex II: Factsheets and lessons learned 

and formulate steps forward from there. Ease of implementation will depend on internal 

capacity and knowledge about the issue in each administration. Therefore,  a national or 

EU approach urging regions and municipalities to draft sustainable mobility plans, while at 

the same time offering financial support and capacity building, appears promising to drive 

progress  in  addressing  the  challenge  of  sustainable  mobility.  Such  an  approach  should 

include  minimum  requirements  for  mobility  plans.  They  should  define  an  overarching 

vision,  set  quantitative  goals  and  in-between  milestones,  define  short-term  actions  and 

include  issue-specific  indicators  to  track  progress.  Moreover,  planning  should  allow  for 

participation of citizens and stakeholders as well as coordination with neighbouring regions 

and  communities.  Finally,  each  strategy  or  plan  needs  to  be  reviewed  and  updated  at 

regular intervals. 

With  respect  to  implementation  measures,  mandatory  standards  (e.g.  requiring  bike 

parking spots in new buildings) are promising in terms of overall effectiveness. The EU-

level requirement for e-mobility readiness has forced all national governments to address 

the issue. Mandatory approaches often face political push-back due to cost and feasibility 

concerns. However, once in place, the scaling effect due to the high number of builders 

and developers forced to comply can quickly improve ease of implementation as everyone 

gets  familiar  with  the  technology,  integrating  it  into  planning  processes  from  the  start. 

Experiences from Denmark and the Netherlands, where bike-friendly infrastructure has a 

long history, support this assessment. 

renovation and modernisation of the  

36 

 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

built environment 
Digital technologies for energy efficiency and 
renovation – Factsheet  

Authors: Julien Pestiaux, Benoît Martin  

September 2020 

Tender N° ENER/C3/2019-468/03 

37 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

3.1 Introduction  

This  factsheet  provides  an  overview  of  how  different  policy  instruments  and  selected 

private initiatives can help to achieve European objectives and effectively address key EU 

challenges in the strategic area of digital technology. The findings draw upon a policy 

screening for 15 EU Member States, 3 non-EU countries and 5 European regions covering 

broadly  the  climatic  zones  of  the  EU.  In  addition,  the  factsheet  draws  on  additional 

information provided by external experts as well as on the long-standing expertise of the 

authors, meaning policy examples going beyond the researched country and region cases 

are  occasionally  added.  The  concluding  assessment  draws  on  the  findings  and  detailed 

analysis of the good practice cases as well as on the in-house expertise of the partners.  

3.2 Digital technology 

Digital technologies can be used and applied across the lifecycle of buildings from design 

and construction to the building use phase. Digitalisation is a key enabler of building stock 

decarbonisation  in  the  renovation  phase.  First,  it  has  a  great  potential  to  increase  the 

quality  and  scalability  of  solutions,  improving  design  and  renovation  (e.g.  building 

information  modelling  [BIM],  automation,  3D  printing),  execution  (e.g.  digital 

collaboration  platforms),  and  updated  operation  and  maintenance  (e.g.  building 

automated  management  systems,  controllable  devices  and  smart  appliances,  data 

collection). Second, by enabling smart and flexible energy services for building users, it 

allows  the  development  of  demand-side  management  strategies  that  help  to  further 

integrate variable and decentralised renewable energy sources in the energy system.  

There are a number of key drivers and trends relevant for the area. The Internet of Things 

is connecting an increasing number of appliances and services to the internet; this allows 

remote management, notably in buildings. Many cities have developed local energy plans 

that aim to organise energy supply in a smart, sustainable yet secure way, for example 

by creating smart grids. The growing integration of renewables in the system means that 

matching production with consumption cannot happen solely on the production side, and 

demand-side measures are increasingly contributing to the flexibility effort. 

Digitalisation has an impact on the overall targets for the EU building stock. It helps to 

optimise energy use for renovated buildings, reducing energy bills, and opens the way for 

new  business  models  reaping  the  potential  of  digital  technologies  to  facilitate  the  low-

carbon transition. It is  a key enabler for  making use of buildings’ flexibility to integrate 

more  low-carbon  variable  energy  sources.  Industrialised  solutions  enabled  by  digital 

technologies  will  help  to  reduce  construction  and  demolition  waste.  Digitalisation  of 

buildings  also  allows  and  supports  better  access  to  and  collection  of  relevant  data, 

including energy data.  

The  following  challenges  have  been  identified  as  key  for  the  strategic  area  of  digital 

technology:  

1)  Unleash  the  flexibility  potential  of  energy  uses  via  digitalised  energy-

consuming appliances and services 

1a) Foster local consumption of decentralised and variable energy sources. 

1b) Support the global energy system with flexible energy consumption patterns. 

With a growing penetration of intermittent sources in the production mix, flexibility is more 

and more needed on the consumption side. While mature business models already exist 

38 

Annex II: Factsheets and lessons learned 

for large-scale flexibility harvesting (e.g. industry), the key challenge is to harvest small-

scale flexibility, e.g. at residential level. Digitisation is key in this process and in keeping 

the cost of the energy transition under control. 

2) Mainstream optimal energy uses via digitalised energy-consuming appliances 

and services 

Optimising  energy  use  through  digitalisation  helps  reap  the  full  benefits  of  deep 

renovations;  self-regulating  devices  limit  unnecessary  energy  use  and  help  address 

technical  failures  that  could  lead  to  additional  energy  consumption.  However,  the 

mainstreaming of digitalisation techniques to enable smart buildings is hampered by split 

incentives  (buildings  owners  that  do  not  directly  occupy  their  buildings  have  no  direct 

incentive  to  increase  energy  performance  by  installing  self-regulating  devices)  and  the 

cost of digitalisation for building technical systems. 

3) Digitalise the buildings renovation supply chain 

The whole construction ecosystem can benefit from digitalisation, e.g. by using BIM that 

allows  increased  collaboration  during  construction,  transparency  and  trust;  when  used 

during operation, BIM can help optimise the building’s management, reducing energy and 

overall resource consumption. However, there are many barriers to the complete uptake 

of BIM such as lack of investment, lack of trained employees, lack of software (often due 
to cost) and data security considerations.17 

4) Digitalise data collection about the building stock across Europe 

There  is  an  increasing  amount  of  data  on  building  energy  use  and  building  occupants’ 

energy consumption patterns. Collecting this data and making it available in a transparent 

way would be useful both for policymaking and to support the creation of innovative energy 

services and business models. To this end, the key challenge is to create a framework that 

systematises data collection by allowing the integration of data from different sources (for 

example smart meters or energy performance certificate repositories) and the automation 

of  the  process  with  minimal  manual  intervention.  In  addition,  digitalisation  of  data 

collection  should  ensure  compliance  with  data  protection  regulation  and  broadly  ensure 
digital security.18  

3.3 Provisions to address key challenges  

This section gives an overview of the policies considered to be most successful at tackling 

key challenges in the area of digital technology. To operationalise the challenges and allow 

for  quantitative  estimations  on  selected  aspects,  the  country  screening  looked  for 

provisions that foster local electricity consumption, increase the flexibility of consumption 

patterns,  and  support  digitised  energy-consuming  appliances,  supply  chains  and  data 

collection.  

Figure 1 provides an overview  of the policy  screening. Since countries vary in  size, the 

number of provisions does not necessarily reflect the effectiveness of the policy mix. While 

17  European  Commission  (2010).  Supporting  digitalisation  of  the  construction  sector  and  SMEs  –  Including 
Building Information Modelling 
18  Challenge  expressed  by  the  Commission  in  its  H2020  call  “European  building  stock  data  4.0”. 
https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/opportunities/topic-details/lc-sc3-b4e-7-
2020  

39 

 
 
Annex II: Factsheets and lessons learned 

the  number  of  provisions  found  may  give  an  indication  of  the  breadth  and  diversity  of 

approaches, it should not be taken as the sole indicator for how effective the provisions 

are  for  tackling  key  challenges.  One  well-designed  policy  instruments  may  be  more 

effective  than  a  multitude  of  less  adequate  instruments.  Therefore,  an  additional 

qualitative discussion as well as insights from the good practice analysis are provided in 

the remaining parts of the paper. 

The first two key challenges listed above are also mentioned in the newly adopted Energy 

System Integration Strategy. In this strategy, the digitisation of the energy system is seen 

as  way  to  interlink  energy  carriers  more  easily,  match  production  and  consumption  at 

smaller  scale,  maximise  the  autoconsumption  of  energy  and  unleash  the  full  flexibility 

potential of final customers in order to ease the integration of more renewable energy. In 

order  to  do  so,  one  key  initiative  of  this  strategy  directly  linked  to  the  digitisation  of 

residential and tertiary buildings is “to develop a Network Code on Demand Side Flexibility 

to unlock the potential of electric vehicles, heat pumps and other electricity consumption 

to  contribute  to  the  flexibility  of  the  energy  system  (starting  end-2021).”  This  EU-level 

standardisation  initiative  is  an  important  step  towards  large-scale  harvesting  of  small-

scale flexibility. 

At national and regional scale, 18 countries and 5 regions were checked for the relevance 

of their provisions concerning digital technology. This covers a wide range of measures, 

including, e.g. initiatives, project funding, knowledge creation, incentives and legislation, 

and estimates their impact on the above five key challenges related to digital technology 

and its role in the transformation of buildings across Europe. The impact of the provisions 

on the key challenges is scored from 1 to 3; only provisions scoring 2 and 3 are counted 

and represented in Figure 2 below, with the provisions scoring 2 given half the weighting 

of those scoring the maximum of 3 points. 

The  assessment  shows  a  very  contrasting  picture,  with  policies  encouraging  the  use  of 

digital  technology  being  implemented  at  very  different  levels  across  EU  Member  States 

and the other countries and regions covered. Two Member States  (Germany and Spain) 

already have a large set of relatively comprehensive policies with more than 15 provisions 

identified  to  cover  all  five  key  challenges.  Portugal  stands  out  as  well,  with  two  key 

challenges covered by more than 15 provisions and two others with 10 provisions or more. 

Then  follow  two  groups  of  countries  with  fewer  provisions  :  a  group  of  ~10 

countries/regions with mostly 5-10 provisions per key challenge, and a last group of ~10 

countries/regions with about 0-5 provisions for each key challenge.  

Taking  the  average  across  Europe  shows  that  the  two  key  challenges  with  the  fewest 

provisions are 1a (Foster self-consumption and locally produced energy) and 3 (Digitalise 

the buildings renovation supply chain). 

1a) Foster local consumption of decentralised and variable energy sources: there 

are many provisions in place in Germany and Spain, and another couple of countries have 

close to 10 related provisions (Poland and Sweden). Most other countries are below five 

provisions.  

1b) Support the global energy system with flexible energy consumption patterns: 

this  is  one  of  the  strongest  dimensions  represented,  with  many  countries  having 

implemented impactful measures. Germany, Spain and the UK stand out here.  

2) Mainstream optimal energy uses via digitalised energy-consuming appliances 

and  services:  this  dimension  has  a  high  average  of  nine  related  provisions.  Beyond 

40 

Annex II: Factsheets and lessons learned 

Germany and Spain, where more than 25 provisions touch upon it, Portugal stands out as 

well as Denmark and Sweden.  

3) Digitalise the buildings renovation supply chain: this is slowly taking off, with an 

average  of  six  provisions  per  country/region.  A  lot  of  work  is  also  taking  place  in  this 

respect  at  the  European  level  to  push  for  more  advanced  tools  in  the  buildings  sector, 

although this wasn’t the focus of the present work.  

4)  Digitalise  data  collection  about  the  building  stock  across  Europe:  Portugal, 

Germany and Spain stand out with 18 or 19 provisions touching upon this topic, but this 

dimension  is  relatively  evenly  covered  across  Members  States  with  an  average  of  nine 

provisions per country/region.  

41 

 
Annex II: Factsheets and lessons learned 

The percentages on top of the chart refer to the amount of provisions rated with high vs medium impact 

5%  44%  42%  50%  73%  17%  10%  19%  83%  0%  75%  35%  38%  51%  50%  53%  100%  15%  73%  33%  73%  83%  50% 

s
n
o
i
s
i
v
o
r
p

f
o

r
e
b
m
u
N

 40

 35

 30

 25

 20

 15

 10

 5

 -

1a) Foster local consumption of decentralized and variable energy sources
1b) Support the global energy system with flexible energy consumption patterns
2) Mainstream optimal energy uses via digitalized energy-consuming appliances and services
3) Digitalise the buildings renovation supply chain
4) Digitalise data collection about the building stock across Europe

Figure 2 – Number of provisions covering the key challenges of digital technology per country  

(The impact of the provisions is scored from 1 to 3, and only provisions scoring 2 and 3 are counted, giving half the weight to score 2 vs the maximum 
score 3)

42 

 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

3.4 Effectiveness of the policy landscape to address key challenges 

This section presents an assessment of the overall policy landscape that a previous country 

screening  identified  as  relevant  for  the  covered  countries  and  regions.  The  assessment 

takes into account the diversity of instruments (regulation, pricing, support, information 

etc.), whether there are particularly interesting and innovative instruments, and whether 

the instruments identified together seem to be adequate to address the given challenges. 

The overview tables are followed by a discussion of policy instruments.  

In this context, the classification in Tables 1 and 2 should be interpreted as follows: 

Good policy landscape with at least one innovative instrument targeting  district 

approach 

Adequate  policy  landscape  with  instruments  that  could  in  the  future  better 

integrate district approach in the building renovation policies 

Inadequate  policy  landscape,  with  no  instruments  identified  in  relation  to  the 

given challenges 

Not conclusive 

1a) Flexibility 
: Foster local 
consumption 
of 
decentralised 
and variable 
energy 
sources 

Belgium* 
Croatia 
Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 
BW 
Silesia 

Table 1 – Legislative policies  

Digital technology – legislative policies 
KEY CHALLENGES 
2) Mainstream 
optimal energy 
uses via 
digitalised 
energy-
consuming 
appliances and 
services 

1b) Flexibility : 
Support the 
global energy 
system with 
flexible energy 
consumption 
patterns 

3) Digitalise 
the buildings 
renovation 
supply chain 

4) Digitalise 
data 
collection 
about the 
building stock 
across 
Europe 

43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Umea 

Table 2 – Non-legislative policies. 

Digital technology – non-legislative policies 
KEY CHALLENGES 
2) Mainstream 
optimal energy 
uses via 
digitalised 
energy-
consuming 
appliances and 
services 

1b) Flexibility : 
Support the 
global energy 
system with 
flexible energy 
consumption 
patterns 

3) Digitalise 
the buildings 
renovation 
supply chain 

4) Digitalise 
data 
collection 
about the 
building stock 
across 
Europe 

1a) Flexibility 
: Foster local 
consumption 
of 
decentralised 
and variable 
energy 
sources 

Belgium 
Croatia 
Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 
BW 
Silesia 
Umea 

1a)  Flexibility:  Foster  local  consumption  of  decentralised  and  variable  energy 

sources 

Apart  from  Spain  and  Germany,  and  to  some  extent  Poland  and  Portugal,  this  key 

challenge is tackled to only a limited extent across Europe. These regions provide some 

interesting examples of legal instruments supporting more appropriate local consumption. 

In Spain, the national energy and climate plan (NECP) includes Measure 1.3 focused on 

the  development  of  self-consumption  of  renewables  and  distributed  generation  through 

various measures such as increased financing, third-party energy services, and boosting 

self-consumption  in  vulnerable  sectors.  Portugal’s  NECP  also  includes  measures  to 

promote distributed production and self-consumption of energy, for example by promoting 

the  creation  and  development  of  energy  communities.  In  Germany,  the  Law  on  the 

Digitization of the Energy Turnaround (GDEW) is a German federal law on the equipment 

and operation of intelligent metering systems ("smart meters") in connection with energy 

system  transformation;  it  includes  specific  elements  defining  protection  profiles  and 

technical  guidelines  for  intelligent  measuring  systems  to  ensure  data  protection,  data 

security and interoperability. It also contains detailed regulations on who may access what 

data and when.  

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

1b)  Flexibility:  Support  the  global  energy  system  with  flexible  energy 

consumption patterns 

This area is more extensively covered across European countries, although in most cases 

there  is  still  ample  room  for  additional  policy  instruments.  Some  interesting  examples 

include  Italy,  where  an  “eco-bonus”  was  introduced  in  2016  for  home  automation  with 

remote control of heating, hot water production and air conditioning systems of housing 

units. In Lithuania an amendment to the Law on Electricity enables the emergence of new 

services with independent aggregators of electricity demand to improve the flexibility and 

management  of  the  electricity  system.  This  is  important  when  planning  new  electricity 

generation and consumption facilities in renovated buildings. Another example is the Royal 

decree  in  Spain  which  regulates  self-consumption  of  electric  energy,  clarifying 

administrative, technical and economic conditions for self-consumption (e.g. what is the 

definition  of  a  nearby  facility  qualifying  as  local  consumption?),  which  allows  local 

consumption to be extended and made more flexible. Portugal also included Measure 3.3 

in its NECP to promote the acquisition and renewal of heat and cold production systems 

from renewable energy sources, where digitalisation allows more flexible exploitation of 

these systems to support a more efficient energy system. 

2) Mainstream optimal energy uses via digitalized energy-consuming appliances 

and services 

Most  countries have at  least  one provision in place, and there are promising examples. 

Portugal has a new smart grid regulation which allows electricity bills to be calculated using 

real data, without any estimates, improving energy management. Poland has started the 

implementation  and  support  of  national  intelligent  specialisations,  which  makes  smart 

technologies  an  economic  priority  for  research,  development  and  innovation.  Also 

connected  to  research  and  innovation,  new  federal  funding  in  Germany  for  the  pilot 

programme "saving meters" supports innovative digital solutions with funding of up to €2 

million. The aim is to test various technologies with different user groups and bring them 

to market maturity. Also, the energy action plan in Andalusia includes elements to increase 

the use and improve the management of renewable energy thanks to innovative energy 

storage systems and the use of information and communication technologies. 

3) Digitalise the buildings renovation supply chain 

At  least  two  countries  provide  a  number  of  adequate  policy  examples  addressing  the 

challenge at hand (Germany and Spain) although others also have interesting initiatives. 

Typically the digitalisation of the planning phase of the buildings industry is making strong 

progress  in  Germany,  where  a  special  qualification  programme  was  put  in  place  by  the 

chamber  of  architects  and  engineers  of  Baden-Württemberg  to  increase  the  amount  of 

qualified  staff.  Lithuania  aims  to  digitise  all  construction  management  processes  in  one 

common information system through its Programme of the Government of the Republic of 

Lithuania (2016 Nr. XIII-82) but details are lacking. Some other countries also have non-

legislative provisions, but in general provisions are lacking. Interesting examples include 

Energiesprong in the Netherlands, where the whole buildings renovation market is set up 

to encourage large volumes of renovation, which drives innovation and  industrialisation. 

This  ultimately  relies  on  BIM  for  scaling  and  cost  reductions,  as  does  PLANBIM  2022  in 

France (itself inspired by the UK example) to push innovation through the buildings market 

(both new and renovations). PLANBIM 2022 aims to provide professionals with concrete 

45 

 
 
Annex II: Factsheets and lessons learned 

methods  and  tools,  capacity  building  and  sharing  best  practices  to  massively  upscale 

digitalisation.  

4) Digitalise data collection about the building stock across Europe 

Digitalised data collection is one of the stronger dimensions with most countries having 

some  provisions,  both  legislative  and  non-legislative.  However,  most  still  remain  far 

behind the better practices of Portugal or Spain. Portugal has had an energy observatory 

in  place  since  2017  which  provides  a  database  with  all  legislation,  action  plans, 

programmes  and  other  instruments  that  configure  energy  policies.  In  Spain  the  2030 

Navarre  Energy  Plan  is  deploying  energy  consumption  metering,  creating  a  centralised 

inventory of consumption centres using the ICEGONA software, centralising procurement 

of  energy  supplies,  and  selecting  and  prioritising  investments  in  energy  service 

procurement, with costs linked to savings. 

Several countries are now putting in place a digital logbook for buildings – a repository for 

all  relevant  building  data,  allowing  the  information  to  be  dynamically  recorded  and 

accessed.  Examples  include  the  Belgian  Woningpas  in  Flanders,  which  gathers  relevant 

information  about  buildings  in  a  digital  passport,  and  the  French  carnet  numérique  du 

logement,  which from  2022  will  require  all  energy  efficiency-related  information  on 

buildings  renovation  to  be  gathered  electronically.  Several  private  logbooks  have  also 
appeared, with different purposes:  

•  The  German  Eigenheim  Manager  and  Swedish  MinVilla  offer  building  owners  the 

possibility to store information in a digital safe.  

•  The Dutch MADASTER and Swedish Basta Logbook log information about the materials 
used in the construction phase, enabling the recycling of materials and traceability of 

various chemicals.  

The EU Commission is  also looking into  digital logbooks in the context of the EU  Green 

Deal,  having  issued  a  tender  on  developing  an  EU  framework  for  a  digital  buildings 

logbook. The project is ongoing and will be finalised by the end of 2020.  

More generally, more and more is communicated in an open and transparent way about 

the level of energy efficiency of buildings across Europe. In the UK energy performance 

certificates (EPCs) are available in an online register to everyone with an estimate of the 

cost of energy efficiency refurbishments required. In the same way, the Brussels region 

has an online database where everyone can access existing EPCs; another example would 

be  Denmark.  Looking  across  countries,  Enerfund  is  trying  to  convert  open-source 

databases  across  Europe  into  geocoded  information  to  rate  and  score  deep  renovation 

opportunities,  drawing  on  parameters  such  as  EPCs,  number  of  certified  installers, 

governmental  schemes  etc.  These  are  all  initiatives  that  should  be  assessed  and 

streamlined across Europe. 

Blockchain technology is currently being tested in pilots, some of which are already used 

in real business cases. They help provide data that complies with strong data protection 

rules.  An  example  is  the  Energy  Card,  where  blockchain  technology  enables  the 

visualisation of measured energy consumption data on a district level, indicating best- or 

worst-performing districts while protecting individual buildings data. The most prominent 

example  for  blockchain  use  is  peer-to-peer  energy  trading  of  decentrally  produced 

electricity  (see.  e.g.  pebbles).  This  can  help  unlock  the  flexibility  potential  of  electrified 

heat through local energy communities and creates synergies between heating and cooling 

46 

 
 
Annex II: Factsheets and lessons learned 

production,  improving  the  cost-efficiency  of  renewable  heat  by  better  aligning 

(aggregated) demand and production. Studies highlight how blockchain technology could 

be used for asset management as well as process optimisation throughout the building’s 

lifecycle.  Examples  could  include  business  models  that  aim  to  build  demand  through 

project  aggregation,  as  well  as  process  optimisation  and  automation  in  a  complex  and 

fragmented  value  chain.  The  technology  allows  data  aggregation  to  better  manage 

processes, thereby reducing investment risks, without the need to manage data protection 

of scattered data (see e.g. dena, BDEW).

47 

 
 
Annex II: Factsheets and lessons learned 

3.5 Highlighting good practice examples 

Based on the results of the previous research as well as on expert knowledge, this section portrays selected good practice examples. Each 

example fulfils one or several of the following selection criteria: innovation (new mechanism, triggering innovation, scaling up innovation), 

impact  (on  EU  objectives,  energy  savings,  CO2  emission  reductions,  potential  renovation  impact),  ease  of  implementation  (including 

transferability,  scalability,  transaction  and  administrative  costs,  budget  (in-)dependency,  compatibility  with  existing  legislative/policy 

framework) and coverage of diverse jurisdiction and climatic zones.  

Country 
Denmark 

Policy 
Energy agreement 
with a focus on 
renewable energy, 
energy efficiency 
improvements, 
research and 
energy regulation 

Brief description 
The  government  has  an  “Energy  agreement”  to  further  build 
Denmark’s  international  positions  of  strength  with  a  focus  on 
renewable  energy,  energy  efficiency  improvements,  research 
and  energy  regulation.  This  agreement  is  very  comprehensive 
and touches  on a lot  of issues, including  “A smart and flexible 
energy  system”.  Initiatives  in  focus  include  testing  regulatory 
free zones and improved use of data and digitisation in the utility 
sectors.  Cross-energy  flexibility  is  particularly  important  and 
such initiatives must be replicated.  

Source  
Description  by  the  Ministry  of 
Foreign Affairs for investors 

Full agreement 
https://kefm.dk/ministeriet/aftaler
-og-politiske-udspil/energiaftalen/ 

Spain 

Framework for the 
develop-ment of 
renewable thermal 
energies 

Germany   Law to support 
grid flexibility 

fossil 

fuels,  expand 

Spain’s  framework  for  the  development  of  renewable  thermal 
energies  aims  to  increase  renewable  energy  sources  and 
displace 
for  which 
implementation is limited, and support the participation of new 
actors  and  innovation.  It  leverages  two  main  mechanisms: 
reviewing  and  increasing  energy  efficiency  and  renewable 
energy requirements in the Technical Building Code for all new 
buildings  and  refurbishments,  and  providing  aid  programmes 
(loans and subsidies). 

technologies 

English version  

Spanish version 

The Law on the Digitization of the Energy Turnaround (GDEW) is 
a  German  federal  law  on  the  equipment  and  operation  of 
intelligent metering systems ("smart meters") to support energy 
system  transformation.  In  addition  to  amending  two  other 
federal laws and 10 directives, the Act on the Digitisation of the 
Energy Sector Transformation contains the new Act on Metering 
Point  Operation  and  Data  Communication  in  Intelligent  Energy 
Networks (Metering Point Operation Act - MsbG).  

Legal text  
https://www.bmwi.de/Redaktion/
DE/Downloads/Gesetz/gesetz-zur-
digitalisierung-der-
energiewende.pdf?__blob=publica
tionFile&v=4 

48 

 
 
 
 
  
 
Germany  Optimise energy 

use through 
automation and 
self-regulation 

Spain 
(Navarra) 

2030 Energy plan 

Germany   Mainstream and 

establish building 
information 
modelling (BIM) 

Annex II: Factsheets and lessons learned 

through 
This  policy  supports  optimal  energy  use 
automation  and  self-regulation.  The  aim  of  the  federal 
funding for the pilot programme for energy-saving meters is to 
make  the  trend  towards  digitalisation  also  useful  for  energy 
efficiency. To this end, companies that help their end customers 
to save one or more of the energy sources electricity, oil, gas, 
biomass,  heating,  cooling  or  primary  energy  by  means  of 
innovative  digital  solutions  will  receive  funding  of  up  to  €2 
million. The aim is to test various technologies with different user 
groups and bring them to market maturity. 

the  key  aspect  of 

On 
improving,  standardising  and 
strengthening  data  collection  about  the  building  stock 
across Europe, the region of Navarra in Spain has devised a 
2030 energy plan. Measures include encouraging hiring energy 
service  companies  in  sectors  with  the  greatest  potential  (both 
public  and  private)  to  develop  procurement  procedures  and 
contract  models  and  set  up  a  support  framework  for  possible 
financing; energy consumption metering; creating a centralised 
inventory of consumption centres using the ICEGONA software; 
centralised  procurement  of  energy  supplies;  and  the  selection 
and prioritisation of investments in energy service procurement, 
with costs linked to savings. 

Many countries show advancements on the digitalisation of the 
buildings  renovation  supply  chain  to  optimise  processes 
and save costs and energy. As one example, the Ministry of 
Transport and Infrastructure plans to establish and mainstream 
BIM.  After  a  first  preparatory  phase  with  large  funds,  in  the 
second  stage  (2017-2020)  four  pilot  projects  are  to  be 
significantly  expanded  so  that  experience  can  be  gathered 
across  all  design  and  construction  phases.  In  the  third  stage 
(from 2020), BIM is to be regularly applied for new projects that 
the Ministry is responsible for.   

Legal text 
https://www.bmwi.de/Redaktion/
DE/Downloads/Gesetz/gesetz-zur-
digitalisierung-der-
energiewende.pdf?__blob=publica
tionFile&v=4 

Text in Spanish 

Text in German 
https://www.bmvi.de/SharedDocs
/DE/Publikationen/DG/stufenplan-
digitales-
bauen.pdf?__blob=publicationFile  

Spain  

Updating criteria for 
energy performance 
certification 

Spain has also updated its criteria for recognised documents for 
energy  performance  certification  to  increase  the  chances  of 
including advanced solutions to improve the energy performance 
of buildings and promote technological innovation in the sector. 

49 

 
 
  
 
Spain 

Annex II: Factsheets and lessons learned 

Since 2016, the recognised programmes for energy performance 
certification  have  to  generate  a  digital  file  in  XML  format, 
containing  all  the  data  from  the  certificate,  which  must  be 
provided at the time of registering. 

Spain  has  put  in  place  a  large  plan  for  energy  saving  and 
efficiency, promotion of renewable energy and self-consumption 
in  public-sector  buildings, 
infrastructure  and  equipment 
administered by the Valencian regional government. 

It helps with the following issues: 

•  Creating a building energy management platform 
•  Promoting  energy  audits  and  energy  certificates  for 

public buildings 

Text in English  

Text in Spanish 
https://ec.europa.eu/energy/sites/
ener/files/documents/es_neeap_2
017_es.pdf  

•  Creating  an  energy  management  plan 
buildings, infrastructure and equipment 
Investing  in  energy  saving  and  efficiency,  as  well  as  in 
renewable energy 

for  public 

• 

•  Promoting electricity production for self-consumption 
• 

Including  energy  efficiency  criteria  in  the  system  of 
procurement and management procedures 

•  Creating  mobility  plans  and  implementing  training, 
awareness-raising and information programmes for users 
and energy management officers in public buildings. 

50 

 
 
 
 
Annex II: Factsheets and lessons learned 

3.6 Concluding assessment 

The key identified challenges of the digital technology policy area are tackled to a varying 

degree across regions, but mostly to a disappointing degree as reflected in the two main 

tables of this factsheet. Overall, Germany and Spain have developed a large set of policies 

that touch on the five key aspects of digitalisation, and some others have started well on 

certain dimensions (Portugal, the UK), but most other countries have limited ambitions, 

especially with regard to fostering local consumption of energy and digitising the buildings 

renovation supply chain. Many countries tend to have non-legislative initiatives in place 

but  lack  a  sufficiently  strong  supporting  legal  environment  and  will  need  to  make 

significant progress. 

Looking across the provisions in place, we see that there are: 

•  Comprehensive  strategies:  these  typically  cover  a  much  wider  range  of  policies 
than  just  digitalisation  but  include  some  of  the  elements  required  to  support  it. 

Typical  examples  include  the  German  national  strategies  (e.g.  Energiewende, 

Energy  Efficiency  strategy  for  buildings).  They  don’t  seem  to  be  coming  out  as 

strongly in other countries.  

•  More specific programmes on digital issues: a whole series of policies have been 
implemented across Europe, from the Smart Meters Act of 2018 in the UK, to the 

agreement on a smart and flexible energy system in Denmark, or the Royal Decree 

regulating self-consumption of electric energy in Spain. Many countries are failing 

to cover sufficiently the various key aspects with these specific instruments.  

Assessment of impact per type of policy instrument 

The country analysis allows us to draw general trends regarding the various types of policy 

instruments and the impact they have on key challenges.  

The  results  of  the  country  analyses  contain  very  few  examples  of  private  financing 

instruments.  When  they  are  mentioned,  they  mostly  support  realising  the  flexibility 

potential  from  dispersed  consumption/production  and  optimising  energy  use  through 

digitisation (key challenges 1 and 2).  

Public  financing  initiatives,  such  as  grant  mechanisms,  are  more  common.  They  also 

mainly address key challenges 1 and 2. For example, in Spain, the low-carbon economy 

network  REBECA  subsidises,  among  other  things,  the  transition  to  low-energy 

consumption  in  public  and  residential  building  projects,  notably  through  smart  energy 

management.  

Not surprisingly, standardisation initiatives were found to address mainly key challenges 

3 and 4, i.e. the digitisation of the building renovation supply chain and the building stock 

data collection respectively. A good example is the national implementation in Germany 

of  the  buildingSMART  International  Industry  Foundation  Classes.  The  impact  of  these 

initiatives is usually judged as high. 

The second most represented category is legislative instruments, which are found across 

all key challenges. In the country analysis, the impact of such instruments was found to 

be high as often as medium. Those that have a high impact often relate to smart metering 

and  real-time  tariffing.  Countries  with  such  ‘high  impact’  pieces  of  legislation  include 

Denmark, Germany, Spain, Greece, Portugal and the UK. 

51 

 
 
 
Annex II: Factsheets and lessons learned 

As the most represented category, public and private initiatives cover all key challenges 

in  the  most  balanced  way.  These  are  also  the  most  diverse  type  of  instrument,  with 

initiatives such as events, dissemination of information and pilot projects. As the impact 

of  these  initiatives  varies,  we  have  not  attempted  to  assess  their  energy  saving  and 

greenhouse  gas  emissions  reduction  potential.  Among  such  initiatives  ranked  with  high 

impact on the key challenges, we can point out pilot projects carried out by municipalities, 

Alba Iula (Smart City Initiative) and Umea (Energy Project). 

Ease of implementation per type of policy instrument 

Financing instruments have to be considered cautiously in light of the EU legislation on 
state aid and competition. This has been seen in the recent past, notably for state 
subsidies to residential PV installation. 

In terms of standardisation, even though some standards cover international areas, habits 

and  inertia  in  national  buildings  institutions  might  hamper  harmonisation  between 

countries  of  digital  technology  standards  to  facilitate  the  transition  towards  low-energy 

buildings.  However,  standardisation  of  e.g.  interfaces  is  highly  relevant  in  this  area  to 

allow for integrated building systems, monitoring, data collection and renovation planning, 

especially in the case of project aggregation. It can thus be considered as one of the main 

fields of action the EU could support. One such initiative is the smart readiness indicator 

developed by the European Commission in order to foster smarter buildings. 

Legislative  instruments,  as  well  as  private  and  public  initiatives,  can  be  replicated  from 

one  country  to  another,  but  successful  adaptation  of  good  practices  depends  on  the 

political regime at national level and local specificities. 

52 

 
 
Annex II: Factsheets and lessons learned 

renovation and modernisation of the 
built environment 
District approach – Factsheet  

Authors: Quentin Jossen, Louis Louvet 

September 2020 

Tender N° ENER/C3/2019-468/03 

53 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

4.1 Introduction 

This  factsheet  provides  an  overview  of  how  different  policy  instruments  and  selected 

private initiatives can help to achieve European objectives and effectively address key EU 

challenges  in  the  strategic  area  of  district  approach.  The  findings  draw  upon  a  policy 

screening for 15 EU Member States, 3 non-EU countries and 5 European regions covering 

broadly  the  climatic  zones  of  the  EU.  In  addition,  the  factsheet  draws  on  additional 

information provided by external experts as well as on the long-standing expertise of the 

authors, meaning policy examples going beyond the researched country and region cases 

are  occasionally  added.  The  concluding  assessment  draws  on  the  findings  and  detailed 

analysis of the good practice cases as well as on the in-house expertise of the partners.  

4.2 District approach  

Building renovations can be planned and organised by adopting a comprehensive approach 

that  aims  to  renovate  not  only  single  building  units,  but  rather  a  district  or  a 

neighbourhood at the same time. Renovations at the district level can lead to potentially 

significant cost reductions through economies of scale, industrialisation of solutions and 

smart logistics; they can also increase the attractiveness of investments thanks to project 

aggregation  and  distributed  risk  portfolios.  Moreover,  the  approach  fosters  synergies 

between energy efficiency and other needed transformations in the district, including joint 

consideration  with  the  development  of  local  renewable  energy  sources  or  urban 

development strategies. Given all these aspects, district approaches have the potential to 

lead to optimal solutions at macro level, combining energy efficiency with a maximisation 

of its multiple benefits and ensuring consistency with the other aspects of the sustainable 

development of cities and territories. 

District approaches will help to tackle three key challenges in the renovation of existing 

buildings in the EU: 

1) Developing integrated approaches maximising the synergies between energy 

efficiency and renewable energy (integrated energy efficiency (EE)/renewable energy 

sources (RES) approaches): reaching decarbonised buildings by 2050 requires integrated 

approaches  planning  renewables  and  energy  efficiency  measures  together.  Optimal 

renewable and energy efficiency solutions are more likely to be found when designed on 

a  district  level,  considering  the  constraints  and  the  potential  of  the  specific  location  in 

order to minimise total costs and maximise benefits.  

2) Streamlining and aggregating renovation solutions and processes (streamlining 

and  aggregation):  residential  districts  typically  have  common  building  characteristics, 

requiring  similar  renovation  solutions,  but  very  often  renovation  opportunities  are  not 

aggregated  at  the  district  level.  The  key  challenge  is  to  identify  and  capture  the 

standardisation  and  aggregation  potentials  of  renovation  solutions  and  processes 

considered at the district level. 

3)  Developing  comprehensive  (sub)urban  strategies  combining  energy  and 

carbon efficiency of the building stock with sustainable solutions for growth and 

improvement of citizens’ wellbeing (Comprehensive (sub)urban strategies): growing 

demographic  and  evolving  living  and  mobility  patterns  might  push  towards  an 

unsustainable urban  exodus.  The key  challenge is to embed building  energy  renovation 

into  larger  land-use  planning  strategies.  Planning  renovation  and  infill  strategies  at  the 

district level maximise benefits and increase positive synergies. 

54 

Annex II: Factsheets and lessons learned 

Provisions related to the above challenges were collected for 18 countries and 5 regions, 

mainly in the EU. The present analysis aims to highlight interesting initiatives from these 

countries or regions with regards to district approaches to renovation and, more broadly, 

to provide an overview of what is happening in the EU on this topic. To this end, the paper 

summarises and discuss how those countries and regions consider district approaches in 

their  building  renovation  policies.  The  paper  starts  with  a  general  overview  of  collected 

policies in Section 3. Then, specific insights for each  of the three key EU challenges are 

provided  in  Section  4  and  best  practice  examples  are  highlighted  in  Section  5.  Lessons 

learned to further foster the development of district approaches to buildings renovations 

are provided in the conclusions drawn in Section 6.  

4.3 Provisions to address key challenges  

This section gives an overview of the policies considered to be most successful at tackling 

key  challenges  in  the  area  of  district  approaches.  To  operationalise  the  challenges  and 

allow for quantitative  estimations on  selected  aspects, the country screening looked  for 

provisions that could maximise synergies between energy efficiency and renewable energy 

sources, streamline renovation solutions and support sustainable urban growth. 

The figure provides an overview of the policy screening. Since countries vary in size, the 

number of provisions does not necessarily reflect the effectiveness of the policy mix. While 

the  number  of  provisions  found  may  give  an  indication  of  the  breadth  and  diversity  of 

approaches, it should not be taken as the sole indicator for how effective the provisions 

are  for  tackling  key  challenges.  One  well-designed  policy  instruments  may  be  more 

effective  than  a  multitude  of  less  adequate  instruments.  Therefore,  an  additional 

qualitative discussion as well as insights from the good practice analysis are provided in 

the remaining parts of the paper. 

District approaches to efficiently unlock the renovation of the building stock are relatively 

new  in  political  agendas  of  all  kinds.  Only  a  few  specific  policies  consider  building 

renovation at the district level (we found less than 10 provisions for most of the considered 

countries  and  regions  and  very  few  strongly  connected  to  district-scale  renovation  of 

existing buildings). Pioneering countries in this regard are usually at an experimentation 

stage (they are conducting initiatives in order to assess the requirements and benefits of 

such approaches) and most initiatives are  recent (less than  five years old, and rarely a 

continuation of previous initiatives/programmes). 

The scale of implementation can be very local. Since it is a new approach, most measures 

have  not  yet  reached  the  national  level  (e.g.  national  legislation  or  major  plans  and 

programmes  like  the  national  energy  and  climate  plan  (NECP),  long-term  renovation 

strategy (LTRS), etc.). The overview does not pretend to be exhaustive given potentially 

weak  international  communications  of  local  initiatives.  We  therefore  carried  out  an 

additional review focused on local initiatives to complement the initial review of policies 

led at national and regional levels. Furthermore, several pioneering international projects 

provide recent learnings on district approaches, which are reflected in the discussion as 

well as in more detail in section 4.2. They are, however, not included in the assessment 

figures below. 

An  overview  of  the  number  of  provisions  addressing  each  key  challenge  is  provided  in 

Figure 1. The following paragraphs discuss the results in terms of key challenge coverage 

and  geographies.  A  total  of  80  provisions  were  found  dealing  with  district-scale  actions 

55 

Annex II: Factsheets and lessons learned 

providing  a  favourable  policy  landscape  to  further  develop  district  approaches  to 

renovation (Figure 1, top). Of these, we assess that only 22 provisions have the potential 

to  impact  the  challenges  discussed  above  (Figure  1,  bottom).  In  terms  of  numbers,  a 

single overarching provision can certainly have more impact than 10 smaller provisions. 

However, with the exception of schemes found in the Netherlands and discussed below, 

no overarching provisions related to district approaches to renovation were found in the 

country review and the additional analysis. 

Many provisions targeting district-scale actions relate to district heating/cooling and urban 

planning. These are mature policies in several Member States, well reflected at the national 

or  regional  level,  which  explains  the  higher  amount  of  provisions  relating  to  the 

corresponding  key  challenges  (64  provisions  for  integrated  EE/RES  approaches  and  41 

provisions  for  comprehensive  (sub)urban  strategies).  However,  there  is  no  systematic 

strong  connection  with  energy  renovation  of  existing  buildings.  Thirty  provisions  were 

found in connection with the streamlining and aggregation of renovation. A series of them 

focus  on  streamlining  renovation  processes  and  structuring  scalable  solutions  without 

specifically addressing district approaches at their current development stage. 

District  approach  provisions  with  potentially  strong  impact  on  the  renovation  of  the 

envelope  and  heating  systems  of  the  existing  building  stock  mainly  relate  to  the 

streamlining  and  aggregation  of  renovation  works  (15  provisions).  Explicit  connections 

with building renovation were found for only a few provisions relating to integrated EE/RES 

approaches  and  comprehensive  (sub)urban  strategies  (six  and 

five  provisions 

respectively). 

In terms of geographies, provisions strongly connected to building energy renovation and 

the given challenges were found in Flanders,  Denmark and the Netherlands (with  three 

provisions each) and Brussels, Ireland and Tirol (two provisions each), and finally Wallonia, 

Germany, Lithuania, Poland Romania, Spain, Sweden and the USA (one provision each). 

56 

Annex II: Factsheets and lessons learned 

10

s
n
o
i
s
i
v
o
r
p

5

0

d
e
t
a
e
r

l

f
o

r
e
b
m
u
n

l

a
t
o
T

5

0

s
n
o
i
s
i
v
o
r
p

l

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a
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-
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i

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N

KC1: maximizing synergies between EE and RES

KC 2: streamline renovation solutions

KC 3: urban strategies for sustainable growth

Figure 3 – Number of provisions by country and by key challenge relating to district-scale approaches (top) and subset of these with 
explicit connections to the renovation of the existing building stock and the given challenges (bottom)

57 

 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

4.4 Effectiveness of the policy landscape to  address key challenges  - overview 

and description 

This section presents an assessment of the overall policy landscape that a previous country 

screening  identified  as  relevant  for  the  covered  countries  and  regions.  The  assessment 

takes into account the diversity of instruments (regulation, pricing, support, information 

etc.), whether there are particularly interesting and innovative instruments, and whether 

the instruments identified together seem to be adequate to address the given challenges. 

The overview tables are followed by a discussion of policy instruments.  

In this context, the classification in Tables 1 and 2 should be interpreted as follows: 

Good policy landscape with at least one innovative instrument targeting a district 

approach 

Adequate  policy  landscape  with  instruments  that  could  in  the  future  better 

integrate a district approach in the building renovation policies 

Inadequate  policy  landscape,  with  no  instruments  identified  in  relation  to  the 

given challenges 

Not conclusive 

Tables 1 and 2 lead to the following observations, further discussed by key challenge in 

the next sub-sections: 

•  With the exception of Flanders and Ireland, no country or region has both legislative 
and non-legislative provisions strongly connected to district approaches to buildings 

renovation  in  place.  Regarding  provisions  that  target  district-scale  actions  in  a 

broader sense, the combination of legislative and non-legislative provision is found 

in  12  of  the  reviewed  countries  for  the  first  key  challenge,  and  three 

countries/regions for each of the two other key challenges. 

•  A good policy landscape is found in Spain, with high-relevance legislative provisions 
for two key challenges. The same  goes for non-legislative provisions in Brussels, 

Denmark, the Netherlands and Tirol. 

There is not always a clear distinction between legislative and non-legislative provisions. 

Therefore, the two tables are jointly discussed below for each of the three key challenges. 

58 

 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Table 1 – Legislative policies  

District approach – legislative policies 
KEY CHALLENGES 
Streamlining and 
aggregating 
renovation 
solutions and 
processes 

Developing 
comprehensive 
(sub)urban strategies 
combining energy and 
carbon efficiency 

Develop integrated 
approaches 
maximising the 
synergies between 
EE/RES  

Wallonia  
Flanders  
Brussels region  
Croatia 
Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 
BW 
Silesia 
Umea 

Wallonia  
Flanders  
Brussels region  
Croatia 

Table 2 – Non-legislative policies. 

District approach – non-legislative policies 
KEY CHALLENGES 
Streamlining and 
aggregating 
renovation 
solutions and 
processes 

Developing 
comprehensive 
(sub)urban strategies 
combining energy and 
carbon efficiency  

Develop integrated 
approaches 
maximising the 
synergies between 
EE/RES 

59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 
BW 
Silesia 
Umea 

1) Developing integrated approaches maximising the synergies between energy 

efficiency and renewable energy  

Two provisions were found fully tackling the integration of energy efficiency and RES at 

the district scale. The first is found in the Netherlands with its Heat Transition Vision, where 

participating  municipalities  commit  to  develop  by  2021  a  vision  on  how  each  of  their 

districts  could  be  made  natural  gas-free,  and  the  related  national  programme  aimed  at 

supporting districts/municipalities to become natural gas-free through deep  renovations 

and integration of renewable heating at district level. The second provision is the districtPH 

tool – developed by the Passive House Institute in the Austrian state of Tirol – designed 

for  the  evaluation  of  energy  saving  and  RES  heat  potentials  at  the  district  level. 

Furthermore, the Smart Cities Information System platform provides general guidelines 

to  approach  district  renovation  and  heating  and  balancing  energy  efficiency  and  the 

integration  of  renewables,  for  example  in  its  solution  booklets  for  district  heating  and 

cooling, building envelop retrofit, and heat pump driven district heating systems. 

A series of other provisions relate to the integration of EE and RES approaches without an 

explicit  connection  to  the  renovation  of  the  existing  building  stock.  These  were  mainly 

three types:  

•  Deployment  and  decarbonisation  of  heating/cooling  districts.  Some 
countries are conducting studies (e.g. measure 4.7 of the Spanish NECP: Promotion 

of  high-efficiency  cogeneration  and  district  heating  and  cooling  that  includes  the 

development of a tool to identify the share of the heating demand that could be 

met with efficient district heating) while others have already brought requirements 

into law (e.g. the Swedish district heating law) or standards (e.g. the Italian district 

energy system standard). A series of other provisions aim to increase the share of 

RES in district heating. 

•  RES  heat  potential  mapping.  Many  regions  are  conducting  mapping  of  their 
district  in  order  to  assess  the  geothermal/solar/heat  capacity/etc.  potential:  the 

BruGeoTherMap  in  Brussels  aims  to  valorise  the  geothermal  potential  of  the 

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Brussels region, Flanders is developing local heat zoning plans to adapt the heat 

supply  to  local  characteristics  (NECP  p.88),  and  Croatia  is  mapping  its  energy 

system  with  a  comprehensive  database  of  geo-referenced  information  on  the 
consumption  of  energy  and  energy  sources,  buildings  and  infrastructure  (4th 
NEEAP, measure HC.1, p.110). 

•  Energy communities. These provisions consist of micro-grid initiatives aiming to 
balance  local  production  and  consumption  of  energy.  Examples  include  Brussels 

with a collective self-consumption pilot project with solar production from schools 

shared  with  the  neighbourhood  outside  of  school  hours;  Italy  with  single  and 

collective self-consumption systems where electricity consumers can join together 

to become self-consumers of renewable energy acting collectively, thus creating a 

renewable  energy  community  (NECP  p.141  related  to  law  decree  No  162  of  30 

December 2019); and similar provisions in Portugal (NECP p.34) and Spain (NECP 

measure  1.11,  p.75).  Other  interesting  initiatives  are  the  better  energy 

communities grant in Ireland and the Portland Clean Energy Community Benefits 

in the USA. 

Although connections with building renovation are not yet explicit in these provisions, they 

are useful enabling initiatives to structure integrated EE/RES approaches to renovation.  

2) Streamlining and aggregating renovation solutions and processes 

Most provisions related to the streamlining and aggregation of renovations explicitly foster 

building renovation at the district level and provide learnings from pilot projects.  Cities 

and districts are, in fact, a big driver for the aggregation of renovation demand and larger 

numbers of dwellings in projects directly affect associated risks and can drive economies 

of  scale.  Communities  driving  the  development  of  district  approaches,  like  Smart  Cities 

Networks,  thereby  help  drive  (deep)  building  renovation”.The  district  refurbishment  in 

Aalborg, Denmark, tackles the renovation of around 950 dwellings (representing 97,000 

m²  of  heated  floor  area)  and  should  provide  results  in  the  course  of  2020.  The 

demonstration  project  for  collective  renovation  in  Flanders  aims  to  trigger  the 

refurbishment  of  875  houses  in  two  cities  (Antwerp  and  Mechelen)  towards  ambitious 

energy performance levels and runs until 2024. The ICCARus project (Improving housing 

Conditions for Captive Residents in  Ghent) aims to renovate 100 dwellings from energy 

precarious households and to build a replicable and sustainable system through analysis 

of  the  social  return  on  investment.  The  project  expects  numerous  co-benefits  for 

applicants,  including  progress  on  health,  social  networks,  socio-economic  position,  etc. 

Some pilot projects have already been upscaled due to their success, as is the case for 

the collective renovation in Ghent. 

Additional pilot projects testing district-level renovation approaches are also found in the 

reviewed international projects (see section 4.2). Under the Sinfonia project, 37,000 m² 

of social housing in Bolzano (Italy) and 66,000 m² in Innsbruck (Austria) were refurbished; 

a total of 226,000 m² across six European cities were retrofitted within EU-GUGLE; and 

City-zen and R2CITIES projects have respectively renovated 76,000 m² and 57,000 m². 

Moreover, the EU Smart Cities Information System (SCIS) provides information on several 

other  projects  where  single  or  multiple  districts  will  be  renovated  to  become  energy 

efficient  or  energy  positive  districts  all  over  Europe.  This  is  illustrated  by  projects  like 

E2REBUILD (cost-effective and advanced energy efficiency retrofit strategy development), 

FLEXYNETS (new generation intelligent district heating and cooling), or PITAGORAS (smart 

thermal grids). 

61 

Annex II: Factsheets and lessons learned 

Despite the generally local character of district approaches, some provisions are structured 

at  the  national  or  regional  level.  The  Renovation  accelerator  in  the  Netherlands  is  a 

national programme to incentivise large-scale energy renovations that runs for the period 

2019-2023, with a project threshold at 150 buildings units, thereby also promoting the 

Stroomversnelling/Energiesprong  initiative.  The  Neighbourhood  Grant  in  Flanders  is  a 

bonus for project supervisors who collectively supervise a number of homes (at least 10) 

in order to make them energy efficient. The Community Areas Housing Efficiency Strand 

2020 in Ireland is a grant scheme supporting large retrofitting and encouraging scalability. 

It also includes a one-stop-shop approach. A special regional support programme supports 

serial renovation in Baden-Württemberg. 

Industrialised  prefabricated  renovation  solutions  are  developed  within  some 

initiatives.  The  prefabricated  renovation  solution  in  Hyldespjaeldet  (Denmark)  (Green 

solar cities p.4.127-4.130 and annex 2 & 3 from TUE) consists of prefabricated modules 

for external insulation of flat roofs and walls. The roof module  combines insulation with 

solar  photovoltaics,  solar  thermal  and  water  recuperation.  Within  EURECA  in  Flanders, 

researchers  are  developing  a  circular  façade  system  for  fast  and  scalable  renovation 

solutions. 

3)  Developing  comprehensive  (sub)urban  strategies  combining  energy  and 

carbon efficiency of the building stock with sustainable solutions for growth and 

improvement of citizens’ wellbeing  

Some  interesting  provisions  structure  energy  efficiency  and  renovation  plans  at  higher 

scales than individual buildings. The Vulnerability and Residential Building Atlas in Spain 

is  a  web  platform  supporting  the  assessment  of  local  renovation  needs  to  promote 

municipal  urban  renovation,  regeneration  and  renewal  strategies.  In  Romania,  local 

authorities  with  more  than  5,000  inhabitants  must  draw  up  an  EE  improvement 

programme,  and  those  with  more  than  20,000  inhabitants  must  appoint  an  energy 

manager. In Wallonia, the territorial development plan measure AM.1 aims to reuse “well” 

located  buildings  and  combat  urban  sprawl  thus  providing  a  sustainable  solution  for 

growth.  In  the  same  fashion,  in  Germany  a  grant  for  energetic  urban  redevelopment 

finances neighbourhood concepts and redevelopment managers. 

Provisions  with  less  explicit  links  with  the  energy  renovation  of  existing  buildings  were 

mainly of three types: 

•  Infill  strategies  and  rehabilitation  of  buildings:  For  example,  Spain  has  a 
housing  plan  for  2018-2021  that  aims  to  promote  urban  rehabilitation  and 

regeneration, and projects can be funded through the JESSICA FIDAE Fund. In the 

Netherlands, Crowdbuilding is an online platform to facilitate the reuse of vacant 

buildings through collective buying. In Portugal, the Financial Instrument for Urban 

Rehabilitation  and  Revitalization  aims  for  23%  of  business  volume  in  the 

construction sector to be allocated to urban rehabilitation. A provision is structured 

in Wallonia to ensure smart use of lands and well-located buildings via fiscal and 

urban planning instruments 

•  Sustainable urban energy efficiency plans: the POLLEC campaigns help local 
authorities in Wallonia to implement an energy-climate policy and to develop and 

implement municipal action plans for sustainable energy. The National Operation 

Programme for metropolitan cities 2014-2020 in Italy is a programme dedicated to 

sustainable urban development. 

62 

Annex II: Factsheets and lessons learned 

•  Sustainable urban planning projects encompassing energy efficiency, RES 
and health benefits (new built): In the Baden-Würtenberg region, Riselfeld, the 

largest  district  project,  covers  an  area  of  some  70  hectares,  and  now  provides 

3,700 homes for 10,500 people. All houses have been built as low-energy buildings. 

Photovoltaics and solar thermal systems harness the energy from the sun in many 

homes, and a systematic water supply plan and consideration of climatic aspects 

attest to the fundamentally forward-looking approach of this very new district.  A 

similar  approach  exist  for  the  Vauban  district  (for  about  5,700  people).  The 

CORDEES  project  in  Paris  is  creating  a  new  54-hectare  energy  eco-district 

combining  energy  efficiency,  85%  of  self-supplied  energy  and  energy  managed 

through  the  Urban  Sustainability  Trustee  Facilitator.  A  similar  project  is  being 

developed  in  Berlin  Neulichterfelde.  These  district-scale  pilot  initiatives  relate  to 

new  builds,  but  certainly  bring  learnings  for  district  approaches  to  renovation  of 

existing buildings. 

63 

Annex II: Factsheets and lessons learned 

4.5 Highlighting good practice examples 

Based on the results of the previous research as well as on expert knowledge, this section portrays selected good practice examples. Each 

example fulfils one or several of the following selection criteria: innovation (new mechanism, triggering innovation, scaling up innovation), 

impact  (on  EU  objectives,  energy  savings,  CO2  emission  reduction,  potential  renovation  impact),  ease  of  implementation  (including 

transferability,  scalability,  transaction  and  administrative  costs,  budget  (in-)dependency,  compatibility  to  existing  legislative/  policy 

framework) and coverage of diverse jurisdiction and climatic zones.  

Best practice examples provided in Table 3 were selected to highlight inspiring provisions explicitly relating to the given key challenges as 

well as to key success factors, namely methodologies and tools. Priority in the selection was given to ongoing projects or policies. 

Table 3 – Selection of best-practice policies 

Policy 

Country 
Initiatives providing new methods and tools 
Sweden 

Brief description 

•  Development  of  a  digital  tool  based  on  GIS  which  uses  a  multi-criteria  analysis 
valuation  method  to  integrate  energy  efficiency  and  climate  aspects  in  municipal 

planning. 

•  The project is interesting for other municipalities that have access to GIS software. 

Source 

https://www.ovan
aker.se/boendeoc
hmiljo/samhallspl
aneringochplaner/
projektinomsamha
llsplanering.4404.
html  

•  districtPH is a tool used to create energy balances for neighbourhoods, taking into 
account grids for electricity and heat, renewable energies, electromobility and public 
consumers. 

districtPH 

•  This tool has been developed with the Sinfonia project and is used by the Passive 

House Institute, which was a stakeholder of the project. 

Passive 
Institute booklet 

House 

•  The tool has been used to renovate multiple districts in Innsbruck and results from 

those projects can serve as best practice guidance for future refurbishment. 

•  The involvement of stakeholders from the start is of prime importance in conducting 

any type of refurbishment project. 

•  Local  roundtables  bring  all  stakeholders  and  interested  parties  around  the  table 

locally: governments, individuals, associations, businesses etc. 

•  Developing projects of "district-level renovation", thereby including local authorities 
to identify the needs, citizens and businesses concerned in the neighbourhood to 
be  renovated,  local  energy  and  housing  organisations,  the  financial  sector,  local 
suppliers and installers of sustainable products. 

NECP p.291 

64 

in 

in 

Integration of 
energy  and 
climate 
aspects 
planning 
work 
Ovanakers 
municipality 
Tool 
energy 
savings 
potential  and 
related  best 
practices 

for 

Tirol (DE) 

Flanders 
(BE) 

Local  climate 
roundtables 
for 
level 
renovation 

district 

 
 
 
 
 
Annex II: Factsheets and lessons learned 

•  Sharing good practices with other local climate roundtables. 

Provisions developing integrated EE/RES approaches 
The 
Netherland
s 

Natural  Gas-
Free  Districts 
Programme 

• National programme aimed at supporting districts/municipalities to become natural 
gas-free  through  deep  renovations  and  integration  of  renewable  heating  at  district 
level.  
• Objective: to get 1.5 million buildings "natural gas-free" by 2030.  
•  Requirement  for  each  municipality  to  develop  a  vision  on  how  each  of  its  districts 
could be made natural gas-free. 
• Next step will be the development of district implementation plans to put the vision 
into practice. These plans will have to include the deadline by which each district will 
be cut off from natural gas. 

https://aardgasvri
jewijken.nl/default
.aspx 

https://ec.europa.
eu/energy/sites/e
ner/files/documen
ts/nl_final_necp_
main_en.pdf 
(NECP p. 31-32) 

• First "learning" phase 2018-2021 based on two pillars: 

o  A "Knowledge and Learning Centre" (accessible for all Dutch municipalities) will 
provide technical support and facilitate information sharing/best practices 
financial  support 

o  Frontrunner  municipalities  or  districts  can  get 

for 

Flanders 
(BE) 

Local 
zoning plans 

heat 

demonstration/implementation in "Test Beds for Natural Gas-Free Districts".  

•  Area-specific heat plans, including a heat zoning plan, a heat vision and measures 

NECP p.88 

to bring about the transition. 

•  Rationale: the possibilities for utilisation of residual heat or production of green heat 
depend strongly on the local (spatial) context. It is necessary for the heat supply 
to be area-specific. It is therefore desirable for local authorities to draw up (or have 
drawn up) heat plans for their territory. 

Provisions aiming at streamlining and aggregating renovation 
The 
Netherland
s 

The 
renovation 
accelerator 

• Objective: to bundle/aggregate the demand for renovation of similar housing types, 
and have the supply chain match it. Through standardisation and economies of scale, 
this is expected to lower costs, optimise supply chains and timing, etc. 
• Supports housing corporations both through subsidies (budget of €100 million over 
the period 2019-2023) and through technical and process assistance. 
•  Order  of  magnitude:  for  the  subsidies,  the  threshold  for  a  project  is  at  least  150 
building  units  (with  at  least  two  housing  corporations  participating  for  at  least  50 
housing units each). 
The project renovated 2,200 dwellings in the municipality of Albertslund, focusing on 
concrete  buildings.  The  municipality  aimed  to  serve  as  Danish  climate  test  site 
concerning energy-efficient renovation of concrete housing areas. 

Denmark 

"Master  Plan 
South" 
project 
Albertslund 

in 

https://derenovati
eversneller.nl 

NECP p.65 

https://albertslun
d.dk/servicemenu
/english/about-
albertslund/housin

65 

 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

and 
prefabricated 
renovation  in 
Hyldespjælde
t 

Amongst a series of subprojects, an innovative initiative in Hyldespjaeldet consisted of 
renovating  390  flat-roof  houses  with  a  high  degree  of  industrial  prefabrication.  The 
prefabricated renovation solution consisted of: 

•  A  roof  module  combining  external  insulation,  solar  photovoltaics  and  solar 
thermal modules, and a water recuperation system (solar prism from Velux) 

•  A façade external insulation module. 

Flanders 
(BE) 

Neighbourho
od Grant 

The  vision  is  to  enable  independence  of  households  from  all  grid  networks  but 

electricity. 
•  Bonus for project supervisors who collectively supervise several homes (at least 10) 

in order to make them energy efficient. 

•  At least 10 houses or apartments situated in the same street or municipality. 
•  The  project  supervisor  provides  support  to  citizens  in  realising  energy-saving 

investments. 

•  As a citizen, you have more certainty that the renovation work will be carried out 

more quickly, with lower investment costs. 

Valuing  land 
reusing 
and 
"well-
located” 
buildings  

Provisions developing comprehensive (sub)urban strategies 
Wallonia 
(BE) 

and control mobility. 

•  Objective: to combat urban sprawl, make rational use of territories and resources 

•  Measures include:  

o  Aiming for 50% new housing in urban and rural centres by 2030 and 75% 

by 2050. 

o  Modifying tax incentives and renovation premiums based on the suitability 

of the location. 
Identifying the areas in which intensification of housing is appropriate. 

o 

g  

Green  solar  cities 
p.4.127-4.130 

annex  2  &  3  from 
TUE 

https://www.ener
giesparen.be/bure
npremie 

https://www.vlaa
nderen.be/burenp
remie-voor-
collectieve-
renovatieprojecte
n 

Territorial 

Development  Plan 

(2019),  measure 

AM1, p.46 

66 

 
 
 
 
 
Annex II: Factsheets and lessons learned 

Table 4 provides an overview of EU projects also considered as best practices in the field 

of district approaches. They consist of research and/or pilot projects to boost knowledge 

and experience on district-scale renovations, shedding light on the key success factors for 

such approaches. They generally involve two or three pioneer cities testing the solutions 

as well as replication cities to test the replicability of the developed methodology and tools. 

Besides  national,  regional  and  local  initiatives,  a  series  of  international  projects  bring 

valuable insights on the required components to enable and foster district approaches to 

energy  renovation  of  existing  buildings.  Some  of  these  are  included  within  national  or 

regional provisions: 

•  Mutual  trust,  clear  communication  and  stakeholder  involvement  is  tremendously 
important and is necessary from the very  start to  ensure  a  smooth process.  For 

this  communication  and  involvement  to  take  place  in  complex  contexts,  some 

projects  have  developed  tools  to  clarify  and  smooth  the  overall  process  (e.  g. 

NewTREND, OptEEmAL for international projects, but also at the national/regional 

scale the local climate roundtables in Brussels and the  Renovation Accelerator in 

the  Netherlands).  Another  necessary  requirement  for  a  successful  initiative  is  a 

strongly supportive municipality (or public authority) that must be the leader and 

owner of the project. The natural-gas free district programme in the Netherlands 

is a good example of public authority support. 

•  There  are  three  key  roles  to  ensure  successful  initiatives:  activators  should 
understand  platform-based  approaches  and  methods  to  empower  people; 

facilitators ease the renovation process on the entire customer journey once they 

are initiated; monitoring committees composed of local stakeholders should follow 

all  initiatives  in  a  district  to  ensure  their  consistency  with  different  objectives. 

Amongst these, the role of facilitator is already getting attention with a number of 

provisions:  the  Neighbourhood  Grant  in  Flanders  (provides  a  bonus  for  project 

supervisors  that  supervise  at  least  10  homes  for  energy  efficiency  renovation); 

Energetic  urban  redevelopment  in  Germany  (grant  to  support  sustainable  urban 

redevelopment  at  district  level  with  special  financing  for  the  preparation  of 

renovation  managers);  the  Renovation  Accelerator  in  the  Netherlands  (boosting 

large-scale energy renovations with strong focus on developing the supply chain to 

match the demand).  

•  There is a need for new operating methods and tools adapted to coherent district 
approaches.  These  tools  and  methods  should  ensure  the  success  of  projects  no 

matter the context-specific issues that are inherent with a localised approach. Many 

of the international projects presented in section 4 designed and assessed different 

models and tools  adapted to district-level renovation projects, including  MODER, 

EU-GUGLE, OptEEmAL, Sinfonia and NewTREND. Methodologies and tools are also 

being  developed  under  annex  75  from  IEA  EBC  and  should  be  delivered  in  the 

course of 2021. The development of tools and appropriate methodologies is also 

considered  in  a  selection  of  national  provisions:  the  residential  building  atlas  in 

Spain (web platform that supports local assessment of renovation needs and urban 

renovation by developing a standard methodology); the Renovation Accelerator in 

the  Netherlands  (national  programme 

to 

incentivise 

large-scale  energy 

renovations,  promoting  standardisation  of  practices);  the  DistrictPH  in  Germany 

(tool  for  the  evaluation  of  energy-saving  potentials  at  district  level);  GIS-based 

tool for municipal planning in Sweden (to integrate energy efficiency and climate 

aspects). 

67 

 
 
Annex II: Factsheets and lessons learned 

Multiple factors hinder replication of successful initiatives:19  

•  The  “we  are  unique”  syndrome:  Success  and  failure  factors  derive  from  both 
generic features  of the  scheme and local context specificities. It’s not  just about 

technologies and business plans. Everything must be there at the right place at the 

right moment.  

•  Business as usual is too easy: There is a high demand for building and installation 
contractors, which provides no incentive for innovation. On top of this, financiers 

display strong risk aversion and wait for innovative markets to be fully established.  

•  From payback time to secondary benefits and willingness to pay: There is a need 
to  monitor  and  document  multiple  benefits  of  deep  renovation  projects,  and  to 

communicate and build capacity at all stages within the market and the authorities.  

•  Regulatory bottlenecks sustained by vested interests and system inertia: The given 
rules  need  to  be  re-read  or  re-studied  to  bring  forward  possibilities  that  were 

previously ignored. Bringing multiple political responsibilities on board will be key 

to activate the needed modifications.  

The upcoming challenge will be to overcome these barriers and foster market uptake and 

replication.

19 European Commission, 2018. Why may replication (not) be happening 

68 

 
 
 
Annex II: Factsheets and lessons learned 

Table 3 – EU projects bringing valuable insights on district approaches 

Project 
IEA  EBC  annex 
75 (International 
Energy  Agency, 
Energy 
in 
Buildings 
and 
Communities 
programme) 
[2017-2022] 

Brief description 
• Title: Cost-effective Building Renovation at District Level combining Energy Efficiency and Renewables 
• Objectives: 

-  To  give  an  overview  on  various  technology  options  and  how  challenges  specifically  occurring  in  an  urban 

context can be overcome 

-  To  develop  a  methodology  supporting  decision-makers  in  the  evaluation  of  the  efficiency,  impacts,  cost-

effectiveness and acceptance of various strategies for renovating urban districts 

-  To  illustrate  the  development  of  such  strategies  in  selected  case  studies  and  gather  related  best-practice 

examples 

-  To give recommendations to policymakers on how they can influence the uptake of cost-effective combinations 
of energy efficiency measures and renewable energy measures in building renovation at district level, and to 
give guidance to building owners/investors on related cost-effective renovation strategies. 

MODER project 

•  Title: Mobilization of innovative design tools for refurbishing of buildings at district level 
•  Objectives: 

[2015 - 2018] 

-  To develop tools for design at district and neighbourhood level that enable the comparison of different RES 

systems 

-  To improve non-technical stakeholders’ understanding of the behaviour of complex energy systems through 

visualisation of alternative energy scenarios. 

-  To improve holistic energy-system design at district level considering renewable energy systems (through 

optimal selection and sizing of energy conversion units as well as the energy distribution system) 

-  To develop processes and practices that enable building owners to activate refurbishment with the help of 
energy management companies and engineering companies, and develop business models for engineering 
companies, consultants and energy managers to profitably offer these services.  
•  Title: Smart INitiative of cities Fully cOmmitted to iNvest In Advanced large-scale energy solutions 
•  The SINFONIA project is a five-year initiative to deploy large-scale, integrated and scalable energy solutions in 

Sinfonia  

[2014 - 2019] 

mid-sized European cities. 

•  At the heart of the initiative is a unique cooperation between the cities of Bolzano and Innsbruck, complemented 
by five ‘early adopter’ cities (Pafos (CY), Rosenheim (DE), Seville (ES), La Rochelle (FR) and Borås (SE)) and more 
than 40 replication cities across the EU. 

•  A large part of the project is therefore dedicated to the transferability and scalability of the solutions. 
•  SINFONIA will define a limited set of district typologies and corresponding refurbishment models, enabling cities 

EU-GUGLE  

to easily assess their needs and efficiently define their long-term refurbishment strategies. 
•  Title: European cities serving as Green Urban Gate towards Leadership in sustainable Energy 
•  Objectives:  

[2013 – 2019] 

-  Development and implementation of a methodology for energy diagnosis and refurbishment of buildings, 

including an economic viability check tool for energy efficiency measures 

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Annex II: Factsheets and lessons learned 

-  Definition and testing of a smart metering concept, based on consultations and feedback received from end 

users 

-  Development of different smart promotion schemes to promote innovative integration of energy measures 

READY  

-  Analysis report of financing energy efficiency and RES integration. 

•  Title: Resource Efficient cities implementing ADvanced smart citY solutions 
•  Objective: Demonstration of a whole city approach including, among others: 

into buildings 

[2014 – 2019] 

-  Demonstration of a balanced and holistic approach towards affordable retrofitting of residential buildings 

and offices. 

-  Development and demo of flexible combined grid balancing/energy storage solutions for buildings and RES 

systems  

-  Development  and  demo  of  new  solutions  for  low-temperature  district  heating,  components  and 

management ICT systems 

-  Solutions for water efficiency and wastewater energy recovery. 

R2 cities  

•  Title: Renovation of residential urban spaces: towards nearly zero energy cities 
•  Objective: Develop and demonstrate  replicable strategies for designing, constructing and managing large-scale 

[2013 - 2017] 

district renovation projects for achieving nearly zero energy cities 

ZenN  

•  3 demo sites: Genoa (IT), Kartal (TK), Valladolid (ES) 
•  Title: nearly Zero ENergy Neighbourhood 
•  Objectives: 

[2013 - 2017] 

-  Demonstrate  the  feasibility  of  innovative  low  energy  renovation  processes  for  buildings  at  the 

- 

neighbourhood scale 
Identify,  optimise  and  disseminate  the  most  promising  management  and  financial  schemes  to  facilitate 
large-scale replication 

-  Develop, improve and launch ambitious replication plans at local and regional scales. 

CITyFIED  

•  Title: Replicable and innovative future efficient districts and cities 
•  Objective: A mix of demonstration, innovative technologies and sound business models towards the smart city of 

[2014 – 2019] 

the future 

▪  CITyFiED  aimed  to  deliver  sustainable  and  efficient  urban  districts  and  to  provide  a  high  quality  of  life  to  their 

inhabitants through optimal management of resources. 

City-zen  

[2014 – 2019] 

•  City-zen was a joint project of Amsterdam, Grenoble and 28 partners that was granted EU-funding to develop and 
demonstrate energy efficient cities and to build a methodology and tools for cities, industries and citizens to reach 
the 20-20-20 targets. 

•  The success of the technology implementation also depends on the involvement of citizens. A serious game will 

be created to engage citizens in an innovative way in the development of their smart city. 

OptEEmAL  

[2015 – 2019] 

•  Title: Optimised Energy Efficiency design platform for refurbishment at district level 
•  Objective: to develop an Optimised Energy Efficient Design Platform to improve the energy behaviour of a district. 
•  The tool will reduce time delivery and uncertainties and result in improved solutions when compared to business-

as-usual practices. 

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Annex II: Factsheets and lessons learned 

NewTREND  

•  Title: New integrated methodology and Tools for Retrofit design towards a next generation of ENergy efficient and 

[2015- 2018] 

•  Objectives: 

sustainable buildings and Districts 

-  Develop an integrated design methodology for energy retrofit 
-  Address all phases of the refurbishment process (concept design to implementation and operation) 
-  Develop a toolkit to support each phase 
-  Foster collaboration among stakeholders and involve building inhabitants and users  
-  Establish energy performance as a key component of refurbishments 
-  Cover  detailed  design  of  one-two  buildings  taking  into  account  interactions  with  the  surrounding 

neighbourhood 

-  Facilitate the use of BIM for retrofit. 

CONCERTO 

•  Aims at demonstrating that the energy optimisation of districts and communities as a whole is more cost-effective 

[2005 – 2014] 

•  Consisted of projects in 58 communities in 23 countries that ran from 2005 to 2014.  

than optimising each building individually  

Note: My Smart City District group (MSCD) is an eight-project consortium that contains most of the above-mentioned projects (EU-GUGLE, 

R2CITIES, ZenN, CITyFIED, Sinfonia, READY, City-zen and Celsius). Its goal is to cluster a number of their activities to share and promote 

energy efficient renovation solutions for cities and communities EU-wide. 

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Annex II: Factsheets and lessons learned 

4.6 Concluding assessment 

District  approaches  to  the  renovation  of  existing  buildings  consist  of  comprehensive 

approaches that aim at renovating not only single building units, but rather a district or a 

neighbourhood  at  the  same  time.  District  approaches  will  help  to  tackle  three  key 

challenges  regarding  renovation  of  existing  buildings  in  the  EU:  developing  integrated 

approaches maximising the synergies between energy efficiency and renewable energy, 

streamlining  and  aggregation  of  renovation  solutions  and  processes,  and  developing 

comprehensive  (sub)urban  strategies  combining  energy  and  carbon  efficiency  of  the 

building  stock  with  sustainable  solutions  for  growth  and  improvement  of  citizens’ 

wellbeing.  

The following conclusions are based on the analysis of policies in 18 countries and 5 regions 

and additional research on local and international initiatives. 

District approaches to efficiently unlock the renovation of the building stock are relatively 

new in political agendas and the scale of implementation can be very local. Hence, existing 

national  and  regional  legislation  is  scarce.  Where  initiatives  exist,  they  are  often  at  the 

stage  of assessing the  requirements and benefits  of such approaches. Exceptions  exist, 

and some pioneering provisions have been highlighted.  

Even  though  provisions  that  aim  to  streamline  and  aggregate  renovation  solutions  and 

processes  at  neighbourhood  level  are  fewer  in  number  compared  to  policies  addressing 

other challenges, they are generally strongly related to the renovation of existing buildings 

at the district level. While the two other key challenges (i.e. integrated EE/RES approaches 

and  comprehensive  (sub)urban  strategies)  are  better  addressed  in  terms  of  quantity  of 

policy  instruments,  these  are  generally  less  targeted  to  the  renovation  of  the  building 

stock.  

Regarding  integrated  approaches  to  maximise  both  EE  and  RES  potentials,  three  main 

types of initiatives were identified: district heating developments, local/regional mapping 

of  renewable  heat  potentials,  and  energy  communities.  Provisions  aiming  to  streamline 

and  aggregate  renovation  solutions  are  mainly  initiatives  and  studies  exploring  the 

strengths  and  weaknesses  of  such  approaches,  but  the  results  of  those  initiatives  have 

tremendous  potential  for  future  replication  and  scaling  up.  Finally,  most  provisions 
regarding comprehensive (sub)urban strategies can be clustered into three types: infill20 
strategies and rehabilitation of buildings, sustainable urban energy efficiency plans, and 

sustainable  urban  planning  projects  encompassing  energy  efficiency,  RES  and  health 

benefits (new builds). 

Recent international projects bring valuable insights on the required components to enable 

and foster district approaches to energy renovation of existing buildings. They also provide 

a  series  of  pilot  cases,  methodologies  and  tools  to  support  the  development  and 

dissemination of district approaches. Most of these ended a few months ago. The challenge 

lies in the dissemination and replication of their results. 

20  In  urban  planning,  infill  is  the  rededication  of  land  in  an  urban  environment,  usually  open  space,  to  new 
construction. 

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Annex II: Factsheets and lessons learned 

Assessment of impact per type of policy instrument 

A broad range of policy instruments is needed in order to mainstream district approaches 

for  renovation.  Allowing  for  the  integration  of  both  cost-efficiency  and  social 

considerations, district approaches need to boost the renovation of the existing building 

stock  and  the  deployment  of  renewable  energy  solutions.  Given  the  early  stage  in  the 

development  of  district  approaches  for  renovation  in  the  EU,  a  quantitative  impact 

assessment  cannot  be  provided  here.  Instead,  the  role  of  each  type  of  instrument  is 

discussed, as illustrated in Figure 4. 

Figure  4.  Interactions  between  policy  instruments  for  the  deployment  of  district 
approaches to the renovation of the existing building stock 

Information and awareness raising will play a major role in the deployment of district 

approaches. In particular, awareness raising and capacity building of local administrations 

on the benefits of such approaches are indispensable for the emergence of district-scale 

renovation projects. Appropriate information combined with financial support can trigger 

voluntary  actions  (pilot  projects,  sustainable  district  certification  schemes,  etc.)  that 

demonstrate the benefits and stimulate innovation in business models, tools and financing 

models.  Improved  data  on  the  building  stock  will  also  support  private  initiative 

developments of innovative solutions for group renovations of specific buildings segments. 

Technical support: District-level initiatives involve a large number of stakeholders from 

different sectors as well as different building types and ownerships. While information and 

awareness raising can trigger interest, effective results depend on the development and 

dissemination of the tools required for such approaches (for the stakeholder engagement 

and  decision-making  processes, 

the 

techno-economic  design,  etc.),  and 

the 

implementation  of  specific  roles  for  the  activation  and  facilitation  of  district-level 

73 

Annex II: Factsheets and lessons learned 

renovations. Again, the availability of financial support can enable such technical support 

instruments. 

Financial  support  such  as  subsidies  can  create  an  economic  incentive  to  trigger 

investments both on the demand side and on  the supply  side. More importantly  on the 

demand  side,  financial  support  will  help  to  bring  the  required  technical  support  to  local 

stakeholders and help facilitate participation processes. On the supply side, it can support 

private pioneer actors in developing innovative solutions. 

Voluntary  instruments  (private  pilot  projects,  voluntary  certification  schemes,  large-

scale  renovation  of  public  buildings)  are  crucial  to  demonstrate  the  benefits  of  district-

level  approaches  and  build  capacity  of  all  stakeholders  with  these  approaches.  District 

approaches are inherently deeply impacted by the local context with specific stakeholders 

and characteristics of the building stock. Careful analysis of success and failure factors is 

crucial  to  maximise  the  impacts  of  the  district-scale  renovation  projects  triggered  by 

voluntary (and surrounding) instruments. 

Strategies  and  planning  maximise  benefits  and  increase  positive  synergies  (possibly 
reducing  the  total  required  investments).  Appropriate  energy  planning  tools21  allow 
projects to go beyond technical and economic criteria, integrating social considerations.22  

Mandatory instruments at the local level (e.g. targets such as average energy efficiency 

level, RES contribution or maximum levels of greenhouse gas emissions, or through means 

such  as  regional  or  local  heat  plans)  can  foster  the  integration  of  energy  and  climate 

objectives in local planning and strategies. They can also trigger discussion between local 

stakeholders and lead towards cost-optimal solutions at district level (generally better than 

the  sum  of  individual  cost-optimal  solutions).  Furthermore,  legislative  instruments  can 

mandate such integration of land-use and  energy planning to capture, amongst  others, 

the potential of densification to connect sustainable mobility, buildings energy renovation 
and revitalisation challenges. 

Financing  instruments  provide  the  ability  to  invest,  but  only  apply  where  there  is 

already  a  need  or  desire  to  take  measures.  While  district  approaches  can  drive  the 

mobilisation  of  investments  (such  as  higher  investment  volumes  and  diversified  risk 

portfolios) they also bring specific challenges to be addressed by financing schemes  for 

the feasibility of community projects. 

Market-based  instruments  were  not  identified  in  the  country  analysis  behind  this 

factsheet, nor in the literature review. However, minimum energy efficiency requirements 

applied  to  individual  buildings  are  expected  to  affect  prices  on  the  real  estate  market. 

Likewise, mandatory targets framed at the local level could impact this price signal and 

foster district/neighbourhood approaches. 

Private  initiatives  (e.g.  business  model  innovation,  innovation  in  renovation  products 

and processes, large-scale private investments in the renovation of groups of private or 

public buildings) will be made possible through facilitated demand markets, quality data 

on the building stock and mandatory instruments that provide certainty and clear targets. 

21 InSMART: Integrative Smart City Planning  
22 European Alliance to Save Energy, 2020. Recommendations for a neighbourhood approach to maximize energy 
efficiency in renovation and energy planification. 

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Annex II: Factsheets and lessons learned 

In order to scale up innovation, both an improvement of the conditions for innovation on 
the supply side and market demand for innovative decarbonisation solutions are needed.23  

In  conclusion,  information  and  technical  support  combined  with  financial  support  and 

innovation  are  seen  to  deliver  a  binary  impact,  i.e.  nothing  will  be  achieved  unless 

significant  efforts  are  devoted  to  deploying  such  instruments.  They  are  the  ground  for 

voluntary instruments that provide the needed learning and demonstration lab. Strategies 

and  planning  embedding  RES,  energy  efficiency  and  carbon  targets  together  with  the 

broader challenges in the development of sustainable cities will help to identify the local 

resources,  constraints,  and  synergies  to  lower  the  costs  and  maximise  the  multiple 

benefits  of  buildings  energy  renovation  projects.  Building  on  this  ground,  mandatory 

instruments can be framed to encourage district approaches to renovation but will only be 

actionable  if  adapted  financing  schemes  are  mainstreamed.  The  paradigm  shift  for 

renovation,  from  individual  building  units  to  groups  of  neighbouring  buildings,  can  be 

further supported by private initiatives, steering innovation on the whole supply chain and 

the mobilisation of private investments.  

Based  on  our  review  of  existing  policy  instruments,  we  conclude  that  Member  States 

mainly  implement  single  policies  out  of  this  broad  set  of  possible  instruments  (with 

strategies and planning, and financing instruments being the least considered). Guidance 

on  the  implementation  of  comprehensive  policy  packages  to  foster  district-scale 

renovation projects would certainly help to strengthen the efficiency of existing policies. 

Ease of implementation per type of policy instrument 

There is still an important gap in capturing the potential of district approaches. This final 

section briefly discusses the possible efforts of the EU Commission to fill this gap. 

Information and awareness raising is probably the biggest challenge in terms of efforts for 

all political levels. Efforts at the EU level could focus on targeting local government and 

enable  them  to  disseminate  information  and  raise  awareness  toward  their  local 

stakeholders. This could be done via specific workstreams dedicated to district approaches 

for  renovation  in  initiatives  such  the  Covenant  of  the  Mayors  or  the  Positive  Energy 

Districts  (PED)  programme.  This  will  be  usefully  supported  by  communications  on  best 

practice examples, distinguishing between generic and context-specific success and failure 

factors. 

The required technical support (accompaniment and tools) can be structured based on the 

learnings  from  a  short  list  of  (recently  closed  and  ongoing)  EU-funded  projects  and 

international initiatives focusing on district approaches to renovation. This support can be 

brought to local stakeholders via a combination of central (EU) and decentralised groups 

of technical experts, together with the financing of this expertise. 

The PED programme – aiming to support the planning, deployment, and replication of 100 

Positive  Energy  Neighbourhoods  by  2025  and  coordinated  by  JPI  Urban  Europe  –  is  an 

important  initiative  to  raise  awareness,  increase  knowledge  and  trigger  voluntary 

initiatives. 

Comprehensive  strategies  and  planning  require  stakeholder  participation,  which  can  be 

enabled  through  tried-and-tested  facilitation  processes,  tools  and  frameworks.  The 

23 CE Delft, 2020. Zero carbon buildings 2050 

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Annex II: Factsheets and lessons learned 

integration  of  different  objectives  in  the  development  of  sustainable  cities  into  holistic 

strategies and planning could be fostered by national legislation, mandated or encouraged 

at EU level. 

Mandatory instruments certainly need strong political commitment,  should be affordable 

(enabled  amongst  others  by  innovation,  financing  schemes  and  financial  support)  and 

depend  on  the  availability  of  technical  support.  Article  19  of  the  revised  Energy 

Performance of Buildings Directive (EPBD) indicates that, by 1 January 2026 at the latest, 

“the  Commission  shall  examine  in  what  manner  Member  States  could  apply  integrated 

district or neighbourhood approaches in Union building and energy efficiency policy, while 

ensuring  that  each  building  meets  the  minimum  energy  performance  requirements,  for 

example by means of overall renovation schemes applying to a number of buildings in a 

spatial context instead of a single building.” Moving in that direction, a clear definition of 

a  neighbourhood  approach  should  be  established,  e.g.  specifying  the  ratio  of  worst-

performing buildings in a given area to be renovated, to avoid a ‘pick and choose’ approach 

where  only  buildings  that  are  easier  to  renovate  are  part  of  the  district  renovation 
strategy.24 District approaches transposing the EPBD, as found in the new German law on 
energy in buildings, need to be  evaluated carefully to make  sure they are not watering 
down renovation ambition compared to previous legislation.25 

Finally,  private  initiatives  could  be  facilitated  by  the  creation  of  innovation  ecosystems 

connecting different actors in the innovation value chain, including universities, technology 

suppliers  and  construction  companies.  They  can  also  be  triggered  by  large-scale 

renovation programmes of public buildings that could be fostered or mandated at EU level. 

24 European Alliance to Save Energy, 2020. Recommendations for a neighbourhood approach to maximize energy 
efficiency in renovation and energy planification. 
25  The  so-called  “Innovationsklausel”  (§103  Gebäudeenergiegesetz)  allows  the  previously  existing  minimum 
efficiency  requirements  for  new  buildings  to  be  fulfilled  at  the  district  level,  thereby  lowering  the  minimum 
requirements for individual buildings. 

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renovation and modernisation of the 
built environment 
Engaging transformation and phasing out inefficient 
buildings –Factsheet  

Authors: Janne Rieke Boll, Rutger Broer, Sibyl Steuwer, Jonathan Volt 

September 2020 

Tender N° ENER/C3/2019-468/03 

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Annex II: Factsheets and lessons learned 

5.1 Introduction   

This  factsheet  provides  an  overview  of  how  different  policy  instruments  and  selected 

private initiatives can help to achieve European objectives and effectively address key EU 

challenges in the strategic area of engaging transformation. The findings draw upon a 

policy  screening  for  15  EU  Member  States,  3  non-EU  countries  and  5  European  regions 

covering  broadly  the  climatic  zones  of  the  EU.  In  addition,  the  factsheet  draws  on 

additional  information  provided  by  external  experts  as  well  as  on  the  long-standing 

expertise of the authors, meaning policy examples going beyond the researched country 

and region cases are occasionally added. The concluding assessment draws on the findings 

and detailed analysis of the good practice cases  as well as on the in-house expertise of 

the partners. 

5.2 Engaging transformation and phasing out inefficient buildings  

Engaging transformation and phasing out inefficient buildings is at the core of achieving a 

decarbonised building stock in the EU. Some 40% of EU energy consumption and 36% of 
its CO2 emissions are related to buildings.26 Renovating the least efficient buildings in the 
EU can contribute to bringing down these figures significantly. To establish a deep-retrofit 

market to decarbonise the building stock, certain key challenges need to be overcome:  

1.  Create  an  enabling  framework  for  deep  renovations  that  are  currently  not  cost-

effective.  

2.  Trigger  behavioural  change  and  acceptance  of  deep  energy  renovation  among 

building owners and occupants.  

3.  Accelerate  the  market  penetration  of  innovative  solutions  for  deep  energy 

renovations  

4.  Achieve deep renovations in a heterogenous building stock with mixed ownership. 

The following sections provide:  

•  A summary and specification of selected policy instruments that have been scanned 
for in each country/region covering instruments to phase out the worst-performing 

building  stock  and  introduce  building  renovation  passports,  one-stop-shops  and 

information instruments.  

•  An  overview  of  the  policy  mix  (both  legislative  and  non-legislative)  in  place  to 
address the key challenges mentioned above in all 23 countries and regions.  

•  A shortlist of good practice examples.  
•  A concluding assessment analysing the impact and transferability across all types 

of policies. 

5.3 Provisions to address key challenges  

This section gives an overview of the policies considered to be most successful at tackling 

key challenges in the area of  engaging transformation. To operationalise the challenges 

and allow for quantitative estimations on selected aspects, the country screening looked 

for provisions including instruments to phase out inefficient buildings, building renovation 

passports, and provisions to set up one-stop-shops (OSS).  

26 European Commission. (2019). Link 

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Annex II: Factsheets and lessons learned 

A  broad  spectrum  of  policy  instruments  is  applied  across  the  EU  to  address  the  key 

challenges in this strategic area. Table 5 provides an overview of a selection of key policy 

instruments  assessed  for  all  targeted  jurisdictions.  These  policy  instruments  are  rather 

novel and address important gaps in the policy mix.  

Policy  instruments  to  phase  out  inefficient  buildings  refer  to  a  variety  of  regulations, 

programmes,  (financial)  schemes  and  strategies  that  Member  States  implement  to 

renovate  the  worst-performing  buildings.  A  distinction  is  made  between  mandatory 
instruments and non-mandatory instruments.27  

Mandatory instruments 

Almost  all  countries  have  implemented  forms  of  mandatory  instruments  to  phase  out 

inefficient buildings, e.g. the obligation to upgrade the energy performance of a building 

when major renovations take place. Most of the time, these instruments are transposing 

the  requirements  of  Article  4  (and  Article  7)  of  the  Energy  Performance  of  Buildings 

Directive (EPBD), but do not go beyond. Only in a few countries do provisions go beyond 
EPBD requirements, in particular the  Minimum Energy Efficiency Standards28 for private 
rented property in England and Wales, minimum performance requirements in Flanders,29 
Mandatory Renovation in Brussels,30 EPC level C for office buildings larger than 100m2 in 
the Netherlands by 202331 and Minimum Energy Performance for Buildings in France32. In 
certain  countries  specific  mandatory  minimum  requirements  apply  to  public  buildings 

transposing  Article  6  of  the  Energy  Efficiency  Directive  into  national  legislation,  for 
example in Brussels33 and Spain34, where public buildings can only be purchased or leased 
if they obtain an EPC label of C or better. 

Another type of mandatory measure is the phasing out of fossil fuel-fired heating boilers, 

which a growing number of European countries have put/are putting in place. Mostly, it 

applies  to  oil-fired  boilers  in  new  buildings  (Brussels,  Flanders,  some  Austrian  regions, 
Germany).  Ireland  also  includes  a  ban  on  gas-fired  boilers35,  the  UK  includes  all  fossil-
fuel-based heating and the Dutch government decided to phase out gas use for heating in 

new buildings from 2020. In Poland, the frontrunner Krakow and the  Malopolska region 

decided to phase out coal-fired boilers in 2013 (in force since 2019) inspiring other Polish 

regions to set up minimum emissions standards, thereby not only reducing CO2 emissions 

27 Mandatory instruments include minimum performance requirements for existing buildings or renovation 
regulations that go beyond European requirements. Among non-mandatory measures, the focus is on the 
renovation of the worst-performing building segments and measures taken to incentivise the renovation up to 
a certain building performance standard (e.g. EPC class). The non-mandatory instruments can also include 
financial support, as well as programmes to renovate inefficient buildings in vulnerable areas (e.g. many 
energy-poor households). 
28  The  Energy  Efficiency  Regulations  (2015).  Minimum  Energy  Efficiency  Standard  (MEES)  for  private  rented 
property in England and Wales.  
29 Minimum performance requirements in the Flemish Building Code (2019). Mandatory insulation levels for roofs 
by 2020 and windows by 2023. Regulation. Art 39.  
30  Strategy  to  reduce  environmental  impact  of  buildings  Brussels  (2020).  Mandatory  renovations  at  5-year 
intervals to achieve decarbonisation in 2050. LTRS, p42. 
31 EPC level C for office buildings - Bouwbesluit (2012). Obligation for offices larger than 100m2 must achieve 
EPC C in 2023. Link regulation,  
32  Minimum  energy  performance  buildings.  (2015).  France.  Minimum  requirements  for  rented  properties  in 
residential and non-residential sector. Article 12. 
33  EE  standards  for  rented  or  purchased  public  buildings  (2013).  Ordinance  of  Air,  Climate  and  Energy 
Management. Art. 2.1 Anex 2.1 
34 Law on the rationalization of the public sector (2014). EE requirements for procurement of goods and buildings 
of public authorities.  
35 Government of Ireland (2019) Climate Action Plan, p. 82  

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but also air pollution.36. In 2016, Denmark banned oil-fired boilers for existing buildings 
when there is the opportunity to connect to district heating. In Norway, from 2020, the 

use of oil-fired boilers is banned for all existing buildings. 

Non-mandatory instruments 

Non-mandatory  instruments  to  phase  out  inefficient  buildings  often  take  the  shape  of 

financial support linked to energy efficiency in specific building renovation  programmes. 

One  example  is  Lithuania’s  renovation  (modernisation)  of  multi-apartment  buildings 
programme37 which aims to renovate a large share of its apartment buildings up to the 
EPC  level  C.  In  France,  through  subsidies  for  replacing  old  and  inefficient  oil  (and  gas) 
boilers, the government aims to achieve zero oil boilers in the next 10 years.38 Another 
example is a grant for residential building renovation with  free energy advice for A+++ 
renovation  in  Baden-Württemberg39.  Examples  for  other  instruments  include  the 
facilitation of energy-efficient renovation to an EPC level A in case of a major renovation 
for the social housing sector in Brussels40 and a programme to renovate worst-performing 
schools  (with  an  EPC  level  G)  by  2022  in  the  Netherlands.41  In  Finland,  buildings  with 
energy classes F and G can benefit preferentially from the energy subsidy scheme, which 

can also be combined with a demolition subsidy for vacant and poor quality buildings. 

Building  renovation  passports  (BRPs)  are  documents  (paper  or  digital)  that  outline  a 

stepwise roadmap with renovation measures tailored to individual buildings with a 15-20-
year  timeline.42  They  aim  to  help  to  align  renovation  according  to  individual  needs  and 
long-term requirements.  

BRPs are not yet widespread across Europe. Currently implemented BRPs are the Flemish 
Energy  Performance  Certificate  [Belgium]43,  the  local  Energy  House  Passport  [France]44 
and  private  Energy  Efficiency  Passport  [France]45,  the  Individual  Renovation  Plan 
[Germany]46, as well as pilots tested in the iBRoad project (with pilots in Poland, Portugal, 
Germany,  Bulgaria  and  stakeholder  engagement  in  Greece,  Romania  and  Austria).47 
Ireland is currently piloting a building renovation passport48, based on the iBRoad model.  

One-stop-shops for energy renovation of buildings cover the complete customer journey 

from the monitoring of savings, structure and provision of financial support and technical 

36 RESOLUTION No. XVIII/243/16 of the SEJMIK OF THE MAŁOPOLSKIE VOIVODSHIP of 15 January 2016 on the 
introduction of restrictions on the operation of installations where fuels are burned in the area of the Municipality 
of Kraków” https://bip.malopolska.pl/umwm/Article/get/id,1159347.html  
37  Renovation  (Modernisation)  of  multi-apartment  buildings.  (2021-2030).  Lithuanian  National  Energy  and 
Climate Plan. Lithuanian government. p146 
38https://www.ecologique-solidaire.gouv.fr/communique-presse-francois-rugy-et-julien-denormandie-
annoncent-lancement-progressif-prime 
39 Support Programme for Climate Friendly Housing (2020). Freiburg. Free Energy Saving at Home A+++  
40 Strategy to reduce environmental impact of buildings Brussels (2020). Energy performance of social housing. 
P47 
41 The Building Agenda (2017). Roadmap sustainability of schools. Target: schools  with EPC-G renovated before 
2022. 
42 BPIE (2018). . Link 
43 The Flemish EPC has been updated to include a building renovation passport.  
44  European  Commission  (2019).  Technical  study  on  the  possible  introduction  of  optional  building  renovation 
passports 
45 P2E. (2017). Energy Efficiency Passports. Passeport Efficacité Energétique (P2E).  
46 BPIE. (2017). Building Renovation Passports. Individueller sanierungsfahrplan. 
47 IBroad, pilot implementation of BRP in Greece, Poland and Portugal. H2020 project.  
48  IGBC  (2019).  Building  Renovation  Passport  Pilot.  Irish  Green  Building  Council  and  Limerick  Institute  of 
Technology. 

80 

 
 
Annex II: Factsheets and lessons learned 

assistance to information provision.49 For clients, they are an accessible and transparent 
tool to select and commission renovation measures, while for suppliers in the renovation 

sector they provide opportunities for innovative business models. 

While many countries have attempted to provide aggregated services for renovation, fully-

fledged one-stop-shops including the provision of financing are not yet in place throughout 

Europe.  Picardie  Pass  Rénovation  in  France  was  a  pioneer  in  integrating  third-party 
financing in its OSS model for homeowners. RenoWatt in Wallonia50 facilitates renovations 
of public buildings through simplified tendering procedures, financial packages including 

energy  performance  contracting  and  aggregation  of  projects.  The  public  Bedre  Bolig 
Scheme51 and private BetterHome, both in Denmark, use publicly available building data 
to trigger energy renovation projects. Superhomes [Ireland]52 and Oktave [France] focus 
solely on the deep renovation of single-family houses, while Operene [France] does the 

same for larger buildings. ProEnergyHomes in Ireland uses energy efficiency obligations 

in its OSS to compile an attractive offer. 

49 JRC (2018) Link  
50 RenoWatt, Wallonia, is an OSS for public buildings specialised in energy audits, technical studies and energy 
performance contracting.  
51 The Bedre Bolig scheme. Law 1876. Denmark. Facilitates OSS through an amendment on the promotion of 
energy savings in building.  
52  Superhomes  in  Ireland  is  a  OSS  that  offers  cost-effective  building  performance  measures  in  an  integrated 
solution  

81 

 
 
Annex II: Factsheets and lessons learned 

Table 5 - Overview of selected instruments adopted in the jurisdictions analysed53 

Country/ 

Instruments to phase out inefficient buildings 

Region 

Mandatory 

Voluntary/recommended 

Building renovation passports 

Provisions to set up 

OSS 

√ 

√ 

√ 

√ 

Andalusia 

Baden-Württemberg  

Brussels 

Flanders 

Wallonia 

Croatia  

Denmark 

France  

Germany  

Greece  

Ireland 

Italy  

Lithuania 

Netherlands 

√ 

Norway  

Poland 

√ 

√ 

√ 

(√) 

(√) 

√ 

√ 

(√) 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

(√) 

√ 

√ 

√ 

√ 

(√) 

√ 

(√) 

(√) 

(√) 

53 Check marks within brackets indicate that there are measures that only partially comply with the definition provided above. 

82 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Portugal  

Romania 

Silesia 

Spain 

Sweden 

Tirol 

UK 

Umea 

USA 

√ 

(√) 

(√) 

√ 

√ 

(√) 

√ 

(√) 

√ 

83 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

If  we  group  the  existing  policies  in  three  categories  (regulation54,  financial  measures55, 
and  informative  measures56)  most  countries  have  adopted  a  mix  of  policies,  some 
privileging  informative  measures  (e.g.  Portugal,  Romania,  Spain)  over  financial  support 

(e.g.  Croatia,  Germany,  Ireland,  but  also  most  regions)  or  regulations  (e.g.  France, 

Greece, Belgium, Poland). 

While all analysed countries and regions have implemented forms of financial measures to 

stimulate  the  renovation  of  inefficient  buildings,  the  financial  support  for  renovation  is 

mostly  not  targeted  at  the  worst-performing  building  stock  in  particular,  but  at  certain 

segments  of  the  buildings  stock  (e.g.  all  residential  buildings,  all  buildings  with  co-

ownership, etc.). The long-term renovation strategies (LTRS) submitted in 2020 show that 

Member  States  have  generally  got  better  at  identifying  the  worst-performing  building 

stock.  However,  this  does  not  always  translate  into  clear  policies  to  renovate  these 

buildings.  Informative  measures  represent  an  important  share  of  measures  in  many 

countries. This indicates that raising awareness and sharing knowledge is relatively easy 

to implement. It can become an effective way to trigger acceptance by building owners, 

inhabitants and construction professionals if part of a wider policy mix including financial 

support and mandatory instruments.

5.4 Overall assessment for effectiveness - overview and description 

This section presents an assessment of the overall policy landscape that a previous country 

screening  identified  as  relevant  for  the  covered  countries  and  regions.  The  assessment 

takes into account the diversity of instruments (regulation, pricing, support, information 

etc.), whether there are particularly interesting and innovative instruments, and whether 

the instruments identified together seem to be adequate to address the given challenges. 

The overview tables are followed by a discussion of policy instruments.  

The given classification in Table 6 and Table 7 should be interpreted as follows: 

Good  policy  landscape  with  at  least  one  innovative  instrument  targeting 

engagement 

Adequate  policy  landscape  with  instruments  that  could  in  the  future  better 

integrate engagement in building renovation policies 

54  Regulations  here  entail  mandatory  performance  requirements,  sections  with  minimum  performance 
requirements and technical standards in the building code, mandatory public procurement policies about renting 
properties, obligations to save energy (public/private), and bans on fossil heating sources.  
54 Financial measures relate to financing renovation of inefficient buildings, mostly consisting of grants, subsidies, 
ESCO financing schemes, tax rebates and public/private financing. 
54 Informative measures are policies designed to enhance awareness, knowledge generation and dissemination. 
This 
renovation  passports, 
environmental/energy efficiency certification or labels, awareness campaigns and guidance documents, free or 
subsidised energy audits, (digital) knowledge sharing platforms or tools, and training and education programmes. 

certificates,  one-stop-shops,  building 

includes  energy  performance 

84 

 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Inadequate policy landscape, with no instruments identified in relation to the 

given challenges 

Not conclusive 

Table 6 - Legislative policies 

Engaging transformation - legislative policies 
KEY CHALLENGES 

Create an 
enabling 
framework for 
deep renovations 
that are currently 
not cost-effective 

Trigger 
behavioural 
change and 
acceptance of 
deep energy 
renovations 
among building 
owners and 
occupants  

Accelerate the 
market 
penetration of 
innovative 
solutions for 
deep 
renovations 

Achieve deep 
energy 
renovations in 
an 
heterogenous 
building stock 
with mixed 
ownership 

Belgium 
Croatia 
Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 
BW 
Silesia 
Umea 

Table 7 - Non-legislative policies 

Engaging transformation – non-legislative policies 
KEY CHALLENGES 

Create an 
enabling 
framework for 
deep renovations 
that are currently 
not cost-effective 

Trigger 
behavioural 
change and 
acceptance of 
deep energy 
renovations 
among building 

Accelerate the 
market 
penetration of 
innovative 
solutions for 
deep 
renovations 

Achieve deep 
energy 
renovations in 
an 
heterogenous 
building stock 
with mixed 
ownership 

85 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

owners and 
occupants 

Belgium 
Croatia 
Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 
BW 
Silesia 
Umea 

86 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

1)  Create  an  enabling  framework  for  deep  renovations  that  are  currently  not 

cost-effective 

To  reach  the  European  long-term  targets  for  climate  protection  in  the  building  sector, 

measures that are not yet cost-effective from a purely financial perspective will have to 

be implemented. While both the current regulatory framework in the EU as well as policies 

in several Member States are mostly focused on implementing cost-effective measures, 

there are still numerous provisions in place that promote deep renovation. 

While mandatory requirements rarely go beyond EU requirements (for exceptions, see 

above),  all  countries  and  regions  have  financial  support  in  place  to  encourage  deep 

renovation  (see  also  factsheet  on  financing  renovation).  Some  grant  schemes  are 

performance  oriented  and  provide  (close  to)  sufficient  financing  for  climate-proof 

renovation.  One  of  the  most  prominent  schemes  is  the  German  KfW  energy  efficient 
renovation57 programme which was recently updated and topped up with additional grants 
and better loan conditions. It is combined with  the KfW Energy Efficiency Standard58 to 
provide more funding for very efficient renovations. 

The  availability  of  funds  at  the  regional  level  varies.  While  there  are  regions  with  only 

limited grants available at the local level dedicated to carrying out deep energy renovation 
(e.g.  the  Catching-Up  2  Regions  programme  in  Silesia59  promotes  renovation  to  fight 
smog), there are others that offer a wide range of grants. An example is Tirol with several 
regional  grants  to  support  energy  renovation60  in  the  building  sector  that  can  be 
complemented  by  other  local  grants,  e.g.  the  municipal  grant  offered  in  the  city  of 

Innsbruck. Both programmes provide additional support (Ökobonus) for deep renovation 
and  also  support  renewable  building  material61.  Another  example  is  the  renovation 
programme  in  Pays  Voironnais  in  France62  to  renovate  condominiums.  In  certain 
jurisdictions,  these  programmes  are  tailored  to  social  housing  or  buildings  in  socio-

economically disadvantaged areas, like for example the Better Energy Communities and 
Energy Efficiency Retrofit Programme in Ireland6364, the Support for Housing Associations 
in  disadvantaged  areas  in  Sweden,  Umea65  and  the  Saving  at  Home  programme  II  in 
Greece66. In Spain’s National Housing Plan, Spain67 loans and grants for energy-efficient 

(2020) 

Investitionszuschuss“ 

57  KfW  Programm  151,  152  „Energieeffizient  sanieren  –  Kredit“  (2020),  https://www.kfw.de/PDF/Download-
Center/F%C3%B6rderprogramme-(Inlandsf%C3%B6rderung)/PDF-
Dokumente/6000003743_M_151_152_EES_Kredit_2018_04.pdf, KfW Programm 430 „Energieeffizient sanieren 
– 
https://www.kfw.de/PDF/Download-Center/F%C3%B6rderprogramme-
(Inlandsf%C3%B6rderung)/PDF-Dokumente/6000004311_M_430_Zuschuss.pdf 
58 KfW Energy Efficiency Standard. (2020). KfW Group. Germany. 
59 Catching-up 2 Regions. Fight against smog: financial instruments for increasing the energy efficiency of single-
family buildings)", URL: https://powietrze.slaskie.pl/content/projekt-poland--catching-up-regions 
60  Land  Tirol:  Wohnhaussanierungsrichtlinie  (2020),  URL:  https://www.tirol.gv.at/fileadmin/themen/bauen-
wohnen/wohnbaufoerderung/downloads_2019/ws-richtlinie_01-01-2020.pdf  
61  Landeshauptstadt 
Wohnhaussanierungsrichtlinie 
https://energie.innsbruck.gv.at/data.cfm?vpath=subsites/energie1/dokumente42/sanierungsfoerderung  
62 Renovation in Pays Voironnais (2013-2017). Communauté d’Agglomération du Pays Voironnais. ADEME and 
the Ministry of Environment and Energy. p37 
63 Better Energy Communities (2019-2020). Sustainable Energy Authority of Ireland.  
64  Energy  Efficiency  Retrofitting  programme  (2013-2019).  Irish  Department  of  Housing,  Planning  and  Local 
Government.  
65 Energy Renovation in Vulnerable Areas (2017-2018). Swedish National Board of Housing Boverkets.  
66 Saving at Home Programme II. Energy Efficiency Trends and Policies in Greece. Centre for Renewable Energy 
Sources and Saving Greece. p29 
67National Housing Plan 2018-2021. Spain. Royal Decree 106/2018. 

(Zusatzförderung  zur 
URL: 

fördert:  energetische  Sanierung 

Innsbruck 
des 

Innsbruck: 

Landes 

Tirol), 

87 

 
 
 
Annex II: Factsheets and lessons learned 

building renovation linked to achieving a certain level of EPC are combined with specific 

programmes to support vulnerable groups (e.g. youth and elderly). 

While all countries have informative measures in place to highlight the benefits of deep 

renovation, there is little well-targeted information available about benefits and the long-

term necessity of measures that are not yet cost-effective for the owner. BRPs and general 

energy  renovation  guidelines  by  governments  are  exemplary  measures  that  contain 

information on the necessity to reach long-term renovation targets. The definition of cost-

effectiveness  mostly  does  not  include  wider  benefits  and  follows  mainly  conservative 

approaches to define economic efficiency. Exceptions to this are the planned initiative to 
reform the  cost-effectiveness calculation to include wider benefits in  Wallonia68 and the 
update of criteria to renovate public buildings for federal buildings in Germany, now also 

allowing for deep renovation that is not yet cost-effective. 

Deep energy renovation of heritage buildings while preserving their cultural value is 

a challenge that is acknowledged in a variety of policy instruments. The KfW programmes 

specify  exceptions  for  technical  requirements  for  heritage  buildings  (“Effizienzhaus 
Denkmal”).  Ireland’s  Sectoral  Adaptation  Plan  –  Built  and  Archaeological  Heritage69 
addresses the twin challenges of reducing the energy consumption of heritage buildings 

and  enhancing  their  climate  resilience  at  a  strategic  level.  In  Croatia,  the  energy 
renovation programme for buildings with cultural heritage status70 is especially dedicated 
to finding energy renovation solutions for these buildings. 

2)  Trigger  behavioural  change  and  acceptance  of  deep  energy  renovations 

among building owners and occupants  

Initiatives  to  change  the  behaviour  of  building  owners,  occupants,  investors  and  other 

actors are becoming more common across the EU.  

The Energy Performance Certificate, now introduced in all Member States (and in the 

UK and Norway) as mandated by the EPBD, is widely used to influence behaviour and has 

the potential to become the most effective instrument to do that if improved and supported 

by  other  measures.  Flanders  has  evolved  its  EPC  framework  into  a  building  renovation 

passport,  with  step-by-step  renovation  advice  making  sure  the  suggested  measure  is 

logical  in  the  short  and  the  long  term.  Some  countries  have  also  modified  their  EPC  to 

become more attractive or user-friendly. The energy performance of the building envelope 

is  shown  in  the  Italian  EPC  with  qualitative  “smileys”,  indicating  its  ability  to  thermally 

insulate the building. On the front page of Portugal’s EPC, figures showing the building’s 

renewable energy use and CO2 footprint are presented. Several Austrian regions, e.g. the 

Salzburg region, have established a regional EPC database ZEUS.  

The energy expert/advisor can play an important role as “promoter” of the idea of deep 

energy renovations. The expert earns the owner’s trust by providing objective and easy-

to-understand information and personalised support on what a rational approach for their 

68  Draft  Walloon  Long-Term  Strategy  for  Energy  Renovation  of  Buildings  (LTRS)  (April  2020)  -  Chapter  IV.C, 
Action 41.1 
69 Department of Culture, Heritage and the Gaeltacht (2019) Built & Archaeological Heritage - Climate Change 
Sectoral 
Plan. 
https://www.dccae.gov.ie/documents/Built_%20and_Archaeological_Heritage_Climate_Adaptation_Plan.pdf 
70 Ministry of Environment and Energy (2019) Integrated National Energy and Climate Plan for the Republic of 
Croatia for the period 2021-2030, p. 140  

Adapta 

on 

88 

 
 
 
Annex II: Factsheets and lessons learned 

energy renovation might be. Project Zero in Sonderborg, Denmark has, among other one-

stop-shops, shown that this approach motivates a far larger share of owners to choose 

an energy renovation than in cases with only a financial incentive. Frontrunner cases (the 

Individual Renovation Plan in Germany, Picardie Pass Rénovation in France or the German 

energy  audits  scheme)  have  shown  that  tailored  and  personal  renovation  advice 
triggers building owners to renovate deeper and choose higher-performing components.71  

Several online tools exist to assist building owners to become more energy efficient. The 

National Digital Platform in the Netherlands helps homeowners to make their home more 

sustainable.  The  platform  also  makes  links  to  providers  and  financiers.  Other  examples 

were presented under the section on one-stop-shops above. 

The most common form of instruments to trigger acceptance and behavioural change are 

communication  and  awareness  campaigns.  Prominent  examples  are  the  digital 
training  for  landlords  and  tenants  on  green  leases  [Sweden]72,  energy  efficiency 
campaigns for public real estate managers [Portugal]73, the Deutschland macht's effizient 
[Germany], and the Big Energy Saving Week [UK]74. The Flemish “Ik BEN mee” campaign 
promotes  nearly  zero-energy  buildings  to  different  actors  in  the  value  chain  as  well  as 

building owners. In Croatia, an instrument including an energy service model aims to raise 
awareness of energy renovations.75 The ecotirol [Austria] is an advisory service informing 
the  region  on  various  topics,  including  energy  renovation.  In  Ireland,  Home  Energy 

Savings  Kits,  including  all  tools  to  assess  the  residential  energy  performance,  were 

available  free-of-charge  in  public  libraries.  An  education  and  information  campaign  in 

Silesia, Poland, linked to LIFE, is addressing all residents in the region.  

Some countries provide practical guides to illustrate the potential of energy renovations. 

The  Spanish  “Practical  guide  to  energy  for  building  renovation”  provides  detailed 

information  to  homeowner  associations.  In  Germany,  advisory  services  for  private 

individuals are available, free or for a small fee, across the country. 

Other jurisdictions use training programmes to get different actors to grasp and promote 

the value of deep energy renovations. Examples include digital training on hiring ESCOs 
and energy management [Spain],76 and the training programmes for  residential energy 
consumers  [Italy]77,  the  extensive  expert  training  [Tirol,  Austria]  and  the  Energilyftet 
[Sweden], a web-based training programme aimed at building performance professionals. 

The ADENE Academy in Portugal seeks to reinforce the professional skills and qualifications 

of technicians, which is needed for a transition towards deep renovations.  

Actions  are  also  being  taken  to  improve  awareness  in  the  public  sector.  Some 

countries focus on transparency of public building data to trigger additional energy-saving 

measures. Portugal’s Energy Efficiency Barometer was launched to characterise, compare 

and disseminate the energy performance of public entities. In Denmark, the energy use 

of the different ministries is publicly available, together with information on what measures 

71  European  Commission  (2019)  Technical  study  on  the  possible  introduction  of  optional  building  renovation 
passports.  
72 Web training Green Leases. (2018). Sweden. Swedish Energy Agency.  
73 EcoTalks. (2018). Portugal. Awareness campaign about EE. ADENE. 
74 BESW (2020). UK. Advice about energy efficiency. Ministry for Business, Energy& Industrial Strategy. 
75 Croatia NEEAP (2017) Fourth National Energy Efficiency Action Plan of the Republic of Croatia for the Period 
from 2017 to 2019 
76 Digital E-learning platform. Spain. Spanish National Energy Efficiency Action Plan (2017-2020). P87 
77 Training for energy customers. (2014). Italy. Italian National Energy and Climate Plan (2019). P34 

89 

 
 
Annex II: Factsheets and lessons learned 

they  have  implemented.  The  Action  Plan  for  Energy  Efficiency  in  Public  Buildings  in  the 

Autonomous Community of Arago, Spain trains public sector staff about energy efficiency 

in  an  effort  to  lead  by  example.  Similarly,  Brasov  in  Romania  collects  real-time  energy 

data in municipal buildings and uses this information to raise awareness among staff.  

Networks  can  also  be  a  trigger  for  behavioural  change  regarding  deep  energy 

renovations. BEBO in Sweden is a network of larger multi-family building owners (private 

and public), in which they aggregate projects and exchange knowledge and experiences. 

Similarly, the Knowledge and Innovation Platform in the Netherlands is a network to share 

information and best practices on making public buildings more sustainable. In Andalusia, 

Spain, a network has been established to share experiences on energy efficiency to raise 

awareness  and  promote  cooperation  between  local  governments  to  achieve  common 

objectives.  

‘Nudges’ and other actions to influence people’s energy consciousness are also becoming 

more  common.  The  objective  of  the  TRIBE  project  in  Spain  is  to  contribute  citizens’ 

behaviour change towards energy efficiency in public buildings, through their engagement 

in the experience of playing a social game.  

3)  Accelerate  the  market  penetration  of  innovative  solutions  for  deep 

renovations 

Compared to the other challenges, comparatively fewer policy initiatives have been found 

throughout Europe to incentivise innovations and accelerate their market share. 

The  business model  to  renovate  buildings  to  a  net-zero  energy  standard  making 

use  of  prefabrication  and  automation  developed  in  the  Netherlands  (Stroomversnelling) 

has been transferred to other European countries under the label Energiesprong. In Baden-

Württemberg,  renovations  with  prefabricated  facades  are  eligible  to  receive  a  specially 

tailored grant. The German government intends to implement a  support programme for 

similar purposes until the end of 2020 parallel to supporting the  German Energiesprong 

Initiative. The Realize-Initiative of the Rocky Mountain Institute brings the Energiesprong 

Initiative to America. 

The City of Portland Green Building Policy [USA, municipal level] consists of an integrative 

approach including requirements not only for energy efficiency but also e.g. construction 

waste  prevention,  or  pre-cabling  and  installing  charging  infrastructure  in  the  planning 

phase. 

One-stop-shops also help to accelerate the renovation of the building stock. Especially at 

the  regional  level,  there  are  considerable  initiatives  implemented  in  France  (e.g.  Pass 

Rénovation  [Région  Hauts-de-France],  Oktave  [Région  Grant  Est])  and  Ireland 

(SuperHomes, ProEnergy Ireland).  

The  Deep  Retrofit  multi-annual  programme78  in  Ireland  gathered  experience  on  the 
challenges  and  opportunities  of  deep  renovations  of  residential  buildings.  The  lessons 

learned will feed into a new retrofit model to upgrade 500,000 homes at large scale under 

the Irish Climate Action Plan.  

78 Deep Retrofit Programme, Sustainable Energy Authority Ireland (SEAI), 2017-2019 

90 

 
 
Annex II: Factsheets and lessons learned 

In other countries, innovative financing schemes related to energy service companies 

(ESCOs)  and  energy  efficiency  contracting  have  been  implemented,  including  the 
Programme  for  Energy  Renovation  of  Public  Buildings  in  Croatia79  and  Romania’s 
PadovaFIT  EXPANDED  programme  to  renovate  condominiums.80  Another  innovative 
financing instrument is the building-related financing in the Netherlands81 which will allow 
the  transfer  of  loans  for  energy  efficiency  measures  to  new  owners  when  a  property  is 

sold.  

4)  Achieve  deep  energy  renovations  in  a  heterogeneous  building  stock  with 

mixed ownership 

Policy  instruments  to  overcome  the  split-incentive  dilemma  include  mandatory 

minimum requirements (MMR) that oblige the building owner to adopt a certain level of 

energy  efficiency  performance  to  ensure  the  building  is  marketable  or  complies  with  a 

certain energy performance level at a specific point in time.  

The  Dutch  government  discusses  the  right  for  tenants82  to  require  their  landlord  to 
implement  deep  renovations,  including  reasonable  rent  increases  which  would  alleviate 
the split-incentive dilemma. In Germany landlords can transfer a share of the costs83 for 
energy efficiency improvements and modernisation to their tenants. An amendment of the 
Commercial  Rental  Act  makes  the  same  possible  in  Denmark84  and  the  Wallonian 
government wants to develop a “warm rent” system according to its draft LTRS to keep 

rent and heating costs constant after renovations.  

Energy service contracting is an approach to finance renovation that addresses the split-

incentive dilemma and is used in various European countries. Energy service companies 

(ESCOs) offer energy efficiency improvement measures that are repaid through the energy 

costs saved. In Portugal, a general tender process was established in 2011 to support the 

public  sector  in  setting  up  an  energy  service  market.  Italy’s  National  Energy  Efficiency 
Fund85  supports  measures  carried  out  by  ESCOs,  while  the  Energy  Efficiency  Fund86  in 
Ireland  lends  to  ESCOs  in  order  to  support  energy-efficient  building  renovations  in  the 

public and private sector. At the local level, under the Dublin Climate Action Plan, Dublin 

city council facilitated an energy performance contract for energy upgrades of public non-

residential  buildings  and  the  Belgian  region  of  Wallonia  plans  to  develop  the  legal  and 
regulatory framework of ESCOs87 including a regional facilitating agency.  

A consumer-centric, innovative approach to financing renovation works is the EuroPACE88 
integrated home renovation platform using on-tax financing to make long-term payback 

projects possible.  

79 Programme for Energy Renovation of Public Buildings (2014-2015). National Energy and Climate Plan Croatia. 
Ministry of Environment and Energy. p34. 
80 PadovaFIT EXPANDED. (2019-2022) Metropolitan area of Timisoara. H2020.  
81 Building Related Financing (GGF) (2019) Climate Agreement. Amendment to the civil law is expected in 2020. 
p23. The Netherlands. 
82 LTRS, the Netherlands, p. 38 
83 Modernisation apportionment, German Civil Code, §559 „Mieterhöhung nach Modernisierungsmaßnahmen“ 
84 Amendment of Commercial Rental Act, LTRS Denmark, 2017 
85 Fondo Nazionale per l’Efficienza Energetica [FNEE], Decree 22 December 2017 
86 Ireland Energy Efficiency Fund (IEEF) was launched by the Department of Communication, Climate Action and 
the Environment in 2014 and is managed by the private actor Sustainable Development Capital Limited (SDCL) 
87  Draft  Walloon  Long-Term  Strategy  for  Energy  Renovation  of  Buildings  (LTRS)  (April  2020)  -  Chapter  IV.C, 
Measure 34 
88 EuroPACE Horizon 2020 project, 2018-2021, https://www.europace2020.eu/  

91 

 
 
Annex II: Factsheets and lessons learned 

The Romanian national thermal rehabilitation programme89 addresses the issue of mixed 
ownership  in  apartment  buildings.  A  French  order90  from  2012  required  certain 
apartment buildings under co-ownership to carry out energy audits until January 2017 to 
initiate  renovation  projects,  while  information  campaigns  try  to  motivate  condominium 
syndicates to renovate (e.g Renovation in Pays Voironnais, p.37). At the local level, French 
initiative  mur  I  mur91  funds  co-owned  apartment  blocks  built  between  1945-1975.  The 
Brussels LTRS plans to establish a co-ownership facilitator under the Sustainable Building 
Facilitator:  this  dedicated  service  for  co-owned  apartment  buildings92  to  encourage 
renovation works intends to support at least 4% of co-ownerships per year by 2030. 

89  National  program  on  increasing  the  energy  performance  of  apartment  buildings,  government  decision  no. 
18/2009, MINISTRY OF PUBLIC WORKS, DEVELOPMENT AND ADMINISTRATION, Romania 
90 Decree no. 2012-111 from 27 January 2012 relating to the obligation to carry out an energy audit for buildings 
for the main use of residential condominiums of fifty lots or more and to the thermal regulation of new buildings, 
Ministry of Ecology, Sustainable Development, Transport and Housing, France. 
91 Incentive campaign Mur I Mur by the Grenoble-Alpes Métropole, Auvergne-Rhône-Alpes, France  
92 Brussels capital-region LTRS, p. 96 (Action 22) 

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Annex II: Factsheets and lessons learned 

5.5 Highlighting good practice examples 

Based on the results of the previous research as well as on expert knowledge, this section portrays selected good practice examples. Each 

example fulfils one or several of the following selection criteria: innovation (new mechanism, triggering innovation, scaling up innovation), 

impact  (on  EU  objectives,  energy  savings,  CO2  emission  reduction,  potential  renovation  impact),  ease  of  implementation  (including 

transferability,  scalability,  transaction  and  administrative  costs,  budget  (in-)dependency,  compatibility  with  existing  legislative/policy 

framework) and coverage of diverse jurisdictions and climatic zones.  

Country 
UK 

Brussels 

Germany/ 
Baden-
Württemberg 

Mandatory 
minimum 
requirement 
linked 
to 
building 
renovation 
passport 
Support 
renovation 

Policy 
Minimum 
Energy 
Efficiency 
Standard 

Brief description 
• 

Establishes  a  minimum  level  of  energy  efficiency  for  privately  rented 
properties  (residential  and  non-residential)  in  England  and  Wales.  These 
properties must have an EPC rating of E or higher to be rented out since 1 
April 2018. 

•  Mandatory renovations at five-year intervals to achieve decarbonisation in 
2050. The requirements are linked to a building renovation passport setting 
out the renovation steps.  

a 

serial 

• 

The Ministry of Environment, Climate and Energy in BW provides up to 40% 
of the costs per m2 of residential buildings up to €500,000 

Lithuania 

Flanders 

Renovation 
[modernisation] 
of multi-
apartment 
buildings 
Digital  Building 
Logbook 

•  Continuation  of  an  existing  renovation  programme  that  aims  to  upgrade 

5,000 multi-apartment buildings between 2021- 2030 to an EPC C rating. 

• 

The  Flemish  EPC  for  single-family  homes  has  been  updated  to  include  a 
building  renovation  passport,  including  a  renovation  roadmap  and  cost 
estimates.  

Source 
The  Energy  Efficiency 
(Private 
Regulations 
Rented 
Property) 
2015.  England  and 
Wales  
Strategy to reduce the 
environmental  impact 
of buildings in Brussels 
(2020). LTRS, p42. 

Ministry 
of 
Environment,  Climate 
and  Energy.  Baden-
Württemberg.  DENA. 
Energiesprong 
Germany. (2019) 
National  Energy  and 
Climate  Action  Plan  of 
the 
of 
Republic 
for  2021-
Lithuania 
2030. p.146 
BEreel!. 
(2019). 
Belgium Renovates for 
Energy Efficient Living  

93 

 
 
Annex II: Factsheets and lessons learned 

•  Renovation  roadmap  for  individual  residential  buildings  that  details  the 

steps the homeowner can take to decarbonise the building towards 2050. 

German 
Agency. (2016). iSFP 

Energy 

Germany 

United 
States 
America 
Denmark 

of 

Individual 
Renovation Map 
for  Residential 
Buildings (iSFP) 
New  York  City 
Building 
Emissions Law 
Bedre Bolig 

Ireland 

Better  Energy 
Communities  

• 

• 

• 

The New York City council has adopted a minimum mandatory requirement 
for  various  building  segments  based  on  a  maximum  carbon  intensity  per 
square metre. 
Promotes energy efficiency in single-family houses, apartment blocks and 
other  large  buildings  through  a  one-stop-shop  approach  in  which 
homeowners can obtain a complete energy renovation package. 
Energy  performance  renovation  grants  for  residential  and  non-residential 
buildings,  providing  higher  grants  to  areas  more  vulnerable  to  energy 
poverty. 

France 

Picardie 
Renovation 
Pass 

•  Within the region of Picardie, the Picardie Pass Rénovation is a single point 
for  homeowners  for  energy  audits,  recommendations  for  measures, 
financial solutions and post-installation checks. 

Romania 

Portugal 

National 
thermal 
rehabilitation 
programme 
Energy 
Certification  of 
Buildings 

• 

Poland/ 
Silesia 

Poland Catching 
up 2 Regions 

• 

•  Governmental renovation programme aimed at condominium associations 

that provides up to 80% of renovation costs.  

The Portuguese EPC system managed by the Portuguese Energy Agency is 
one of Europe’s frontrunners and has a database with more than 1.6 million 
EPCs. Plans exist to link EPCs with financial schemes (IFRRU 2020) and the 
one-stop-shop CasA+.  
The  programme  in  the  Silesia  region  includes  financial  instruments  for 
increasing  the  energy  efficiency  of  single-family  buildings  through  the 
replacement of old heating installations, improving air quality and reducing 
smog. 

Ireland 

Pro Energy 

Homes 

•  One-stop-shop initiative by private credit unions that provides low interest 
renovation  loans  that  are  supplemented  with  a  35%  grant  from  the 
Sustainable Energy Authority of Ireland. 

Local  Law  97.  (2019). 
The City of New York  

The 
Bedre 
scheme. Law 1876.  

Bolig 

Energy 
Better 
(2019-
Communities 
2020). 
Sustainable 
Energy  Authority  of 
Ireland 
Regional  Board  of  the 
for 
Public 
in 
Energy  Efficiency 
Hauts 
France. 
de 
(2013).  France  (p3). 
Link to website  
National 
Rehabilitation 
Programme, Romania  

Thermal 

Service 

energy 
system. 

Portuguese 
certificate 
ADENE. 
Link to website  
Catching  up  2  regions 
initiative. 
(2016). 
European 
Commission/World 
Bank  
ProEnergy 
Homes. 
(2019).  Credit  Union 
Development 
Association 

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Annex II: Factsheets and lessons learned 

Scotland 

Sweden 

Climate  Action 
Historic 
Plan 
Environment 
Carbon tax 

•  Strategic approach to address needs of cultural heritage buildings to reduce 
their  energy  consumption,  enhance  their  climate  resilience  and  assure 
financial sustainability. 

•  With a carbon price of approximately €110, the Swedish price is amongst 
the  highest  in  Europe  and  has  contributed  to  emission  cuts  in  the  built 
environment. 

Historic  Environment. 
(2019). Climate Action 
Plan 2020-25 
Government  Offices  of 
Sweden. 
(2020). 
Carbon Tax Sweden 

95 

 
 
Annex II: Factsheets and lessons learned 

5.6 Concluding assessment 

The challenges of the strategic area “engaging transformation and phasing out inefficient 

buildings”  have  existed  for  decades.  Most  of  the  legislative  and  non-legislative  policy 

instruments considered in this study try to address these challenges. However, the policy 

mix  does  not  sufficiently  incentivise  measures  that  are  not  yet  cost-effective,  or  to 

accelerate the renovation rate to the necessary level in order to reach the EU’s long-term 

target of a decarbonised, highly efficient building stock.  

Mandatory  minimum  requirements  (Belgium,  France,  UK,  Netherlands,  USA),  massively 

increased  dedicated  funding  for  deep  energy  renovation  (Germany,  Tirol),  progressive 

EPCs  (Portugal,  Flanders)  as  well  as  building  renovation  passports  (Flanders,  Germany, 

France)  to  better  inform  homeowners  show  promising  ways  to  accelerate  deep  energy 

renovations  to  meet  long-term  objectives.  Other  promising  examples  that  could  be 

transferred  to  other  jurisdictions  are  initiatives  to  aggregate  renovation  projects 

(Netherlands,  Baden-Württemberg)  as  well  as  integrated  service  providers  (French 

regions, Ireland, Denmark). While there is no silver bullet, there is a growing diversity of 

better  tailored  and  integrative  approaches  that  can  be  used  to  trigger  further  policy 

development.  

Assessment of impact per type of policy instrument 

Mandatory  instruments,  especially  minimum  requirements  to  gradually  phase  out 

inefficient  buildings,  are  considered  as  the  most  effective  policy  instruments  regarding 

energy savings and greenhouse-gas emission savings. However, the introduction of a well-

designed  and  therefore  effective  scheme  faces  several  challenges  (see  below).  Even 

though the design of existing cases could be optimised, they are very valuable frontrunner 

cases helping to understand good practice design elements. The ban of fossil-fuel heating 

is  a  first  step  to  limit  greenhouse-gas  emissions,  with  the  most  practical  examples 

including a ban on oil-fired boilers. Strategies  and long-term planning including binding 

long-term targets are an important precondition for designing proper mandatory schemes 

to phase out inefficient buildings and prevent technological lock-ins.  

Market-based 

instruments, 

in  particular  CO2  prices,  are  considered 

important 

complements to widely used financing schemes. However, in order to effectively reduce 

carbon emissions in the building sector and boost the renovation market, the CO2 price 

has  to  be  considerably  higher  than  in  existing  cases  (estimations  vary  but  are  typically 
higher than those in place93).  

While  the  most  successful  subsidy  schemes  helped  to  generate  significant  savings  and 

have had some success in achieving deeper renovation, they are not yet able to accelerate 

the  renovation  activity  significantly.  Instruments  for  project  aggregation  and  one-stop-

shops  are  promising  developments.  So  too  are  the  new  accelerator  programmes  for 

industrial renovation, which combine the insights of innovation theory and existing good 

practice  subsidy  programmes.  However,  support  for  production  capacity  (of  e.g. 

prefabrication of facades on an industrial scale) is still missing in the existing programmes 

and could be the missing link to reach the full potential impact.  

93  See  e.g.  assumption  in  a  report  evaluating  Germany’s  climate  protection  measures  until  2030 
www.bmwi.de/Redaktion/DE/Publikationen/Wirtschaft/klimagutachten.pdf?__blob=publicationFile&v=8 

96 

 
 
Annex II: Factsheets and lessons learned 

In order to increase synergies between different strategic areas and thereby reduce energy 

and CO2 emissions, public policymaking can learn from private initiatives. This is especially 

true for private certification schemes and standards (e.g. DGNB, BREEAM, NOM keur, etc.). 

All policy instruments will need to be accepted by a range of different actors. Information 

is therefore an important part of any enabling framework and has to be well tailored to 

specific building segments and target groups in order to be effective. 

Assessment of ease of implementation per policy type 

While mandatory instruments, especially minimum requirements to phase out inefficient 

buildings,  are  considered  effective,  their  implementation  faces  some  difficulties. 

Policymakers will have to gain political acceptance, provide financial support to minimise 

the burden on vulnerable groups, overcome subsidiarity issues, and ensure enforcement, 

monitoring and a smooth market uptake, amongst others. If designed well, they are very 

promising in terms of  effectiveness, but need to be prepared well upfront, e.g. through 

no-regret measures like improving reliable EPC schemes and accessible EPC databases. 

The ban on fossil-fuel-based heating boilers is easier to implement, as it addresses only 

one element in the building energy system. Still, it is a highly political intervention and 

needs to match the political agenda. In some cases this depends on Member States’ long-

term climate strategies, or other goals such as reducing air pollution. To give an example, 

if  green  hydrogen  is  considered  highly  relevant,  a  phase-out  of  gas-based  heating  is 

unlikely. 

Renovation strategies and planning are comparatively easy to implement. However, good 

strategies  require  proper  research  based  on  a  robust  data.  Strategic  planning  on  the 

individual  building  level,  e.g.  digital  building  logbooks  or  building  renovation  passports, 

which  could  also  count  as  information  or  monitoring  instruments,  require  a  thorough 

design and testing phase. Existing cases are promising and can be considered a starting 

point to gradually improve the schemes to make them easily understandable, accessible 

and  meaningful  for  homeowners,  but  also  for  public  administrations  as  a  data  source. 

Differences  in  the  EPC  schemes  across  European  Member  States  show  the  path-

dependence of policy instruments and illustrate the difficulty of changing the scheme over 

time. Changes need to be stimulated at the European level (EPBD). 

The existing European emissions trading scheme could be an entry point to introduce a 

CO2 price to the EU building sector by extending it to heating fuels. However, there are 

doubts that politically accepted price levels could activate renovation activity. 

Informative  and  voluntary  instruments  are  easy  to  implement.  However,  their 

effectiveness unfolds only if combined with other instruments, such as financing schemes 

and/or  mandatory  requirements.  The  implementation  of  financial  support  is  highly 

dependent on the availability of funding. Grants depending on the annual public budget 

are  more  difficult  to  set  up  and  to  sustain.  Therefore,  it  is  helpful  to  establish  budget-

independent income streams. Apart from existing European finance instruments, revenues 

from the EU emissions trading scheme could provide another income stream for Member 

States. 

97 

 
 
 
 
Annex II: Factsheets and lessons learned 

renovation and modernisation of the 
built environment 
Financing renovation – Factsheet 

Author: Andrea Real Ruiz, Laura Pérez del Olmo, Pedro Luis Espejo 

September 2020 

Tender N° ENER/C3/2019-468/03 

98 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

6.1 Introduction 

This  factsheet  provides  an  overview  of  how  different  policy  instruments  and  selected 

private initiatives can help to achieve European objectives and effectively address key EU 

challenges in the strategic area of financing renovation. The findings draw upon a policy 

screening for 15 EU Member States, 3 non-EU countries and 5 European regions covering 

broadly  the  climatic  zones  of  the  EU.  In  addition,  the  factsheet  draws  on  additional 

information provided by external experts as well as on the long-standing expertise of the 

authors, meaning policy examples going beyond the researched country and region cases 

are  occasionally  added.  The  concluding  assessment  draws  on  the  findings  and  detailed 

analysis of the good practice cases as well as on the in-house expertise of the partners. 

6.2 Financing renovation 

Availability and accessibility of financing and appropriate financing tools are essential to 

increase the rate and depth of building renovations. Public finance alone cannot support 

this  effort  and  must  be  used  to  leverage  additional  private  investment.  Innovative 

financing  schemes  and  business  models  are  emerging  to  maximise  the  effectiveness  of 

funds,  as  well  as  to  target  specific  market  failures  for  renovations  or  more  vulnerable 

groups  of  citizens.  Three  key  challenges  to  unlocking  an  increasing  amount  of  private 

resources to finance building renovations have been identified: 

1) Unlocking financing for renovations for end-users: to increase renovation rates, 

there  is  a  clear  need  to  create  and  proactively  deliver  mechanisms  and  support 

programmes  with  the  financing  capacity  to  stimulate  investments,  including  targeting 

buildings occupied by the most vulnerable consumers. First, to achieve lower cost financing 

and  better  access  for  tenants  and  occupants,  the  creditworthiness  and  security  of 

repayments for energy efficiency retrofits must be improved. Building occupants are the 

most engaged stakeholders; however, they are also the least likely to engage in building 

renovation unless they are also the homeowner. Second, many end-users lack available 

funds, which prevents them from implementing the desired measures. The involvement of 

banks  and  energy  suppliers  in  the  supply  of  energy  efficiency  retrofit  solutions  to  their 

individual and commercial customers can lead them to offer more profitable products to 

those  same  customers.  Third,  investments  from  the  public  sector  are  also  necessary. 

Member States should implement and design effective mechanisms that allow all users to 

execute renovations at reasonable cost, taking into consideration the difficulties they may 

face (e.g. lack of available funds, high upfront costs, etc.). 

2)  Financing  building  renovations  in  the  presence  of  market  failures:  adequate 

financial  instruments  to  overcome  market  failures  are  of  central  importance  to  achieve 

and sustain higher deep renovation  rates.  Market failures are understood as a  range  of 

problems that tend to delay the transformation of the building stock and the tapping of 

cost-effective  energy  savings  potential.  These  may  include,  for  example,  lack  of 

understanding of energy use in buildings and potential savings resulting from renovations; 

lack  of  attractive  financial  products;  high  upfront  costs  of  renovation  and  long  payback 

periods;  low  energy  prices  negatively  affecting  payback  of  energy  savings  measures; 

limited  information  and  data  availability  about  the  building  stock;  limited  uptake  of 

efficient  and  smart  technologies;  split  incentives.  Adequate  financial  instruments  to 

overcome market failures, a sufficient workforce with the right skills, and affordability for 

all  citizens  are  of  central  importance  if  the  Union  is  to  achieve  and  sustain  higher 

renovation rates. 

99 

 
Annex II: Factsheets and lessons learned 

3) Mobilising and de-risking energy efficiency investment: lack of evidence on the 

performance of energy efficiency investments in buildings makes financial risk harder to 

assess  and  mobilisation  of  both  public  and  private  investments  more  difficult.  Suitable 

platforms for dialogue and exchange of good practice, promoting the provision of reliable, 

comparable  and  verifiable  information,  are  needed  in  order  to  de-risk  energy  efficiency 

investments  and  engage  stakeholders.  There  is  also  a  lack  of  standard  financial 

approaches for building renovations, such as agreed protocols and benchmarking rules for 

private capital investment and ‘ready to use’ financial products that would facilitate de-

risking of investments. Additionally, risks related to energy efficiency investments can fall 

under five categories: economic and financial; behavioural and operational; measurement 

and verification; contextual and technological; and regulatory. The factors that determine 

the categorisation of risks/barriers and how they can be solved range from market-specific 

(e.g. lack of appropriate financing vehicles or debt instruments, regulatory risks, volatile 

energy  prices),  investor-specific  (e.g.  risk  aversion,  behavioural  bias,  perceived  lack  of 

collateral),  to  project-specific  barriers  (e.g.  high  initial  costs,  long  payback  periods, 

uncertainty of technology). 

6.3 Provisions to address key challenges  

This section gives an overview of the policies considered to be most successful at tackling 

key challenges in the area of financing renovation. To operationalise the challenges and 

allow for quantitative  estimations on  selected  aspects, the country screening looked  for 

provisions  including  de-risking  tools,  schemes  to  alleviate  energy  poverty,  mandatory 

support take-up, standard financial approaches and innovative financing schemes.  

The figure provides an overview of the policy screening. Since countries vary in size, the 

number of provisions does not necessarily reflect the effectiveness of the policy mix. While 

the  number  of  provisions  found  may  give  an  indication  of  the  breadth  and  diversity  of 

approaches, it should not be taken as the sole indicator for how effective the provisions 

are  for  tackling  key  challenges.  One  well-designed  policy  instruments  may  be  more 

effective  than  a  multitude  of  less  adequate  instruments.  Therefore,  an  additional 

qualitative discussion as well as insights from the good practice analysis are provided in 

the remaining parts of the paper. 

Financing renovation is essential for the building sector as it is the key pillar of Member 

States’  long-term  renovation  strategies.  The  policies  identified  (65.5%  legislative  and 

34.5% non-legislative) associated with mobilisation of both public and private investments 

in order to overcome the identified key challenges. 

Our research finds that the most common practice to address the key challenges is through 

standard financial approaches, which have been implemented across research countries 

(except  Greece and  Lithuania) in a multitude of  ways: via public and private loans, tax 

rebates,  subsidies  or  grants.  This  type  of  measure  promotes  renovation  by  providing 

funding to support energy efficiency investments and enabling more effective use of public 

funding and better targeting of subsidies towards vulnerable consumers or specific market 

failures. Such measures tend to be implemented in national and regional legislation, as in 

100 

 
Annex II: Factsheets and lessons learned 

Germany  (e.g.  KfW  Energy  Efficiency  Programme94  at  national  level  and  Bavarian 
modernisation  programme:  State  funding  for  the  renovation  of  rented  apartments  and 
care places in Bavaria95  at regional) and Spain (e.g. Measures to support energy efficiency 
in central government96 at national level and 2014-2020 ERDF Operational Programme for 
Extremadura97 at regional level). However, other jurisdictions have non-legislative support 
programmes (e.g. California’s Green Retrofit Program for Multifamily Housing98).  

Innovative  financial  schemes  are  more  and  more  common  among  Member  States  and 

represent a way to access attractive financing solutions and benefit from innovative energy 
services in the form of e.g. energy performance contracting99, on-tax and on-bill financing, 
or mortgages for energy efficiency. Member States have been taking important actions to 

promote  these  services,  especially  in  the  public  sector.  Relevant  approaches  include, 
among others, Spain’s measures to promote energy services100, Italy’s Ecobonus101 which 
deducts up to 110% of the costs incurred in the tax declaration process or the Netherlands’ 
Building-related Financing102  and the USA’s Energy Efficient Mortgages103, which link loans 
for energy renovations to the respective building instead of the building owner. 

On  the  other  hand,  the  lack  of  evidence  on  the  performance  of  energy  efficiency 

investments in buildings makes the benefits and the financial risk harder to assess. In this 

context,  de-risking  tools  refer  to  those  measures  that  provide  reliable,  comparable  and 

verifiable  information,  imperative  to  de-risk  energy  efficiency  investments  for  building 

renovation.  This  was  identified  by  the  “Smart  Finance  for  Smart  Buildings”  investment 

initiative  as  one  of  the  main  issues  to  address  to  incentivise  the  uptake  of  energy 

renovations. In this regard, the picture among Member States is not completely clear; the 

approaches  taken  by  countries  vary  widely.  Some  recurring  measures  include  public 
financing  (e.g.  the  Greek  Saving  at  Home  II  Program104),  databases  compiling  relevant 

94  IKU  –  Energieeffizient  Bauen  und  Sanieren  (220,  219).  Kfw.de.  (2020).  Retrieved  12  August  2020,  from 
https://www.kfw.de/inlandsfoerderung/%C3%96ffentliche-Einrichtungen/Kommunale-
Unternehmen/Kommunale-Geb%C3%A4ude/Energieeffizient-Sanieren-kommunale-Unternehmen-(220-219)/.  
95  Bayerisches  Modernisierungsprogramm  für  Wohnungsgesellschaften  |  BayernLabo.  Bayernlabo.de.  (2020). 
Retrieved 
https://bayernlabo.de/mietwohnraumfoerderung/bayerisches-
modernisierungsprogramm/?L=0.  

August 

2020, 

from 

12 

PLAN. 

PLAN. 

ACTION 

ACTION 

ENERGY 

ENERGY 

Retrieved 

Retrieved 

EFFICIENCY 

EFFICIENCY 

96  GOVERNMENT  OF  SPAIN  MINISTRY  OF  ENERGY,  TOURISM  AND  DIGITAL  AGENDA.  (2017). 2017-2020 
from 
NATIONAL 
https://ec.europa.eu/energy/sites/ener/files/documents/es_neeap_2017_en.pdf  
97  GOVERNMENT  OF  SPAIN  MINISTRY  OF  ENERGY,  TOURISM  AND  DIGITAL  AGENDA.  (2017). 2017-2020 
NATIONAL 
from 
https://ec.europa.eu/energy/sites/ener/files/documents/es_neeap_2017_en.pdf  
98 American Recovery and Reinvestment Act of 2009, Public Law 111-5, Title XII. 
"Assisted Housing Stability and Energy and Green Retrofit Investments" under "Housing Programs".  
99https://eur-lex.europa.eu/resource.html?uri=cellar:fa6ea15b-b7b0-11e6-9e3c-
01aa75ed71a1.0001.02/DOC_2&format=PDF 
100  Plan  MOVALT  Vehículos  |  IDAE.  (2020).  Retrieved  1  July  2020,  from  https://www.idae.es/ayudas-y-
financiacion/para-movilidad-y-vehiculos/convocatorias-cerradas/plan-movalt-vehiculos 
101 
Energy 
https://ec.europa.eu/energy/sites/ener/files/documents/it_neeap_2017_en.pdf  
102  Netherlands  Enterprise  Agency.  (2020). Long-Term  Renovation  Strategy,  En  Route  to  a  low-CO2  Built 
Environment. Retrieved from https://ec.europa.eu/energy/sites/ener/files/documents/nl_2020_ltrs_en.pdf  
103  Energy  Efficient  Mortgages.  Energystar.gov. 
https://www.energystar.gov/newhomes/mortgage_lending_programs/energy_efficient_mortgages.  
104 ΕΛΛΗΝΙΚΗ ΔΗΜΟΚΡΑΤΙΑ ΥΠΟΥΡΓΕΙΟ ΠΕΡΙΒΑΛΛΟΝΤΟΣ KAI ΕΝΕΡΓΕΙΑΣ ΕΠΙΤΕΛΙΚΗ ΔΟΜΗ ΕΣΠΑ ΥΠΕΝ ΤΟΜΕΑ 
ΕΝΕΡΓΕΙΑΣ ΟΔΗΓΟΣ. (2020). ΟΔΗΓΟΣ ΕΦΑΡΜΟΓΗΣ ΠΡΟΓΡΑΜΜΑΤΟΣ «ΕΞΟΙΚΟΝΟΜΗΣΗ ΚΑΤ’ ΟΙΚΟΝ II». Αθήνα. 
Retrieved 
https://exoikonomisi-
b.ypen.gr/documents/10182/3568822/2%CE%97+%CE%A4%CE%A1%CE%9F%CE%A0+%CE%9F%CE%94+
%CE%95%CE%9E%CE%9F%CE%99%CE%9A_II_2019+%CE%92+final.pdf/07cccb97-535b-44ad-a2ea-
c89c9ed912d8 

(2020).  Retrieved  12  August  2020, 

(2017). Italian 

Retrieved 

Efficiency 

Action 

Plan. 

from 

from 

from 

PAE. 

101 

 
 
 
 
Annex II: Factsheets and lessons learned 

information about legislation and available funding (e.g. Portugal’s Energy Observatory105) 
or more informative measures looking to portray the benefits of building renovations (e.g. 
Andalusia’s diffusion of energy improvement in sectors of the Andalusian economy106). All 
these have the aim of showcasing the benefits of energy renovations and incentivising the 

mobilisation of resources to implement such measures.  

Finally,  awareness  of  energy  poverty  is  growing  rapidly  across  Member  States.  In  fact, 

80% of the researched countries present schemes to alleviate energy poverty and to tackle 

the  renovation  of  the  worst-performing  buildings,  thus  reducing  the  household  energy 
bills.  Article  2a  of  the  Energy  Performance  of  Buildings  Directive107  (EPBD)  requires 
Member  States  to  establish  specific  measures  and  financing  instruments  in  their 

renovation  strategies  to  decrease  energy  demand  and  contribute  to  the  alleviation  of 

energy poverty. Approaches taken by researched countries include France’s Social Housing 
Eco-loan108  for  the  energy  renovation  of  social  housing  or  the  USA’s  High  Energy  Cost 
Grants109,  which  helps  energy  providers  to  lower  the  energy  costs  for  families  and 
individuals that live in areas with extremely high per-household energy costs.

1 

July 

Retrieved 

(Observatório 

Energia,2020). 

105 
da 
https://www.observatoriodaenergia.pt/pt/politicas-publicas 
106  Junta  de  Andalucía.  (2020). Plan  de  Acción  2018-2020,  Estrategia  Energética  de  Andalucía  2020 [Ebook]. 
Retrieved 
from 
https://www.agenciaandaluzadelaenergia.es/sites/default/files/documentos/plan_de_accion_2018-2020.pdf 
107  Energy  performance  of  buildings  directive  -  European  Commission.  (2020).  Retrieved  1  July  2020,  from 
https://ec.europa.eu/energy/topics/energy-efficiency/energy-efficient-buildings/energy-performance-buildings-
directive_en  
108  Rénovation  Energétique  des  Bâtiments.  (2018). Stratégie  à  long  terme  de  la  France  pour  mobiliser  les 
investissements dans la rénovation du parc national de bâtiments à usage résidentiel et commercial, public et 
privé. 
https://www.cohesion-territoires.gouv.fr/sites/default/files/2020-
02/200210_Strat%C3%A9gie_de_r%C3%A9novation_2020_vf.pdf  
109  7  U.S.  Code  Subchapter  I  -  RURAL  ELECTRIFICATION.  (2020).  Retrieved  1  July  2020,  from 
https://www.law.cornell.edu/uscode/text/7/chapter-31/subchapter-I  

Retrieved 

2020, 

from 

from 

102 

 
 
 
Annex II: Factsheets and lessons learned 

35

30

25

20

15

10

5

0

De-risking tools
Schemes to alleviate energy poverty

Mandatory support take-up
Standard financial approaches

Innovative financing schemes (on-bill, on-tax, etc.)

Figure 5 - Key aspects of financing renovation per country 

103 

 
Annex II: Factsheets and lessons learned 

6.4 Effectiveness of the policy landscape to address key challenges  – overview 

and description 

This section presents an assessment of the overall policy landscape that a previous country 

screening  identified  as  relevant  for  the  covered  countries  and  regions.  The  assessment 

takes into account the diversity of instruments (regulation, pricing, support, information 

etc.), whether there are particularly interesting and innovative instruments, and whether 

the instruments identified together seem adequate to address the given challenges.  The 

overview tables are followed by a discussion of policy instruments.  

The given classification in Table 8 and Table 9 should be interpreted as follows: 

Good policy landscape with at least one innovative instrument targeting financing 

renovation 

Adequate  policy  landscape  with  instruments  that  could  in  the  future  better 

integrate financing in building renovation policies 

Inadequate  policy  landscape,  with  no  instruments  identified  in  relation  to  the 

given challenges 

Not conclusive 

Table 8 – Legislative policies 

Financing renovation – legislative policies 
KEY CHALLENGES 

Unlocking financing 
renovation for end-
users 

Financing 
renovations in the 
presence of 
market failures 

Mobilising and de-
risking EE 
investments 

Flanders 
Wallonia 
Brussels 
Croatia 
Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 

104 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Table 9 – Non-legislative policies 

Financing renovation – non-legislative policies 
KEY CHALLENGES 

Unlocking financing 
renovation for end-
users 

Financing 
renovations in the 
presence of 
market failures 

Mobilising and de-
risking EE 
investments 

Baden-
Württemberg 
Silesia 
Umea 

Flanders 
Wallonia 
Brussels 
Croatia 
Denmark 
France 
Germany 
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
USA 
Andalusia 
Tirol 
Baden-
Württemberg 
Silesia 
Umea 

As mentioned earlier, the policies identified in the researched countries regarding financing 

renovation  tend  to  be  legislative.  Because  of  this,  when  conducting  an  analysis  of  the 

effectiveness of the policy landscape and the measures implemented, their effect on the 

key challenges will be analysed in tandem.  

1) Unlocking financing for renovation for end-users 

To  increase  renovation  rates,  there  is  a  clear  need  to  create  mechanisms  and  support 

programmes  with  the  financing  capacity  to  stimulate  investments,  including  targeting 

buildings occupied by the most vulnerable consumers. Those mechanisms must come from 

the effort of relevant stakeholders in the field: national, regional and local governments, 

financial institutions and service providers.  

Because the spectrum of policies that can serve to “fix” this key challenge is so vast, the 

approaches taken by countries are quite varied, some of which are highlighted below: 

105 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

In Croatia, a programme has been created to combat energy poverty via public financing. 

The specific objective of the measure is the establishment of a system that would allow 

vulnerable energy buyers to improve energy efficiency at household level while improving 

housing conditions.  The programme  establishes a list of available measures and rate of 

co-financing for individual measures.  

In the United States, the  Green Retrofit Program for Multifamily Housing110, handled by 
the  Department  of  Housing  and  Urban  Development,  gives  loans  and  grants  to  eligible 

property owners to make energy and green retrofit investments in the property, and to 

ensure  the  maintenance  and  preservation  of  the  property,  the  continued  operation  and 

maintenance  of  energy  efficiency  technologies,  and  the  timely  expenditure  of  funds. In 
Portland, to finance the Clean Energy Community Benefits Fund111, large retailers pay a 
surcharge  of  1%  on  gross  revenues  from  retail  sales.  The  capital  raised  is  distributed 

among  several  programmes,  including  clean  energy  ones  focused  on  renewable  energy 

and  energy  efficiency  projects,  with  an  emphasis  on  those  that  benefit  low-income 

individuals  and  that  broaden  access  to  energy  efficiency  and  clean  renewable  energy 

infrastructure to low-income communities and communities of colour. 

The Housing Bank112 in Norway grants loans to individuals which can be used to improve 
the  environmental  performance  and  accessibility  of  new  and/or  existing  buildings.  In 
Poland, the government has approved a tax relief113 for thermo-modernized single-family 
residential buildings. 

Portugal  uses  its  social  tariff114,  managed  by  the  Directorate-General  for  Energy  and 
Geology,  as  social  support  for  end-consumers  to  have  a  discount  on  the  tariff  for  low 

voltage electricity and low-pressure natural gas networks.  

In  Andalusia,  a  grant115  has  been  created  for  the  energy  rehabilitation  of  residential 
buildings.  Incentives  are  provided  for  energy  saving  measures,  energy  efficiency 

improvements,  the  use  of  renewable  energies  and  reduced  carbon  dioxide  emissions  in 

existing buildings belonging to the public administrations of Andalusia, for use as housing 

for low-income families or people with special needs. 

In  Lithuania,  the  renovation/modernisation  of  multiapartment  buildings116  aims  to 
renovate  by  the  end  of  2030  around  5,000  multi-apartment  buildings  (500  multi-

apartment  buildings  each  year)  to  class  C  and  save  40%  of  the  building’s  energy 

110  HUD  Archives:  Green  Retrofit  Program  for  Multifamily  Housing.  (2020).  Retrieved  1  July  2020,  from 
https://archives.hud.gov/recovery/programs/green.cfm  
111 Chapter 7.07 Portland Clean Energy Community Benefits | The City of Portland, Oregon. (2020). Retrieved 1 
July 2020, from https://www.portlandoregon.gov/citycode/78811  
112  HAKJ,  m.  (2020).  Lån  fra  Husbanken  for  privatpersoner  -  Husbanken.  Retrieved  1  July  2020,  from 
https://husbanken.no/person/lan-fra-husbanken/?redirect=/privat/lan-fra-husbanken/  
113  Kancelaria  Sejmu.  USTAWA  z  dnia  9  listopada  2018  r  o  zmianie  ustawy  o  podatku  dochodowym  od  osób 
fizycznych  oraz  ustawy  o  zryczałtowanym  podatku  dochodowym  od  niektórych  przychodów  osiąganych  przez 
osoby fizyczne (2018).  
114 Energy Social Tariff – Policies - IEA. (2020). Retrieved 1 July 2020, from https://www.iea.org/policies/2619-
energy-social-tariff?country=Portugal&qs=portug  
115  Junta  de  Andalucía.  (2020). Plan  de  Acción  2018-2020,  Estrategia  Energética  de  Andalucía  2020 [Ebook]. 
Retrieved 
from 
https://www.agenciaandaluzadelaenergia.es/sites/default/files/documentos/plan_de_accion_2018-2020.pdf  

116 NECAP Lithuania. (220). National Climate and Energy Action Plan of the Republic of Lithuania for 
2021-2030. 
at: 
https://ec.europa.eu/energy/sites/ener/files/documents/lt_final_necp_main_en.pdf 

Accessible 

106 

 
 
 
 
Annex II: Factsheets and lessons learned 

consumption,  seeking  to  reduce  heating  costs  for  consumers,  improve  their  living 

conditions and save a total of 5.5 TWh of energy. 

Lastly, in France, the Coup de pouce (Helping Hand)117 scheme for energy savings enables 
all  households  to  benefit  from  a  one-off  grant  to  assist  them  in  funding  certain  energy 

renovation works, helping all individuals to get out of fossil fuels, to insulate their homes 

and thus significantly reduce their heating bills. It is financed within the framework of the 

energy  savings  certificates,  a  generally  available  funding  stream  in  France.  Another 
relevant  subsidy  available  is  the  French  tax-free  zero-rated  eco-loan  scheme118,  which 
allows landlords to get a loan to finance energy refurbishment works (insulation, heating 

or water heating using renewable energies) for their main residence.  

2) Financing renovations in the presence of market failures 

Adequate financial instruments to overcome market failures are of central importance to 

achieve  and  sustain  higher  deep  renovation  rates.  Some  of  the  most  relevant  market 

failures  identified  include  the  split-incentive  dilemma  and  conflicts  of  interest,  limited 

financing/insufficient  budgets,  lack  of  funds  for  energy  efficiency  service  providers,  and 

the difficulties in conveying energy and non-energy benefits of retrofits. The approaches 

taken by countries to diminish the extent of such market failures are very diverse but are 

largely  focused  on  private  and  public  financing  (whether  via  loans  and  grants  or  tax 

rebates)  and  the  promotion  of  energy  services.  This  key  challenge  is  the  one  that 

researched countries have taken the most successful actions to tackle, as shown in the 

tables above. 

Ireland has come up with a few tax rebates aiming at involving, among others, tenants 
and  landlords.  The  Home  Renovation  Incentive119  is  a  tax  credit  scheme  that  allows 
homeowners, landlords and local authority tenants to claim income tax relief for repairs, 

renovation  or  upgrades  of  owned  or  rented  buildings.  The  scheme  enables  eligible 

candidates to claim a tax credit of 13.5% of the total costs of building repairs, renovations 
or  energy  efficiency  improvements.  The  Living  City  Initiative120  offers  tax  relief  for 
renovation works and building upgrades in  special regeneration areas (old/historic town 

centres). 

In  Spain,  an  action  plan  for  training  energy  service  companies  implemented  several 
measures to promote121 and drive the market for efficient and sustainable energy services 
as  part  of  the  cooperation  agreement  between  the  Institute  for  the  Diversification  of 

Energy and Energy Savings (IDAE) and the School for Industrial Organization. A similar 

measure has been implemented in Romania, with the creation of an ESCO [energy service 

117 Ministere de la transition ecologique (2018) Long-term strategy of France for mobilising investment in the 
renovation of the national stock of residential and commercial buildings, both public and private. 
https://ec.europa.eu/energy/sites/ener/files/documents/fr_ltrs_2020_en.pdf 
118  Qu'est-ce  que  l'éco-prêt à  taux  zéro  ?.  Economie.gouv.fr.  (2020).  Retrieved  28  August  2020, 
from https://www.economie.gouv.fr/cedef/eco-pret-a-taux-zero. 
119 
from 
https://www.revenue.ie/en/property/home-renovation-incentive/hri-for-homeowners-and-landlords/index.aspx  
120 
from 
(LCI) 
https://www.revenue.ie/en/property/living-city-initiative/lci-definitions.aspx  
121 BORRADOR DEL PLAN NACIONAL INTEGRADO DE ENERGÍA Y CLIMA 2021-2030. (2020). Retrieved from 
https://ec.europa.eu/energy/sites/ener/files/documents/spain_draftnecp.pdf  

homeowners 

definitions. 

landlords. 

Retrieved 

Retrieved 

Initiative 

(2020). 

(2020). 

Living 

2020, 

2020, 

July 

City 

July 

HRI 

and 

for 

1 

1 

107 

 
 
 
Annex II: Factsheets and lessons learned 

company]  Working  Group122    which  promotes  dialogue  between  representatives  of  the 
national  government  and  international  institutions  and  NGOs  for  the  development  of  a 

standardised energy performance contracting model to support local public authorities in 

carrying out building efficiency improvements. 

The On-Bill Financing123 service offered by the Burlington Electric Department in California 
provides business customers with the option to finance  electric efficiency improvements 

on their electric bill.  

3) Mobilising and de-risking energy efficiency investments 

Lack of evidence on the performance of energy efficiency investments in buildings makes 

financial  risk  harder  to  assess  and  mobilisation  of  both  public  and  private  investments 

more difficult. The Smart Buildings Initiative stresses the importance of the need to de-

risk energy efficiency investments in buildings by giving investors and private financiers a 

better understanding of the risks and benefits of energy efficiency.  

In general, this key challenge has been the least tackled by analysed countries, though 

there  are  some  relevant  schemes  in  Member  States.  These  include  energy  efficient 
mortgages  like  the  Green  Mortgage  programme124  in  Romania.  Together  with  the 
Raiffeisen Bank, the programme offers discounted mortgage pricing to suitably qualified, 

prospective homebuyers for buildings certified by Romanian Green Building Council within 

the Green Homes certification scheme. 

Crowdfunding  has  also  gained  some  ground  in  recent  years  by  offering  support  to 

sustainable  energy projects through debt financing options, even though they currently 

account only for a very small share of the sector. For instance, Bettervest in Germany is 

a crowdfunding platform which has started supporting energy efficiency projects.  

Energy  efficiency  insurance,  an  innovative  product  which  aims  to  shield  from  under-

achievement and increase trust and awareness of energy efficiency projects, is currently 
used in Wallonia125 through an insurance mechanism for group loans.  

Other vehicles to drive more investments are specialised energy efficiency funds, like the 
Spanish National Energy Efficiency Fund126, which aims to activate and integrate financial 
entities to raise investment for energy efficiency and renewable energies with the support 

of all public and private agents and regional administrations. 

Information-based  provisions  include  Portugal’s  Energy  Observatory127,  which  aims  to 
provide reliable, comparable and verifiable information, and measures looking to portray 

the benefits of building renovations (e.g. Andalusia’s diffusion of energy improvement in 

from 

122  ANRE,  AUTORITATEA  NAȚIONALĂ  DE  REGLEMENTARE  ÎN  DOMENIUL  ENERGIEI.  (2019). R  A  P  O  R  T  de 
monitorizare a implementării Planului Național de Acțiune în domeniul Eficienței Energetice (PNAEE IV) – 2018. 
Retrieved 
https://www.anre.ro/ro/eficienta-energetica/rapoarte/rapoarte-de-monitorizare-a-
implementarii-planului-national-de-actiune-in-domeniul-eficientei-energetice-pnaee  
123  On-Bill  Financing  |  Burlington  Electric  Department.  (2020).  Retrieved  1  July  2020, 
https://www.burlingtonelectric.com/on-bill-financing  
124  Niculescu,  I.  (2020). Romania  Green  Building  Council  -  Green  Mortgage.  Rogbc.org.  Retrieved  27  August 
2020, from http://www.rogbc.org/en/projects/green-mortgage.  
125 LTRS-W p. 145. 
https://ec.europa.eu/energy/sites/ener/files/documents/be_wallonie_building_renov_2017_fr.pdf  
126  Draft 
(2019) 
plan 
energy 
https://ec.europa.eu/energy/sites/ener/files/documents/es_final_necp_main_en.pdf  
127  LEGISLAÇÃO  DO  SETOR  ENERGÉTICO  PESQUISA  DE  LEGISLAÇÃO.  (2020).  Retrieved  1  July  2020,  from 
https://www.observatoriodaenergia.pt/pt/politicas-publicas  

2021-2030. 

integrated 

national 

climate 

from 

and 

the 

of 

108 

 
 
 
Annex II: Factsheets and lessons learned 

sectors  of  the  Andalusian  economy128).  In  France,  the  Tinergy129    platform  simplifies, 
secures  and  optimises  personal  home  energy  renovation  projects  by  offering  a  support 

service  upstream  and  downstream  of  the  work.  It  also  supports  local  professionals  and 

facilitates their access to the energy renovation market.

128  Junta  de  Andalucía.  (2020). Plan  de  Acción  2018-2020,  Estrategia  Energética  de  Andalucía  2020 [Ebook]. 
Retrieved 
from 
https://www.agenciaandaluzadelaenergia.es/sites/default/files/documentos/plan_de_accion_2018-2020.pdf  

129 ADEME. (2016). RÉNOVATION ÉNERGÉTIQUE DE L’HABITAT, 15 INITIATIVES DE TERRITOIR E S. Retrieved 
from 
https://www.ademe.fr/sites/default/files/assets/documents/renovation-energetique-habitat-initiatives-
territoires-8890.pdf  

109 

 
 
 
 
Annex II: Factsheets and lessons learned 

6.5 Highlighting good practice examples  

Based on the results of the previous research as well as on expert knowledge, this section portrays selected good practice examples. Each 

example fulfills one or several of the following selection criteria: innovation (new mechanism, triggering innovation, scaling up innovation), 

impact  (on  EU  objectives,  energy  savings,  CO2  emission  reduction,  potential  renovation  impact),  ease  of  implementation  (including 

transferability,  scalability,  transaction  and  administrative  costs,  budget  (in-)dependency,  compatibility  with  existing  legislative/policy 

framework) and coverage of diverse jurisdiction and climatic zones. 

Country 
Germany  

USA  

Policy 
KfW Energy 
Efficiency 
Programme - 
Energy-
efficient 
renovation 
investment 
subsidy 
Property 
Assessed 
Clean Energy 
(PACE) 

Brief description 
•  This programme serves to promote comprehensive refurbishment into “KfW efficiency 
houses” or individual measures to improve energy efficiency. As well as repayment 
bonuses dependent on the primary energy consumption of the efficiency house, a special 
promotion is possible if construction is supervised by an external technical expert. 

o  Through the loan, applicants can receive an investment subsidy that depends on 

Source 
KfW 

the energy standard achieved. 

•  Property Assessed Clean Energy (PACE) is a way to finance a wide range of energy and 
water efficiency, renewable energy, and hazard mitigation improvements permanently 
attached to residential (R-PACE) and commercial properties (C-PACE).  

o  Established by state statutes and enabled by local governments, PACE financing 

PACE 

is structured as an assessment to the property and not the property owner. PACE 
provides 100% of the cost of qualified structural improvements, which the 
property owner repays annually or semi-annually through a special assessment 
added to the property tax bill. 

o  The average repay period is typically over 10 to 20 years through property 

assessments, which are secured by the property itself and paid as an addition to 
the owner’s property tax bills.  

France 

Denormandie 
Law 

•  The Denormandie Law aims to renovate dilapidated housing in some French cities 

through an advantageous tax exemption programme for investors  

LTRS 
P62 

•  Renovation work should: 

o 

Improve the energy performance of housing by at least 30% (20% in collective 
housing) 

o  Represent two types of work out of a choice of five: roof insulation, change of 
boiler, wall insulation, window insulation, change in hot water production 

110 

 
 
Annex II: Factsheets and lessons learned 

Poland 

Stop smog 

Italy 

Ecobonus/ 
Superbonus 

•  The Denormandie Law allows tax exemption of up to 21% of the price of the property 
purchased if it is rented for 12 years. This will act as an incentive for the renovation of 
rented properties, tackling the split-incentive dilemma. 

•  The programme finances the replacement or elimination of heat sources and thermo-
modernisation in residential buildings for those in energy poverty. Applicants are 
municipalities, which obtain up to 70% co-financing of investment costs from the state 
budget.  

•  The scope of the project includes: 

o  Replacement or elimination of high-carbon heat sources for low-carbon ones 
o  Thermo-modernisation of single-family residential buildings 
o  Connection to the heating or gas network. 

• 

Implementing financial measures that ensure those under the energy poverty line are 
not left behind is vital for a fair energy transition.  

•  Tax credit equal to up to 110% of the energy renovation investment that can be 

recovered in five years by either the final user, the construction company or a financial 
intermediary. 
In general, deductions are recognised for: 

o  Reduced energy requirements for heating 
o  Thermal improvement of the building (insulation/floors/windows, including 

fixtures) 
Installation of solar panels 

o 
o  Replacement of winter air-conditioning systems. 
It applies to residential, non-residential and mixed buildings. 

• 

• 

Stop 
smog 

Gazzetta 
Ufficiale 

Croatia 

Methods of 
making energy 
renovation 
investments 
more 
attractive to 
banks and 
private 
investors 

o  The Superbonus can set an example in Europe as a useful tool to promote a 

green recovery in the building sector, by setting incentives for households and 
companies. 

•  Establishment of a national revolving fund by means of redeploying resources from 
European structural and investment funds, which allows energy service providers to 
access to a long-term funding source at more favourable market conditions. Banks can 
also place resources through the fund. 

o  By introducing special guarantee instruments, risk for private investor funds is 

LTRS 

reduced; 

o  Subsidising the interest rates on commercial loans enables commercial banks to 

finance building energy renovation. 

o  Developing a standard energy performance contract and standardised methods 
for measuring and verifying energy savings will enhance the trust of users and 
financial institutions in the ESCO model. 

111 

 
Annex II: Factsheets and lessons learned 

Netherlands   Tenants’ right 
of initiative for 
deep 
renovation 

•  Lack of evidence on the performance of energy efficiency investments makes the 
benefits and the financial risk harder to assess. This measure can help reduce the 
perceived risks associated with building retrofits and mobilise funds  

•  Consideration to change the Civil Code to enable tenants to obligate landlords to make 

certain improvements  

LTRS 
P38-39 

o  Under current Civil Code the lessor is obliged to make certain improvements at 

their own expense at the request of the tenant, provided that the tenant accepts 
a rent increase in reasonable proportion to these costs (e.g. insulating the 
external partitioning structures).  

o  Government is currently assessing whether rules should be amended to allow the 

deep renovation of the housing stock and whether the standards and target 
values can play a role in a possible adjustment. 

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Annex II: Factsheets and lessons learned 

6.6 Concluding assessment  

Assessment of impact per type of policy instrument 

Financing is a key strategic area in achieving the goals set out by Member States in their 

renovation strategies. Three key challenges have been defined:  

•  Unlocking financing for renovations for end-users 
•  Financing building renovations in the presence of market failures  
•  Mobilising sustainable investments and de-risking energy efficiency investment. 

Several  barriers  hinder  the  increase  in  financing  for  renovation.  Split  incentives  and 

inadequate information about costs and benefits are major obstacles, while high upfront 

costs, lack of access to finance and scarcity of private capital emphasise the need for more 
policy and market action.130  

Because grants are available across most analysed countries, and can cover up to 100% 

of the costs of renovation activities, their impact can be considerable in terms of deeper 

renovations.  They  directly  fill  an  immediate  financial  gap  and  thus  enable  a  temporary 

shift in the market. However, they typically rely on limited resources and can, therefore, 

neither offer a sustainable solution nor support mass-market uptake programmes. 

One  of  the  issues  identified  with  this  type  of  instrument  is  that  instead  of  targeting  a 

specific  typology  or  neighbourhoods  with,  for  example,  high  levels  of  energy  poverty, 

projects are often chosen based on the readiness of the recipient (municipalities, banks, 

etc.) and the simplicity of the project. These unambitious aims can have a negative effect 

on  the  depth  of  renovation,  since  setting  insufficient  energy  performance  targets  may 
create a lock-in effect that prevents future  renovations.131 Also, allocating public grants 
may not trigger the private investment needed to meet targets.  

Debt financing in the form of loans can be a more sustainable means of up-scaling energy 

efficiency investments as they can provide liquidity and direct access to capital. Loans can 

be more relevant for energy efficiency measures attached to high upfront costs, especially 

in  deep  renovation  projects  which  comprise  a  package  of  multiple  intervention 
measures.132 

Government programmes can partly or fully finance energy efficiency retrofit transactions 

(eg. KfW and Green Deal), and offer subsidised interest rates and placement fees to banks 

or utility distribution networks for sale and transaction processing services. Low interest 

rates are a common feature of most of national loan schemes in the EU targeting energy 

efficiency investments. 

Private debt financial products designed specifically for energy renovations in buildings are 

currently  not  fully  developed,  as  financial  institutions  are  often  unfamiliar  with  these 

investments and thus perceive energy efficiency loans as high-risk. High transaction costs 

for relatively small projects and failure to offer financing for terms long enough to support 

deeper measures are additional factors hindering market uptake. 

130 Bertoldi, P. and Economidou, M. (2014). Financing Building Energy Renovations 
131 BPIE (2017). Financing the Future of Buildings in Central, Eastern And South-East Europe. 
132 JRC (2019). Accelerating Energy Renovation Investments In Buildings  

113 

 
 
Annex II: Factsheets and lessons learned 

Taking the example of Germany and KfW’s Energy Efficiency Programme, the measures 

supported by the programme are helping to reduce carbon emissions by almost 9 million 

tonnes per year. It has also triggered investments of over €260 billion in building measures 

and  secured  an  average  of  320,000  jobs  per  year  in  the  building  industry  and  regional 

trades. Every second newly built home in Germany is currently supported by funds from 

the "Energy-efficient Construction" programme and close to 290,000 homes received an 

energy-efficient  makeover  with  the  help  of  KfW  in  2016.  However,  while  deeper 

renovations are triggered with the programme, its effect on the renovation rate is minor. 

The  creation  of  innovative  financial  instruments,  such  as  on-bill  schemes,  and  more 

dedicated and effective use of funding streams is essential to renovate the building stock. 

The main objective of these mechanisms is to move from grants towards instruments that 

leverage private sector resources.  

In the current context of available capacity in the economy and stress on public budgets, 

energy savings projects are a particularly attractive option to increase economic activity, 

as several structural barriers are holding back otherwise profitable investments.  

Experience shows that while on-bill schemes can successfully overcome important barriers 

such as upfront cost and split incentives, there are still issues that need to be addressed. 

These  include  the  need  to  modify  billing  systems,  the  role  of  utilities  as  financial 

institutions,  risks  of  no  payment,  handling  transfer  of  property,  diversifying  sources  of 

capital, etc. 

On-tax financing mechanisms can reduce first-cost barriers by linking repayment of energy 

efficiency  investments  to  taxes,  allowing  customers  to  pay  back  part  or  all  of  the  costs 

over time. The funds can originate from utilities, the state or third parties, e.g. commercial 

banks. 

In terms of impact, PACE in California,  for  example, saved 29.754 billion kWh between 

2009 and 2019. This translates into CO2 emission savings of up to 7.44 billion tonnes in 

the  same  period.  Furthermore  attaching  these  mechanisms  to  the  property  itself  (as 

opposed to its occupant) reduces their risk and should remove them from the relatively 

high-cost  world  of  consumer  finance  (bringing  them  more  appropriately  into  the  lower-

cost world of asset finance). 

Energy  efficiency  obligations,  required  under  the  EU  Energy  Efficiency  Directive,  are 

instruments enacted by governments in order to stimulate energy efficiency investments 

through  obligations  placed  on  energy  companies.  Under  an  energy  efficiency  obligation 

scheme,  energy  distributors  or  retail  energy  sales  companies  are  required  to  achieve  a 

certain amount of energy savings in a pre-defined time. Member States typically mandate 

energy  companies  to  achieve  yearly  energy  savings  of  1.5%  of  annual  sales  to  final 

consumers.  Once  implemented,  energy  efficiency  obligations  have  the  advantage  of 

boosting the market for energy efficiency investments by stimulating the development of 

new  business  models  such  as  ESCOs  and  provide  an  additional  income  stream  for 

renovation  programmes.  In  addition,  if  designed  properly,  they  give  a  fairly  good 

estimation of the actual savings achieved through the programme. 

Finally, guarantees can provide a valuable solution in cases where financial intermediaries 

(lenders) are reluctant to fund energy efficiency projects due to high perceived risks. There 

are different types of guarantee mechanisms, such as loan guarantees and risk sharing 

arrangements.  By  providing  financial  guarantees  to  enhance  project  creditworthiness, 

114 

Annex II: Factsheets and lessons learned 

guaranteed  loans  can  boost  energy  efficiency  while  at  the  same  time  reducing  tax 
deductible interest payments, creating more taxable income for governments.133  

Assessment of ease of implementation per policy type 

The  level  of  transferability  of  grants  across  countries  is  considered  high,  since  they  are 

easy to manage, require less administrative preparation and maintenance, and don’t need 

legislative  changes  to  implement.  In  fact,  most  of  the  countries  analysed  already  have 

grants in place for renovation.  

Loans  can  be  easily  implemented  by  banking  institutions,  reducing  long  bureaucratic 

processes often linked with government grant schemes. However, the decision falls mainly 

on  financial  institutions  that  are  usually  private  organisations.  In  addition,  financial 

institutions traditionally perceive a higher risk in energy efficiency investments which may 

hinder their deployment. 

Energy  performance/energy  service  contracts,  which  are  mostly  offered  by  ESCOs,  are 

considered risky due mainly to the temporary link of the instrument with the life of the 

ESCO, which can be significantly affected by economic or political instability. Therefore, 

the level of transferability will be higher in countries with economic and political stability.  

On-bill  schemes  and  on  tax-programmes  exist  in  several  states,  regions  and  local 

governments.  Programmes  vary  across  several  dimensions  including  the  level  of 

organisation  (state-wide  vs.  local  programmes),  financing  structures,  and  eligible 

measures.  These  programmes  are  typically  enabled  through  state  legislation  and 

authorised  at  the  local  government  level.  Municipalities  may  administer  residential 

programmes directly, or through public-private partnerships with one or more providers. 

The degree of transferability across countries is considered moderate, since the feasibility 

is  dependent  on  internal  regulation  in  each  country.  The  role  of  municipalities  or  local 

governments as a capital provider might cause conflicts in certain countries. 

A  number  of  EU  Member  States  have  already  introduced  suppliers’  obligations  to 

encourage  energy  efficiency  improvements,  usually  based  on  quantified  energy  savings 

obligations with certification of energy savings (via white certificates), and the option to 

trade  them.  However,  implementing  energy  saving  obligations  involves  a  set  of 

administrative  tasks  related  to  enforcing  the  scheme,  including  measurement  and 

verification of project savings and standard registration tasks. Furthermore, a specific body 

responsible  for  the  organisation  and  the  maintenance  of  the  white  certificate  trading 
platform  is  necessary.134  Considering  all  these  requirements,  the  transferability  across 
countries is considered low.  

133 Bertoldi, P. and Economidou, M. (2014). Financing Building Energy Renovations. 
134 Bertoldi P. and Rezessy S. (2009). Energy Saving Obligations and Tradable White Certificates.  

115 

 
 
 
 
 
Annex II: Factsheets and lessons learned 

renovation and modernisation of the 
built environment 
Health and wellbeing - Factsheet  

Author: Vivian Dorizas, Janne Rieke Boll 

September 2020 

Tender N° ENER/C3/2019-468/03 

116 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

7.1 Introduction  

This  factsheet  provides  an  overview  of  how  different  policy  instruments  and  selected 

private initiatives can help to achieve European objectives and effectively address key EU 

challenges in the strategic area of health and wellbeing. The findings draw upon a policy 

screening for 15 EU Member States, 3 non-EU countries and 5 European regions covering 

broadly  the  climatic  zones  of  the  EU.  In  addition,  the  factsheet  draws  on  additional 

information provided by external experts as well as on the long-standing expertise of the 

authors, meaning policy examples going beyond the researched country and region cases 

are  occasionally  added.  The  concluding  assessment  draws  on  the  findings  and  detailed 

analysis of the good practice cases as well as on the in-house expertise of the partners. 

7.2 Health and wellbeing 

As people spend about 90% of their time indoors, the indoor environment has a significant 
effect on their health and wellbeing.135 A great number of scientific studies show that the 
indoor environmental quality (IEQ) plays a crucial role in ensuring the quality of life and 
general health and wellbeing of occupants.136 The major determinants of IEQ are indoor 
air quality, thermal comfort, acoustics and lighting. In addition to improving IEQ, energy 
efficiency  renovation  improves  air  quality  by  reducing  fossil  fuel  use.137  Reduction  of 
energy  consumption  through  building  renovations  also  reduces  energy  poverty.  Finally, 

energy efficiency renovations coupled with the elimination of accessibility barriers are also 

associated with increased wellbeing of occupants. 

The  revised  Energy  Performance  of  Buildings  Directive  (EPBD)  has  sparked  a  change 

towards the right direction by including elements of health, comfort and air quality. Article 

2a  of  the  EPBD  requires  Member  States  to  incorporate  in  their  long-term  renovation 

strategy  (LTRS)  an  evidence-based  estimate  of  expected  energy  savings  and  wider 

benefits,  such  as  those  related  to  health,  safety  and  air  quality.  The  Commission 
Recommendation  on  building  renovations138  clearly  mentions  that  measures  to  address 
energy performance can contribute to the creation of a healthy indoor environment and 

spells out some of the wider benefits related to health and wellbeing, such as lower illness 

and health costs and greater labour productivity from better working and living conditions. 

The  transformation  towards  an  energy-efficient  building  stock  will  simultaneously  have 

positive effects on the health and wellbeing of occupants. An important driver of healthy 

buildings are sustainable building certification systems, which set standards in areas such 

as indoor environment, ecology, sociocultural aspects, active and healthy lifestyles, and 
safety. They include the German Sustainable Building Council’s DGNB139, the Leadership 

135 WHO (2012). Burden of disease from Household Air Pollution for 2012. World Health Organization 
136 Al horr et al. (2016). Impact of indoor environmental quality on occupant well-being and comfort: A review 
of the literature, International Journal of Sustainable Built Environment 5(1):1-11. 
137  EPA,  Environmental  Protection  Agency,    (Available  at:  https://www.epa.gov/indoor-air-quality-iaq/health-
energy-efficiency-and-climate-change)  
138 Commission Recommendation (EU) 2019/786 of 8 May 2019 on building renovation 
139  The  German  Sustainable  Building  Council  developed  a  voluntary  certification  system,  the  DGNB  system. 
https://www.dgnb.de/en/ 

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Annex II: Factsheets and lessons learned 

in  Energy  and  Environmental  Design  (LEED)  rating  system140,  the  BREEAM  assessment 
method141, the Irish Home Performance Index142 and the WELL Building Standards.143  

The three identified key challenges in the strategic area of health and wellbeing are:  

1)  Integrating  health,  wellbeing  and  comfort  aspects  in  legislation  and  policy 

instruments associated with renovations. 

2)  Enforcing  and  mainstreaming  existing  IEQ  provisions  (e.g.  through  EN  and 

ISO standards) in Member States  

3)  The  lack  of  systematic  quantification  of  health  and  wellbeing  benefits  and 

their integration in the cost-optimal methodology to boost the renovation rate.  

This  factsheet  gives  an  overview  of  the  legislative  and  non-legislative  provisions  in  the 

focus countries which address these challenges. The identified measures are assessed on 

their  effectiveness  to  tackle  the  key  challenges,  and  good  practice  examples  are 

highlighted. 

7.3 Provisions to address key challenges  

This section gives an overview of the policies considered to be most successful at tackling 

key challenges in the area of health and wellbeing. To operationalise the challenges and 

allow for quantitative  estimations on  selected  aspects, the country screening looked  for 

provisions that integrate IEQ in policy instruments, alleviate energy poverty, establish IEQ 

requirements  and  guiding  documents,  are  certification  schemes  or  include  accessibility 

provisions.  

Figure 1 provides an overview  of the policy  screening. Since countries vary in  size, the 

number of provisions does not necessarily reflect the effectiveness of the policy mix. While 

the  number  of  provisions  found  may  give  an  indication  of  the  breadth  and  diversity  of 

approaches, it should not be taken as the sole indicator for how effective the provisions 

are for tackling key challenges. One well-designed policy instrument may be more effective 

than  a  multitude  of  less  adequate  instruments.  Therefore,  an  additional  qualitative 

discussion as well as insights from the good practice analysis are provided in the remaining 

parts of the paper.  

Many of the analysed countries have aspects of health and wellbeing integrated in their 

legislative  or  non-legislative  building  policies,  while  several  provisions  address  the  key 

identified challenges to a varying degree. Table 1 gives a qualitative overview of the main 

aspects addressed per country or region, while Figure 2 shows the number of provisions 

for the examined aspects.   

The  category  ‘integration of IEQ in policy instruments’  refers to measures that improve 

IEQ,  reduce  negative  health  effects  and  remove  harmful  substances  from  the  indoor 

environment (Figure 2, dark blue bar). National policies regulating the energy efficiency 

of buildings often mention improved living conditions covering thermal comfort and better 

BREEAM, 

140 LEED, Leadership in Energy and Environmental Design rating system, https://www.usgbc.org/leed 
141 
https://www.breeam.com/engage/research-and-development/consultation-engagement/active-design-and-
breeam/ 
142 Home Performance Index certification, http://homeperformanceindex.ie/ 
143 The WELL Building Standards https://www.wellcertified.com/ 

Environmental 

Establishment 

Research 

Building 

Method, 

118 

 
 
Annex II: Factsheets and lessons learned 

air  quality  as  drivers  for  renovation  (e.g.  Warmth  and  Well-being  scheme  [Ireland]144, 
Clean  Air  Programme  [Poland]145,  Planning  and  Building  Ordinance  2011  [Sweden]). 
Research projects, on the other hand, develop new technologies or strategies to improve 
and  monitor  the  indoor  climate  (e.g.  PRO-CLIMAT  [Brussels]146,  Solbjerg  skole 
[Denmark]147).  The  removal  of  harmful  substances  contributes  to  better  indoor  climate 
and  is  taken  up  by  different  provisions,  for  example  in  the  planned  asbestos  removal 
bonus148  in  Flanders,  Belgium,  the  asbestos  fund  of  the  Netherlands149  and  the  Radon 
grant150  in  Sweden.  In  addition,  regulations  reducing  noise  in  residential  buildings  are 
implemented  in  France  (Energy  and  acoustic  renovation)151  and  Sweden  (Ordinance  on 
traffic  noise  in  residential  buildings152)  and  are  supported  by  a  grant  in  Umeå,  Sweden 
(Grant for noise protection153).  

The  ‘IEQ    requirements  and  guiding  documents’  cover  concrete  IEQ  criteria  such  as  for 

thermal  comfort  and  ventilation  and  national  guidelines  on  how  to  design  and  operate 

healthy  indoor  environments,  but  also  guiding  documents  and  platforms  promoting 
healthy living (e.g. Platform live healthy154, healthy housing155 in Germany) (Figure 2, red 
bar). Ventilation requirements (in l/s per person) are included in building codes in most 

countries,  such  as  Germany,  UK,  Poland,  Greece  and  Romania  but  are  not  always 

compulsory.  Mandatory  ventilation  requirements  are  implemented  in  Denmark,  France, 

Italy,  Ireland,  Netherlands,  Norway  and  Sweden.  Additionally,  most  countries  have 

national standards in place adopted by a corresponding European standard (e.g. ΕΛΟΤ ΕΝ 

119 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

13779 in Greece, DIN EN ISO 13791 in Germany, SR EN 16798-1 in Romania etc.) that 

are  not  represented  in  the  diagram.  The  Netherlands,  for  example,  has  non-legislative 
guidance  documents  providing  principles  on  healthy156  and  comfortable 
indoor 
environments  as  well  as  a  coalition  of  stakeholders157,  developing  a  healthy  building 
governance  code  in  order  to  get  health  and  wellbeing  on  the  agenda  of  the  Dutch 

government. 

The category ‘certification schemes’ refers to voluntary building certification schemes in 

place that are implemented by either private actors or national green building councils and 

consider  health  and  wellbeing  aspects  (Figure  2,  green  bar).  LEED  certification,  which 

takes the whole lifecycle of a building into account, is international and is used in many of 

the  analysed  countries  (e.g.  California,  Italy,  UK,  Greece).  The  WELL  building  standard 

was more recently launched (in 2014) and has also been adopted in many of the analysed 

countries such as the UK, Italy and Sweden. The WELL standard sets a stronger focus on 

the health of occupants. Another certification scheme is the BREEAM system developed in 

the UK, which is also used in the Netherlands, Norway, Sweden and Spain. Additionally, 
national  certification  systems  are  implemented  in  Germany  (DGNB),  Italy  (BioSafe158), 
Ireland (Home Performance Index) and California (Living Building Challenge 4.0159, Indoor 
airPLUS label160). France launched its E + C -161 (Positive Energy and Carbon Reduction 
Building) label in 2016 to foreshadow future energy regulation and performance standards, 

representing  a  step  towards  Level(s),  the  European  common  reporting  framework  of 

sustainable  performance  of  buildings.  Level(s)  brings  the  key  aspects  of  a  building’s 

sustainability  performance  beyond  the  use-phase  energy  consumption  into  focus,  with 
health and wellbeing among being one of the key areas.  

As  these  are  voluntary  certification  schemes,  they  only  address  the  first  key  challenge 

regarding the integration of IEQ parameters in policy instruments but do not necessarily 

support  enforcement.  However,  legal  provisions  in  the  United  States  such  as  the  King 
County Green Building Ordinance162, aim at making LEED certification mandatory, which 
can  indeed  support  enforcement.  Most  certification  systems  were  initially  developed  for 

commercial  and  institutional  non-residential  buildings  but  are  increasingly  applied  in 

120 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

residential  building  projects  as  the  demand  for  a  healthy  indoor  environment  and 
sustainable housing is rising and certification can enhance the value of properties.  

‘Energy  poverty  alleviation’  refers  to  instruments  promoting  the  elimination  of  energy 
poverty (Figure 2, purple bar). Energy poverty provisions are implemented in 11 out of 24 
regions/countries.  Renovation  and  energy  saving  measures  for  vulnerable  residents  are 
highly supported by grants or offered at no cost for the residents in Ireland (Warmth and 
wellbeing scheme, Warmer Homes scheme163) and Scotland, UK (Warmer Homes Scotland 
Scheme164),  while  Croatia  launched  a  consulting  and  capacity  building  programme165 
around energy poverty and established a programme for combating energy poverty that 
provides co-financing for energy efficiency measures to vulnerable consumers. 

‘Accessibility  provisions’  refer  to  social  equality  aspects  and  measures  that  eliminate 

accessibility barriers for people with disabilities (Figure 2, light blue bar). Accessibility is 
often  addressed  by  grants  (Support  for  barrier-reduction  fund166  [Saxony,  Germany]), 
standards  or  guidelines  but  usually  not  in  legislative  provisions.  Exceptions  include 
regulations for people with disabilities in for example California167 and Greece168 and the 
accessibility  chapter  in  the  building  codes  of  Denmark,  Ireland,169  Sweden170,  and  the 
Netherlands. Most provisions on this topic have been identified in Germany (e.g. standards 

on barrier-free housing and thermal performance), Sweden and Tirol (Figure 1).  

The Federal Disability Act covers accessibility in the built environment in Austria. All three 

regions  of  Belgium  have  technical  prescriptions  and  guidelines  on  accessibility.  In 

particular, the Flemish Decree supports urban development for the accessibility of public 

buildings,  the  Walloon  Code  guarantees  accessibility  to  public  and  private  buildings  for 

people  with  reduced  mobility  and  disability,  and  the  Regional  Urban  Development 

Regulation of Brussels sets the rules for public space adaptation. Royal Decree 505/2007 

in Spain approves the conditions on accessibility of people with disabilities to be able to 

access  public  spaces  and  buildings  and  sets  out  accessibility  standards  in  public  spaces 

and infrastructures.  

121 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

The 1994 Law on construction in Poland introduced the obligation to consider the needs of 

people with disabilities in new construction projects but also when modernising existing 

public  and  multi-family  buildings.  A  new  programme  called  Accessibility  Plus  was 

announced in 2018 aiming to make 1,000 public facilities accessible to disabled persons, 

including schools (100), nurseries (100), universities and healthcare centres.   

The  accessibility  law  (Decree-Law  163-2006)  of  Portugal  defines  accessibility  standards 

for public buildings, facilities and spaces and covers general norms and principles to be 

applied in residential buildings. For the protection and promotion of rights of people with 

disabilities, accessibility measures related to public buildings were included by the National 

Institute  for  Rehabilitation  law  448/2006  of  Romania;  however,  many  public  buildings 

remain  inaccessible  for  people  with  wheelchairs.  According  to  the  National  Disability 

Strategy, the main reason for this is the lack of a strict commitment to ensure accessibility 

of  local  and  central  authorities.  The  Building  Code  of  the  Netherlands  governs  usability 

including  accessibility,  but  contains  no  sanction  if  the  regulations  are  violated.  In  Italy, 

several laws cover the right of accessibility such as the Decree 114 containing guidelines 

for the elimination of architectural barriers in places of cultural interest and the Presidential 
Decree 503 regulating the removal of architectural barriers in public buildings.171  

The  quantification  of  health  and  wellbeing  benefits  seems  to  be  addressed  to  a  much 

smaller  extent.  There  are  no  mandatory  policies  in  place  addressing  the  topic  in  the 

analysed countries, although a few non-legislative initiatives and research projects (e.g. 

in a Danish school in the city of Aarhus) tackle the issue. The  regional internal pollution 

intervention unit in Belgium, in addition to carrying out indoor pollution diagnostics upon 

medical request, monitors the improvement of health which can be a starting point for the 

quantification  of  health  and  wellbeing  benefits  from  building  renovations.  The  Coalition 
Healthy  Buildings23  in  the  Netherlands  is  developing  a  system/model  for  appraising  the 
value of healthy buildings based on guaranteed performance that is accepted by institutes, 

banks and investors. 

171 The Academic Network of European Disability Experts (ANED), DOTCOM: the Disability Online Tool of the EU 
Commission.  

122 

 
 
Annex II: Factsheets and lessons learned 

s
n
o
i
s
i
v
o
r
p

f
o

r
e
b
m
u
N

9

8

7

6

5

4

3

2

1

0

Integration of IEQ in policy instruments

IEQ requirements & guiding documents

Certification schemes

Energy poverty alleviation

Accessibility provisions

Note: National provisions are not counted in the regions 

Figure 6 - Key aspects of health and wellbeing per country  

123 

 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Table 10: Overview of policy instruments on health and wellbeing per country 

IEQ requirements  

Country 

(ventilation, thermal 

Accessibility 
provisions 

comfort etc.) 

Provisions 
alleviating energy 
poverty 

Certification/labelling 
systems (excl. EPCs) 

Quantification of 

health & wellbeing 

Andalusia 

BW  

Brussels 

Flanders 

Wallonia 

California/ USA 

Croatia  

Denmark 

France  

Germany  

Greece  

Ireland 

Italy  

Lithuania 

Netherlands 

Norway  

Poland 

Portugal  

Romania 

Silesia 

Spain 

Sweden 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ (research project) 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√  

(on national level in Belgium) 

√ 

√ 

√ 

√ 

√ 

√ 

√  

√ 

√ (EPC incl. IAQ) 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

124 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Tirol 

UK 

Umea 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

125 

 
 
 
 
 
 
 
 
 
   
Annex II: Factsheets and lessons learned 

7.4 Effectiveness of the policy landscape to address key challenges  – overview 

and description 

This section presents an assessment of the overall policy landscape that a previous country 

screening  identified  as  relevant  for  the  covered  countries  and  regions.  The  assessment 

takes into account the diversity of instruments (regulation, pricing, support, information 

etc.), whether there are particularly interesting and innovative instruments, and whether 

the instruments identified together seem to be adequate to address the given challenges. 

A discussion of policy instruments follows the tables.   

The given classification in Tables 2 and 3 should be interpreted as follows: 

Good  policy  landscape  with  at  least  one  innovative  instrument  targeting  health 

and wellbeing 

Adequate  policy  landscape  with  instruments  that  could  in  the  future  better 

integrate health and wellbeing in building renovation policies 

Inadequate  policy  landscape,  with  no  instruments  identified  in  relation  to  the 

given challenges 

Not conclusive 

Table 2 – Legislative policies  

Health and wellbeing – legislative policies 

Integrating of health, 
wellbeing and comfort 
aspects in legislation 
and policy instruments 
associated with 
renovations 

KEY CHALLENGES 

Enforcing and 
mainstreaming existing 
IEQ provisions in 
Member States 

Quantifying health 
and wellbeing 
benefits from 
building renovations 
and integrating 
them in the cost-
optimal 
methodology to 
boost the 
renovation rate 

Belgium 
Croatia 
Denmark 
France 
Germany 
Baden 
Wurttemberg  
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 

126 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

Table 3 – Non-legislative policies 

Health and wellbeing – non-legislative policies 
KEY CHALLENGES 

Enforcing existing 
provisions in support of 
IEQ 

Quantifying health and 
wellbeing benefits from 
building renovations and 
integrating them in the 
cost-optimal methodology 
to boost the renovation rate 

Integrating 
health, 
wellbeing and 
comfort 
aspects in 
legislation and 
policy 
instruments 
associated 
with 
renovations 

Norway 
California/ 
USA 
Andalusia 
Alpine (Tirol) 
Silesia 
Umea 

Belgium 
Croatia 
Denmark 
France 
Germany 
Baden 
Wurttemberg  
Greece 
Ireland 
Italy 
Lithuania 
Netherlands 
Poland 
Portugal 
Romania 
Spain 
Sweden 
UK 
Norway 
California/ 
USA 
Andalusia 
Alpine (Tirol) 
Silesia 
Umea 

127 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Factsheets and lessons learned 

1)  Integrating  health,  wellbeing  and  comfort  aspects  in  legislation  and  policy 

instruments 

In Sweden, the Building Ordinance (Planning and Building Ordinance (2011:338)172) states 
that buildings should be designed in a way that does not create health issues related to 

indoor air pollutants such as hazardous particles or gases in the air, smoke and presence 

of  moisture  on  the  buildings’  surfaces.  In  addition,  buildings  shall  have  technical 

characteristics related to protection against noise. Obligatory ventilation control (based on 
the  Planning  and  Building  Act  (2010:900)173)  is  applicable  to  all  buildings  and  must  be 
performed regularly to check if the indoor climate is good and the ventilation systems are 

functional.  The  Danish  building  code  integrates  similar  ambitious  IEQ  requirements, 

including regulations on daylighting and noise protection. 

California applies a great number of national  and state-level certification schemes (e.g. 
US EPA Indoor airPLUS label, GreenPoint Rated174 etc.) which cover topics either partially 
or entirely related to IEQ and therefore health, wellbeing and comfort. The integration of 

these aspects in legislation is supported by building ordinances that make building rating 

systems  such  as  LEED  mandatory.  LEED  considers  indoor  air  quality  as  an  assessment 

criterion.  

The Polish Clean Air programme175 aims to improve air quality by allowing homeowners of 
specific  income  levels  to  get  a  grant  or  subsidy  for  the  thermal  modernisation  of  their 

building. 

In the  Brussels  capital  region  of  Belgium, awareness  raising  campaigns176 on indoor air 
quality, the use of highly emissive building materials and products and improving health 

are part of the sustainable building guide. In Flanders, a legislative provision is planned to 

financially support the renovation of roofs containing asbestos. 

In  support  of  the  integration  of  health  and  wellbeing  aspects  in  policy  instruments, 

Germany has developed a series of platforms and guidelines on healthy housing and air 
pollutants (e.g. Healthy housing platform177 , health living178). 

As part of the housing renovation directive in Tirol, the regional government offers grants 
for reducing pollutant emissions179 and improving comfort.  

The guidelines180 for energy efficiency and ventilation in the UK are in approved documents 
of the building regulations giving guidance on airtightness and ventilation and specifying 

air quality standards for limited substances. While these regulations apply for both new 

and renovated buildings, they are most likely to be enforced for new buildings. Indoor air 

172 Planning and building Ordinance 2011:338 Chapter 3 section 9: requirements for the protection with regard 
to hygiene, health and environment, Swedish Ministry of Finance 
173 Planning and Building Act 2010, Chapter 8, section 25 and the Planning and Building Ordinance Chapter 5, 
§1, Swedish Ministry of Finance 
174 GreenPoint Rated certification system by Build It Green organisation, California, US 
175  Clean  Air  Programme  (2018-2029),  National  Fund  for  Environmental  Protection  and  Water  Management, 
Poland 
176 LTRS Brussels, p. 91 (Action 19), Government of the Brussels-Capital Region 
177 Gesund Wohnen, Online Magazine for healthy living, www.gesund-wohnen.com 
178 Wohnen Sie gesund, information portal on healthy housing, "Zukunftsinitiative Handwerk" (ZIH), Economic 
ministry of North Rhine-Westphalia  
179 Single grant for construction measure, §35 Tirolean Housing Promotion Act, LGBl. No. 144/2018, Tirol regional 
government 
180 UK Indoor Air Quality, Approved Documents of the Building regelation, Parliamentary Office of Science and 
Technology, House of Parliament, UK 

128 

 
 
Annex II: Factsheets and lessons learned 

quality can be improved through changes to regulations, such as giving greater emphasis 

on ventilation and setting air quality standards for common air pollutants. 

Within  Lithuania’s  technical  building  regulations181  and  hygiene  standard182,  IEQ 
requirements are found.  

Air protection programmes183 of Silesia aim to achieve acceptable levels of pollutants in 
the air.  

Another  good  example  can  be  found  in  Finland  where  ARA,  the  Housing  Finance  and 
Development  Centre,  grants  subsidies184  for  residential  building  owners  and  owners  of 
housing  units  that  show  humidity  or  microbial  damage  or  other  indoor  air  problems. 

Support can also be granted for the renovation planning phase.   

2) Enforcing and mainstreaming existing IEQ provisions in Member States  

France  sets  minimum  requirements  for  ventilation185  and  mandatory  labelling  of 
construction products186 to limit the sources of indoor air pollutants. 

In  Denmark,  the  private  initiative  Clean  Air  School  Districts187  offers  monitoring 
instruments,  educational  material  and  consultation  services  to  students,  teachers  and 

parents on improving the IEQ of the schools.  

Germany has adopted a great number of EN ISO standards related to the IEQ dealing with 
ventilation  requirements188,  construction  products189,  assessment  and  evaluation  of  the 
release of dangerous substances.190  

Norway  has  implemented  building  technical  regulations  that  include  provisions  and 

requirements  related  to  all  determinants  of  IEQ  (thermal  comfort,  indoor  air  quality, 
ventilation and radon accumulation191).  

New and renovated buildings should meet requirements192 of natural ventilation, lighting, 
acoustics and material emissions in Italy.  

181 Technical Building Regulations STR 2.09.02: 2005 "Heating, Ventilation and Air Conditioning” and STR 2.01.01 
[5]: 2008 "Essential requirement for construction”, “Noise protection", MINISTER OF THE ENVIRONMENT OF THE 
REPUBLIC OF LITHUANIA 
182 Lithuanian Hygiene Standard HN 42: 2009 “Microclimate of Residential and Public Buildings”, MINISTER OF 
HEALTH OF THE REPUBLIC OF LITHUANI 
183  Air  protection  program  for  the  Silesian  region,  Resolution  NO  VI  /  12/7/2019  of  the  Slesian  regional 
government 
184  LTRS  Finland,  p.  39,  Long-term  renovation  strategy  2020–2050  FINLAND,  European  Commission  website, 
2020 
185 Order of June 13, 2008 relating to the energy performance of existing buildings with a surface area greater 
than 1,000 square meters, when they are the subject of major renovation works, Ministry of State, Ministry of 
Ecology, Energy, Sustainable Development and Regional Planning, and the Ministry of Housing and City, France 
186 Order of April 19, 2011 relating to the labeling of construction or wall or floor covering products and paints 
and varnishes on their emissions of volatile pollutants, Ministry of Ecology, Sustainable Development, Transport 
and  Housing,  the Ministry  of the  Economy, Finance  and  Industry  and  the Ministry  of  Labor,  Employment  and 
Health, France 
187 Clean Air School Districts (CASD) campaign by leapcraft, Denmark 
188  DIN CEN/TR  16798-6  and DIN  SPEC 32739-6  Energy  efficiency  of  buildings  - Ventilation of buildings, DIN 
(German national organization for standardization) 
189 DIN EN 16687 Construction products - Evaluation of the release of dangerous substances - Terminology 
190 DIN EN ISO 10456 Construction products - Assessment of the release of dangerous substances - Barriers to 
trade 
191 Building Technical Regulations TEK 17- Indoor Air Quality (Article 13.1-13.3), Thermal Comfort (13.4) and 
Radon removal (Article 13.5), Norwegian Building Authority 
192 Minimum environmental criteria for entrusting design services and works for the new construction, renovation 
and maintenance of public buildings, Interministerial Decree of 11 January 2017, Italy  

129 

 
 
Annex II: Factsheets and lessons learned 

Under the revised energy efficiency regulation of buildings in Greece (KENAK 2017), the 
technical chamber of Greece has published technical specifications193 for the estimation of 
the energy efficiency of buildings which specify requirements of the indoor environment 

covering aspects of thermal comfort, ventilation and lighting.  

The  energy  performance  certificate  (EPC)  in  Portugal  also  covers  indoor  air  quality  and 

natural  ventilation  is  given  priority  over  mechanical  ventilation.  The  EPC  also  specifies 

minimum values of  fresh air rates and thresholds for  concentrations  of air pollutants in 

order to safeguard the health and wellbeing of occupants. 

3)  Quantifying  health  and  wellbeing  benefits  from  building  renovations  and 

integrating them in the cost-optimal methodology to boost the renovation rate 

In  general,  there  is  a  lack  of  cases  quantifying  the  health  and  wellbeing  benefits  from 

building renovations across the analysed countries. The listed provisions only touch upon 

the topic but do not particularly help in addressing this challenge. 

In Denmark, recent research in a school in Aarhus (p.17) quantified the benefits on health 

and  productivity  arising  from  building  renovations;  however,  there  is  no  standardised 

methodology for calculating the health, wellbeing and productivity benefits arising from 

building renovations. 

The cost of poor air quality and the effects of air pollution on the environment and human 

health can be found in the air protection programme of Silesia; however, no details are 

given on the calculation method behind the estimation of these costs.  

Even though the regional internal pollution intervention unit194 in Brussels, Belgium carries 
out indoor pollution diagnostics on medical request, monitors the improvements on health 

and evaluates the indoor environmental conditions, the benefits on health and wellbeing 

are not thoroughly quantified.  

193 Technical instructions of the Technical Chamber of Greece, National analytical specifications for the estimation 
of the energy efficiency of buildings and the issuance of the energy performance certificate, KENAK 2017 
194  Cellule  Régionale  d’Intervention  en  Pollution  Intérieure  (CRIPI),  Bruxelles  Environnement  /  Département 
Planification Air, Climat et Energie, Belgium 

130 

 
 
 
 
Annex II: Factsheets and lessons learned 

7.5 Highlighting good practice examples 

Based on the results of the previous research as well as on expert knowledge, this section highlights selected good practice examples. Each 

example fulfils one or several of the following selection criteria: innovation (new mechanism, triggering innovation, scaling up innovation), 

impact  (on  EU  objectives,  energy  savings,  CO2  emission  reduction,  potential  renovation  impact),  ease  of  implementation  (including 

transferability,  scalability,  transaction  and  administrative  costs,  budget  (in-)dependency,  compatibility  to  existing  legislative/  policy 

framework) and coverage of diverse jurisdiction and climatic zones.  

Country 
Belgium 

California 

Policy 
Strengthen 
diagnostic 
and  remediation  services 
interior  pollution- 
for 
Internal 
(Regional 
Pollution 
Intervention 
Unit [Brussels])  
Healthy Housing Rewards 
(Federal National 
Mortgage Association – 
Fannie Mae) 

California 

(1) Green Building 
Ordinance 

Brief description 
In addition to carrying out indoor pollution diagnostics on 
medical request, the regional unit is responsible for:  

•  Monitoring the improvement of health 
•  Statistical evaluation of the environmental condition 

of the interiors of diagnosed buildings 

•  Developing recommendations for decision support. 
Fannie Mae provides financial incentives (loans) to lenders 
for: 

•  Healthy  Housing  Rewards  Healthy  Design:  if  the 
incorporates  health-promoting  design 

property 
features and practices 

•  Healthy  Housing  Rewards  Enhanced  Resident 
Services: if the property offers services to improve 
the health and stability of residents. 

(1) This mandatory building ordinance implemented in 
San  Mateo,  California  specifies  that  all  new  or 
remodelled commercial buildings over 3,000 square 
feet must earn LEED certification 

Source  

PACE p.132 

https://multifamily.fanniem
ae.com/sites/g/files/koqyhd
161/files/migrated-
files/content/fact_sheet/hea
lthy-housing-rewards-flow-
chart.pdf  

37122 
Comprehensive 
update of the Green Building 
policy 

(2) King County Green 
Building Ordinance 
17709 

(2) King County, with regard to green building, should 
direct county departments to incorporate the use of 
the LEED green building rating system. 

King  County  Green  Building 
Ordinance  

(3) A resolution 

promoting the use of 
LEED standards in the 

(3) The  Bellingham  City  Council  requires  all  new 
municipal building construction and renovation over 
5,000  square  feet,  and  where  the  city  provides  a 

Resolution No.2005-21  

131 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
construction and 
renovation of city 
buildings and in the 
construction practices 
of the private sector  

Denmark   Building regulations for 

good indoor climate 

Ireland  

Ireland 

Poland  

Portugal  

Warmth and Well-being 
Pilot Scheme (running 
under the Better Energy 
Programme, initiated by 
the Department of 
Communications, Climate 
Action and Environment, 
the Department of Health 
and the Health Services 
Executive). 
Home Performance Index 

Clean Air Programme 
(Institution implementing 
the National Fund for 
Environmental Protection 
and Water Management) 
Certificate of Energy 
Performance and Indoor 
Air Quality, 2013 

Annex II: Factsheets and lessons learned 

majority  of  the  funding,  to  earn  LEED  Silver 
certification. 

•  Minimum requirements: have access to daylight or 
protection  against  noise,  air  quality;  limiting  the 
presence of harmful substances. 
It must be ensured that hazardous substances such 
as  asbestos,  PCB,  lead  or  particles  from  insulation 
materials  from  already  built-in  materials  are  not 
spread to the indoor climate. 

• 

https://bygningsreglemente
t.dk/~/media/Br/BR-
English/BR18_Executive_or
der_on_building_regulation
s_2018.pdf  

•  Building  occupants  with 

respiratory 
conditions  (mainly  older  people  and  children)  are 
eligible for a free home insulation upgrade. 

chronic 

www.seai.ie/grants/home-
energy-grants/free-
upgrades-for-eligible-
homes/warmth-and-
wellbeing  

• 

Ireland's first national voluntary certification system 
for quality and sustainable residential development. 
•  Health and well-being is one of its main categories.  

•  Allows  building  owners  on  low  incomes  to  get  a 
subsidy  for  the  thermal  modernisation  of  the 
building aiming to improve the air quality.  

http://homeperformanceind
ex.ie/wp-
content/uploads/2020/01/H
PI-Technical-Manual-
v2.0.pdf 
https://czystepowietrze.gov
.pl  

• 

In existing buildings, the energy certificate provides 
improve  energy 
information  on  measures  to 
performance and indoor air quality 

•  With regard to indoor air quality, natural ventilation 
is  given  priority  over  mechanical  ventilation 
equipment.  

www.iea.org/policies/2547-
certificate-of-energy-
performance-and-indoor-
air-quality-
2013?country=Portugal&pa
ge=2&qs=portug 

132 

 
Annex II: Factsheets and lessons learned 

•  Sets minimum values of fresh air flow per space and 
indoor  air 
for  concentrations  of 
thresholds 
pollutants,  in  order  to  safeguard  the  health  and 
well-being of the occupants. 

Sweden 

Radon Grants 

•  Grant for Radon remediation for homeowners. 

Sweden 

Obligatory 
control for housing 

ventilation 

•  Obligatory  ventilation  control  applicable  to  all 
buildings and must be performed regularly to check 
if  the  indoor  climate  is  good  and  the  ventilation 
systems are functional. 

Umeå 

Grants 
protection 

for 

noise 

US  

WELL Building Standard  

UK 

BREEAM 
scheme 

certification 

•  The  municipality  provides  grants  to  reduce  noise 
disturbance from road traffic or other outdoor noise 
sources. 

•  The  grants  are  applicable  to  improve  the  acoustic 

insulation of windows. 

•  The  WELL  Building  Standard  was  developed  in  the 
USA but now applied in several European countries 
(e.g. Italy, the Netherlands and Poland) 

•  Certification  criteria  are  air,  water,  nourishment, 
fitness,  comfort  and  mind,  which  are 

light, 
measured and monitored.   

another 

•  The  BREEAM  (Building  Research  Establishment 
Environmental Assessment Methodology) scheme is 
a 
scheme 
incorporating health and wellbeing standards.  
•  The standard  covers  schemes for construction  and 
in-use  and  refurbishment  of  non-

certification 

planning, 
residential and domestic buildings 

building 

www.boverket.se/sv/bidrag
--garantier/radonbidrag/  
www.boverket.se/en/start/
building-in-
sweden/swedish-
market/laws-and-
regulations/national-
regulations/obligatory-
ventilation-control  
www.umea.se/umeakommu
n/byggaboochmiljo/bulleroc
hluftkvalitet/buller/bullersk
yddsbidrag.4.232bb3eb132
b9e0c2ca800068080.html  

www.wellcertified.com  

www.breeam.com 

133 

 
 
 
Annex II: Factsheets and lessons learned 

7.6 Concluding assessment 

The key identified challenges of the policy area of  health and wellbeing are tackled to a 

varying  degree.  Many  of  the  analysed  countries  have  some  form  of  IEQ  provisions 

implemented  in  their  building  renovation  policies,  often  as  standards,  guidance  or 

voluntary  requirements.  Also,  national  certification  schemes,  research  projects  and 

awareness raising campaigns integrate health, wellbeing and comfort aspects.  

In order to better asses the effectiveness and impact of existing provisions, an ongoing 

close monitoring of the policies is essential to increase the data availability (for IEQ this is 

still  very  limited).  In  particular,  private  programmes  and  initiatives,  e.g.  building 

standards/ certifications, are often not monitored or the data is not publicly available. 

Compared to the mere existence of provisions, the enforcement of IEQ is less advanced. 

This can partly be explained by the lack of harmonised methodologies and criteria at EU 

level.  Countries  like  Sweden,  Denmark,  France,  Italy  and  Ireland  apply  legislative 

(mandatory) IEQ requirements (e.g. ventilation and thermal  criteria). Dedicated polices 

regarding noise protection are less often found but are implemented in Sweden and the 

Swedish region of Umeå.  

Additionally, building certification schemes as well as EPCs covering IEQ aspects could spur 

enforcement when their implementation is mandatory. Among the good practice schemes 

is California, which requires certain commercial and municipal new buildings to be LEED 

certified. Also, the Portuguese EPC incorporating requirements for minimum fresh air rates 

and thresholds for concentrations of indoor air pollutants offers aspects to replicate. 

Assessment of impact per type of policy instrument 

Policies aimed at improving IEQ do not necessarily have an effect on energy savings or 

greenhouse gas emission reductions, which makes a general impact assessment difficult. 

It becomes clear when assessing impact that policies that solely address the improvement 

of health and wellbeing, such as radon removal, noise protection or accessibility, do not 

always lead to the improvement a building’s energy efficiency.  

Voluntary and private certification schemes can  be effective in reducing energy use and 

greenhouse  gas  emissions  if  they  are  widespread  in  the  building  stock  (compare 

mandatory certification in the US). Indicators of health and wellbeing could improve EPCs 

and  encourage  their  utilisation  as  renovation  advice  instruments  triggering  deeper 

renovation. 

The impact of financial support schemes that are often implemented in the form of grants 

(e.g. Swedish noise protection or radon removal grant) is high regarding the alleviation of 

IEQ issues, though they do not always add to energy savings or greenhouse gas emission 

reductions unless embedded in a relevant policy framework.  

Informative  measures  which  increase  awareness  on  the  importance  of  health  and 

wellbeing aspects when renovating, especially residential and educational or recreational 

buildings,  are  often  effective  to  trigger  deep  retrofits.  A  holistic  monitoring  and 

quantification  of  these  benefits  is  important  to  communicate  them  to  the  relevant 

stakeholders (e.g. building owners).  

134 

 
Annex II: Factsheets and lessons learned 

Regulations  set  in  the  building  codes  of  many  countries  are  effective  when  they  are 

mandatory  provisions  and  cover  not  only  specific  ventilation  requirements  but  have 

thermal comfort, lighting and noise requirements, as in Denmark.  

Ease of implementation per type of policy instrument 

The Danish building code shows a good example of a progressive integration of mandatory 

thermal comfort, lighting and noise requirements that are not  yet implemented in other 

Member  States.  The  transferability  could  be  increased  by  an  amended  EU  legislation 

(EPBD) demanding a stronger integration and enforcement of IEQ requirements. 

Most policies are administered at the national level, although some American and Swedish 

regional authorities have implemented ambitious policies (mandatory certifications, grant 

schemes).  Guidance  at  EU  level  allowing  some  flexibility  to  be  tailored  at  national  level 

with country-specific requirements would strongly facilitate implementation.  

Although  the  Joint  Research  Centre  has  published  a  report  on  Promoting  healthy  and 
energy  efficient  buildings  in  the  European  Union’195  showing  various  studies  that  have 
quantified  the  benefits  in  terms  of  improved  quality  of  life,  a  systematic  quantification 

approach of health and wellbeing benefits among EU countries is lacking. Some research 

projects (e.g. Denmark, Belgium) were identified but a large-scale integration of quantified 

IEQ benefits in cost-optimal calculations is missing.  

Accessibility provisions are implemented in most of the analysed countries in the form of 

standards,  guidelines  and  grants  to  adapt  the  building  to  users’  needs  (cf.  Germany, 

Umeå). However, they are not systematically used to trigger deep energy renovation or 

vice versa. Yet in Poland, when modernising existing public and multi-family buildings, the 

needs of people with disabilities should be considered. 

Strategies addressing energy poverty are mostly implemented in countries where energy 
poverty is widespread and on the political agenda, as in England (UK)196 and Ireland197. 
Greece,  Italy,  France  and  Croatia  have  also  planned  or  applied  provisions  to  alleviate 
energy  poverty  through  financial  support  schemes198,  monitoring  platforms199  and 
education campaigns200. 

Despite  the  good  practice  policies  and  initiatives  presented  in  this  factsheet,  regulatory 

and legislative measures have so far failed to fully integrate health and wellbeing aspects 

in building legislation. Though the impacts of the indoor environment on building occupants 

are researched intensively, it is still a challenging and complex procedure to isolate and 

quantify  the  benefits  to  health,  wellbeing,  comfort  and  productivity  from  building 

renovation. Communication campaigns to increase the awareness of IEQ among building 

occupants and owners should be implemented at large scale to drive deep renovations.

195 Promoting healthy and energy efficient buildings in the European Union : National implementation of related 
requirements of the Energy Performance Buildings Directive (2010/31/EU)  
196  Fuel  Poverty  Strategy,  England/  UK,  Fuel  Poverty  Strategy  Team,  Department  for  Business,  Energy  and 
Industrial Strategy, UK 
197 Strategy to combat energy poverty, 2016-2019, Department of Communications, Energy & Natural Resources, 
Ireland 
198 ‘Saving at home II’ Programme (replacement of oil boilers with gas boilers to "low-income owners"), Croatia; 
‘Bonus sociale’ (discounted energy bills for low income families), Italy 
199 National Observatory for Energy Insecurity, France, www.onpe.org 
200 Capacity building for combating energy poverty, measure H.3 of the 4th NEEAP, Ministry for protection of the 
environmental and energy, Croatia, 2017, p.34 

135 

 
 
 
 
 
 
Lessons learned to inform 
integrated approaches for the 
renovation and modernisation 
of the built environment 

 Annex III: Good practice examples 

ENER/C3/2019-468/03 

Written by:  
Buildings Performance Institute Europe ASBL (BPIE), 
CLIMACT SA,  
Creara Consultores SL, and  
Ecologic Institute 

December 2020 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex III: Good practice examples 

CONTENTS 

1  CRITERIA TO CHOOSE GOOD PRACTICE EXAMPLES ............................................. 4 

2  GOOD PRACTICE EXAMPLES: CLEAN AND SUSTAINABLE MOBILITY ....................... 5 

2.1  Wallonia (Belgium) – Regional Mobility Strategy ............................................ 5 

2.2 

Portugal – Mobility and transport action plans for sustainable urban mobility .... 7 

2.3  Denmark – Local mandatory norms on bike parking ...................................... 9 

2.4  Germany - Low-interest loans for municipalities ...........................................11 

2.5 

Belgium – Establishment of multi-modal stations called “mobipôles” ...............13 

2.6  Germany – Information hub for promotion of cycling ....................................15 

3  GOOD PRACTICE EXAMPLES: DIGITAL TECHNOLOGY ..........................................17 

3.1 

France – Realise digital transformation of the PLANBIM 2022 .........................17 

Spain – Improving, standardising and strengthening data collection of the building 

3.2 
stock  19 

3.3  Denmark – Denmark energy agreement ......................................................21 

3.4  Germany – Digitalisation of the Energy Transition Act ...................................24 

4  GOOD PRACTICE EXAMPLES: FINANCING RENOVATION ......................................27 

4.1 

4.2 

Croatia – Methods to make energy renovation attractive ...............................27 

The Netherlands – Tenants’ right to initiate deep renovations ........................29 

4.3  USA – Property Assessed Clean Energy (PACE) ............................................30 

4.4  Germany – KfW Energy Efficiency Programme .............................................34 

4.5 

4.6 

France – the Denormandie law ...................................................................37 

Italy – Ecobonus / Superbonus ..................................................................41 

5  GOOD PRACTICE EXAMPLES: HEALTH AND WELLBEING ......................................45 

5.1 

5.2 

5.3 

5.4 

5.5 

5.6 

5.7 

Brussels (Belgium) - Regional Intervention Pollution Unit (CRIPI) ...................45 

California (US) - Healthy Housing Rewards (Fannie Mae) ...............................47 

California (US) - Green Building Ordinance, San Mateo .................................49 

Ireland – Warmth and wellbeing scheme .....................................................52 

Ireland - Home Performance Index (HPI) ....................................................55 

Poland – Clean Air Programme ...................................................................58 

Portugal – Energy Certification of Buildings and IAQ EPC ...............................61 

5.8  Denmark – National building regulations (BR18) ..........................................64 

5.9 

Sweden - Grant for radon remediation for homeowners ................................67 

5.10 

5.11 

5.12 

5.13 

Sweden - Obligatory ventilation control for housing ...................................69 

Umeå, Sweden – Grant for noise protection ..............................................71 

US/International – WELL Building Standard ..............................................73 

UK – BREAAM Certification scheme ..........................................................75 

6  GOOD PRACTICE EXAMPLES: DISTRICT APPROACHES ........................................77 

6.1 

6.2 

6.3 

The Netherlands – Natural Gas-Free Districts Programme ..............................77 

The Netherlands – Renovation Accelerator ...................................................80 

Belgium – Neighbourhood Grant .................................................................83 

 
Annex III: Good practice examples 

6.4 

European Union – MODER project ...............................................................86 

7  Good practice examples: engaging transformation ..............................................89 

7.1 
England  and  Wales  (UK)  –  Minimum  Energy  Efficiency  Standard  (MEES) 
regulations .......................................................................................................89 

7.2 

7.3 

7.4 

7.5 

Brussels (Belgium) – Mandatory minimum requirements linked to BRP ...........91 

Baden-Württemberg (Germany) – Support for serial renovation .....................93 

Lithuania – Renovation [modernisation] of multi-apartment buildings .............95 

Flanders (Belgium) – Digital building logbook ..............................................98 

7.6  Germany – Individual renovation roadmap for residential buildings (iSFP) ..... 101 

7.7  New York City (USA) – Building Emissions Law ........................................... 104 

7.8  Denmark – Better Home programme ........................................................ 107 

7.9 

Ireland - Better Energy Communities ........................................................ 109 

7.10 

7.11 

7.12 

7.13 

7.14 

7.15 

7.16 

France – Picardie Renovation Pass ......................................................... 112 

Romania – National Thermal Rehabilitation Programme ............................ 114 

Portugal – Energy Certification of Buildings ............................................. 116 

Poland – Catching Up Regions programme ............................................. 119 

Ireland - ProEnergyHomes .................................................................... 121 

Sweden – Carbon tax........................................................................... 123 

Scotland – Historic Environment climate action plan ................................ 125 

8  Good practice examples: built environment and adaptation to climate change ..... 127 

8.1 

Croatia – Croatian Building Act ................................................................. 127 

8.2  Denmark – Circle House Lab .................................................................... 130 

8.3 

The Netherlands – Transition Agenda Circular Construction Economy ............ 132 

8.4  United Kingdom – Aggregates Levy .......................................................... 134 

8.5  Germany – Circular Economy Act ............................................................. 138 

8.6 

8.7 

Spain – Demolition Waste National Plan for 2016-2022 ............................... 140 

Ireland – Building Regulation Part L (technical guidance)............................. 142 

8.8  Gräfelingen (Germany) – Support programme for rainwater utilisation .......... 144 

8.9  Norway – Technical building regulations .................................................... 145 

8.10 

8.11 

8.12 

8.13 

8.14 

8.15 

8.16 

Bavaria (Germany) – Support for rainwater use ...................................... 146 

Denmark – Climate Atlas ...................................................................... 147 

USA – Watersense programme ............................................................. 148 

Tyrol (Austria) – Climate-friendly construction ........................................ 149 

City of Portland (USA) – Green Building Policy ........................................ 150 

Germany – Green in the City ................................................................ 152 

The Netherlands – City Deal Climate Adaptation ...................................... 153 

3 

 
 
 
 
Annex III: Good practice examples 

1  CRITERIA TO CHOOSE GOOD PRACTICE EXAMPLES  

The  following  criteria  have  been  considered  to  choose  the  good  practice  examples 
presented in this document. Please note that a good practice examples do not necessarily 
have to fulfil all requirements. 

•  Adequacy in addressing key EU challenges of the strategic area: 

-  Fast carbon emission reduction 
-  Contribute to long-term targets 
-  Tailored to a challenge specific to the area 

•  Ease of implementation: 

-  Possibility to scale up the policy (e.g. increase scope, rate or depth of 

renovations) 

-  Replicability potential (How much depends on country-specific information? 
What is the degree of transferability across countries, regions, climate 
zones and building typologies?) 

-  Low transaction and administrative costs including costs for preparing the 

policy 

-  Possibility to implement it within existing regulatory framework 

• 

Innovative approach: 

-  A new mechanism to be used for a certain building segment/a certain 

objective 

-  Triggers innovation  
-  Boosts innovation  

4 

 
 
 
 
 
Annex III: Good practice examples 

2  GOOD PRACTICE EXAMPLES: CLEAN AND SUSTAINABLE MOBILITY 

2.1  Wallonia (Belgium) – Regional Mobility Strategy 

Policy/initiative 

Regional Mobility Strategy (Stratégie Régionale de Mobilité)  

Location 

Start year 

Status  

Belgium – Wallonia 

2019 

Ongoing 

Building types 

City level, district level 

Type of policy 

Strategy 

Short description 

Aiming at making transport  safer, more fluid and more  sustainable, 
Wallonia’s  mobility  strategy  sets  clear  overarching  targets  for 
emission reduction and modal shift (as well as security and reduction 
of gridlock). Based on this vision, it derives 10 strategic axes in three 
areas for orienting change, namely 1) mobility governance, 2) supply 
of  transport  options,  and  3)  demand  for  transport.  The  proposed 
action  areas  combine  short-term  and  longer-term  measures,  often 
including measure-specific indicators adequate to monitor progress in 
the specific area. Chapter 8 focuses on urban and regional planning, 
declaring priority for  centrality, density and diversity of activities so 
as to reduce the demand for transport and limit urban sprawl. Mobility 
issues  are  to  be  integrated  from  the  design  of  new  districts  or  new 
projects as well as in existing residential areas (e.g. pedestrian routes 
to public transport stops, pooling of parking and deliveries, space for 
public transport terminals or depots). As the next step, the strategy 
foresees  plans  at 
level  breaking  down 
implementation in concrete multi-year action programmes. 

local  and  regional 

Primary 
savings  

energy 

The strategy itself will not directly lead to primary energy savings, but 
it aims at triggering concrete measures which in total should reduce 
Wallonia’s transport emissions by 40% by 2030 (compared to 2005). 

CO2 emission savings 

See above. 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

The strategy does not contain a cost estimation. 

Not applicable. 

The  policy,  i.e.  the  process  of  developing  a  strategy  for  mobility  on 
regional  or  national  level,  appears  to  be  highly  transferrable.  While 
the priority areas and concrete measures have to be adapted to local 
circumstances,  the  overall  approach  of  developing  a  vision,  setting 
concrete  targets,  deriving  principles,  developing  action  plans  and 
building  an  adequate  multi-level  governance  structure  can  be 
replicated in other regions. 
The  strategy  covers  the  Belgian  region  of  Wallonia,  but  the 
governance structure provides for taking into account and influencing 
action at national and local level. 
Compliance: The strategy explicitly recognises that governing change 
in  the  transport  sector  is  the  biggest  challenge.  It  aims  at 
implementing  a  governance  structure  that  ensures  that  all  public 
decisions  in  the  transport  sector  contribute  to  achieving  the  Vision 
FAST  goals.  The  Wallonian  regional  administration  declares  itself  to 
be  responsible  for  coordinating  and  monitoring  compliance  with  the 
targets,  establishing  accountability  for  results.  A  monitoring  system 
based a set of indicators is planned (some are already included in the 

5 

 
 
Annex III: Good practice examples 

strategy, local communities are required to formulate additional ones, 
e.g. on the km of bike lanes they plan to erect). 
Interaction with other measures: Due to its nature as an overarching 
strategy,  the  measure  interrelates  with  many  other  measures,  both 
strategies in a range of other policy areas and on other governance 
levels and concrete actions on the ground. The measure has a guiding 
character and therefore appears to be complementary.  

The strategy contributes to and explicitly relates to Belgium’s target 
under the EU Effort Sharing Regulation. Under the regulation, Belgium 
has to achieve a reduction in non-ETS GHG emissions of 35% by 2030 
compared to 2005.  

The measure predominantly aims for an upgrade of urban context by 
strengthening  sustainable  transport  infrastructure.  The  other  aim  is 
to improve quality of life in urban and village centres to reduce the 
need for mobility as well as urban sprawl.  
It  specifically  aims 
strengthening active transport modes, i.e. walking and cycling. 
In a section on tariffs for mobility service, the strategy aims to address 
higher  costs  that  can  result  from  a  mobility  transition  for  rural 
households and aims to adjust tariffs for shared mobility so as to make 
them accessible for low-income households to ensure a fair transition. 

improve  public  health 

to  also 

through 

Since the strategy is relatively recent, it cannot be evaluated yet how 
successful it will be.  
However,  key  strengths  appear  to  be:  the  strategic  approach  to 
transformation,  i.e.  a  process  building  on  a  concrete  vision;  clear 
overarching  and  issue-specific  targets;  comprehensive  strategic 
principles; new governance structures, including measures to initiate 
and monitor implementation on the ground.  
The  key  challenges  of  implementation  include  the  need  for 
cooperation from other governance levels. Successful implementation 
will  only  be  possible  if  the  national  level,  neighbouring  regions  and 
local communities are as committed to implementation as the regional 
administration  is.  For  example  the  strategy  aims  to  improve  train 
traffic  which  will  require  coordination  beyond  the  region.  Moreover, 
the strategy proposes a new tariff approach building on the principle 
of mobility as a service. The vision is to provide every inhabitant with 
a  mobility  pass  that  allows  access  to  all  forms  of  shared  mobility. 
Again,  this  endeavour  will  only  be  possible  if  the  region  can  ensure 
cooperation  with  other  actors,  including  local  communities,  other 
regions, the national government and transport operators.  

The mobility strategy is explicitly linked to the digitisation agenda as 
well as to economic, energy, climate policy and public health agendas. 
In addition to contributing to Belgium’s climate targets, the strategy 
is expected to lead to better air quality, and to higher economic output 
(through more fluid transport) 

•  Wallonie (2017). Vision FAST, Vision de la mobilité wallonne à 

2030. 

•  SPW Mobilité et Infrastructures (2019). Stratégie Régionale de 

Mobilité, Volet I – Mobilité des personnes.  

6 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve health 
and wellbeing 

•  Increased 

sustainable infra-
structure in built 
environment  
•  Increase smart 
readiness of 
buildingss 
•  Secure fair 
transition 

•  Upgrade of urban 

context  

Lessons learned 

Synergies 

Bibliography 

 
 
 
Annex III: Good practice examples 

2.2  Portugal – Mobility and transport action plans for sustainable urban mobility 

Policy/initiative 

Mobility and transport plans and action plans for  sustainable 
urban mobility (as element of measure bundle called ‘decarbonising 
cities’ – descarbonizar as cidades) 

Location 

Start year 

Status  

Portugal 

2020 

Planned 

Building types 

City, district-level 

Type of policy 

Strategy 

Short description 

The  measures  included  in  Portugal’s  NECP  aim  to  put  cities  at  the 
forefront of sustainable mobility by creating conditions for a paradigm 
shift in urban mobility. It encompasses a number of action items:  

•  Develop and implement mobility and transport plans (PMT) or 
action plans for sustainable urban mobility (PAMUS) by cities 
and municipalities with more than 50,000 inhabitants or that 
are district capitals. 

•  Promote demand management (passengers and goods) and 
urban planning in order to reduce the volume of travel 
(traffic) and the distance of travel.  

•  Adopt tools to support management of mobility and 

information systems and technologies for IT-based mobility 
management. 

•  Promote urban design that favours pedestrians over cars.  
•  Promote greater inter-municipal cooperation, e.g. through 

densification, by offering essential services in all 
neighbourhoods. 

Primary 
savings  

energy 

Since the strategy is only starting, no information on primary energy 
savings is available. 

CO2 emission savings 

Since  the  strategy  is  only  starting,  no  information  on  CO2  emission 
reductions is available. 

Costs 

According to Portugal’s  NECP,  costs  of the  measures have not been 
estimated. 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Not applicable. 

Transferability:  The  core  of  the  approach  –  demanding  cities  and 
larger  towns  draw  up  sustainable  mobility  plans  based  on  certain 
principles  –  appears  transferrable  to  other  countries.  Transferability 
will of course depend on the constitutional relationships between the 
national,  regional  and  local  level  which  may  impede  the  national 
government’s options to make such municipal plans mandatory.  
Governance: The measure is initiated at national level, but requires 
action at local level. 
Compliance:  The  NECP  does  not  include  information  on  compliance 
mechanisms. 
Relation to other policies: In addition to addressing GHG emissions, 
the measure aims at improving air quality. 

The  policy  contributes  to  achieving  Portugal’s  target  under  the  EU 
Effort  Sharing  Regulation,  stipulating  that  the  country  must  reduce 
emissions in sectors that are not covered by the EU ETS by 17% by 
2030 compared to 2005. 

7 

 
 
Annex III: Good practice examples 

The measure’s focus is to achieve an upgrade of urban infrastructure, 
in particular transport infrastructure, but it is linked to a wider range 
of decarbonisation measures in cities. These include promoting green 
spaces and urban farming to improve microclimatic outcomes in cities 
to  improve  wellbeing  and  resilience  against  climate  change.  In  the 
same  bundle,  the  NECP  includes  a  measure  to  improve  energy 
efficiency of infrastructure (e.g. lightening, water infrastructure). 

Address 

• 

•  Energy poverty 
Improve health 
• 
and wellbeing 
Increased 
sustainable 
infra-structure 
in built 
environment  
Increase smart 
readiness of 
buildings 
•  Secure fair 

• 

transition 

•  Upgrade of 

urban context  

Lessons learned 

Synergies 

Bibliography 

Success factors: All local municipalities, not completely clear if plans 
are  mandatory  and  how  compliance  will  be  checked.  Needs  more 
detail. 
Challenges: Lacks clear targets. 

The measures have synergies with efforts to improve digitalisation. 

Government of Portugal (2019): Plano Nacional Energia e clima 2021-
2030 (PNEC 2030), p.58f. 

8 

 
 
 
 
 
Annex III: Good practice examples 

2.3  Denmark – Local mandatory norms on bike parking 

Policy/initiative 

Local mandatory norms on bike parking 

Location 

Start year 

Status  

Denmark, municipal level 

Diverse 

Ongoing 

Building types 

Residential multi-family buildings, commercial and public buildings. 

Type of policy 

Regulation 

Short description 

An increasing number of municipalities in Denmark have implemented 
regulation that makes it mandatory to install bike parking spots when 
a  new  building  is  constructed.  The  regulation  forces  developers  to 
foresee facilities for bike parking in the planning for each project and 
include  the  costs  for  it  when  drawing  up  the  budget  for  the 
construction. In most cases, the regulation covers different types of 
buildings and differentiates the number of minimum parking spots per 
building type. Building categories include offices or other workplaces, 
educational  institutions,  public  traffic  terminals,  shopping  centres, 
multi-family residential buildings, cultural and sports establishments, 
and  squares  and  shopping  streets.  In  addition  to  quantitative 
standards  (how  many  bike  parking  spots)  norms  also  include 
qualitative criteria, specifying e.g. how many parking spots should be 
covered by a roof as well as specifications on accessibility or distance 
to entrance. 

For the city of Copenhagen, the regulation established in 2015 set the 
following minimum standards: residential buildings, student housing, 
working  places  and  shops  need  four  bike  spots  per  100  m2  surface 
area,  senior  homes  need  1.5  spots  per  100  m2,  and  educational 
institutions need 0.5 spots per student and staff. 

The  norm  serves  as  a  minimum  threshold.  The  final  number  and 
design of bicycle parking facilities needs approval from municipal staff 
familiar with the impact of cycling on urban space and transport flows 
as well as the qualitative factors like accessibility.  

Primary 
savings  

energy 

A quantification of energy savings is not possible since bike parking 
spaces are only one factor in each individual transport decision – albeit 
an important one. 

CO2 emission savings 

See above. 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Not applicable. 

Transferability:  The  policy  is  highly  transferrable.  It  is  important, 
however,  that  the  policy  is  integrated  into  a  bundle  of  measures  to 
promote  bike  riding,  because  parking  spots  alone  will  not  lead  to 
increased  bike  traffic  if  e.g.  safe  bike  lanes  do  not  exist.  Moreover, 
the  policy  requires  trained  staff  at  the  municipal  level  to  inform 
developers and ensure enforcement.  
Administration:  The  policy  is  administered  at  the  local  level,  but 
several  national  institutions  support  municipalities  e.g.  with  best 
practice guides. 
Compliance: Compliance checks are included in standard construction 
oversight  through  municipal  institutions  and  processes  (building 
licence).  

9 

 
 
 
Annex III: Good practice examples 

Complementary  measures:  In  Denmark,  the  measure  is  successful 
through a combination with other investments in bike traffic, in safe 
and convenient bike lanes. 

Matching  EU  policy 
framework 

The measure contributes to fulfilling Denmark’s obligations under the 
EU Effort Sharing Regulation to reduce GHG emissions outside the EU 
Emissions Trading Scheme by 39% compared to 2005.  

The  measures  primarily  aim  at  upgrading  the  urban  context  by 
establishing  the  infrastructure  for  cycling  as  a  key  sustainable 
transport  option.  At  the  same  time,  the  measures  contribute  to 
addressing  air  pollution  (by  replacing  the  need  for  car-based 
transport), public health (by promoting an active form of transport) 
and improved quality of life (fewer accidents, less noise, more efficient 
use of scarce public space).  

Address 

• 

•  Energy poverty 
Improve health 
• 
and wellbeing 
Increased 
sustainable 
infra-structure 
in built 
environment  
Increase smart 
readiness of 
buildings 
•  Secure fair 

• 

transition 

•  Upgrade of 

urban context  

Lessons learned 

Synergies 

Success  factor:  The  mandatory  norm  makes  sure  bicycle  parking 
becomes  an  integral  part  of  building  planning  from  the  start. 
Integrating it in the planning process also reduces costs compared to 
add-on solutions to existing buildings. 
Challenges of implementation: Implementation requires trained staff 
in the relevant administration overseeing building licensing. Moreover, 
the  measure  will  only  be  successful  in  increasing  the  share  of  trips 
made by bike if combined with public investments in safe bike lanes. 
For  cities  with  a  low  numbers  of  bike  lanes,  the  start  might  be 
relatively challenging.  

The policy has a synergy with the built  environment strategic area: 
by  shifting  to  a  mode  of  mobility  that  uses  public  space  devoted  to 
transport  more  efficiently  than  car-based  traffic,  the  measure  can 
liberate public space for other uses, e.g. parks or other blue or green 
spaces. 

Bibliography 

Cycling Embassy of Denmark (2019): Bicycle parking.  

Cykelparkering  i  nybyggeri  –  Best  practice  og  Københavnske 
erfaringer, Gehl for Københavns Kommune (2017).  

Cyklister  er  guld  værd  for  byerne”,  Celis,  Pablo  &  Nielsen,  Malene 
Kofod, Trafik & veje, (Juni/juli 2016)  

Undersøgelse af cykelparkering / Vaner og adfærd ved cykelparkering 
i byen”, Rambøll for Københavns Kommune (2015).  

”Idékatalog  for  cykeltrafik”,  Cycling  Embassy  of  Denmark  (2012). 
”Bedre  samspil  mellem  cyklen  og  den  kollektive  trafik,  Idekatalog”, 
Trafikstyrelsen (2009).  

10 

 
 
 
 
 
 
Annex III: Good practice examples 

2.4  Germany - Low-interest loans for municipalities 

Policy/initiative 

Low-interest  loans  for  municipalities  (“Investitionskredit  Kommunen 
208”)  

Location 

Start year 

Status  

Building types 

Germany, national level supporting the municipal level 

2012 

Ongoing 

City level 

Type of policy 

Public loans 

Short description 

Germany’s public development Kreditanstalt für Wiederaufbau (KfW) 
offers  low-interest  loans  of  up  to  €150  million  per  year  to  German 
municipalities who invest in their municipal infrastructure. Loans can 
be used to invest in schools and kindergardens, broadband internet 
access,  water,  sewage  or  tourist  infrastructure  and  for  redesigning 
traffic infrastructure.  

Not available. 

energy 

Primary 
savings  
CO2 emission savings  Not available. 
Not available. 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Not applicable. 

Transferability:  Whether  the  measure  can  be  replicated  elsewhere 
depends  on  the  constitutional  arrangements  governing  financial 
relationships  between  the  national,  regional  and  local  levels  of 
government  and  it  may  depend  on  availability  of  funds  at  national 
level. KfW enjoys positive ratings which allow it to borrow at negative 
rates  in  global  capital  markets.  This  is  not  the  case  for  all  Member 
States. This underlines the importance of EU lending institutions like 
the  European  Investment  Bank  and  the  importance  of  inter-EU 
solidarity. 
Administration:  The  measure  is  administered  at  national  level,  but 
demand  comes  from  the  municipal  level  where  the  investment 
planning and implementation takes place.  
Compliance check: Municipalities need to provide planning documents 
for  receiving  the  loan  and  need  to  present  documentation  of  their 
spending several months after pay-out. 
Complementary  measures:  The  measure  is  one  element  of  a 
comprehensive  bundle  of  national-level  measures  supporting  local 
municipalities in becoming more sustainable. It includes other grant 
and  loan  programmes  by  KfW,  e.g.  grant  for  model  projects  Smart 
city  and  loans  for  building  efficiency  improvements.  Another  key 
programme 
(‘Nationale 
Klimaschutzinitiative  –  NKI’),  the  programme  using  Germany’s 
receipts  from  auctioning  EU  ETS  certificates  to  foster  low-carbon 
investments.  As  part  of  the  initiative,  the  German  government 
finances the development of local climate change mitigation strategies 
and  provides  resources  for  the  employment  of  ‘climate  change 
managers’ in municipal administrations. In addition, it funds a number 
of  programmes  and  projects  enabling  best  practice  exchange,  e.g. 
provided  by  the  Deutsche  Institut  für  Urbanistik  (see  as  a  recent 
example  a  best  practice  guideline  publication  commissioned  by 
Umweltbundesamt  2020).  Moreover,  as  regulatory  measure  the 
federal government has adopted a number of changes in traffic rules 

the  National  Climate 

Initiative 

is 

11 

 
 
 
Annex III: Good practice examples 

that  protect  cyclists  and  walkers  and  enable  municipalities  to  take 
additional action where needed. 

Matching  EU  policy 
framework 

The measure contributes to Germany’s efforts for reaching its national 
GHG emission reduction target under the EU Effort Sharing Regulation 
(-38% by 2030 compared to 2005). 

Address 

•  Energy poverty 
•  Improve health 
and wellbeing 

•  Increased 

sustainable infra-
structure in built 
environment  
•  Increase smart 
readiness of 
buildings 
•  Secure fair 
transition 

•  Upgrade of urban 

context  

Lessons learned 

Synergies 

Bibliography 

The measure predominantly aims at increasing investments in urban 
infrastructure. It has no particular focus on sustainability, but it can 
be used for sustainable urban transformations.  

Strengths:  The  measure  addresses  a  key  challenge  for  urban 
transformation: the lack of investment capital in municipalities which 
hampers infrastructure renewal.  
Challenges:  For  indebted  municipalities,  loans  –  even  from  public 
banks – increase debt levels and may reduce financial wriggle room 
in  the  future.  Due  to  lower  tax  revenues  during  the  covid-19 
pandemic, this problem is poised to exacerbate in the near future. As 
described  in  its  national  energy  and  climate  plan,  the  federal 
government is increasingly forseeing grants to support municipalites 
in  building  infrastructure  for  increased  walking  and  cycling  (Federal 
Ministry for Economic Affairs and Energy, p. 95f.)  

The measure (and related KfW loan programmes) can also be used to 
support district approaches. 

IKK  – 

(2020): 

Investitionskredit  Kommunen,  Website 

KfW 
Kreditanstalt für Wiederaufbau. 
Federal Ministry for Economic Affairs and Energy (2020): Integrierter 
nationaler Energie- und Klimaplan. 
Umweltbundesamt 
Verkehrsbelastungen reduzieren und Flächen gewinnen, Leitfaden. 

Quartiersmobilität 

gestalten. 

(2020): 

12 

 
 
 
 
 
 
Annex III: Good practice examples 

2.5  Belgium – Establishment of multi-modal stations called “mobipôles” 

Policy/initiative 

Establishment of multi-modal stations called “mobipôles” 

Location 

Start year 

Status  

Building types 

Belgium, regional government of Wallonia 

2018 

Ongoing 

City-level 

Type of policy 

Infrastructure investment 

Short description 

The "mobipôles" will offer various services and allow modal exchange 
for  people,  with  car  parks,  in  particular  carpooling,  secure  bicycle 
shelters, bus, tram  and new rapid bus lines perfectly  connected  co-
working spaces, shared bicycles and cars, charging stations, etc. The 
infrastructure hub can take different forms depending on local needs. 
They can be located close to existing hubs like train stations or park-
and-ride  stations  or  can  be  created  from  scratch  in  city  or  village 
centres. 

Mobipôles  aim to promote  “smart mobility”, that is to say a system 
that includes both sustainable, efficient and innovative solutions and 
mobility behaviours. The Wallonian regional transport  strategy aims 
to  implement  a  minimum  of  one  mobipôle  per  local  community  by 
2030. 

In 2019, the regional government of Wallonia has commissioned the 
construction of five pilot mobipôles which will cost €7.5 million.   

Not available  

energy 

Primary 
savings  
CO2 emission savings  Not available  
Not available 

Costs 

Not applicable 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve health 
and wellbeing 

•  Increased 

sustainable infra-
structure in built 
environment 
(including 
enhanced 
resilience of 
building) 

•  Increase smart 
readiness of 
buildings 
•  Secure fair 
transition 

13 

 
 
 
 
 
Annex III: Good practice examples 

•  Upgrade of urban 
context (including 
access to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

The policy  has a synergy with the built  environment strategic area: 
by  shifting  mobility  to  a  mode  that  uses  public  space  devoted  to 
transport  more  efficiently  than  car-based  traffic,  the  measure  can 
liberate public space for other uses, e.g. parks or other blue or green 
spaces. 

SPW  Mobilité  et  Infrastructures  (2019).  Stratégie  Régionale  de 
Mobilité, Volet I – Mobilité des personnes. 
Belgium  government  (2019):  Belgischge 
Energie-enKlimaatplan2021-2030. 
Wallonie (2019): 5 mobipôles pilotes en Wallonie, 09.01.2019. 

ïntegreerd  Nationaal 

14 

 
 
 
 
 
 
Annex III: Good practice examples 

2.6  Germany – Information hub for promotion of cycling 

Policy/initiative 

Information  hub  for  promotion  of  cycling  (Informationsportal  zur 
Radverkehrsförderung)  

Location 

Start year 

Germany, regional government of Baden-Württemberg 

Upgraded to central information hub in the cycling strategy, published 
in 2016 

Status  

Building types 

Ongoing 

City-level 

Type of policy 

Capacity building tool 

Short description 

The regional government of Baden-Württemberg funds an information 
hub on all matters relating to cycling. It provides local authorities in 
the region with up-to-date information covering the following areas: 
legal  provisions,  financing,  guidebooks,  best  practice  examples, 
statistics and ideas for communication strategies. 

implementation  of  the  regional 
The  tool  contributes  to  the 
government’s  cycling  strategy 
for  Transport  and 
Infrastructure  Baden-Württemberg,  2016).  It  aims  to  increase  the 
share of cycling in all trips to 16% by 2020 (up from 8% in 2008) and 
to 20% by 2030. 

(Ministry 

Primary 
savings  

energy 

Not  available.  The  guidebook  is  only  one  element  in  promoting 
infrastructure change that can enable a modal shift in cities. 

CO2 emission savings  Not  available.  The  guidebook  is  only  one  element  in  promoting 

infrastructure change that can enable a modal shift in cities. 

Not applicable 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve health 
and wellbeing 

•  Increased 

sustainable infra-
structure in built 
environment 
(including 
enhanced 
resilience of 
building) 

•  Increase smart 
readiness of 
buildings 
•  Secure fair 
transition 

•  Upgrade of urban 

context 

15 

 
 
 
 
 
 
 
Annex III: Good practice examples 

(including access 
to sustainable 
mobility) 

Lessons learned 

Synergies 

The policy has a synergy with the built  environment strategic area: 
by  shifting  mobility  to  a  mode  that  uses  public  space  devoted  to 
transport  more  efficiently  than  car-based  traffic,  the  measure  can 
liberate public space for other uses, e.g. parks or other blue or green 
spaces. 

Bibliography 

Ministry for Transport and Infrastructure Baden-Württemberg (2020): 
Informationsportal zur Radverkehrsförderung. 

Ministry for Transport and Infrastructure Baden-Württemberg (2016): 
Radstrategie Baden-Württemberg. 

16 

 
 
 
 
 
 
 
Annex III: Good practice examples 

3  GOOD PRACTICE EXAMPLES: DIGITAL TECHNOLOGY  

The  following  pages  provide  examples  of  good  practice  policies  in  the  strategic  area  of 
digital technology.  

3.1  France – Realise digital transformation of the PLANBIM 2022 

Policy/initiative 

Concrétiser la transformation numérique du bâtiment PLANBIM 2022 

Realise the digital transformation of the PLANBIM 2022 building (BIM 
= building information modelling) 

Location 

Start year 

Status  

French territories 

2018 

Ongoing 

Building types 

Two tracks: new buildings and renovation 

Type of policy 

Short description 

Primary 
savings  

energy 

CO2 emission savings 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Capacity  building,  providing  methods  and  tools,  sharing  of  best 
practices, accompanying local actors in the buildings value chain, with 
a clear focus on SMEs 

The  aim  of  the  "BIM  2022"  plan  is  to  provide  professionals  with 
concrete methods and tools to massively digitalise uses around two 
priority areas: 1) facilitating and guaranteeing the proper use of BIM 
and  optimising  the  interactions  between  the  different  businesses 
through  fine-tuning  contracts  and  definition  of  standard  clauses  for 
the use of BIM   2) equip actors with the tools they need to work in 
BIM through training, the provision of adapted collaborative tools and 
dissemination in the territories. 

The French initative is inspired by the UK BIM initiative. 

• 

Impact is expected to vary across the projects; benefits are 
expected in terms of time, cost and quality, improvements in 
the way of working and assets produced  

•  No information available yet on the results nor on the targets 

• 

of BIM 2022 
Impact is expected to vary across the projects; benefits are 
expected in terms of time, cost and quality, improvements in 
the way of working and assets produced  

•  No information available yet on the results nor on the targets 

• 

of BIM 2022 
Impact is expected to vary across the projects; benefits are 
expected in terms of time, cost and quality, improvements in 
the way of working and assets produced  

•  No information available yet on the results nor on the targets 

of BIM 2022 

•  The BIM initiative has been fine-tuned in order to better meet 

the needs of French SMEs 
Impact is expected to vary across the initiatives 

• 
•  No information available yet on the results nor on the targets 

of BIM 2022 

•  The French BIM takes inspiration from the UK  
•  As a process, BIM can be transferred to other countries and 
regions in the EU; however, it needs local adaptation to 
different regions 

•  Other countries could develop similar initiatives 1) with a 
clear objective, 2) where implementation is mainly the 
responsibility of the local level, and 3) where the national 
level provides support through capacity building and 

17 

 
 
Annex III: Good practice examples 

structured exchange of best practices and showcases. The UK 
has already been working on BIM since 2011. 

It can be expected that overall, the programme and its objectives will 
contribute  to  increased  renovation  rate  and  speed,  reduced  costs, 
increased energy efficiency, and more use of renewables. This in turn 
could be linked to the:  

•  Renovation Wave initiative  
•  Energy Efficiency Directive 
•  Renewable Energy Directive 
•  Energy Performance of Buildings Directive 
•  Effort Sharing Regulation 
•  Reducing energy poverty is not seen as one clear objective 

• 

and will depend on the projects selected  
It is expected that the programme will have positive 
environmental benefits 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve health and 

wellbeing 
•  Increased 

infra-
in  built 

sustainable 
structure 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

•  Secure 

transition 

of 

smart 
of 

fair 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

•  Strengths 

-  BIM helps people understand the added value of digital 
technology and of working in collaborative platforms 
-  People are increasingly working in a consistent manner, 

following a standard 

-  Good information management increases productivity and 

reduces the likelihood of problems on projects. This 
reduces time delays, cost overruns and disputes. 

•  Weaknesses 

-  Adoption rate is still low 
-  Lack of manufacturers to provide the digital objects 

•  Opportunities 

-  An increasing proportion of the workforce are now digital 

natives 

-  Further develop the tools 
-  Market the sucesses 

•  Threats 

-  BIM is not understood nor accessible for SMEs 
-  Reluctance from the sector to embark (attitude) 
-  Lack of sharing the benefits to the client 

https://plan-bim-2022.fr 
https://www.thenbs.com/knowledge/10-things-weve-learnt-from-
the-2020-bim-survey 

18 

 
 
 
Annex III: Good practice examples 

3.2  Spain – Improving, standardising and strengthening data collection of the 

building stock 

Policy/initiative 

Improving, standardising and strengthening data collection about the 
building stock in Navarra 

Location 

Start year 

Status  

Spain (Navarra) 

2014 

Ongoing 

Building types 

Public and private 

Type of policy 

• 

Improving, standardising and strengthening data collection 
about the building stock 

•  Focusing on the measurements and control of energy 

expenditure in local entities 

•  Developing energy service contracting 

Short description 

The Navarra 2030 energy plan: 

•  Encourages the hiring of energy service companies in sectors 

Primary 
savings  

energy 

CO2 emission savings 

• 

with the greatest potential (both public and private) 
•  Develops procurement procedures and contract models 
•  Sets up a support framework for possible financing 
• 

Impact varies across the projects. Projects mainly in the 
health sector (one clinic, one hospital) and the administration 
(public council) 
Impact varies across the projects. Projects mainly in the 
health sector (one clinic, one hospital) and the administration 
(public council) 

Range between €200k and €500k yearly savings  

•  ESCO contracting facilitates renovation in the identified cases 
• 

IPMVP as a facilitating factor 

•  Medium  

•  The programme and its objectives will contribute to increased 
renovation rate and speed, reduced costs, increased energy 
efficiency, and more use of renewables. This in turn could be 
linked to the:  

-  Renovation Wave initiative  
-  Energy Efficiency Directive 
-  Renewable Energy Directive 
-  Energy Performance of Buildings Directive 
-  Effort Sharing Regulation 

•  Reducing energy poverty is not seen as a clear objective and 

• 

will depend on the projects selected 
It is expected that the programme will have positive 
environmental benefits 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve health 
and wellbeing 

•  Increased 

sustainable infra-
structure in built 
environment 
(including 
enhanced 
resilience of 
building) 

•  Increase smart 
readiness of 
buildings 

19 

 
 
•  Secure fair 
transition 

•  Upgrade of urban 
context (including 
access to 
sustainable 
mobility) 

Lessons learned 

Annex III: Good practice examples 

•  Strengths 

- 

Improves the centralised energy data management 
(development of the ICEGONA software) 

-  Concrete projects realised  
-  Development of energy services contracting that 

coordinates the different actors 

-  Use of the IPMVP standard 

•  Weaknesses 
-  Scale 
-  Access to financing 
-  Lack of formation 

•  Opportunities 
•  Threats 

-  Administrative burden 

Synergies 

Bibliography 

https://www.navarra.es/NR/rdonlyres/ED666B3E-1CFA-4027-BCBA-
B075B2183C6E/306536/PEN2020.pdf   
https://www.navarra.es/NR/rdonlyres/39C6C3D7-0FC3-4AA2-993E-
53D4C7DE6BE7/386924/ICEGONA_InformeFaseI.pdf  

20 

 
 
 
 
 
Annex III: Good practice examples 

3.3  Denmark – Denmark energy agreement 

Policy/initiative 

“Denmark  energy  agreement”  with  a  focus  on  renewable  energy, 
energy efficiency improvements, research and energy regulation 

Location 

Start year 

Status  

Building types 

Type of policy 

Short description 

Denmark national/regional/municipal level 

Agreement in June 2018 

Ongoing 

Grant,  capacity,  multi-sector  multi-year  policy  and  investment 
framework toward 2020 and 2050 

The government has decided an “energy agreement” to further build 
Denmark’s  international  positions  of  strength  with  a  focus  on 
renewable  energy,  energy  efficiency  improvements,  research  and 
energy regulation. This agreement is very comprehensive and touches 
on a lot of issues, including "a smart and flexible energy system" in 
order  to  support  an  integrated,  market-based  and  flexible  energy 
system, with efficient energy utilisation across the electricity, heating 
and  gas  sectors,  and  with  a  continued  strong  security  of  supply. 
Initiatives  in  focus  include  the  testing  of  regulatory  free  zones  and 
improved  use  of  data  and  digitisation  in  the  utility  sectors.  Cross-
energy flexibility is particularly important and such initiatives must be 
replicated.  

Key elements of the agreement include a commitment to build three 
new  large  offshore  wind  farms,  new  funding  for  onshore  wind  and 
solar  power,  a  targeted  effort  to  achieve  energy  savings  and  a 
targeted strengthening of energy and climate research. 

Primary 
savings  

energy 

The energy agreement includes the following initiatives: 

•  By 2030, three offshore wind farms will be created for a total 

CO2 emission savings 

Costs 

of 2400 MW.  

•  The agreement will enable renewable energy to fully cover 

Denmark’s electricity consumption by 2030. 

•  Modernisation of the heating sector, resulting in green and 

cheap heating for businesses and consumers. 

•  Funds are allocated to manage the abolition of the “basic 

financial contribution” and to improve the use of surplus heat 
and the export of energy technologies. 

•  Phasing out coal in Danish electricity generation by 2030. 
•  With this agreement, Denmark is on track to fulfil the 

government’s objective of transforming Denmark to a low-
carbon society that is independent of fossil fuels by 2050. 

•  The measures combined are estimated to reduce carbon 

dioxide emissions by 34% by 2020. 

•  € 564 million is allocated to a tendering process, where 
different technologies can compete to provide green 
electricity at the lowest price. 

•  More than €537 million is allocated to develop green biogas 

production. A share is reserved for organic biogas. 

•  From 2021 to 2024, €67 million will be allocated annually to a 

market-oriented and energy-saving subsidy pool, €40 million 
for industries and €27 million for energy savings in buildings. 

•  A reserve of €54 million in 2025, and then €67 million per 

year thereafter, will be allocated to further increase the use 
of renewable energy after 2026. 
Immediate easing of taxes on electricity and electric heating, 
amounting to around €268 million in 2025 (excluding VAT). 

• 

21 

 
 
 
Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve health 
and wellbeing 

•  Increased 

sustainable infra-
structure in built 
environment 
(including 
enhanced 
resilience of 
building) 

•  Increase smart 
readiness of 
buildings 
•  Secure fair 
transition 

•  Upgrade of urban 
context (including 
access to 
sustainable 
mobility) 

Annex III: Good practice examples 

•  €67 million is allocated to green transport in 2020-2024 to 

strengthen mobility and green transport. 

•  Energy and climate research will receive an injection of funds 

with a target of €134 million per year by 2024. 

Energy-efficiency measures: with the agreement initiatives, in 2020 
Denmark  will  have  reduced  its  final  energy  consumption  (excluding 
consumption  for  transport)  by  almost  8%  compared  to  2010.  The 
agreement contains the following elements: 

•  Energy companies must realise specific energy savings 

exceeding today’s requirements, e.g. by consulting energy 
experts and by offering subsidies to e.g. households and 
businesses 

•  Energy companies must increase efforts by 75% from 2013 

to 2014, and by 100% from 2015 to 2020 compared to 2010-
12 

•  A comprehensive strategy for energy renovation of all Danish 

buildings will be developed. 

Green heating measures: 

•  Converting from coal to biomass at large-scale power plants 

will be made more attractive by amending the Heating Supply 
Act 

•  Smaller open-field plants that are struggling in the wake of 

high heating prices will be allowed to produce cheap heating 
based on biomass 

•  DKK 35 million will be committed to promoting new 

renewable technologies, e.g. geothermal energy and large 
heat pumps. 

Renewable energy in buildings: the agreement supports the phasing-
out of oil-fired boilers in existing buildings by: 

•  Banning installation of oil-fired boilers and natural gas boilers 

in new buildings from 2013 

•  Banning installation of new oil-fired boilers in existing buildings 
in areas where district heating or natural gas is available from 
2016 

•  Committing DKK 42 million in 2012-15 to fund the conversion 
from  oil-fired  boilers  and  natural  gas  boilers  in  existing 
buildings to renewable energy. 

Renewable energy in industry: industry must also convert to a greener 
energy system, so the agreement lays down that: 

•  A subsidy should be given to help promote investment in 

efficient use of renewable energy in the production processes 
of enterprises. In the period 2014 to 2020, the subsidy will 
be increased to DKK 500 million a year from DKK 250 million 
in 2013. 

•  Funding of DKK 30 million per year from 2013 to 2020 will be 
introduced to maintain and promote industrial combined heat 
and power (CHP) in industries and greenhouses. 

Lessons learned 

22 

 
 
 
 
 
 
Annex III: Good practice examples 

Synergies 

Bibliography 

foreign  affairs 

Description  by  the  ministry  of 
https://investindk.com/insights/new-ambitious-danish-energy-
agreement  
The 
https://ens.dk/sites/ens.dk/files/Globalcooperation/the_danish_ener
gy_model.pdf 
IEA  Danish  Energy  Agreement  https://www.iea.org/policies/606-
danish-energy-agreement-for-2012-2020 

energy 

Danish 

investors 

model 

for 

23 

 
 
 
 
 
 
Annex III: Good practice examples 

3.4  Germany – Digitalisation of the Energy Transition Act 

Policy/initiative 

Location 

Start year 

Status  

Building types 

Type of policy 

Short description 

Optimise  energy  use  through  automation  and  self-regulation  - 
Digitisation  of  the  Energy  Transition  Act  (‘Gesetz  fur  digitalisierung 
der EnergieWende’) 

Germany national/regional/municipal level 

2016 

ongoing 

Smart meters will become mandatory, implementation will take place 
in stages 

The basis for the roll-out is a market declaration by the Federal Office 
for Information Security (BSI). A large-scale roll-out is expected from 
2020. 

•  Customers with a consumption of over 10,000 kWh per year 

should be converted from 2017 

•  Customers with a consumption of less than 10,000 kWh will 

be converted from 2020 

•  An intelligent electricity meter is optional for households with 

a consumption of less than 6,000 kWh - however, a modern 
meter must be  installed 

This  policy  in  Germany  also  supports  optimal  energy  use  through 
automation and self-regulation. The aim of the federal funding for the 
pilot  programme  for  energy-saving  meters  is  to  make  the  trend 
towards  digitalisation  also  useful  for  energy  efficiency.  To  this  end, 
companies that help their end customers to save electricity, oil, gas, 
biomass, heating, cooling or primary energy by means of innovative 
digital solutions will receive funding of up to €2 million. The aim is to 
test various technologies with different user groups and bring them to 
market maturity. 

With the law on the digitisation of the energy transition, the federal 
government laid the foundation for intelligent electricity meters. The 
core element is the Metering Point Operation Act. This law regulates 
how and when the previous analogue electricity meters are replaced 
by intelligent measuring systems or modern measuring devices. 

Primary 
savings  

energy 

Germany has set itself ambitious goals with the energy transition. The 
goals in numbers: 

•  Share of renewable energies in electricity consumption by 

2025: 40-45% 

•  Shutdown of the last nuclear power plants by 2022  
•  40% less greenhouse gas emissions by 2020 (compared to 

1990) 

•  50% less primary energy consumption by 2050 (compared to 

2008) 

In  order  to  achieve  the  goals,  electricity  from  wind  and  sun  is 
particularly important but is not based on the demand for power. The 
greater  the  proportion  of  electricity  from  renewable  sources,  the 
greater the challenge of balancing the production and consumption of 
electricity.  This  is  where  the  new  digital  electricity  meters  systems 
and modern measuring devices help. 

CO2 emission savings 

24 

 
 
 
 
 
Annex III: Good practice examples 

Overall investment: Approx. €10-20 bn. 

•  Increase smart readiness of buildings: Smart meters 

support the energy transition, digitisation and controllability 
within the power grid. 

•  Energy poverty: The intelligent electricity meters enable the 
possibility of creating variable electricity tariffs or the cost 
savings that result from the fact that intelligent measuring 
systems do not have to be read on-site. 

•  Fair transition  
•  Consumer advantages: Visualisation of power consumption 

almost in real time; better cost control and overview; 
identification of power guzzlers; avoidance of back payments 
for electricity; reduction of power consumption; use of time-
variable electricity tariffs; remote meter reading; better 
transparency – comparison of own consumption with the 
average 

Costs 

Increased 
rate and depth 

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve health 
and wellbeing 

•  Increased 

sustainable infra-
structure in built 
environment 
(including 
enhanced 
resilience of 
building) 

•  Increase smart 
readiness of 
buildings 
•  Secure fair 
transition 

•  Upgrade of urban 
context (including 
access to 
sustainable 
mobility) 

Lessons learned 

• 

In January 2019, the first barometer on the digitisation of the 
energy transition for the 2018 reporting year was published. 
The second barometer describes considerable efforts and 
progress made in implementing the “Law on the Digitization 
of the Energy Transition”. The smart meter rollout after the 
third certification of a smart meter gateway and the 
publication of the market declaration by the Federal Office for 
Information Security at the end of January 2020 were 
positively highlighted.  

•  An important task for 2019 was updating the legal framework 
for the network-oriented control of flexible consumer devices 
according to § 14a EnWG (German Energy Law). The decision 
to use the 450 MHz frequencies for the digitisation of the 
energy industry is also considered a critical success factor. 

•  Ultimately, the end customers need to be more closely 

informed and involved. 

Synergies 

25 

 
 
 
 
 
 
 
Bibliography 

Annex III: Good practice examples 

https://www.eon.de/de/eonerleben/smart-meter-pflicht-in-

Legal text (DE): 
https://www.bmwi.de/Redaktion/DE/Downloads/Gesetz/gesetz-zur-
digitalisierung-der-energiewende.pdf?__blob=publicationFile&v=4  
EON 
deutschland.html 
EY 
https://www.bmwi.de/Redaktion/DE/Artikel/Energie/gutachten-
digitalisierung-der-energiewende.html 
PwC 
https://www.pwc.de/de/energiewirtschaft/Studie_Digitalisierung_un
d_Energiewende.pdf 

Barometer 

26 

 
 
 
 
 
 
Annex III: Good practice examples 

4  GOOD PRACTICE EXAMPLES: FINANCING RENOVATION 

The  following  pages  provide  examples  of  good  practice  policies  in  the  strategic  area  of 
financing renovation.  

4.1  Croatia – Methods to make energy renovation attractive 

Policy/initiative 

Methods of making energy renovation investments more attractive to banks 
and private investors 

Location 

Scope 

Croatia 

National 

Start year 

2014 

Building types 

Public buildings and residential buildings 

Status  

Ongoing 

Type of policy 

De-risking energy efficiency investments with the help of public financing 

Short description  Financial  and  regulatory  mechanisms  aimed  at  mobilising  private 
investment  into  strategic  renovation  of  the  national  building  stock  by 
making it more attractive: 

•  By establishing a national revolving fund by means of redeploying 

resources from ESI funds1, energy service providers will be 
enabled to access a long-term funding source at more favourable 
market conditions, and banks will be enabled to place resources 
through the fund. 

•  By introducing special guarantee instruments, the risk factor of 

private investor funds placement will be reduced. 

•  Subsidising the interest rates on commercial loans will enable 
commercial banks to finance building energy renovation. 

•  Promoting the development of the energy service market through 
the implementation of the programme of renovation of public 
buildings. 

•  Developing standard energy performance contracts and 

standardised methods for measuring and verifying energy savings 
that will enhance the trust of users and financial institutions in the 
ESCO model. 

Primary  energy 
savings  

The energy renovation of public buildings programme (2014-2015) covered 
69  buildings  with  active  contracts,  saving  a  potential  70  GWh  of  energy 
annually. About 55% of delivered energy savings have been achieved. 

The energy renovation programme for public sector buildings 2016-2020, 
co-financed through the allocation of grants from ESI funds, aims to save 
about 50 GWh/year and to reduce energy consumption by up to 70%.  

The  2014-2020  multi-residential  buildings  energy  renovation  programme 
was expected to deliver on average 66% energy savings. 

CO2 
savings 

emission 

No data available  

Increased 
renovation 
and depth  

The energy renovation of public buildings (2014-2015) covered an area of 
257,000 m2 of 69 buildings.  

rate 

1  The  European  Structural  and  Investment  Funds  (ESIF)  comprise  the  European  Regional  Development  Fund 
(ERDF), the Cohesion Fund (CF), the European Agricultural Fund for Rural Development (EAFRD), the European 
Social Fund (ESF), and the European Maritime and Fisheries Fund (EMFF). 

27 

 
 
 
 
 
 
Annex III: Good practice examples 

The  2014-2020  multi-residential  building  energy  renovation  programme 
had 2,355 applications approved in two years. 

The  2014-2020  family  houses  energy  renovation  programme  has  15,000 
projects. 

Synergies 

Engaging transformation and phasing out inefficient buildings: This 
measure helps to tackle renovations with long pay-back periods, enabling 
the implementation of less cost-effective measures. 

District  approach:  This  measure  assesses  multi-building  renovations, 
hence streamlining and aggregating renovation solutions.  

Bibliography 

Ministry of Construction and Physical Planning (2017). Proposal of the Long-
Term  Strategy  for  Mobilising  Investment  in  Renovation  of  the  National 
Building Stock of the Republic of Croatia. 

https://ec.europa.eu/energy/sites/ener/files/documents/lts_croatia_2017.
pdf 

Ministry  of  Construction  and  Physical  Planning (2017). Energy  renovation 
of buildings in Croatia. 

https://ec.europa.eu/energy/sites/ener/files/documents/006_kriz_selendi
c_seif_milan_16-11-17.pdf  

28 

 
 
 
 
 
 
 
Annex III: Good practice examples 

4.2  The Netherlands – Tenants’ right to initiate deep renovations 

Policy/initiative 

Lange  Termijn  Renovatiestrategie  |  Long-Term  Renovation  Strategy  / 
Tenants’ right to initiate deep renovations 

Location 

Scope 

The Netherlands 

National 

Start year 

To be determined 

Building types 

Residential (rented homes)  

Status  

In research 

Type of policy 

Regulation 

Short description  Under the regulation in force, at least 70% of the tenants must agree to a 
renovation of a complex. The civil code already offers a solution for certain 
cases  in  which  the  tenant  requests  energy  saving  measures,  and  the 
landlord is obligated to carry out and pay for these investments providing 
the tenant is prepared to accept an increase in the rent.  

Since  minimum  standards  will  become  mandatory  in  2050  for  all  rented 
homes,  government  is  currently  assessing  whether  rules  should  be 
amended  to  allow  tenants  to  require  landlords  to  carry  out  a  deep 
renovation  of  the  house  and  whether  these  standards  and  2050  target 
values can play a role in a possible adjustment.  
This  initiative  is  still  under  review.  There  are  no  estimations  available  on 
the primary energy savings this initiative would have.  

This  initiative  is  still  under  review.  There  are  no  estimations  available  on 
the CO2 emission savings this initiative would have.  

Primary  energy 
savings  

CO2 
savings 

emission 

Increased 
renovation 
and depth  

Synergies 

Bibliography 

Over 40% of homes in The Netherlands are rented. This represents 3 million 
rental homes.  Minimum sustainability standards will be mandatory for all 
rented homes by 2050.  

rate 

Engaging transformation and phasing out inefficient buildings: The 
proposoal to change the civil code to enable tenants to obligate landlords 
to make certain improvements would address the split-incentive dilemma 
by achieving deep energy renovation in an heterogenous building stock with 
mixed ownership.  

Netherlands  Enterprise  Agency.  (2020,  March).  Long  term  renovation 
strategy. 
https://ec.europa.eu/energy/sites/ener/files/documents/nl_2020_ltrs_en.
pdf 
Rented housing. Government.nl. (2020). Retrieved 11 August 2020, from 
https://www.government.nl/topics/housing/rented-housing.  

29 

 
 
 
 
  
 
 
 
 
Annex III: Good practice examples 

4.3  USA – Property Assessed Clean Energy (PACE) 

Policy/initiative 

Property Assessed Clean Energy (PACE) 

Location 

Scope 

USA 

Regional 

Start year 

2008 

Building types 

Residential and commercial  

Status  

Ongoing 

Type of policy 

Short description 

On-tax financing 
Property Assessed Clean Energy (PACE) is a way to finance a wide range of 
energy  and  water  efficiency,  renewable  energy,  and  hazard  mitigation 
improvements  permanently  attached 
to  residential  (R-PACE)  and 
commercial (C-PACE) properties. 

Established  by  state  statutes  and  enabled  by  local  governments,  PACE 
financing is structured as an assessment against the property and not the 
property  owner.  PACE  provides  100%  of  the  cost  of  qualified  structural 
improvements, which the property owner repays annually or semi-annually 
through a special assessment added to the property tax bill. 

The  average  repayment  period  is  typically  over  10  to  20  years  through 
property assessments, which are secured by the property itself and paid as 
an addition to the owner’s property tax bills.  

Typical  home  improvement  projects  include  replacement  of  broken  or 
failing heating and cooling systems and hot water heaters; air sealing and 
insulation;  ENERGY  STAR  doors,  windows,  roofing;  ENERGY  STAR 
appliances;  solar  photovoltaic  systems;  and  water  conservation  and 
resiliency measures (e.g., seismic retrofits and wind hazard protection). 

Non-payment  generally  results  in  the  same  set  of  repercussions  as  the 
failure to pay any other portion of a property tax bill. 

Primary  energy 
savings  

CO2 
savings 

emission 

Cumulative energy saved (kWh) (2009 - 2019)2 

•  C-PACE: 7,929,319,000  
•  R-PACE: 21,811,465,000 
•  Total: 29.754 billion 

Total carbon abated (metric tonnes) (2009 – 2019)3 

•  C-PACE: 2,850,000 
•  R-PACE: 4,587,000 
•  Total: 7,44 million 

Increased 
renovation 
and depth  

rate 

Through 2019, 37 states and Washington D.C. have passed PACE-enabling 
legislation, 22 states and Washington D.C. have active C-PACE and 3 states 
have active R-PACE (California, Florida and Missouri). 

In 2019, C-PACE: 

•  Surpassed US$1.5 billion cumulative investment on 2,400 

buildings 

•  Created 18,000 jobs 
•  Reached US$670 million annual investment equal to 150% growth 

over 2018 

2  Impacts  are  estimated  over  useful  lifetime  of  installed  measures.  Includes  data  reported  to 
PACENation as of April 1st, 2020. 
3  Impacts  are  estimated  over  useful  lifetime  of  installed  measures.  Includes  data  reported  to 
PACENation as of April 1st, 2020. 

30 

 
 
  
 
 
 
Annex III: Good practice examples 

• 

Investment by project type: 49% energy efficiency, 23% 
renewable energy, 7% resiliency and 22% mixed-projects.  
•  The building type most invested was hospitality (US$161.3 

million), followed by office (US$128.7 million) and retail (US$93.3 
million) 

•  14% of the investment was in new construction. 

In 2019, R-PACE: 

•  Surpassed US$6.2 billion cumulative investment on over 280,000 

homes. 

•  Created 108,000 jobs. 
•  Was poised for growth in 2020 with programmes in development in 

Ohio and New York.  

•  Exceeded US$650 million in cumulative investment for hurricane 

• 

resiliency and seismic strengthening 
Investment by project type: 70% energy and water efficiency, 
21% renewable energy and 9% resiliency. 

The  financing  model  was  launched  in  California  in  2008  and  has  been 
successfully carried out in the United States for several years. In the past 
four years, the PACE market reached over US$4.7 billion in funded projects 
nationwide, including the retrofit of over 200,000 homes, which resulted in 
more  than  42,000  new  local  jobs  and  the  creation  of  hundreds  of  new 
companies. 

C-PACE programmes exist in several states, regions and local governments. 
Programmes  vary  across  several  dimensions  including  the  level  of 
organisation  (statewide  vs.  local  programmes),  financing  structures,  and 
eligible measures. More than 35 states plus the District of Columbia have 
C-PACE enabling legislation and more than US$800 million in projects have 
been financed. 

PACE  programmes  are  typically  enabled  through  state  legislation  and 
authorised  at  the  local  government  level.  Municipalities  may  administer 
residential  PACE  programmes  directly,  or 
through  public-private 
partnerships with one or more PACE providers. 

Unlike  C-PACE  programmes,  which  have  been  broadly  adopted  and 
launched  across  dozens  of  states  and  thousands  of  municipalities  but 
funded a smaller volume  of projects, R-PACE has experienced challenges 
due  to  concerns  raised  by  the  mortgage  banking  industry  and  consumer 
advocates. 

The  degree  of  transferability  across  countries  is  considered  as  medium, 
since internal regulation of each country must allow this scheme. The fact 
of municipalities or local governments acting as a capital provider might be 
conflictive in certain countries.  

This  measure  could  be  included  in  the  national  long-term  renovation 
strategies  of  the  EU  countries,  which  are  an  obligation  under  the  Energy 
Efficiency  Directive  (2012/27/EU),  as  it  is  a  policy  that  stimulates  cost-
effective  deep  renovation  of  buildings  and  targets  the  split-incentive 
dilemma and energy poverty.  

It  could  also  fit  in  the  Renovation  Wave  initiative  because  it  promotes 
energy efficiency investments in buildings. 

It would fit the clean energy for all Europeans package as this proposition 
is  in  line  with  the  commitment  to  tackle  energy  poverty  and  protect 
vulnerable consumers. 

Ease 
implementation 

of 

Matching 
EU 
policy framework 

Costs 

No data available 

31 

 
 
 
  
Objectives 
tackled 

Annex III: Good practice examples 

Secure fair transition: By putting the burden of the loan on the building 
rather  than  on  the  person,  it  allows  for  certain  groups  who  may  have 
difficulty accessing credit, such as low-income people and the elderly, to do 
the necessary work. 

Energy  poverty:  Innovative  financing  instrument  to  upgrade  residential 
properties and lower energy bills for vulnerable populations. 

Improve  health  and  wellbeing:  Typical  home  improvement  projects 
might include replacement of broken or failing heating and cooling systems 
and  hot  water  heaters;  air  sealing  and  insulation;  ENERGY  STAR  doors, 
windows,  roofing;  ENERGY  STAR  appliances;  solar  photovoltaic  systems; 
and water conservation and resiliency measures (e.g., seismic retrofits and 
wind hazard protection), improving the  indoor environmental quality.  

Increased  sustainable  infrastructure  in  built  environment:  Studies 
demonstrate that renovations under the programme reduce vulnerability to 
earthquakes and hurricanes. 

Lessons learned 

Success factors, strength and opportunities 

•  Allows for secure financing of comprehensive projects over a 

longer term, making more projects cash-flow positive. 

•  Spreads repayment over many years, seldom requires an upfront 

payment, and removes the requirement that the debt be paid at 
sale or refinance. 

•  Can lead to low interest rates because of the high security of loan 

repayments attached to the property tax bill. 

•  Helps some property owners deduct payments from their income 

tax liability. 

•  Allows municipalities to encourage energy efficiency and renewable 

energy without putting general funds at risk. 

•  Taps into large sources of private capital. 
•  Direct benefits such as reduction in electricity and natural gas use, 

increase in renewable electricity generation, reduction in the 
emission of greenhouse gases, reduction in water use and 
reduction in vulnerability to earthquakes and hurricanes. 
•  Co-benefits include increase in business sales revenue, GDP, 

personal income and employment, increase in tax revenues for 
various levels of government, reduction in property damage, 
reduction in disaster relocation cost and reduction in hazard 
insurance premiums. 

Challenges of implementation (weaknesses and threats) 

•  Available only to property owners. 
•  Cannot finance portable items (screw-in light bulbs, standard 

refrigerators, etc.). 

•  Can require dedicated local government staff time. 
•  May require high legal and administrative setup obligations. 
•  Not appropriate for investments below US$2,500. 
•  Potential resistance by lenders/mortgage-holders whose claims to 
the property may be subordinated to the unpaid assessment 
amount should the property go into foreclosure. 

•  Uncertainty about the likelihood of tax foreclosure on properties in 
default of C-PACE payments and the risks local governments bear. 

•  Uncertainty about the staff labour commitment associated with 
administering the programme, including the execution of the 
special tax assessment process. 

32 

 
 
 
Synergies 

Bibliography 

Annex III: Good practice examples 

Health and wellbeing: It has potential to improve health and wellbeing 
as typical home improvement projects might include replacement of broken 
or failing heating and  cooling  systems and hot water heaters; air sealing 
and  insulation;  ENERGY  STAR  doors,  windows,  roofing;  ENERGY  STAR 
appliances;  solar  photovoltaic  systems;  and  water  conservation  and 
resiliency  measures  (e.g.,  seismic  retrofits  and  wind  hazard  protection), 
improving the indoor environmental quality. 

Engaging transformation and phasing out inefficient  buildings: By 
putting the burden of the loan on the building rather than on the person,  
it allows for certain groups who may have difficulty accessing credit, such 
as  low-income  people  and  the  elderly,  to  do  the  necessary  work.  In 
addition, it could tackle energy poverty by potentially lowering energy bills 
for vulnerable populations. 

Built environment sustainability and adaptation to climate change: 
Among  its  direct  benefits  we  can  find  reduction  in  vulnerability  to 
earthquakes and hurricanes and reduction in water, electricity and natural 
gas use.  

2020, 

August 

Retrieved 

Property  Assessed  Clean  Energy  Programs.  https://www.energy.gov/. 
(2020). 
from 
7 
https://www.energy.gov/eere/slsc/property-assessed-clean-energy-
programs.  
Rose, A., & Wei, D. (2019). Impacts of the Property Assessed Clean Energy 
(PACE) Program on the Economies of California and Florida. 
http://www.schwarzeneggerinstitute.com/images/files/SI_White_Paper%
20PACE_Economic_Impacts_FINAL_3_6_19.pdf  
PACENation. 
(2019). PACE 
content/uploads/2020/04/PACE-Facts-4-24-20.pdf  
PACE Market Data | PACENation. PACENation. (2020). Retrieved 10 August 
2020, from https://pacenation.org/pace-market-data. 

https://pacenation.org/wp-

Facts. 

33 

 
 
 
 
 
Annex III: Good practice examples 

4.4  Germany – KfW Energy Efficiency Programme 

Policy/initiative 

KfW energy efficiency programme - Energy-efficient renovation investment 
subsidy 

Location 

Scope 

Germany 

National 

Start year 

2007 

Building types 

Residential houses and condominiums (must be primary residences) 

Status  

Ongoing 

Type of policy 

Loan programme 

Short description  This programme serves to promote comprehensive refurbishment into “KfW 
efficiency houses” or individual measures to improve energy efficiency. As 
well as repayment bonuses dependent on the primary energy consumption 
of  the  efficiency  house,  a  special  promotion  is  possible  if  construction  is 
supervised by an external technical expert. 

Through  the  loan,  applicants  can  receive  an  investment  subsidy  that 
depends on the energy standard achieved: 

•  KfW Efficiency House 55: up to €48,000 (40% of a maximum of 

€120,000 of eligible costs per residential unit) 

•  KfW Efficiency House 70: up to €42,000 euros (35% of a 

maximum of €120,000 of eligible costs per residential unit) 
•  KfW Efficiency House 85: up to €36,000 (30% of a maximum of 

€120,000 of eligible costs per residential unit) 

•  KfW Efficiency House 100: up to €33,000 euros (27.5% of a 
maximum of €120,000 of eligible costs per residential unit) 

• 

•  KfW Efficiency House 115 and Monument: up to €30,000 (25% of 
a maximum of €120,000 of eligible costs per residential unit) 
Individual measures: up to €10,000 (20% of a maximum of 
€50,000 of eligible costs per residential unit). These include 
thermal insulation of walls, roof surfaces, basement and storey 
ceilings, renewal of the windows and external doors, connection to 
local or district heating, optimisation of an existing heating system 
and the renewal or installation of a ventilation system 

Primary  energy 
savings  

The energy-efficient renovation investment subsidies are a part of the KfW’s 
“energy-efficient  refurbishment”  programme.  In 
terms  of  energy 
conservation, the energy use in newly retrofitted buildings has decreased 
from approximately 120 kWh per square metre per year to 80 kWh/m2/yr. 

CO2 
savings 

emission 

Increased 
renovation 
and depth  

rate 

The energy-efficiency measures supported by the programmes are helping 
to reduce carbon emissions by almost 9 million tonnes per year. 

Overall, KfW's promotional funding has triggered investments of over €260 
billion  in  building  measures  and  secured  an  average  of  320,000  jobs  per 
year in the building industry and regional trades. Every second newly built 
home in Germany is currently supported by funds from the "energy-efficient 
construction" programme and close to 290,000 homes received an energy-
efficient makeover with the help of KfW in 2016. 

Ease 
implementation 

of 

Steps to obtain funding: 

1.  Hire  experts  for  energy  efficiency:  Energy-efficient  renovation 
requires complex specialist knowledge. An energy efficiency expert 
ensures  that  the  construction  work  leads  to  the  desired  result.  All 
experts  who  are  included  in  the  expert  list  of  the  German  Energy 
Agency (dena) for federal funding programmes are admitted. 

34 

 
 
 
Annex III: Good practice examples 

2.  Applicants  can  combine  funding  opportunities:  combine  further 
funding and at the same time remove barriers during the renovation. 
3.  Invesment  grant  application:  before  works  start  or  the  purchase 
contract is signed, applicants must submit their application directly 
in the KfW grant portal. 

4.  Proof  of  identity:  applicants  must  give  proof  of  their  identity  once 

the grant has been awarded 

5.  Finalisation:  once  the  project  has  been  finalised  the  applicant, 
together  with  the  expert  must  fill  out  the  “confirmation  after 
implementation” form, after which the investment grant will be paid. 

The degree of transferability across countries is considered high.  

Matching 
EU 
policy framework 

Could  match  and  be  used  to  meet  the  requirements  established  in  the 
Energy Performance of Buildings Directive. 

Costs 

Objectives 
tackled 

National Energy Efficiency Funds, which are set by the Directive 2012/27 

Could  also  be  part  of  the  Renovation  Wave  initiative,  allocating  specific 
funds to guarantee this type of financing 

The  German  Ministry  for  Economic  Affairs  and  Energy  (BMWi)  currently 
issues over €2 billion a year for the programmes, which form part of the 
campaign “efficiency first”.  
KfW commitments amount to around €70-80 billion p.a 

Increased  sustainable  infrastructure  in  the  built  environment: 
Owners  of  dwellings  are  able  to  implement  energy  efficiency  measures, 
financing  their  investments  through  the  loans.  As  a  result,  the  housing 
stock in Germany is more sustainable.  

Improved  health  and  wellbeing:  The  implementation  of  the  energy 
efficiency  measures  covered  by  the  programme  also  increases  both  the 
wellbeing  and  the  health  of  the  residents,  as  they  have  better  thermal 
conditions and better insulation, among others.  

Lessons learned 

Success factors, strengths, and opportunities 

•  Provides low-interest and long-term financing of investments 

designed to save energy and reduce CO2 in the residential building 
stock, new buildings and buildings that form part of the municipal 
and social infrastructure 

•  Different grants and loans can be combined by applicants to obtain 

more beneficial conditions 

•  The incentives designed both to internalise external effects in the 
field of climate protection and to promote energy efficiency are 
accompanied by a positive impact on employment and surplus 
government revenues  

•  Stability and attractiveness of promotional product offer – 

established brand (KfW Efficiency House) 
Challenges of implementation (weaknesses and threats) 

•  Lack of public awareness  
•  High budgetary need  
•  Monitoring of effects can be quite challenging and bureaucratic 

procedures can become complicated 

•  Assuring target-oriented use of public funds needs to be closely 

monitored 

Synergies 

Engaging  transformation  and  phasing  out  inefficient  buildings: 
Longer  payback  periods  are  available  with  low  monthly  repayments, 
enabling the implementation of less cost-effective measures.  

Health  and  well-being:  Associated  with  renovations  that  improve  the 
health, comfort and air quality of the occupants, such as thermal comfort 
and better insulation.  

35 

 
 
 
 
 
Annex III: Good practice examples 

Bibliography 

“Ten Years of the KfW's ‘Energy-Efficient Construction and Refurbishment’ 
Programmes.” 
www.kfw.de/KfW-
Group/Newsroom/Latest-News/Pressemitteilungen-Details_403200.html  

Bankengruppe, 

KfW 

Energieeffizient 
– 
www.kfw.de/inlandsfoerderung/Privatpersonen/Bestandsimmobilien/Finan
zierungsangebote/Energieeffizient-Sanieren-Zuschuss-(430) 

Investitionszuschuss 

Sanieren 

(430), 

Dorendorf,  Bettina.  “KfW  Promotional  Programs  for  Energy  Efficiency  in 
Buildings.” 
2018, 
European 
ec.europa.eu/energy/sites/ener/files/documents/08_housing_bettina_dor
endorf_kfw.pdf  

Comission, 

EC, 

36 

 
 
 
 
Annex III: Good practice examples 

4.5  France – the Denormandie law 

Policy/initiative 

The Denormandie law 

Location 

Scope 

France 

National 

Start year 

2019 

Building types 

Residential  

Status  

Ongoing 

Type of policy 

Tax rebate – Regulatory measure 

Short description  The Denormandie law aims to renovate dilapidated housing in some French 
cities  through  an  advantageous  tax  exemption  programme  for  investors. 
The level of tax reduction that it grants ranges from 12 to 21% depending 
on the rental period of the renovated property (6.9 or 12 years).  

Renovation work should: 

• 

Improve the energy performance of housing by at least 30% (20% 
in collective housing) 

•  Represent two types of work from a choice of five: 

-  Roof insulation 
-  Change of boiler 
-  Wall insulation 
-  Window insulation 
-  Change in hot water production 

Primary  energy 
savings  

No data available 

emission 

No data available  

CO2 
savings 

Increased 
renovation 
and depth  

rate 

In territories that have a large old park resulting in major investment needs, 
the effects of the tax benefits introduced by the Denormandie amendment 
would increase real estate yields by 5-8% gross, according to simulations 
carried out by the National Real Estate Federation (FNAIM). 

Ease 
implementation 

of 

Complements the existing system, the Pinel law. The Denormandie is valid 
until December 31, 2022. 

To  benefit  from  the  Denormandie  law,  the  investor  must  be  a  taxpayer 
domiciled in France: the acquisition can be made by a natural person, via 
an SCI (Société Civile Immobilière)4 or in joint  ownership (in the  case  of 
SCI  or  joint  ownership,  the  tax  reduction  is  made  in  proportion  to  the 
shares). 

The tax reduction is not applicable to dwellings whose property rights have 
been dismembered (dissociation between ownership and enjoyment). 

The investor must buy old housing that does not meet the legal criteria for 
decent  housing.  The  property  must  be  located  in  one  of  the  222 
municipalities targeted by the City Heart Action plan or in those which are 
the  subject  of  a  regional  revitalisation  operation.  In  short,  the  acquired 
housing is not yet habitable and is located in a district to be rehabilitated.  

4  Société  Civile  Immobilière  (SCI)  a  rather  specialist  type  of  French  company  (société)  that  is 
constituted  for  the  ownership  and  management  of  property  (immobilière).The  fact  that  it  is  also 
“civile” means that it is a non-trading company, thereby distinguishing it from a company set up to 
pursue commercial objectives. 

37 

 
 
  
 
 
Annex III: Good practice examples 

The amount of the renovation work must represent at least 25% of the total 
value  of  the  transaction.  These  works  concern  both  energy  renovation, 
improving energy performance  by at least 30% for a house and 20% for 
apartments,  as  well  as  modernisation,  sanitation,  development  of  living 
areas (attics and basements) and creation of new living space. 

To  redo  the  accommodation,  applicants  must  go  through  a  company.  As 
with all tax exemption operations, they must be able to provide supporting 
documents to the tax authorities if they request it. 

The  conditions  are  strict  and  will  be  checked.  Applicants  may  not  do  the 
work  themselves  but  must  go  through  a  certified  tradesperson  RGE 
(recognized  guarantor  of  the  environment).  The  property  must  have  an 
energy consumption of less than 331kWh per square metre per year at the 
end  of  the  work.  In  addition  to  the  invoices,  it  will  also  be  necessary  to 
carry  out  an  energy  performance  diagnosis  before  and  after  in  order  to 
prove the evolution. 

The degree of transferability could be considered as high.  

Matching 
EU 
policy framework 

This  measure  would  fit  in  the  national  long-term  renovation  strategies, 
which are a requirement for EU countries under the EPBD (2018/844/EU) 
Article 2 bis, because it supports the transition into a highly energy efficient 
building stock and targets the split-incentive dilemma. 

It  could  also  fit  in  the  Renovation  Wave  initiative  because  it  promotes 
energy efficiency investments in buildings. 

It would fit the clean energy for all Europeans package as this measure is 
in line with the commitment to tackle energy poverty and protect vulnerable 
consumers. 

Costs 

To benefit from this, the amount of the invoice for the energy renovation 
works must be equal to or greater than 25% of the price of the property. 

The amount of the tax benefit is determined on the basis of a double price 
ceiling:  €5,500/m²  without  being  able  to  exceed  €300,000.  If  the  total 
amount of the project reaches €350,000 and does not exceed €5,500/m², 
for example, the tax exemption would be calculated on €300,000. 

In addition to the tax reduction, the taxpayer can deduct from their overall 
income within the limit of €10,700 the following elements: 

•  The property tax, management or management fees, loan 

insurance. 
Insurance premiums  

• 
•  Guaranteed rents (guarantee of rental vacancy and guarantee of 

unpaid rents) 

•  The charges borne by the owner (fees of the building manager). 

Only loan interest is not deductible from overall income; however, this can 
be carried over for 10 years. 

Objectives 
tackled  

Energy poverty: It can help to alleviate energy poverty, restoring property 
in poor condition and addressing the split-incentive dilemma.  

Improve  health  and  wellbeing:  The  possible  actions  (wall  insulation, 
attic insulation, window insulation, heating, hot water production) support 
indoor environmental quality. 

Upgrade  of  urban  context:  The  buildings  renovated  are  located  in  the 
centre of one of the 245 municipalities participating in the “Cœur de Ville” 
operation. Furthermore, the system extends to rural areas. 

Secure  fair  transition:  Tenants  must  have  incomes  below  certain 
thresholds. It will be necessary to rent to a person who has modest income, 
as goods to be rented are reserved for low-income households.  

38 

 
 
 
 
Lessons learned 

Annex III: Good practice examples 

Success factors, strength and opportunities 

•  The main advantage of the Denormandie law is the fact that it 
allows tax exemption of up to 21% of the price of the property 
purchased if it is rented for 12 years. This will act as an incentive 
for the renovation of rented properties, tackling the split-incentive 
dilemma. It is aimed at a large panel who want to both reduce 
their taxes and build up assets. 

•  Older homes are located in the heart of cities, so they are often 

better placed than newer homes. It encourages investment in city 
centres where there are few new real estates offers and very often 
at lower prices than new real estate. 

•  The acquisition is faster – even with the work to be carried out it 
takes on average four months to start renting the property, 
compared to two months for a new property. 

•  The system extends to rural areas. 

Challenges of implementation (weaknesses and threats) 

• 

• 

Investors cannot deduct 25% of works from their rents to create a 
land deficit, as specified in paragraph F of article 199 novovicies of 
the General Tax Code (CGI). A land deficit is created when the 
expenses are greater than the income. It is impossible to benefit 
from the tax reduction on works and in addition to deductg them 
from the rents during the tax return. 
If, in the same year, the reduction obtained is greater than the tax 
payable, the excess cannot be carried forward. The reduction is 
imputable to the tax for the year of completion of the works 
regardless of the month of this completion, or to the tax for the 
year of acquisition if this is later. 

•  Not all the municipalities eligible for the Denormandie law have the 
same appeal for a real estate investor. Investores must first and 
foremost be interested in the rental market and prospects and not 
focus solely on tax exemption. 

•  The Denormandie law is subject to a certain number of constraints 
(price ceiling per m², rent ceiling, tenant income ceiling); it will be 
necessary, depending on each type of investment, to measure the 
weight of these constraints and to verify that they remain 
acceptable 

•  Another disadvantage of renting under the Denormandie law is the 
obligation to set a ceiling rent in advance. This means that if your 
rent exceeds the authorised ceiling, you will not be able to benefit 
from the tax reduction. The rent ceiling must be calculated each 
time a lease is signed and the ceiling changes every year. 

Synergies 

Engaging  transformation  and  phasing  out  inefficient  buildings:  It 
can help to create an enabling framework for deep renovations that are not 
cost-effective and to increase the rate of deep renovations.  

Health  and  well-being:  The  possible  actions  (wall  insulation,  attic 
insulation,  window  insulation,  heating,  hot  water  production)  support 
indoor environmental quality 

Bibliography 

Loi Denormandie : conseils défiscalisation Denormandie » K&P Finance. K&P 
Finance.  (2020).  Retrieved  7  August  2020,  from  https://www.kp-
finance.com/conseils/defiscalisation-immobiliere/loi-denormandie/.  
Chevillard,  P.  (2020). Défiscaliser  avec  le  Denormandie  dans  l’ancien  - 
from 
PAP.fr. 
https://www.pap.fr/bailleur/choisir-investissement/la-fiscalite-
immobiliere/a1247/defiscaliser-avec-le-denormandie-dans-l-ancien.  
Loi  Denormandie  2020  ⇒  Investir  dans  l'ancien  :  Communes  éligibles  - 
Plafonds - Travaux de rénovation pour défiscaliser en loi Pinel ancien. Loi 

Retrieved 

August 

Pap.fr. 

2020, 

7 

39 

 
 
 
 
Annex III: Good practice examples 

de Normandie. (2020). Retrieved 7 August 2020, from https://www.loi-de-
normandie.fr/. 
Loi DENORMANDIE => De quoi s'agit-il et Comment ça fonctionne?. Corrige 
ton 
from 
https://www.corrigetonimpot.fr/loi-denormandie-impot/.  
www.budget.gouv.fr/documentation/file-download/6982  

Retrieved 

(2020). 

August 

impôt. 

2020, 

7 

40 

 
 
 
 
 
Annex III: Good practice examples 

4.6  Italy – Ecobonus / Superbonus 

Policy/initiative 

Ecobonus/ Superbonus 

Location 

Scope 

Italy  

National 

Start year 

2020 

Building types 

Applies to residential, non-residential and mixed buildings 

Status  

Ongoing 

Type of policy 

Short description 

Tax rebate 
Ecobonus 

Deduction for energy saving works carried out both on single buildings and 
in condominiums. It is possible to access a tax deduction from 50 to 65% 
for works on single buildings, which rises up to 75% for expenses for energy 
requalification interventions in condominiums. 

The deduction for interventions on housing concerns all interventions and 
expenses incurred for the purpose of: 

•  Thermal improvement of the building (insulation, floors, windows 

and fixtures) 
Installation of solar panels 

• 
•  Replacement of winter air conditioning systems 
•  Home automation, e.g. installation of multimedia devices for 

remote control of heating systems. 

Superbonus 

The Superbonus is a subsidy provided by the Relaunch Decree which raises 
to 110% the rate of deduction of expenses incurred from 1 July 2020 to 31 
December 2021 , for specific interventions in the field of energy efficiency, 
anti-seismic  interventions,  installation  of  photovoltaic    systems  or 
infrastructure for charging electric vehicles in buildings. 

Individuals  can  convert  the  ordinary  tax  credits  connected  with  qualified 
building renovation and energy efficiency  costs incurred during 2020 and 
2021 into: (a) a transferable tax credit; or (b) a discount of the relevant 
cost  applied  by  the  service  provider  (in  such  case,  the  transferable  tax 
credit is granted to the service provider). The tax credit cannot be refunded 
or carried forward to subsequent fiscal years. 

It will be recognised exclusively for those jobs that guarantee the highest 
energy saving performance (improvement of at least two building energy 
classes): 

•  Thermal insulation of vertical and horizontal opaque surfaces 

affecting the building envelope with an incidence greater than 25% 
of the gross dispersing surface of the building itself 

•  The replacement of winter air-conditioning systems on common 

parts of buildings and on single-family buildings. 

As an alternative to the direct use of the deduction, it is possible to opt for 
an advance contribution in the form of a discount from the suppliers of the 
goods  or  services  (discount  on  the  invoice)  or  for  the  assignment  of  the 
credit corresponding to the deduction due. 

The assignment can be ordered in favour of: 

•  Suppliers of goods and services necessary for the implementation 

of interventions 

•  Other subjects (natural persons, also performing self-employed or 

business activities, companies and entities) 

41 

 
 
 
Primary  energy 
savings  

Annex III: Good practice examples 

•  Credit institutions and financial intermediaries. 

The subjects who receive the credit have, in turn, the faculty of assignment. 

In  terms  of  energy  savings  achieved  in  2017  by  technology,  the  main 
contribution  derives  from  the  replacement  of  windows  and  shutters  
(584  GWh/year  on  over  1,300),  while  over  a  quarter  of  savings  was 
achieved  thanks  to  interventions  on  walls,  slabs  and  roofs  (about  350 
GWh/year).  In  total,  by  2017  approximately  €3.8  million  was  invested, 
saving 
of  
a 
1,301 GWh/year of energy.  

total 

The trend of achieved energy savings is increasing, with 0.112 Mtoe/year 
in 2017. Energy  savings amount to just  over  0.4  Mtoe/year in the 2014-
2017 period; starting from 2011, the achieved energy savings amount to 
0.77 Mtoe/year; total savings are equal to 1.31 Mtoe/year since the scheme 
started in 2007. 

CO2 
savings 

emission 

The savings achieved in 2011-2017 thanks to all the incentive mechanisms 
including the Ecobonus, prevented the emission of about 19 MtCO2 in 2017, 
more than 5% of the CO2 emissions reported for Italy in 2016. 

Increased 
renovation 
and depth  

rate 

Overall, fiscal incentives and tax deductions for building/energy renovation 
applied  since  1998  have  stimulated  interventions  in  60%  of  Italian 
households (in 2017). 

Ease 
implementation 

of 

Matching 
EU 
policy framework 

In terms of investment, almost €32 billion has been spent on the renovation 
of buildings between 2007 and 2016 

With  the  interventions  related  to  common  parts  of  condominiums,  the 
insulation  of  the  casing  with  affected  surface  must  be  >  25%  dispersing 
surface  and  interventions  related  to  the  facade  must  influence  from  the 
thermal point of view or affecting the plaster for more than 10% of the total 
dispersing surface of the building.  

The policy is administered nationally.  

The beneficiaries of the Ecobonus – all resident and non-resident taxpayers 
–  can  deduct  the  aforementioned  intervention  costs  in  their  tax 
declarations. 

The  procedure  to  benefit  from  the  tax  deduction  implies  specific 
documentation  requirements.  It  also  establishes  precise  rules  regarding 
invoicing  and  condominium  expenses.  First,  an  affidavit  proving  that  the 
intervention has been accomplished following the technical requirements. 
Another required document is an energy certificate, which shall include all 
data  linked  to  the  energy  performance  of  the  building.  Finally,  an 
information sheet specifying the details of the intervention(s) shall be also 
included.  

Within 90 days after the completion of the intervention – starting with the 
day when the test (collaudo) is carried out and not when the payment is 
done – this last document, together with a copy of the energy certificate, 
need to be sent electronically or by certified mail to the National Agency for 
New Technologies, Energy and Sustainable Economic Development - ENEA. 

The degree of transferability across EU countries is considered high.  

The  Ecobonus  contributes  to  the  first  objective  of  the  Construction  2020 
Action Plan (“Stimulating favourable investment conditions”) and also helps 
resource-efficiency, 
third  objective 
to  achieve 
environmental performance and business opportunities”). 

(“Improving 

the 

It is also the transposition of the alternative measure under Article 7 of the 
Energy Efficiency Directive 

42 

 
 
 
 
 
Annex III: Good practice examples 

It  could  fit  in  the  European  Green  Deal,  as  it  will  help  to  achieve  the 
ambitious  goal  of  carbon-neutrality  by  2050  by  improving  the  energy 
efficiency in buildings.  

Costs 

The tax credits purchased are divided into 5 or 10 equal annual instalments.  
The maximum deductible limit is: 

•  €100,000 for energy redevelopment interventions 
•  €60,000 for interventions on the building envelope 
•  €30,000 for the replacement of winter air-conditioning systems, or 
the installation of plants equipped with condensing boilers, high-
efficiency heat pumps and low-enthalpy geothermal systems 

•  €60,000 for the installation of solar panels useful for the 

production of hot water for domestic or industrial use and for 
covering the need for hot water in swimming pools, sports 
facilities, shelter and care homes, schools and universities. 

Objectives 
tackled 

Increased smart readiness of buildings: Due to the intervention related 
to building automation systems. 

Upgrade  of  urban  context  (including  access  to  sustainable 
mobility):.  Due  to  installation  of  photovoltaic  solar  systems  and  the 
infrastructure for charging electric vehicles. 

Lessons learned 

Success factors, strength and opportunities: 

•  Tax deductions are the most generous system of incentives ever 
established by the government to promote energy efficiency and 
sustainable economic development in the Italian construction and 
real estate sector. The Superbonus can set an example in Europe 
as a useful tool to promote a green recovery in the building sector, 
by setting incentives for households and companies. 

•  Thanks to these tax advantages and the possibility to transfer tax 

credits, it is possible to significantly reduce the overall or 
immediate upfront costs of energy efficiency projects. 

•  From a government perspective, the President of the 

Environmental Commission of the Italian government argues that 
the Ecobonus qualifies the trade entrepreneurial system and at the 
same time reduces energy consumption, pollution and household 
bills. 
In addition, the increase in the number of interventions over the 
years proves that citizens are more aware of the benefits of 
improving the energy performance of their buildings. 

• 

•  This will make it easier to achieve the decarbonisation goals for 

2030. 

Challenges of implementation (weaknesses and threats): 

•  This tax incentive is “non-structural”, meaning that it is not a 
stable measure as it needs to be reconfirmed each year.  
•  Despite the success of the measure, two problems that the 

government should take into consideration have been identified: 

-  Firstly, the cost of renovating residential buildings remains 
considerably higher than the typical levels in the industrial 
sector, although the savings are the same: the cost-
effectiveness ratio of tax deductions and energy bills is up 
to eight times higher than with the white certificate 
mechanism.  

-  Secondly, the Ecobonus presumes that families are in 

possession of sufficient financial means to invest in energy 
saving renovation, without giving consideration to those 
families that do not and/or are living in energy poverty. 

43 

 
 
 
 
 
Annex III: Good practice examples 

Synergies 

Built environment sustainability and adaptation to climate change: 
the  110%  Superbonus  will  also  go  to  seismic  adaptation  works 
(sismabonus). 

Digital  technology:  With  jobs  such  as  home  automation,  this  measure 
enhances the optimisation of energy use through digitalisation, helping to 
reap  the  full  benefits  of  deep  renovations.  In  addition,  it  unleashes  the 
flexibility potential of energy uses via photovoltaics and storage systems. 

Engaging  transformation  and  phasing  out  inefficient  buildings: 
Creates an  enabling framework  for non-economical renovations, or those 
with a very long payback period, and to advance approaches to take into 
account wider benefits. 

Clean  and  sustainable  mobility:  Additional  interventions  include 
infrastructure for charging electric vehicles. 

Bibliography 

4 

2020, 

D'Andrea, A. (2020). Ecobonus 202 0, how does it work? News and energy 
saving  deduction  guide.  informazionefiscale.it.  Retrieved  4  August  2020, 
https://www.informazionefiscale.it/ecobonus-2020-detrazione-
from 
risparmio-energetico-come-funziona-spese-limiti-novita.  
Ecobonus e Sismabonus 110% | Deloitte Italy | Tax. Deloitte Italia. (2020). 
Retrieved 
from 
August 
https://www2.deloitte.com/ecosismabonus110.  
EY. (2020). Italy enacts "Relaunch Decree" to further manage COVID-19. 
https://taxnews.ey.com/news/2020-1365-italy-enacts-relaunch-decree-
to-further-manage-covid-19 
Ministry  of  Economic  Development.  (2020). Annual  report  on  energy 
efficiency. Results achieved and targets for 2020”. 
https://ec.europa.eu/energy/sites/ener/files/documents/it_annual_report
_eed_2020_tra.pdf  
Superbonus  110%.  Agenziaentrate.gov.it.  (2020).  Retrieved  5  August 
2020, 
https://www.agenziaentrate.gov.it/portale/superbonus-
110%25.  
European  Construction  Sector  Observatory.  (2018). Policy  measures 
bonus. 
factsheet. 
https://ec.europa.eu/docsroom/documents/33521/attachments/5/translat
ions/en/renditions/native 

Italy. 

from 

Eco 

44 

 
 
 
 
Annex III: Good practice examples 

5  GOOD PRACTICE EXAMPLES: HEALTH AND WELLBEING 

The  following  pages  provide  examples  of  good  practice  policies  in  the  strategic  area  of 
health and wellbeing.  

5.1 

 Brussels (Belgium) - Regional Intervention Pollution Unit (CRIPI) 

Policy/initiative 

Regional Intervention Pollution Unit (CRIPI) 

Location 

Start year 

Status 

Brussels Capital region, Belgium 

2016 (CRIPI established in 2000) 

Ongoing 

Building types 

Residential buildings  

Type of policy 

Awareness raising and supportive measure (non-legislative)  

Short description 

The  environmental department of the  regional Brussels government 
established the Regional Intervention Polution Unit (CRIPI) in 2000 in 
cooperation  with  PSI/Sciensano  (public  health  research  institution) 
and FARES (Foundation against Respiratory Disorders and for Health 
Education) to detect indoor pollution in living spaces that might cause 
health  problems.  The  service  is  intended  to  complement  a  medical 
diagnosis and identify and quantify indoor pollutants. By monitoring 
and building a database, CRIPI helps to inform the public and improve 
indoor environmental quality for Brussels residents [2].  

An assessment of the indoor climate is initiated on a doctor’s request 
and  needs  the  coordination  of  different  actors  in  the  municipality. 
Tests include indoor and outdoor samplings, measurement of airborne 
particles,  room  temperature  and  relative  humidity.  The  analysis 
includes  advice  on  user  behaviour,  ventilation  and,  if  renovation 
measures are needed, information on local aid and financial support 
[3].  

The  2016 
regional  energy  and  climate  plan  of  Bruxelles 
Environnement,  the  environmental  department,  includes  a  measure 
to  strengthen  the  CRIPI’s  diagnostic  and  remediation  services  with 
regard to indoor pollution [1]. 

energy 

Primary 
savings  
CO2 emission savings  No information  

No information 

Costs 

No information available 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No information 

•  Transferability: theoretically possible, but might need 

education of staff (doctors, environmental chemists); the 
measure is planned to be extended to vulnerable groups in 
public buildings, such as schools, nurseries and recreational 
spaces  

•  Administration: regional level (environment and energy 

administration in the Brussels-Capital region) 

•  Compliance checks: one year after the initial analysis of the 
conditions and suggestion of measures, an evaluation of the 
evolution of the state of health is carried out by direct contact 
with the resident and the treating doctor via a questionnaire 
[3].  

45 

 
 
 
Annex III: Good practice examples 

Matching  EU  policy 
framework 

The collection of health and wellbeing data on the indoor environment 
can  contribute  to  the  integration  of  IEQ  in  building  policies;  the 
assessment of indoor pollutants based on a doctor’s request could be 
a  good  practice  to  identify  vulnerable  consumer  groups  and  users 
eligible for funding of renovation measures.  

Addressing 

Improve health and wellbeing:  

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
to 
access 
sustainable 
mobility) 

•  The CRIPI’s main objective is to improve the health and 
wellbeing of homeowners and tenants. By assessing the 
indoor environmental quality, identifying indoor pollutants 
and initiating the required action, IEQ is improved, leading to 
better health and wellbeing of the building residents. 

Between  2000  and  mid-2011,  the  CRIPI  carried  out  more  1,400 
housing  visits  and  5,600  direct  debits  in  apartments  and  houses, 
among which 57% of the samples were contaminated with polluting 
sources, such as benzene (37%), 
VOC (11%), formaldehydes (1.2%) or lead (5.5%) [3]. 

Secure fair transition: 

•  A healthy indoor environment without harmful pollutants is 

essential to the wellbeing of all. This policy targets residents 
with adverse health effects or a concrete disease caused by 
their living situation. The identification of pollutants and 
subsequent improvement of the building helps a fair 
transition with regard to vulnerable (health affected) groups. 
The fact that the CRIPI unit is extended to vulnerable groups 
(especially children in schools, nurseries, recreational spaces) 
adds to that. 

Lessons learned 

•  Success factors (strength and opportunities) 

-  Evaluation of indoor pollutants and direct connection 

with health effects 

-  Education and training of staff 
-  Local guidance and information on local support 

programmes for renovation works 

-  Monitoring of findings and establishment of a database 

•  Challenges of implementation (weaknesses and threats) 

-  Renovation measures not always implemented 
-  Assessment has to be initiated by a doctor’s request, 
meaning evaluation is not precautionary but only 
when health is already affected 

Synergies 

Bibliography 

No 

[1]  Plan  Régionale  Air-Climate-energie.  Bruxelles  Environnement 
(2016). 

https://document.environnement.brussels/opac_css/elecfile/PLAN_A
IR_CLIMAT_ENERGIE_FR_DEF.pdf 

Bruxelles 

[2] 
CRIPIhttps://environnement.brussels/thematiques/air-
interieur/depolluer-son-interieur/cripi 

Environnement 

website. 

[3]  CRIPI  -  an  environmental  diagnosis  tool  for  indoor  pollution, 
complement  to  medical  diagnosis  (2015).  Bruxelles  Environnement 
https://document.leefmilieu.brussels/opac_css/doc_num.php?explnu
m_id=6433 

46 

 
 
 
 
 
  
Annex III: Good practice examples 

5.2  California (US) - Healthy Housing Rewards (Fannie Mae) 

Policy/initiative 

Fannie Mae Healthy Housing Rewards, California, US 

Location 

Start year 

Status  

National level 

2018  

Ongoing 

Building types 

Residential multi-family buildings 

Type of policy 

Short description 

Financing  incentive  scheme  for  healthy  building  design  and  health 
services for residents 

The  Federal  National  Mortgage  Association  (FNMA),  also  known  as 
Fannie Mae, is a company sponsored by the US government. With the 
Healthy  Housing  Rewards,  Fannie  Mae  provides  financial  incentives 
(discounted  loans)  to  lenders  who  incorporate  health-promoting 
design  and  residents’  services  in  their  new  or  renovated  affordable 
multi-family buildings. The properties must be Fitwell certified, a US 
building health certification system [3]. The  rewards  system follows 
two options: 

Healthy Housing Rewards Healthy Design:  

•  Strategies to improve indoor air quality 
•  Features encouraging physical activity  
• 

Includes common space, community gardens, playgrounds or 
exercise facilities 

•  US$6,000 for Fitwell certification 

Healthy Housing Rewards Enhanced Resident Service: 

• 

If the property offers resident services to improve health and 
stability of users (health and wellness programmes, food 
access, youth education, work and financial capability 
support, housing stability support) 

•  US$5,500 Certified Organization for Resident Engagement 

and Services (CORES) sponsor certification  

•  US$750 Enhanced Resident Services (ERS) property 

certification costs paid by Fannie Mae [1] 

The  rewards  system  is  eligible  for  multifamily  affordable  housing 
properties with rent or income restrictions in place (at least 60% of 
tenants are low income groups with 60% of  area median income or 
less) [2]. 

No information 

energy 

Primary 
savings  
CO2 emission savings  No information 
No information 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No information 

•  Transferability: Theoretically transferable to other housing 
companies or financial institutions; could be transferred to 
low-income private homeowners who incorporate aspects of a 
healthy building design (not necessarily limited to rental 
properties); collaboration between lenders and certification 
system needs to be established (possibility to ensure 
compliance with WELL certification system) 

•  Administration: By the private mortgage association Fannie 

Mae, nationwide 

47 

 
 
 
Matching  EU  policy 
framework 

Annex III: Good practice examples 

•  Compliance checks: Buildings have to be Fitwel certified 

(certification system committed to building health), expenses 
are covered by Fannie Mae 

A similar financial incentive targeting healthy building design could be 
implemented  within  the  frame  of  the  Smart  Finance  for  Smart 
Buildings  initiative.  As  the  initiative  aims  at  mobilising  private 
resources for an uptake of energy-efficient buildings, a cheaper loan 
could motivate lenders to invest in the health and wellbeing of building 
users. 

Another option is to incentivise healthy building design connected to 
certified  buildings  under  the  NextGeneration  EU  (Recovery  facility) 
and other EU funding streams. 

Address 

Improve health and wellbeing:  

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
to 
access 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

•  The Fannie Mae incentive programme directly improves the 

health and wellbeing of residents in affordable multifamily 
buildings. The Healthy Design Rewards scheme ensures a 
good indoor air quality and the establishment of community 
spaces that increase the wellbeing of users. The Healthy 
Housing Resident Services scheme goes beyond the building 
features and offers access to healthy food, wellness and 
recreational activities 

Secure fair transition:  

•  The Healthy Housing Rewards programme targets affordable 

apartment buildings that address low income groups  

•  Success factors, strength and opportunities 

-  Financial incentive for healthy affordable housing targets 

vulnerable people 

-  Loan break subject to Fitwell (healthy housing) certification 

prevents false allocation of benefit 

-  Healthy Housing Enhance Resident Services goes beyond 
good indoor air quality but offers education support, 
recreational spaces and other wellbeing-promoting features 

•  Challenges of implementation (weaknesses and threats) 

-  Private sector initiative, no information on costs or energy 

savings 

Not applicable 

[1] Fannie Mae (2020). About Healthy Housing Rewards. Fannie Mae 
Website. 
https://multifamily.fanniemae.com/financing-options/specialty-
financing/healthy-housing-rewards  
[2] Fannie Mae (2019). Frequently Asked  Questions (FAQs)  Healthy 
Housing Rewards™ Healthy Design. 
https://multifamily.fanniemae.com/media/8486/display  
[3] Fitwell website, US healthy building certification scheme. 
https://www.fitwel.org  

48 

 
 
 
 
 
 
 
Annex III: Good practice examples 

5.3  California (US) - Green Building Ordinance, San Mateo 

Policy/initiative 

Green Building Ordinance, San Mateo (US)  

Location 

Start year 

Status  

Building types 

Regional level (County of San Mateo, California, US) 

2008 

Ongoing 

New  and  renovated  residential  buildings  and  commercial  buildings 
>3000 m² 

Type of policy 

Mandatory building certification system 

Short description 

Chapter 14 of Division VII of the San Mateo County Ordinance Code 
(California, US) [1] includes a green building programme to enhance 
public  health  and  welfare  by  encouraging  green  building  measures. 
Measures, among others, are to increase energy efficiency and lower 
energy usage as well as to promote a healthier indoor environment.  

homes, 

houses) 

low-rise  multi-family 

The  ordinance  regulates  that  all  new  residential  buildings  (single-
/two-family 
or 
alterations/renovations of > 50% have to be LEED certified or receive 
50  GreenPoints  or  more  on  the  appropriate  GreenPoint  Rated 
Checklist  (GreenPoint  Rated  is  the  building  certification  system  of 
“Built  It  Green”,  a  non-profit  organisation  publishing  green  building 
guidelines  in  the  US  [5]).  With  a  GreenPoint  Rated  at  75  points  or 
higher  or  a  LEED  for  Homes  certification  the  processing  of  building 
permits can be expedited, and with 100 points or higher or LEED for 
Homes  certification,  a  guaranteed  building  inspection  within  two 
working days is provided [1].  

New  commercial  and  industrial  buildings  of  >3000m²,  including 
alterations,  also  have  to  prove  that  they  will  be  LEED  certified  to 
receive  a  building  permit.  With  a  LEED  Silver  certification  building 
inspections within two working days of request are guaranteed [1].  

Other  US  counties  and  cities  have  implemented  similar  mandatory 
LEED certifications of new and altered buildings, e.g. the Bellingham 
city  council  in  Washington  state  which  requires  all  new  municipal 
buildings and renovations >5000m² to earn LEED Silver certification 
given that the city council provides a majority of the funding. Similar 
regulations for new municipal buildings are in place in Austin (Texas), 
Boston (Massachusetts) and Chicago (Illinois) [2]. 

In 2012, 404,000m² of floor space was LEED certified [3] 

energy 

Primary 
savings  
CO2 emission savings  No information 
No information 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No information 

Transferability:  building  certification,  including  a  strong  health  and 
wellbeing  category  assessment,  could  be  implemented  in  most 
countries.  Prerequisites  would  be  trained  and  qualified  staff  and  a 
green  building  council  and  regional/  local  authority  or  private 
company  to  implement  the  certification  process.  The  mandatory 
nature of private certification schemes is unlikely to be implemented 
in Europe due to the independence of public authorities. In California, 
the mandatory certification could be transferred to existing buildings 
undergoing renovations. 

49 

 
 
 
 
Annex III: Good practice examples 

Administration: The policy is administered on regional level by the San 
Mateo county council 

Compliance checks: Before issuing the final building permit completed 
certificates  from  Built  It  Green  or  LEED  must  be  submitted  to  the 
building  inspection  section.  Temporary  occupancy  can  be  granted  if 
the  certificates  are  not  provided  prior  to  a  final  building  permit 
inspection, requiring a US$5000 deposit.  

Complementary measures: The San Mateo green building ordinance 
regionally complements the 2007 CALGreen Californian green building 
standard code for residential and non-residential buildings [4]. 

Matching  EU  policy 
framework 

Mandatory inclusion and monitoring of health and wellbeing/thermal 
comfort aspects in energy performance certificates.  

Address 

Improve health and wellbeing: 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

•  The LEED Homes certification includes several minimum 

required indicators to be fulfilled, such as ventilation, radon-
resistant construction, air filtering and combustion venting. 
Given these have to the fulfilled to receive certification new 
residential buildings will have high health and wellbeing 
standards. The GreenPoint Rated system also includes 
indicators, like advanced mechanical ventilation for indoor air 
quality and installation of carbon monoxide alarms. 

Increased sustainable infrastructure in built environment: 

•  LEED building certification covers a resource-efficient design 
and construction of buildings, contributing to the objective of 
a sustainable built environment. LEED Zero certifies carbon-
neutral buildings. 

•  Success factors, strength and opportunities 

- 

Indoor environmental quality category in the LEED 
certification scheme 

-  GreenPoint Rated also includes indoor air 

quality/health category [5] 

-  Outreach to and education of building community is 
essential to securing their cooperation in a green 
building programme 

-  LEED training for county staff 

•  Challenges of implementation (weaknesses and threats) 

-  Focus on new buildings 

Not applicable. 

[1]  County  of  San  Mateo,  State  of  California,  Ordinance  4444.  An 
Ordinance  amending  Chapter  14  of  Division  VII  of  the  San  Mateo 
County Ordinance Code (Building Regulations), consisting of sections 
1401-1408,  modifying 
program. 
http://www.co.sanmateo.ca.us/vgn/images/portal/cit_609/51/53/13
38972748GreenBuildingOrdinance.pdf 

building 

green 

the 

50 

 
 
 
 
 
 
 
  
Annex III: Good practice examples 

[2] USGBC, WGBC & C40 (2015). Green Building City Market Briefs. 
https://www.c40.org/researches/c40-usgbc-and-wgbc-green-
building-city-market-brief-compendium  

[3]  Sustainable  San  Mateo  Council  (2013),  Indicators  for  a 
Sustainable 
2013  
http://www.sustainablesanmateo.org/wp-
content/uploads/2013/05/2013-Indicators-For-A-Sustainable-San-
Mateo-County.pdf  

San  Mateo 

Council, 

Annual 

Report 

[4]  Building  Standards  Commission,  CALGreen  (Titel  24,  part  11) 
https://www.dgs.ca.gov/BSC/Resources/Page-Content/Building-
Standards-Commission-Resources-List-Folder/CALGreen 

[5] 
https://www.builditgreen.org/greenpoint-rated 

GreenPoint 

Rated 

certification 

system 

51 

 
 
 
 
 
 
 
 
 
 
 
Annex III: Good practice examples 

5.4  Ireland – Warmth and wellbeing scheme 

Policy/initiative 

Warmth and Wellbeing Scheme, Ireland 

Location 

Start year 

Status  

Building types 

Local level (designated location may change) 

2016  

Ongoing 

Residential  buildings  (owner-occupied  or  rented  from  a  local 
authority/ approved housing association) 

Type of policy 

Grant 

Short description 

the  government's  Strategy 

The  Warmth  and  Wellbeing  Scheme  is  a  grant  scheme  launched  in 
to 
2016  as  a  pilot  under 
Combat Energy Poverty and the “Healthy Ireland Framework” by the 
Irish  government.  The  scheme  offers  free  deep  energy  upgrades  to 
energy-poor households for people diagnosed with chronic respiratory 
conditions for three years in a designated location (currently Dublin). 
The  initiative  is  led  by  the  Department  of  Communications,  Climate 
Action and Environment (DCCAE), in conjunction with the Department 
of  Health  and  the  Health  Service  Executive  (HSE)  and  administered 
by the Sustainable Energy Authority of Ireland (SEAI) [1].  

The free upgrades are available for children under the age of 12 and 
people  aged  55  and  over  who  live  in  households  receiving  a  fuel 
allowance  or  the  Irish  one-parent  family  payment  in  respect  of  the 
child  applying.  The  chronic  respiratory  disease  must  be  officially 
diagnosed by the HSE, which also has to approve the application. If 
an application is successful a dedicated SEAI team assesses the home 
and  recommends  energy  efficiency  upgrades.  Further,  a  survey 
identifies  which  energy  efficiency  measures  are  suitable  for  the 
building  and  users.  The  following  measures  are  covered  for  homes 
built before 2006 with up to €20,000 per household: 

•  Standard attic insulation and appropriate ventilation 
•  Wall insulation: cavity, internal wall and/or external wall with 

appropriate ventilation 

•  Boiler replacement as appropriate (oil or gas) 
•  Draught proofing as appropriate 
•  Other energy efficiency related upgrades where 

recommended. 

Contractors  have  to  be  listed  under  the  SEAI  Better  Energy  Homes 
Schemes  and  a  post-works  building  energy  rating  (Irish  energy 
performance certificate) is issued. 

energy 

Primary 
savings  
CO2 emission savings  No information 

No information 

Costs 

€20 million budget allocated [3] 
(€10 million available for 2017) 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

~400 homes were upgraded in 2016 and ~700 in 2017 

•  Transferability: the pilot scheme could be expanded 

nationwide in Ireland to benefit a higher number of residents 
depending on the budget allocated. Transferability to other 
European countries is possible but should take the share of 
chronic obstructive pulmonary disease (COPD) patients in the 
respective country into account. According to OECD health 
Ssatistics, Ireland has the highest COPD rate (2013) followed 

52 

 
 
 
 
Annex III: Good practice examples 

by Hungary and New Zealand [3]. Prerequisites are 
productive cooperation between health and energy 
departments and authorities and an effective application 
process.  

•  Administration: administered nationally by SEAI 
•  Compliance checks: energy efficiency measures are subject 
to the SEAI Better Energy Homes regulations including the 
list of qualified contractors. A post-works inspection issues a 
building energy rating and verifies that the measures 
installed are in accordance with SEAI’s technical specification 
and relevant standards and regulations. 

•  Complementary measures:The pilot scheme is launched 

under the Strategy to Combat Energy Poverty and adds to 
the other Better Energy Homes grants. No enabling measures 
exist. 

Energy  poverty:  The  pilot  scheme  directly  targets  vulnerable, 
energy-poor households that receive social benefits.  

Improve health and wellbeing: The main objective of the scheme 
is  to  improve  the  health  and  wellbeing  of  residents  with  chronic 
respiratory  diseases.  As  the  renovation  works  and  all  connected 
services  are  delivered  free  of  charge  to  people  with  adverse  health 
effects, the scheme directly improves health and wellbeing  of those 
residents. 

•  Success factors, strength and opportunities 

-  Approval through healthcare officials to assure the 

criteria are met 

-  All services (application process, assessment of 
building) are free for the homeowner/user 

-  Post-works building energy rating (EPC) 
•  Challenges of implementation (weaknesses and threats) 

-  Referral-based scheme, no direct application to SEAI 

possible 

-  Limited residents eligible 

The  free  deep  renovation  scheme  helps  to  phase  out  inefficient 
buildings (targeted and energy-poor households), thus addressing the 
strategic area of engaging transformation. 

by 

[1] SEAI (2018). Get a Free energy upgrade for your home and health. 
Booklet 
Ireland. 
https://www.seai.ie/grants/home-energy-grants/free-upgrades-for-
eligible-homes/warmth-and-wellbeing/2018-10-
WarmthWellbeingA5Booklet.pdf 

Sustainable 

Authority 

Energy 

the 

53 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve health and 

wellbeing 
•  Increased 

infra-
in  built 

sustainable 
structure 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

•  Secure 

transition 

of 

smart 
of 

fair 

•  Upgrade  of  urban 
context  (including 
to 
access 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

 
 
 
 
 
 
 
Annex III: Good practice examples 

[2] Straton, G. (2018). Healthy Ireland and the Warmth and Wellbeing 
Pilot  Scheme.  Energy  Action  European  Energy  Poverty  Conference 
2018. Presentation for the Health and Wellbeing Unit, Department of 
Health, Government of Ireland. 
https://energyaction.ie/ea/wp-content/uploads/2018/12/Greg-
Straton-HSE.pdf 
[3]  Department  of  Communications,  Energy  &  Natural  Resources 
(2016). A Strategy to Combat Energy Poverty, 2016-2019.  
https://www.dccae.gov.ie/en-
ie/energy/publications/Documents/5/A%20Strategy%20to%20Comb
at%20Energy%20Poverty%20-%20Web%20Version.pdf 

54 

 
 
 
 
 
 
 
Annex III: Good practice examples 

5.5  Ireland - Home Performance Index (HPI) 

Policy/initiative 

Home Performance Index (HPI) 

Location 

Start year 

Status  

National level 

2016 (second version HPI v2.0 from 2019) 

Ongoing  

Building types 

(New) residential buildings 

Type of policy 

Voluntary certification system 

Short description 

The Home Performance Index (HPI) is a voluntary certification system 
launched in 2016 in Ireland to complement  existing  schemes in the 
commercial sector, such as BREEAM and LEED. Developed by the Irish 
Green  Building  Council  (IGBC),  the  HPI  provides  a  quality  label  for 
sustainable  residential  development  while  promoting  health  and 
wellbeing aspects [1]. 

The  certification  scheme  is  built  on  five  categories  (Environment, 
Health  &  Wellbeing,  Economic,  Quality  Assurance  and  Sustainable 
Location) that are evaluated by 30 indicators, some of which require 
post-completion  performance  tests.  For  certification,  buildings  have 
to comply with minimum standards exceeding building regulation and 
be checked by a qualified HPI assessor [2].  

In 2019 the latest version was introduced with additional health and 
wellness performance criteria aligning it with WELL Building indicators 
to be approved under WELL Communities certification. The HPI v2.0 
includes  a  zero  carbon  standard  taking  operational  and  embodied 
carbon into account [1].  

Health  and  wellbeing  indicators  include  mechanical  ventilation, 
daylighting, sound insulation, risk of overheating, radiant asymmetry, 
low  VOC  specification  and  testing,  radon  testing,  water  quality  and 
walkable neighbourhood [2].  

To ensure a good performance in use, a post-completion evaluation 
after  12  months  is  carried  out  to  check  if  buildings  perform  as 
expected.  

Although designed initially for new homes only, the intention is that 
the  HPI  should  be  developed  further  for  all  housing,  using  the  key 
indicators to benchmark all buildings [3]. 

No information 

energy 

Primary 
savings  
CO2 emission savings  No information 
No information  

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

•  > 130 homes have been built and certified under the HPI 

system  

•  Another 2,150 being registered for certification in the 

construction phase 

•  Transferability: the certification could – as planned – be used 
for existing buildings as well to certify major renovations, 
which might require additional compliance checks and 
training of HPI sssessors. The expansion to other building 
types would overlap with the existing schemes, e.g. the LEED 
system.  

55 

 
 
 
Annex III: Good practice examples 

Some other countries have similar schemes, e.g. the DGNB system in 
Germany, though health and wellbeing indicators could be transferred 
to stress the importance of this category.  

•  Administration: administered nationally by the Irish Green 

Building Council 

•  Compliance checks: compliance with the numerous indicators 
is evaluated by certified HPI assessors before certification 
and 12 months post-completion to ensure appropriate in-use 
performance.  

•  Complementary measures: the certification scheme is aligned 
with the Irish national building regulation (Building Regulation 
TGD L 2019), EU CEN standards, European Commission’s 
Level(s), the Zero Carbon Standard by the International 
Living Future Institute and is approved under the WELL 
Building Standard as a WELL Community Rating.  

The  voluntary  certification  scheme  complements  the  Irish  EPC  by 
going beyond the building regulation. 

Matching  EU  policy 
framework 

HPI  indicators  could  be  integrated  into  national  EPCs  to  include  the 
health  and  wellbeing  category  more  thoroughly  (as  for  example  is 
already done in Portugal). 

Address 

Improve health and wellbeing: 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

•  HPI-certified buildings can improve the health and wellbeing 

of residents as the scheme covers indoor air quality, 
ventilation, noise prevention, VOC and radon testing as well 
as water quality. As the certification system currently mostly 
covers new buildings an improvement doesn’t necessarily 
happen but good health of the building users can be 
maintained. 

Increased sustainable infrastructure in built environment: 

•  The HPI v2.0 launched in 2019 introduced a net zero carbon 
standard through combining exemplary credits in various 
criteria (energy in use, carbon in use, embodied impacts of 
homes and LCA, post-occupancy evaluation). Further, the 
health and wellbeing indicator “summer and winter comfort” 
ensures that homes are designed to avoid overheating in 
summer months and are resilient to temperature extremes 
due to climate change over their lifetime.   

Upgrade of urban context: 

•  The additional category of sustainable location with the 

indicators of options for transportation (accessibility of public 
transport, availability of low emission transport options, 
availability of walking and bicycle paths) and access to 
amenities (parks and open spaces, education, medical care 
etc.) adds a dimension of the urban context of the building 
and sustainable mobility to the certification. 
•  Success factors, strength and opportunities 

-  Comprehensive categories and indicators (including 

mandatory minimum requirements) 
-  Post-occupancy performance check 

•  Challenges of implementation (weaknesses and threats) 

-  Private initiative, not mandatory 

Synergies 

The  broad  range  of  categories  and  indicators  also  affects  other 
strategic  areas,  such  as  district  sustainable  built  environment  and 
adaptation as well as clean and sustainable mobility (see above). 

Bibliography 

[1] Home Performance Index (HPI) website 

56 

 
 
 
 
Annex III: Good practice examples 

http://homeperformanceindex.ie 
[2] IGBC (2019). Home Performance Index (HPI) Technical Manual - 
Version 2.0. Horizon 2020 funded.  
http://homeperformanceindex.ie/wp-content/uploads/2020/01/HPI-
Technical-Manual-v2.0.pdf 
[3] IGBC (2018). Creating an energy efficient mortgage for Europe – 
Building assessment briefing: Ireland 
https://www.worldgbc.org/sites/default/files/EeMAP_Building_Assess
ment_Briefing_IRELAND.pdf 

57 

 
 
 
 
 
 
 
Annex III: Good practice examples 

5.6  Poland – Clean Air Programme 

Policy/initiative 

Clean Air Programme Poland 

Location 

Start year 

Status  

National level 

2018 (planned until 2029) 

Ongoing  

Building types 

Single-family residential buildings 

Type of policy 

Grant 

Short description 

The  Polish  Clean  Air  Programme  aims  at  improving  air  quality  and 
reducing  GHG  emissions  from  the  residential  building  sector  by 
replacing  fossil  fuel  heat  sources  and  supporting  the  financing  of 
energy efficiency improvements of single-family residential buildings.  

The financing of the energy efficiency and renewable energy measures 
combines  grants  (funded  by  the  National  Fund  for  Environmental 
Protection  and  Water  Management  (NFOŚiGW)  and  the  Provincial 
Fund for Environmental Protection and Water Management in Warsaw 
(WFOŚiGW))  with  bank  loans  to  municipalities  and  the  Polish 
thermomodernisation tax relief.  

Support can be  obtained by building owners and co-owners with an 
annual  income  not  exceeding  PLN  100,000  (€22,650)  for  the 
replacement  of  an  ineffective  heat  source  with  solid  fuel  and  for 
energy  efficiency  improvement  measures,  e.g.  thermal  insulation  of 
the  building  envelope,  replacement  of  windows,  external  doors,  hot 
water  installation,  the  use  of  mechanical  ventilation  with  heat 
recovery and the application of renewable energy sources. Grants are 
given out for projects between 7,000 and 53,000 PLN. Energy audits 
are covered up to 100% while the costs for new heating installation 
are  co-financed  at  45-50%  with  a  maximum  of  €5,700  for  a 
replacement of a solid fuel heating system with a heat pump (up to 
€6,800 with PV). An increased level of funding is granted for building 
owners  with  a  low  income  (up  to  €450  per  month  for  a  single 
household) with funding levels of up to 75% (max. €8,400). 

As of March 2019, 24,150 applications for works in existing building 
were submitted and close to 10,000 for new buildings. 

After  initial  criticism  by  the  European  Commission  the  design 
(administration, application process, involvement of private banking 
sector) was adapted with the second edition of the programme in May 
2020 [6]. 

Primary 
savings  

energy 

•  37,500 GWh/year saved (final energy consumption) [1] → 

4.8 % of total 2030 target (based on 2030 target according 
to draft NECP saving 770,000 GWh (66.2 Mtoe)) 

CO2 emission savings 

The assessment of the progress made by Member States towards the 
national  energy  efficiency  targets  for  2020  (EU  COM  (2019)  224) 
states  that  final  energy  consumption  has  not  fallen  in  Poland  since 
2005.  

•  14 000 000 t CO2 saved per year (whole programme) [1] 
•  Poland emitted 413,781,000.40 tonnes of CO2 in 2017 (OECD 

GHG emissions statistics) 

Costs 

PLN 103 billion (€23.4 billion) total budget from 2018 – 2029 [3]. 

2018-2019:  80,000  applications  for  a  total  amount  of  over  PLN  1.8 
billion (€409 million) of grants and loans [3]. 

58 

 
 
 
 
Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Annex III: Good practice examples 

Total 

Objective  to  renovate  three  million  buildings  over  the  length  of  the 
programme (10 years)  
Context: 
12.1  million 
(https://ec.europa.eu/energy/eu-buildings-database_en)  meaning 
25%  of  detached  residential  buildings  are  planned  to  be  renovated 
(current  “medium”  renovation  rate  at  1.5%,  0%  deep  renovations 
according to JRC (2019)) 

single-family 

dwellings: 

•  Transferability: the main objective of the programme is to 

improve the national air quality which is among the worst in 
Europe due to a high share of coal-fired power plants and old 
heating installations in residential buildings [4]. 
Transferability is possible to (neighbouring) countries with 
similar energy structure (high share of coal power plants 
leading to high levels of air pollution). 

•  Administration: the programme is administered nationally by 
the National Fund for Environmental Protection and Water 
Management with the help of local authorities. 

•  Compliance checks: compliance controlled by National Fund 

for Environmental Protection and Water Management and the 
Provincial Fund for Environmental Protection and Water 
Management in Warsaw during and after the works. 

•  Complementary measures: since 2020, integration with the 
“My Electricity” programme, enabling applicants to obtain a 
grant of up to 5,000 PLN for installing a photovoltaic power 
generation system, without the need to submit two separate 
applications. 

Matching  EU  policy 
framework 

ESI funds  
Funding  mobilised  under  Renovation  Wave  (dedicated  to  countries 
with high air pollution and high levels of energy poverty) 

Address 

Energy poverty: 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

•  The scheme explicitly targets low income groups with old, 
polluting heating systems and grants higher amounts of 
funding to building owners with very low income.  

Improve health and wellbeing: 

•  As the main objective of the scheme is to exchange old, coal-
fired heating system to improve the local air quality, the 
programme tackles the adverse health effects of the high 
level of air pollution in Poland. Also, additional 
thermomodernisation works improve the health and wellbeing 
of residents. 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
to 
access 
sustainable 
mobility) 

Lessons learned 

•  Success factors, strength and opportunities 

-  Support by municipal staff to fill out and verify 

applications (after initial criticism, changed in the new 
edition from May 2020) 

-  Expanded distribution network to over 650 

municipalities with second edition of the programme  

59 

 
 
 
 
Synergies 

Bibliography 

Annex III: Good practice examples 

-  Amount of grant and share of financial support 

determined by household income [1] 

-  Simplified application process (now online) and 
shorter process time (30 days) from 2020 

•  Challenges of implementation (weaknesses and threats) 
-  Administration via national and regional fund, not 
effective; criticism on poor distribution by the 
European Commission in the beginning due to design 
of the scheme [6] 

-  One-third of the budget goes to new buildings, not 

replacing any old heating systems thus not addressing 
the objective [6] 

-  No commercial banks involved in the beginning 

(changed from May 2020) 

[1]  Programme  details.  Official  government  website  (2020) 
https://czystepowietrze.gov.pl/wp-
content/uploads/2020/04/Program-Priorytetowy-Czyste-
Powietrze.pdf  
[2]  Status  of  implementation  Clean  Air  Programme  and  outlook 
implementation by 2030, presentation from March 15, 2019. 
https://ec.europa.eu/energy/sites/ener/files/documents/mslupeczan
ska_-
_stan_realizacji_pp_czyste_powietrze_i_perspektywy_jego_wdrozeni
a_do_roku_2030.pdf  
[3]  Polish  government  website,  “The  Clean  Air  programme  was 
launched a year ago” 
https://www.gov.pl/web/climate/the-clean-air-programme-was-
launched-a-year-ago 
[4] Report from the Commission to the European Parliament and 
the Council (2018) 2018 assessment of the progress made by Member 
States  towards  the  national  energy  efficiency  targets  for  2020  and 
towards  the  implementation  of  the  Energy  Efficiency  Directive  as 
required  by  Article  24(3)  of  the  Energy  Efficiency  Directive 
2012/27/EU 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52019DC0224&from=EN  
[5] World Bank (2019) The fight for clean air in Poland requires both 
knowledge 
determination. 
and 
https://blogs.worldbank.org/europeandcentralasia/fight-clean-air-
poland-requires-both-knowledge-and-determination 
[6]  EURACTIV  (2019)  Poland’s  multi-billion-euro  clean  air  quest  in 
peril. 
https://www.euractiv.com/section/air-pollution/news/polands-multi-
billion-euro-clean-air-quest-in-peril  

60 

 
 
 
 
 
 
 
 
 
Annex III: Good practice examples 

5.7  Portugal – Energy Certification of Buildings and IAQ EPC  

Policy/initiative 

Certificado de Desempenho Energético e da Qualidade do Ar Interior 

Energy Certification of Buildings and Indoor Air Quality, Portugal 

Location 

Start year 

Status  

National level 

2013 

Ongoing 

Building types 

Residential and non-residential buildings  

Type of policy 

Energy performance certificate 

Short description 

The Energy Certification of Buildings and Indoor Air Quality in Portugal 
presents  a  good  practice  example  of  the  energy  performance 
certificate  (EPC)  required  by  European  legislation.  The  latest 
amendment of the Portuguese energy certification regulation of 2013 
(Decree-Law no. 118/2013, of 20 August) transposed the 2010 EPBD 
recast  into  national  law.  Since  2006,  indoor  air  quality  components 
were included in the EPC. Indoor air quality parameters regulated by 
the  certification  scheme  are  carbon  monoxide,  carbon  dioxide, 
formaldehyde, and fungal as well as relative humidity, volatile organic 
compounds, particulate matter and ozone. 

Different requirements apply to EPCs for existing and new buildings in 
the  residential  and  non-residential  (commercial  and  service)  sector 
[2]. With the new 2013 decree, only 8 energy classes (A+ to F) are 
valid and there is an obligation to display the energy certificate in all 
non-residential buildings with areas greater than 250m² and to certify 
all public buildings with areas greater than 250m². In addition, any 
residential or service building that initiates a process or intention to 
sell or lease must have a valid  EPC and indicate the energy class in 
the advertisement [3]. The Portuguese EPCs are valid for 10 years or 
6-8  years 
residential  and  commercial/service  buildings 
respectively.  

for 

A  new  calculation  methodology  was  introduced  with  the  2016 
roadmap  preventing  a  clear  comparison  of  the  real  energy 
consumption of buildings calculated according to the old methodology. 
Consumers  do  not  have  enough  information  or  knowledge  to 
understand the differentiation [3]. 

The  energy  efficiency  certification  scheme  website  provides  a  clear 
overview of national statistics, including the ratio of EPC scores in all 
Portuguese regions and the amount of measures implemented [3]. 

energy 

Primary 
savings  
CO2 emission savings  No information 

No information 

Costs 

1.3 million EPCs issued by 2018 (90% in residential buildings) (iBRoad 
Factsheet)  of  ~  6.9  million  buildings  (European  Building  Stock 
Observatory) → ~ 19% of buildings 

Increased 
rate and depth  

renovation 

Cost range for an EPC: €135-€465 

No information available 

Ease 
implementation 

of 

Transferability: under the EPBD, all Member States implement a form 
of EPC, though large discrepancies exist in the methodology, quality 
assurance and enforcement. The IAQ parameters could be included in 

61 

 
 
 
 
 
Annex III: Good practice examples 

the  EPCs  in  other  Member  States  with  appropriate  regulations,  a 
comprehensive  compliance  process  and  regular  testing.  Different 
European projects (Horizon 2020) are currently developing options for 
improved  EPCs,  including  the  integration  of  IEQ  features,  such  as 
comfort (see X-tendo project). 

Administration:  administered  nationally  by  ADENE,  the  Portuguese 
energy agency 

Compliance  checks:  the  “Quality  Verification  Scheme”  is  structured 
into two phases. The first is the prevention phase which takes place 
before the EPC is issued and includes an on-site visit and automatic 
database  control.  The  second  phase  is  the  correction  phase,  taking 
place after the EPC has been issued.  

Complementary  measures: 
the  Energy  Efficiency  Buildings 
Certification  Scheme  is  complemented  by  other  policy  initiatives. 
These include the energy labelling of installations and products with 
the  voluntary  CLASSE+  certification  and  the  online  portal  casA+. 
CLASSE+  indicates  how  energy  efficient  building  products  are  (e.g. 
installations, windows, etc.). CasA+ functions as a one-stop-shop and 
centralises  all  relevant  information  about  the  building  in  one 
accessible  location  besides  providing  building  owners  with  potential 
renovation measures [1].  

The EPBD requires all EU Member States to implement national energy 
performance certificates in Article 11 and 12. 
The design and verification methodology differs a lot between Member 
States and prevents comparison and a harmonised quality assurance.  
The Renovation Wave could ensure a more stringent implementation 
of EPCs across EU countries and require more detailed features, such 
as indoor environmental quality (see Horizon 2020 projects X-tendo, 
QualDeEPC, U-Cert). 

Matching  EU  policy 
framework 

Address 

Improve health and wellbeing: 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

•  As all new, sold or let residential buildings have to issue an 

EPC and comply with the IAQ regulations, the building owners 
have the incentive to improve health and wellbeing aspects.  

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

•  Success factors, strength and opportunities 

-  High uptake, with more than 1.3 million EPCs issued 

and 19% of the building stock covered [6].  

62 

 
 
 
 
 
 
Annex III: Good practice examples 

-  Centralised database that provides insight into 
national and regional building performance and 
generates awareness amongst building owners and 
tenants.  

-  Link with other policy programmes like casA+ and 
CLASSE+ that enhances public awareness about 
energy efficiency.  

•  Challenges of implementation (weaknesses and threats) 
-  Lack of awareness amongst building owners [5]  
-  Training sufficient qualified experts that can perform 

energy audits [5]  

-  Privacy issues related to public EPC databases [9]  
-  The calculation methodology has changed drastically 
in the past 10 years. As a result, buildings that were 
certified in 2010 will receive a significantly different 
score in terms of primary energy use and emissions. 
This might cause confusions about actual energy 
performance and might deteriorate trust in the rating 
[10].  

The digital EPC and linked to online platforms like casA+ rely on digital 
infrastructure  and  contribute  to  the  digitalisation  of  the  building 
sector.  

[1] Adene website “Energy Efficiency of Buildings” 
 https://www.adene.pt/edificios  
[2] Energy performance certificates website 
https://www.sce.pt/estatisticas  

[3] Vaquero (2019). Buildings Energy Certification System in 
Portugal: Ten years later. Available online at International 
Conference on Energy and Environment Research, ICEER 2019, 22–
25 July, University of Aveiro, Portugal 
https://reader.elsevier.com/reader/sd/pii/S235248471930472X?tok
en=46FCBA9CA9FEED9A192792BE6079E4F7F140B2B38AA262ECD4
627A5BE92F178F386A209D1D0DA7FDB24218D3AC699437  

[4] https://www.odyssee-mure.eu/publications/national-
reports/energy-efficiency-portugal.pdf  

[5] http://ccap.org/assets/CCAP-Booklet_Portugal.pdf  

[6] http://ibroad-project.eu/wp-
content/uploads/2018/01/iBROAD_CountryFactsheet_PORTUGAL.pdf
[7] https://www.adene.pt/Files/flipbook/ADENE-PAO-2019-
2021/mobile/index.html  

Synergies 

Bibliography 

63 

 
 
 
 
Annex III: Good practice examples 

5.8  Denmark – National building regulations (BR18) 

Policy/initiative 

Building regulations for thermal indoor climate, Denmark  

Location 

Start year 

Status  

National level 

2018 

ongoing 

Building types 

Residential and non-residential buildings 

Type of policy 

Regulation (Building code) 

Short description 

The  latest  Danish  building  regulations  (BR18)  include  specific 
requirements  related  to  good  indoor  environmental  quality  (IEQ), 
covering chapters on noise, light and thermal indoor climate [1].  

Chapter 17 requires “satisfactory noise conditions in terms of health 
and  comfort”.  Noise  from  buildings’  technical  installations  and  from 
traffic must be considered as well sound transmission between rooms 
(Chapter  17,  §368,  2).  §368,3  states  that  documentation  on  noise 
conditions can be obtained by calculation or measuring in the finished 
building. Noise levels for residential units must be in accordance with 
call C in “DS 490 Sound classification of residential units” [1]. For non-
residential  buildings,  noise  specifications  are  determined  in  the 
“Guidelines in the building regulations on sound conditions”. 

Chapter  18  requires  that  buildings  “must  have  light  conditions  that 
ensure  that  no  risk  will  occur  to  the  health,  safety  and  comfort  of 
people” and daylight “must be utilised as a source of light to the extent 
it  is  possible”.  The  planning  and  construction  regarding  daylight  is 
subject to the “Guidelines of Transport, Building and Housing Agency 
on light and view of the surroundings” (Chapter 18, §379). §382-384 
specify  the  use  of  electric  light,  including  the  obligation  to  test  the 
lighting system before it is put into use. 

Chapter  19  outlines  the  general  provisions  for  the  indoor  thermal 
climate  and  inspection,  operation  and  maintenance  of  heating  and 
cooling installations. §386 specifies that “In rooms where persons stay 
for  a  longer  period  of  time,  it  must  be  ensured  that  a  satisfactory 
thermal indoor climate can be maintained during the intended use and 
activity and relevant calculation documentation must be obtained for 
buildings” [1]. Installations for heating and cooling systems must be 
carried  out  so  that  they  have  sufficient  capacity  to  ensure  specified 
temperature  conditions  all  year  round.  The  thermal  comfort  is 
determined from the connection between the thermal indoor climate 
and  the  human  activity  and  clothing  (Specification  and  verification 
following DS 474 Standard for specification of thermal indoor climate 
and  DS  /  EN  ISO  7730).  The  installation  of  heating  and  cooling 
systems  must  comply  with  DS  469  Heating  and  cooling  systems  in 
buildings,  ventilation  systems  with  DS  447.  §390  determines  the 
energy consumption in accordance with DS 452 Thermal insulation of 
technical installations. 

Chapter 22  specifies requirements for ventilation for satisfactory air 
quality. 

energy 

Primary 
savings  
CO2 emission savings  No information 

No information  

Costs 

No information 

64 

 
 
 
 
 
Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Annex III: Good practice examples 

No information 

•  Transferability: more EU countries could implement IEQ 

details into their building codes. 

•  Administration: administered nationally by the Ministry of 

Transport, Building and Housing as part of their national 
building regulations (BR18). 

Matching  EU  policy 
framework 

The  Renovation  Wave,  with  a  focus  on  improved  IEQ,  could 
communicate  the  Danish  example  of  specified  IEQ  determinants  in 
building  regulations  as  a  good  practice  example.  The  EPBD  could 
require details on how to improve indoor air quality. 

An indoor comfort feature in EPCs could involve those aspects that are 
already required by the Danish building regulations to be implemented 
in other Member States. 

Address 

Improve health and wellbeing: 

•  The strong focus on good indoor environmental quality in new 
buildings in Denmark tackles the objective of improved health 
and wellbeing directly. The mandatory consideration of 
daylight, noise and indoor thermal climate is a prerequisite 
for a healthy indoor climate in both residential and public 
buildings.  

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

•  Success factors, strength and opportunities 

-  Mandatory requirements and performance checks  
-  Specific guidelines on national conditions with exact 
requirements on noise, daylight, ventilation and 
thermal comfort 

•  Challenges of implementation (weaknesses and threats) 
-  Lack of compliance and mandatory checks 
-  Lack of detailed specifications and actions 

Not applicable 

[1]  Danish  Ministry  of  Transport,  Building  and  Housing  (2018). 
Executive Order No. 1615 of 13 Dec. 2017, January 2018.  
https://bygningsreglementet.dk/~/media/Br/BR-
English/BR18_Executive_order_on_building_regulations_2018.pdf 

[2]  Danish  Ministry  of  Transport,  Building  and  Housing  (2018). 
Buidling  regulations,  Thermal  indoor  climate  and  installations  for 
heating and cooling systems (§ 385 - § 392) 

65 

 
 
 
 
 
 
 
 
Annex III: Good practice examples 

https://bygningsreglementet.dk/Tekniske-
bestemmelser/19/Vejledninger/Termisk-indeklima 

[3] Energy Requirements BR18 – A quick guide for the construction 
industry on the Danish Building Regulations 2018 
https://www.byggeriogenergi.dk/media/2202/danishbuildingregulati
ons_2018_energy-requirements.pdf  

66 

 
 
 
 
 
 
 
 
Annex III: Good practice examples 

5.9  Sweden - Grant for radon remediation for homeowners 

Policy/initiative 

Radon grant, Sweden 

Location 

Start year 

Status  

National level 

2018 

Ongoing 

Building types 

Detached residential buildings 

Type of policy 

Grant 

Short description 

In 2018 the Swedish National Board of Housing, Building and Planning 
adopted  a  regulation  on  subsidies  for  measures  to  reduce  radon 
contamination  in  detached  houses  (Regulation  2018:  7).  The  policy 
determines the volume of subsidies paid for radon elimination in small 
one- and two-family houses. 

Due to the high radon levels among Swedish residential buildings, the 
government decided to fund 50% of reasonable costs (up to €2,500) 
of  radon  decontamination.  In  2020,  the  overall  budget  amounts  to 
SEK 34 million (€3.3 million). The removal of radon in living spaces 
improves  the  indoor  air  and  the  residents’  health  as  radon 
contamination  above  200  Bq  (becquerels)  /  m³  can  cause  health 
issues (e.g. increased risk of lung cancer). Tests are initiated by the 
building owner or the landlord and can be supported by the respective 
municipality  (public  health  office).  According  to  the  Swedish 
Environmental Code, the municipality can also demand radon checks 
if findings suggest inconveniences for human health.  

Sweden's  national  accreditation  body,  Swedac,  lists  accredited 
companies that measure radon in the air. An expert has to measure 
the  indoor  radon  content  and  recommend  measures  to  alleviate 
radon,  such  as  ventilation  measures,  sealing  against  the  ground, 
installing  radon  suction  or  constructing  a  radon  well.  The  ordinance 
2018:158 presents how to carry out measurements: to determine an 
annual  average,  tests  are  to  be  conducted  for  at  least  two  months 
during the heating season, in at least two rooms used every day. The 
testing has to be done with calibrated instruments, and applicants are 
recommended  to  follow  the  Swedish  Radiation  Safety  Authority’s 
measurement method.  

energy 

Does not necessarily save energy as not the objective 

Primary 
savings  
CO2 emission savings  Does not necessarily save CO² emissions as not the objective 
Grant budget of €3.3 million in 2020 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No information  

•  Transferability: possible to countries with high radon levels 

possible  

•  Administration: grant administered on national level, 

supported by municipalities (supervisory responsibility to 
check compliance with regulation (building code states that 
radon levels have to be below 200 Bq/ m³).  

•  Compliance checks: testing by accredited expert (listed with 

Swedac, the national accreditation body) 

No legal requirement for regular checks but it is recommended to do 
radon tests  once a house is  sold  or altered, when the ventilation or 
heating system is changed, or after 10 years. 

67 

 
 
 
 
Annex III: Good practice examples 

•  Complementary measures: the Swedish building regulations 
BFS 2011:6 with amendments up to BFS 2018:4 regulate in 
Article 6:23 that the “annual activity concentration of radon 
in the indoor air must not exceed 200 Bq/m³”. 

Matching  EU  policy 
framework 

Address 

Improve health and wellbeing: 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

•  The main objective is the financial support of radon 
alleviation thus improving the residents’ health.  

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

•  Success factors, strength and opportunities 

-  Direct funding of radon decontamination measures 
-  Comprehensive information on radon contamination 

on government websites 

•  Challenges of implementation (weaknesses and threats) 

Not applicable 

[1] Website of the National Board of Housing, Building and Planning. 
Apply for radon susidies.  

https://www.boverket.se/sv/bidrag--garantier/radonbidrag/  

[2] Website of the National Board of Housing, Building and Planning. 
Check the radon content.  

https://www.boverket.se/sv/byggande/halsa-och-
inomhusmiljo/radon/  

[3] Swedac. List of accredidated companies.  

https://search.swedac.se/sv/ackrediteringar?s=aktivitetsm%C3%A4
tning  

[4] Swedish Radiation Safety Authority. Supervisory guidance radon 
– homes and premises to which the public has access 

https://www.stralsakerhetsmyndigheten.se/publikationer/handbocke
r/tillsynsvagledning-radon--bostader-och-lokaler-dit-allmanheten-
har-tilltrade/  

68 

 
 
 
 
 
 
 
 
 
Annex III: Good practice examples 

5.10  Sweden - Obligatory ventilation control for housing 

Policy/initiative 

Obligatory ventilation control, Sweden 

Location 

Start year 

Status  

Building types 

National level 

1991 

Ongoing  

Residential, public and office buildings (except for houses with S or F 
ventilation) 

Type of policy 

Regulation 

Short description 

The  Swedish  Planning  and  Building  Act  (2010:900),  Chapter  8, 
section 25 regulates the regular checking of ventilation systems for 
most buildings depending on the type of ventilation.  

The Planning and Building Act as well as the Planning and Building 
Ordinance (2011:338) require the owner of a building to ensure “the 
function of the ventilation system in the building is checked before 
the system is used for the first time (first inspection) and thereafter 
regularly  on  recurring  occasions  (recurring  inspection)”  in  order  to 
maintain  “a  satisfactory  indoor  climate”  (Chapter  5.1).  Municipal 
building committees are required according to Chapter 12, Section 1 
to  check  compliance  with  the  obligatory  ventilation  control.  The 
controller  must  also  provide  suggestions  on  how  to  reduce  energy 
consumption for ventilation without this giving rise to a poorer indoor 
environment. 

One- and two-family homes with fan (F) or natural (S) ventilation are 
excluded from the requirement according to Chapter 5, section 1.  

The  inspections  have  to  be  carried  out  at  3-  or  6-year  intervals 
depending on the type of buildings: 

•  Three years: Preschools, schools, care facilities regardless of 

ventilation system and apartment and office buildings with FT 
(mechanical supply and exhaust air ventilation) and FTX (fan-
controlled supply and exhaust air system with heat recovery) 
ventilation  

•  Six years: Apartment and office buildings with F, FX 

(mechanical exhaust air ventilation) and S ventilation. 

No information 

energy 

Primary 
savings  
CO2 emission savings  No information 
No information 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No information  

•  Transferability: mandatory ventilation control regulations can 

be transferred to other countries which have to comply with 
the EPBD regulations 

•  Administration: administered locally by the installed 

municipal building committees  

•  Compliance checks: qualified experts to carry out ventilation 

controls must be accredited and are listed on a central 
website (Boverket); the municipalities may apply financial 
penalties if inspection intervals are not followed 

•  Complementary measures: complements the ventilation 

regulation set out in Sweden’s building code based on EU 
EPBD requirements 

69 

 
 
 
 
 
 
 
Annex III: Good practice examples 

Matching  EU  policy 
framework 

An  EPBD  revision  could  increase  ventilation  requirements  and 
improve  enforcement  of  existing  legislation  (Inspection  of  building 
installations, Article 15 EPBD) to improve air quality. 

Address 

Improve health and wellbeing: 

•  Energy poverty 
•  Improve  health  and 

wellbeing 
•  Increased 

•  A well-functioning ventilation system is essential for healthy 

indoor air quality.  

infra-
in  built 

sustainable 
structure 
environment 
(including  enhanced 
of 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

•  Secure 

transition 

fair 

•  Upgrade  of  urban 
(including 
to 

context 
access 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

•  Success factors, strengths and opportunities 

- 

Implementation and compliance checks by municipal 
committees at regular intervals according to building 
types and ventilation systems 

•  Challenges of implementation (weaknesses and threats) 

-  No connected information measures, building owners 

have to be aware of the funding possibilities 

Not applicable 

[1] Boverket´s building regulations – mandatory provisions and 
general recommendations, BBR (BFS 2011:6 with amendments up 
to BFS 2018:4)   
https://www.boverket.se/en/start/publications/publications/2019/b
overkets-building-regulations--mandatory-provisions-and-general-
recommendations-bbr  

[2]  Boverket  -  National  Board  of  Housing,  Building  and  Planning. 
(website) 
Obligatory 
https://www.boverket.se/en/start/building-in-sweden/swedish-
market/laws-and-regulations/national-regulations/obligatory-
ventilation-control  

Ventilation 

Control 

(OVK) 

the 
[3]  A  Handbook 
 https://www.boverket.se/sv/PBL-kunskapsbanken/regler-om-
byggande/ovk/ovk-besiktning  

Planning 

on 

and  Building  Act 

70 

 
 
 
 
 
 
 
Annex III: Good practice examples 

5.11   Umeå, Sweden – Grant for noise protection 

Policy/initiative 

Umeå noise grant, Sweden 

Location 

Start year 

Status  

Local level 

2015 

Ongoing  

Building types 

Residential buildings 

Type of policy 

Grant 

Short description 

Residents in the municipality of Umeå, Sweden who own a residential 
property can apply for a grant to finance the replacement of windows 
for  noise  protection  based  on  the  ordinance  (2015:  216)  on  traffic 
noise  in  residential  buildings  [1].  Homes  located  on  streets  are 
targeted as they are heavily affected by traffic noise. 

Grants are awarded if all of the following conditions are met: 

•  The property is exposed to road traffic noise above 70 dBA 

more than five times per night (10 pm – 6 am) 

•  The maximum indoor noise level exceeds 50 dBA before 

replacement measures. 

Or if all of the following conditions are met: 

•  The sound level (daily average) at the facade exceeds or is 

equal to 61 dBA free field value (calculated by the 
municipality according to the Nordic calculation model) 
•  The equivalent indoor noise level exceeds 35 dBA before the 

works. 

Grant  applications  are  prioritised  under  heavier  conditions  (e.g. 
exceeding  the  maximum  level  of  70  dBA  more  than  10  times  per 
night). 

The grants are allowed for buildings built before 1997, as for buildings 
built after this, the national buildings code’s noise regulations apply 
(National Board of Housing, Building and Planning) [2]. 

The  volume  of  the  grants  amounts  to  €183  (1,875  SEK)  per  m²  of 
window size which is only granted for windows facing the street side. 
The programme is administered by the ‘Street and parks’ department 
of the Umea municipality (who are also  responsible  for carrying out 
sound  measurements)  but  the  building  owner  is  responsible  for  the 
works (selection of contractor, implementing the schedule). It has to 
be  assured  that  the  ventilation  works  properly  after  the  window 
measures have been implemented [2]. 

After the measure, the equivalent indoor level may not exceed 30 dBA 
and  44  dBA  maximum  at  night.  Prior  to  the  payment,  control 
measurements must be carried out and approved by the municipality. 
The property owner must also have submitted a copy of the technical 
specification of the measures [2]. 

energy 

Primary 
savings  
CO2 emission savings  No information 

No information 

Costs 

Increased 
rate and depth  

renovation 

No information  

71 

 
 
 
 
 
Ease 
implementation 

of 

Matching  EU  policy 
framework 

Annex III: Good practice examples 

•  Transferability: possible to other countries depending on 

noise levels and capabilities on local level to measure as well 
as available financial resources.  

•  Administration: administered locally, by the ‘streets and 

parks’ department of Umea. 

•  Compliance checks: noise measurements after 

implementation of the window replacement works. 

•  Complementary measures: the grant scheme complements 

the national building code that regulates noise protection for 
buildings built after 1997.  

Possible  context  (not  building  renovation):  the  EU  Directive 
2002/49/EC  on  the  assessment  and  management  of  environmental 
noise  requires  Member  States  to  submit  noise  mapping  reports  for 
municipalities  of >100,000 inhabitants. From  31 December 2018, it 
has  been  obligatory  to  use  the  new  Cnossos-EU  (Common  Noise 
Assessment Methods in EU) assessment methods in connection with 
strategic noise mapping 
(http://www.swedishepa.se/Guidance/Guidance/Noise/Strategic-
noise-mapping-).  

The Renovation Wave establishing a stronger focus on IEQ, including 
noise  protection,  could  channel  financial  resources  to  similar  noise 
protection grants. 

Address 

Improve health and wellbeing: 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

•  The grant scheme aims at alleviating disturbances from traffic 
noise (road, train, air traffic) for residential buildings thus 
directly improving the wellbeing of the respective residents. 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

[1] Umeå municipality website, Noise protection grant 
https://www.umea.se/umeakommun/byggaboochmiljo/bullerochluft
kvalitet/buller/bullerskyddsbidrag.4.232bb3eb132b9e0c2ca8000680
80.html  
[2] Guidelines  for noise protection allowances for window measures 
at road traffic noise, Umeå municipality 
https://www.umea.se/download/18.5ec3fe241709e2c4377629c/158
3832579887/Riktlinjer%20bullerskyddsbidrag%2020200310.pdf  

72 

 
 
 
 
 
 
 
Annex III: Good practice examples 

5.12  US/International – WELL Building Standard 

Policy/initiative 

WELL Building Standard 

Location 

National level 

Start year 

2014 

Status  

Ongoing  

Building types 

Developed for institutional buildings, now also residential buildings 

Type of policy 

(Healthy) building certification scheme 

Short description 

The  International  WELL  Building  Institute  (IWBI)  launched  the  WELL 
Building Standard™ in 2014 as a performance-based building certification 
scheme  focusing  on  health  and  wellbeing  of  users.  Initially  targeted  at 
commercial and institutional buildings, the certification standard today can 
be  applied  across  many  sectors.  The  certification  criteria  are  air,  water, 
nourishment,  light,  fitness,  comfort  and  mind  that  are  measured  and 
monitored.  

The certification system is available in three project types in silver, gold and 
platinum certification: 
1. New and existing buildings 
2. New and existing interiors 
3. Core and shell 

The performance verification of the WELL Building Standard is subject to an 
on-site assessment by an authorised ‘WELL Performance Testing Agent’. 

The  standard  is  certified  by  the  Green  Business  Certification  Inc.  (GBCI), 
complementing the LEED building certification scheme that is implemented 
by the same company, developed in 1990 in the UK. 

In  Italy,  the  WELL  Building  Standard  is  promoted  through  a  collaboration 
between  APTA  VITAE  Trust,  an  Italian  non-profit  organisation,  and  IWBI 
since 2017. 

Primary 
savings  

CO2 
savings 

Costs 

energy 

No information 

emission 

No general information 

No information 

Increased 
renovation 
and depth  

rate 

Ease 
implementation 

of 

In  2020  4,395  projects  were  applying  the  WELL  standard  across  62 
countries.  

•  Transferability: the WELL Building Standard has already spread 

over multiple European and non-EU countries. IWBI has established 
partnerships with, e.g. the Blue Building Institute (Netherlands), 
and Polish Green Building Council (PLGBC). A further expansion to 
more countries is possible, depending on competition with already 
used certification schemes.  

•  Administration: the global certification scheme is administered by 

the Green Business Certification Inc. (GBCI). In Italy, it is 
administered nationally by cooperation between IWBI and the 
Italian APTA VITAE Trust.  

•  Compliance checks: the certification is issued based on an 

assessment of WELL accredited professionals. In 2018 nearly 300 
industry professionals were accredited in Europe [4]. 

•  Complementary measures: the WELL standard complements the 
LEED certification scheme that is administered by the same 

73 

 
 
 
 
  
Annex III: Good practice examples 

company, Green Business Certification Inc. (GBCI). GBCI 
administers several certification schemes, among others TRUE, a 
zero waste certification programme for businesses, and EDGE, a 
green building certification system focused on making buildings 
more resource-efficient. 

Matching  EU  policy 
framework 

Features  of  the  (private)  WELL  Building  Standard  could  be  replicated  to 
improve the next generation of EU EPCs. The dedicated wellbeing criteria, 
such as comfort and mind, and the connected indicators could be taken up 
in a further development and function as best practice for EPC design in the 
Member States. 

Address 

Improve health and wellbeing: 

•  WELL certified buildings improve the health and wellbeing of 

buildings users as they require certain IEQ standards to be fulfilled, 
e.g. mould control, limiting pollutants and contaminant 
concentrations as well as monitoring air quality and increasing 
ventilation (for all indicators see 
https://a.storyblok.com/f/52232/x/8c8027863e/well-v1-pdf-with-
2019-q1-addenda_0.pdf). 

•  Energy poverty 
•  Improve  health 
and wellbeing 

•  Increased 

built 

sustainable 
infra-structure 
in 
environment 
(including 
enhanced 
resilience 
building) 

of 

•  Increase  smart 
of 

readiness 
buildings 

•  Secure 

fair 

transition 

•  Upgrade 

of 
urban  context 
(including 
access 
sustainable 
mobility) 

to 

Lessons learned 

Synergies 

Bibliography 

•  Success factors, strength and opportunities 

-  Extensive list of indicators covering aspects of IEQ 
-  Accreditation process of WELL professionals, including a 

two-year maintenance period 

-  WELL certification guidebook as good practice guidance 

document 

-  Complementary nature of LEED and WELL (qualification of 

assessment overlaps) 

-  Collaboration on assessment methods between WELL and 

BREEAM certification 

•  Challenges of implementation (weaknesses and threats) 

-  Strong focus on commercial and office buildings 

[1] WELL Building Standard website https://www.wellcertified.com  
[2] Apta Vitae website https://www.aptavitae.com/en  
[3]  BusinessWire  website  (2018)  WELL  Building  Standard  gaining 
momentum in Europe. 
https://www.businesswire.com/news/home/20180518005447/en/Building-
Standard-Gaining-Momentum-Europe  

74 

 
 
 
 
 
 
 
 
Annex III: Good practice examples 

5.13  UK – BREAAM Certification scheme 

Policy/initiative 

BREEAM Certification System (UK) 

Location 

Start year 

Status  

Building types 

National level 

1990 

Ongoing  

Initially  office  buildings,  now  all  residential  and  non-residential 
buildings 

Type of policy 

Building certification system 

Short description 

BREEAM  is  a  method  of  assessing,  rating  and  certifying  the 
sustainability of new and existing buildings. Launched in 1990 in the 
UK, the Building Research Establishment Environmental Assessment 
Methodology  was  initially  developed  for  large  office  buildings  but  is 
now spread over almost all building types and used in the UK, Norway, 
Sweden,  Spain  and  the  Netherlands.  The  tool  aims  to  quantify  and 
reduce  the  environmental  burdens  of  buildings  by  rewarding  those 
designs that take positive steps to minimise their environmental and 
human health impacts. 

is 

typically  undertaken 

to  demonstrate  compliance  with 
It 
environmental  regulations  but  can  also  be  a  planning  requirement. 
There  are  different  categories  in  which  a  domestic  or  non-domestic 
project (in-use, new build or renovation) is assessed. An assessment 
must be undertaken by a qualified BREEAM assessor. 

for  renovation  projects, 

A  dedicated  standard 
the  BREEAM 
Refurbishment and Fit Out (RFO), aims at certifying the performance 
of building upgrades with a version for (international) non-residential 
buildings  and  residential  buildings  in  the  UK.  It  is  currently  used 
across Europe with certified assessments in the UK, France, Italy and 
Poland.  Partner  scheme  operators  exist  in  the  US,  the  Netherlands, 
Spain, Germany, Norway, Sweden, Austria and Switzerland.  

The health and wellbeing category of the globally used non-residential 
certification scheme includes the indicators visual comfort, indoor air 
quality,  safe  containment  in  laboraties,  thermal  comfort,  acoustic 
performance, safety and security and hazard. The categories  for UK 
residential  buildings  include  daylighting,  sound  insulation,  volatile 
organic  compounds,  inclusive  design,  ventilation  and  safety,  with 
ventilation and safety being minimum standards.  

Projects can reach the rating of Pass (≥30% of the required score), 
Good  (≥45%),  Very  Good  (≥55%),  Excellent  (≥70%)  and 
Outstanding (≥85%). 

No information 

energy 

Primary 
savings  
CO2 emission savings  No information 
No information 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No information 

•  Transferability: high – the certification scheme is already 

implemented and used in several European countries (see 
above). The distribution over building types is also spreading 
(from non-residential to residential). 

•  Administration: administered by a national certification body 
(BRE Global) or national partner operators across Europe 

75 

 
 
Annex III: Good practice examples 

•  Compliance checks: compliance with the numerous indicators 
and requirements is checked by a qualified, accredited BRE 
assessor during and after completion of the project. The 
project management includes a “handover and aftercare” 
section which may cover a site inspection within three 
months of occupation, post-occupancy interviews/ surveys 
and the provision of a helpline for longer-term support. Extra 
credit to achieve a higher level of certification is given where 
thermographic surveying and airtightness testing are carried 
out at both pre- and post-refurbishment stages. 

Features of the (private) BREEAM certification could be replicated to 
improve the next generation of EU EPCs. The dedicated health criteria 
and  the  underlying  indicators  could  be  taken  up  in  a  further 
development  and  function  as  best  practice  for  EPC  design  in  the 
Member States. 

Matching  EU  policy 
framework 

Address 

Improve health and wellbeing: 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  The health and wellbeing category of the BREEAM 

certification includes minimum required indicators to be 
fulfilled and gives a better rating to building projects with 
higher IEQ indicators, e.g. ventilation, accessibility and 
daylighting. 

Increased sustainable infrastructure in the built environment: 

•  BREEAM building certification aims at a resource-efficient 

design and construction of buildings, contributing to the 
objective of a sustainable built environment. Indicators for 
refurbishment projects include flood protection and low-
emission materials.  

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

•  Success factors, strength and opportunities 
•  Challenges of implementation (weaknesses and threats) 

-  Private initiative 

Not applicable 

[1] BREEAM website.  
https://www.breeam.com  
[2]  BRE  Briefing  Paper,  Sustainable  refurbishment  of  domestic 
buildings using BREEAM. 
https://tools.breeam.com/filelibrary/Brochures/63945---
Sustainable-refurbishment-of-domestic-buildings-using-BREEAM.pdf 

76 

 
 
 
 
 
 
 
 
  
 
Annex III: Good practice examples 

6  GOOD PRACTICE EXAMPLES: DISTRICT APPROACHES 

The  following  pages  provide  examples  of  good  practice  policies  in  the  strategic  area  of 
district approaches.  

6.1  The Netherlands – Natural Gas-Free Districts Programme 

Policy/initiative 

Programma  Aardgasvrije  Wijken/Natural  Gas-Free  Districts 
Programme 

Location 

Start year 

Status  

National 

2018 (learning phase from 2018 to 2021) 

Ongoing (learning phase)/planned (large-scale implementation) 

Building types 

All buildings within covered districts  

Type of policy 

Capacity building/grants 

Short description 

The Dutch National Climate Agreement includes the aim to make the 
Dutch buildings sector natural gas-free.  

Whereas implementation is mainly the responsibility of the local level, 
a  national  programme  was 
support  Dutch 
districts/municipalities  to  become  natural  gas-free  through  deep 
renovations and integration of renewable heating at district level.  

launched 

to 

The objective of the programme is to get 1.5 million buildings natural 
gas-free  by  2030.  The  first  step  is  a  “learning  phase”  running  from 
2018 to 2021 (with a budget of €400 million), based on two pillars: 

•  A “knowledge and learning centre” (accessible for all Dutch 
municipalities) will provide technical support and facitiltate 
information sharing/best practices 

•  Frontrunner municipalities or districts can get financial 

support for demonstration/implementation as “testbeds for 
natural gas-free districts”. In a first round, 27 testbeds have 
already received funding, while 77 municipalities have applied 
for funding in the second round. 

Next steps (after 2021) still have to be developed. 

• 

Impact varies between the different testbeds that will receive 
funding, and the approach each municipality eventually 
develops to become natural gas-free 

•  No information available yet on the results of the testbeds 
•  The programme has recently developed a monitoring system 
to assess the impact. First results are expected for 2022. 
Impact varies between the different testbeds that will receive 
funding, and the approach each municipality eventually 
develops to become natural gas-free 

• 

•  No information available yet on the results of the testbeds 
•  The programme has recently developed a monitoring system 
to assess the impact. First results are expected for 2022. 
•  No information available on the total cost of achieving the 
objectives of the programme (1.5 million buildings natural 
gas-free by 2030) 

•  The budget for the learning phase of the programme (2018-

• 

2021) is €400 million 
Impact varies between the different testbeds that will receive 
funding, and the approach each municipality eventually 
develops to become natural gas-free 

•  No information available yet on the results of the testbeds 
•  The programme has recently developed a monitoring system 
to assess the impact. First results are expected for 2022. 

77 

Primary 
savings  

energy 

CO2 emission savings 

Costs 

Increased 
rate and depth  

renovation 

 
 
 
Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve health 
and wellbeing 

•  Increased 

sustainable infra-
structure in built 
environment 
(including 
enhanced 
resilience of 
building) 

•  Increase smart 
readiness of 
buildings 
•  Secure fair 
transition 

•  Upgrade of urban 
context (including 
access to 
sustainable 
mobility) 

Lessons learned 

Annex III: Good practice examples 

•  Other countries could develop similar initiatives 1) with a 
clear objective, 2) where implementation is mainly the 
responsibility of the local level, and 3) where the national 
level provides support through capacity building and financial 
support. However, this would require a strong engagement of 
and interaction between all actors involved (national 
authorities, local authorities, private sector, …). The Dutch 
National Climate Agreement has played a central role in this 
regard.  

•  The Dutch programme is not a standalone programme, but is 
linked to several other initiatives and policies which are all 
included in the Dutch National Climate Agreement. Other 
initiatives include the Transition Vision Heat (commitment of 
all municipalities to develop a strategy to become natural 
gas-free), the Regional Energy Strategy (similar as the 
Transition Vision Heat, but at a regional level), etc. 

The link with the EU policy framework depends on the approach the 
different  municipalities  will  take  to  become  natural  gas-free. 
Nevertheless, it can be expected that overall, the programme and its 
objectives  will  contribute  to  increased  energy  efficiency  (e.g.  better 
insulation, recovery of waste heat for district heating) and increased 
use  of  renewable  energy  (e.g.  switch  to  biofuels,  electrification  in 
combination with renewable electricity production). This in turn could 
be linked to the:  

•  Energy Efficiency Directive 
•  Renewable Energy Directive 
•  Energy Performance of Buildings Directive 
•  Effort Sharing Regulation 
•  Renovation Wave initiative 

Depends  on  the  approach  the  different  municipalities  will  take  to 
become natural gas-free. 

•  Strengths:  

-  Clear mid- and long-term objectives (fully natural gas-
free by 2050, 1.5 million buildings by 2030 as an 
intermediary goal), which are in line with climate 
neutrality by 2050 

78 

 
 
Annex III: Good practice examples 

- 

Integrated in a broader policy agenda, and 
complemented by other policies (via the National 
Climate Agreement) 

-  Broad stakeholder support through the governance 

process leading up to the National Climate Agreement 
(e.g. roundtables on the buildings sector) 

-  Encourages an integrated approach (efficiency + 

renewable energy) with sufficient flexibilities to adapt 
to local circumstances. The objective is to become 
natural gas-free: each municipality can decide for 
itself which is the best way to achieve this goal, based 
on the local potential of the different options (e.g. 
nearby presence of waste heat, etc.) 

-  Clear division of roles (national vs. local level), with 

support from the national level (both capacity building 
and financial) 

•  Weaknesses: 

-  The bulk of the efforts to achieve the objective will 

have to be done after the learning phase (as of 2022). 
No clarity yet on how this will be achieved (no next 
steps/budget provided so far)  

•  Opportunities: 

-  Will put the energy transition on the agenda of all 

local authorities 

-  Could therefore encourage these authorities to 

integrate the energy transition in their overall policies 
(in particular urban planning) 

-  Opportunities to share lessons learned and best 
practices via the knowledge and learning centre 

•  Threats: 

-  A lot of responsibility is left to the local authorities 

(municipalities). There is a risk that these do not have 
the required resources (personnel, know-how, 
financial resources) to achieve the ambitious 
objectives (in particular smaller municipalities). 
Unclear whether the support provided by the national 
level will be sufficient in this regard 

-  No clear governance process to ensure that all 
municipalities follow up on their commitments 
-  Unclear what the following steps will be after the 

learning phase. Next steps will have to be based on 
lessons learned, but the timing for developing next 
steps (before 2022) and achieving the objective (1.5 
million buildings natural gas-free by 2030) is very 
challenging 

-  Delivery of the objectives is therefore uncertain  

Synergies 

Bibliography 

Not applicable 

https://aardgasvrijewijken.nl/default.aspx 

79 

 
 
 
 
 
 
Annex III: Good practice examples 

6.2  The Netherlands – Renovation Accelerator 

Policy/initiative 

Renovatieversneller/Renovation Accelerator  

Location 

Start year 

Status  

National 

2020 

Ongoing 

Building types 

Residential buildings owned/managed by larger housing corporations 

Type of policy 

Various: 

•  Capacity building/process facilitation 
•  Grants 

Short description 

The  Renovation  Accelerator  is  a  national  programme  to  incentivise 
large scale energy renovations by large housing corporations. 

The  programme  seeks  to  bundle/aggregate  the  demand 
for 
renovation of similar housing types, and then facilitate a match with 
the  supply  chain.  This  should  improve  the  cost-effectiveness  of 
renovations,  through  standardisation,  economies  of  scale,  the 
optimisation of supply chains, etc.  

The programme works on the following dimensions: 

• 

• 

• 

It takes the role of a facilitator to match housing corporations 
with each other and with actors from the supply chain, e.g. 
by organising events where these actors can meet each 
other. 
It provides technical and process assistance to support 
relevant projects (e.g. sharing of best practices and knowhow 
on best available technologies, organising joint procurement 
procedures, etc.). 
It provides grants/subsidies to renovation projects. Only 
projects covering at least 150 housing units built before 1995 
and involving at least two corporations (each with at least 50 
housing units) are eligible. Subsidies vary between €2000 
and €7000 per housing unit, depending on the type and the 
achieved energy performance. The budget for the period 
2020-2023 is €100 million. 

•  Only renovation projects that achieve a maximum heating 

need of 70 kWh/m2
subsidy if the performance is below 50 kWh/m2. 

 are eligible for a subsidy (increased 

•  With a budget of €100 million over four years (2020-2023), 
the subsidy scheme could renovate between 14,000 and 
50,000 housing units over this period. 

•  Final energy savings depend on the energy consumption 

before and after the renovation, the average surface, and the 
type of dwellings that receive grants. 

Primary 
savings  

energy 

CO2 emission savings  No information available 

Costs 

The  budget  for  the  subsidy  scheme  is  €100  million  for  the  period 
2020-2023 (€20 million for each of the first two years, €30 million for 
each of the last two years). 

Increased 
rate and depth  

renovation 

No information available (yet) on the private investments leveraged 
through the programme.  

•  The programme only started in 2020, no evaluation results 

available yet. 
If all subsidies are granted, over the four-year period: 

• 

80 

 
 
 
 
 
Ease 
implementation 

of 

Annex III: Good practice examples 

-  Between 33,000 and 50,000 housing units would be 
renovated to a level of maximum 70 kWh/m2 heating 
demand 

-  Between 14,000 and 25,000 housing units would be 
renovated to a level of maximum 50 kWh/m2 heating 
demand. 

•  This would be an increase compared to the “few thousand” 
housing units currently being renovated each year, but the 
exact increase in innovation rate would have to be assessed 
ex post.  

• 

•  Similar programmes could be implemented in other countries 
or for other building types, depending on the structure of the 
market and the building stock: 
It can be particularly useful for countries (like the 
Netherlands) where a large share of the building stock is 
owned by large housing corporations, and/or where the 
building stock is relatively homogenous within certain 
districts (e.g. neighbourhoods with all identical buildings, 
which allow for a one-size-fits-all approach and economies-
of-scale cost reductions) 
It would be less suitable for countries where the market is 
dominated by household ownership (households being the 
owner of their own dwelling) and/or where the building stock 
is more heterogenous (requiring tailor-made renovation 
solutions, therefore reducing the potential for economies of 
scale). 

• 

•  The programme is mainly administered by the Ministry of 

Economic Affairs. 

•  The policy is embedded in a broader national policy 

framework with the overall goal to make the Dutch building 
stock climate neutral and natural gas-free by 2050 (with 
intermediate objectives for 2022 and 2030). It is an 
instrumental part of the “Start Engine”, which aims to get 
100,000 building natural gas-free by 2022. Other, 
complementary policies and programmes are the Natural 
Gas-free Districts Programme, adjustments to the rules on 
housing rentals, etc.  

•  The policy directly contributes to the Renovation Wave 

initiative and the objectives of the Energy Efficiency Directive. 

•  Though it depends on the eventual renovation projects that 

will be subsidised, in general terms the renovation of housing 
units can contribute to reducing energy poverty, improving 
health and wellbeing, etc.  

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

81 

 
 
•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

Annex III: Good practice examples 

•  Strengths: 

-  Combination of financial incentive and 

process/technical assistance 

-  Ambitious requirements for renovations (70 to 50 

kWh/m2) 

•  Weaknesses: 

-  No integration/requirements with regard to low-
emission heat generation (e.g. renewables) 

•  Opportunities: 

-  Could trigger a large number of additional renovations 

(due to the 150 housing units threshold) 

-  Could trigger important cost savings and speed up 
renovations (through economies of scale and 
optimisation between demand and supply) 
-  Even proven successful, a continuation of the 

programme (and if necessary, increase of the budget) 
could trigger a renovation wave within the housing 
corporation-owned building stock, which constitutes a 
significant part of the Dutch building stock 

•  Threats: 

-  Potential risk of windfall profits, if the cost savings and 
subsidies are not passed through in market prices 
(either within the supply chain, from the supply chain 
to the housing corporations, or from the housing 
corporations to the lessees)  

Synergies 

Financing renovations: the programme provides a financial incentive 
to overcome the landlord-tenant dilemma (= market failure). 

Engaging transformation and phasing out energy-inefficient buildings: 
the programme targets older, inefficient buildings (built before 1995) 
where  spontaneous  renovations  might  be  less  likely  due  to  the 
landlord-tenant dilemma. By setting ambitious energy-saving criteria, 
it incentivises deep renovations. 

Bibliography 

www.renovatieversneller.be 
https://www.rvo.nl/subsidie-en-
financieringswijzer/renovatieversneller 

82 

 
 
 
 
 
 
 
 
 
 
 
 
Annex III: Good practice examples 

6.3  Belgium – Neighbourhood Grant 

Policy/initiative 

Burenpremie (Neighbourhood Grant) 

Location 

Start year 

Status  

Regional 

Effective start in October 2017 

Ongoing 

Building types 

Residential (single-family buildings, multi-family buildings, etc.) 

Type of policy 

Grant 

Short description 

Primary 
savings  

energy 

CO2 emission savings 

The objective of this grant is to stimulate collective renovation, though 
no quantified objective has been defined. It is financed by the regional 
network operator and is part of the regional policies.  

How does it work? The grant is allocated to the leader of a collective 
project to renovate several houses or apartments in the same street 
or  neighbourhood.  The  project  leader  will  make  energy  renovations 
more  efficient,  faster  to  implement,  of  higher  quality  and  less 
expensive thanks to a collective approach. They will lead on tasks such 
as housing energy diagnostics, timings of works, carrying out surveys, 
finding contractors, site monitoring and requesting other subsidies. A 
list  of  certified  project  leaders  is  available.  Training  is  organised  by 
the  network  operator.  Anyone  is  eligible  to  be  a  project  leader 
provided they have sufficient architectural and technical knowledge, 
and  understanding  of  the  phased  approach  to  construction  projects 
and  financing  questions.  The  appointed  project  leader  for  collective 
renovations  must  be  commercially  independent  from  professional 
players in the building sector to assure objective guidance and advice. 

For the citizen, it increases the certainty about the smooth running of 
the renovation works and guarantees lower investment costs. 

Additional information: 

•  The project must include at least 10 houses or apartments. 
•  The grant differs for single-family buildings (€400 per house) 
and for multi-family buildings (€100 per housing unit and 
capped at €5000 for an entire building). 

•  The collective project action plan must invest in at least one 
of the seven measures of the total renovation subsidies: roof 
or attic insulation, wall insulation, basement/ground 
insulation, new glazing, solar boilers, heat pumps, pump 
boilers or ventilation systems. 

•  A list of 500 active project leader is available. 
• 

Impact will depend on the number of collective projects 
applying, and the number of housing units and the specific 
refurbishment renovation ambition of each project 

•  No quantified information available  
• 

Impact will depend on the number of collective projects 
applying, and the number of housing units and the specific 
refurbishment renovation ambition of each project 

•  No quantified information available  

Costs 

Increased 
rate and depth  

renovation 

Cost will depend on  the number  of  collective projects applying, and 
the number of housing units and the specific refurbishment renovation 
ambition of each project. 

• 

Impact will depend on the number of collective projects 
applying, and the number of housing units and the specific 
refurbishment renovation ambition of each project. 

•  No quantified information available 

83 

 
 
Annex III: Good practice examples 

•  Other countries could offer similar subsidies at regional or 

national level in any region or climate zone. The renovation 
plan designs custom solutions for each collective project and 
can be implemented for specific building types. The concept 
could be extended to non-residential buildings. 

•  However, this would always require interaction between all 
actors involved (national authorities, local authorities, 
regional network operators, regional energy agency and 
certified project leaders). To ease coordination and decision-
making, financing could come from national or local 
authorities rather than network operators. The key point is to 
make it easier to set up collective projects by bringing project 
leaders and citizens into contact with each other.  

•  The neighbourhood grant is part of a group of subsidies 

proposed by the regional authority. The grant covers specific 
measures specified within the regional renovation plan. This 
ensure consistency in objectives pursued by all regional 
subsidies. Being included in a group of renovation subsidies 
helps to increase visibility and initiation of such district 
initiatives.   

The  link  with  the  EU  policy  framework  depends  on  the  approach  of 
each collective project. Nevertheless, as it supports specific measures 
under  the  regional  renovation  plan,  it  can  be  expected  that  overall, 
the  grant  and  its  objectives  will  contribute  to  increased  energy 
efficiency  (e.g.  better  insulation)  and  increased  use  of  renewable 
energy  (e.g.  increasing  solar,  pump  boilers  or  heat  pumps 
implementation).  It  will  also  encourage  citizens  to  renovate  their 
homes,  which  might  not  have  materialised  without  a  collective 
approach. This in turn could be linked to the:  

•  Energy Efficiency Directive 
•  Renewable Energy Directive 
•  Energy Performance of Buildings Directive 
•  Renovation Wave initiative 
•  Depends on the approach and ambition of each collective 

project, but the realisation of a collective residential project 
can improve  health and wellbeing within the community.  

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

•  Strengths: 

84 

 
 
Annex III: Good practice examples 

-  Lower investment costs for individual citizens, thanks 

to the collective approach 

-  More efficient renovation and potential deep 

renovation as the renovation action plan will be 
designed by a skilled project leader. 

•  Weaknesses: 

-  The amount of the grant is low compared to the total 

renovation costs 

-  This grant could help to initiate new project, but 

should be followed by tools and initiatives to facilitate 
the project once started. 

•  Opportunities: 

-  Encourages citizens to renovate their homes by 
simplifying renovation processes, improving the 
overall renovation rate of the residential building stock 

-  Offers new renovation solutions thanks to the 

collective scale: shared sustainable mobility solutions, 
large-scale heating systems, etc. 

•  Threats: 

- 

It is the responsibility of regional authorities to ensure 
the success of the grant programme by providing 
support to collective project constitution (list of 
certified project leaders, training, advertising, 
coordination between actors…). 

Synergies 

Bibliography 

Depends on the approach of each collective project.  

https://www.energiesparen.be/burenpremie 
https://www.vlaanderen.be/burenpremie-voor-collectieve-
renovatieprojecten 
https://www.fluvius.be/nl/thema/benoveren/benovatiecoach 

85 

 
 
 
 
 
 
 
Annex III: Good practice examples 

6.4  European Union – MODER project  

Policy/initiative 

MODER  Project  (Mobilization  of 
refurbishing of buildings at district level) 

innovative  design 

tools 

for 

Location 

Start year 

Status  

EU 

2015-2018 (36 months) 

Finished 

Building types 

All building types 

Type of policy 

Short description 

Initiative  to  develop  decision-making  tools  to  support  renovation 
actors – offers tools, processes and policies that could be replicated 
at EU and local level 

MODER  was  a  European  project  funded  by  the  Horizon  2020 
programme,  the  main  objectives  of  which  were  to  promote  energy-
efficient  renovation  at  the  district  level  and  help  to  achieve  smart, 
sustainable,  and  inclusive  economic  growth  in  European  and  global 
markets.  The  tools  (processes  and  business  models)  developed  can 
evaluate  the  benefits  to  be  achieved  to  support  decision-making  in 
designing renovation projects at district level. 

Concepts  were  tested  through  four  real  refurbishment  cases  and 
provide detailed data. Case studies include real databases of energy 
audited buildings, a mix of privately and municipally owned buildings, 
ongoing energy refurbishment projects, and districts where the value 
of  the  property  has  increased  annually,  leading  to  socio-economic 
issues. 

Objectives: 

•  To develop tools for use at district and neighbourhood level to 

compare alternative renewable energy systems. 

•  To improve understanding of the behaviour of complex 

energy systems for non-technical stakeholders through easy-
to-understand visualisations of alternative energy scenarios. 

•  To improve holistic energy-system design at district level 
considering renewable energy systems (through optimal 
selection and sizing of energy conversion units as well as the 
energy distribution system). 

•  To develop processes and practices that enable building 

owners to activate refurbishment with the help of energy 
management companies and engineering companies. MODER 
also developed business models for engineering companies, 
consultants and energy managers to profitably offer these 
services for owners. 

Target  audience:  Engineering  companies,  energy  managers, 
local  authorities,  municipalities,  building  owners, 
consultants, 
investors, local businesses 

Partners: SWECO as lead partner. LEAG and REM PRO reported the 
process for the national case studies. 

energy 

Primary 
savings  
CO2 emission savings  Not applicable  – impact depends  on how tools  are used beyond the 

Not applicable  – impact depends  on how tools  are used  beyond the 
MODER project 

MODER project 

Costs 

The project received €3.28M from the EU Horizon 2020 research and 
innovation programme 

86 

 
 
Annex III: Good practice examples 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Not applicable  – impact depends  on how tools  are used beyond the 
MODER project  

MODER  models  have  been  tested  and  validated  with  case  studies 
across  different  European  countries  (Germany,  Finland,  Slovenia, 
Latvia…).  Results  have  also  been  compared  for  different  archetype 
buildings  (predefined  parameters  for  21  archetypes).  Models  also 
include climate parameters. 
The targeted public is diverse – MODER tools can be used at different 
scales and by different profiles of renovation actors. 

The project was financed by the EU Horizon 2020 programme, which 
aims to ensure Europe produces world-class science, removes barriers 
to innovation and makes it easier for the public and private sectors to 
work together in delivering innovation. The funding areas covered are 
energy efficiency and the rational use of energy, new and renewable 
resources, energy in transport and integrated initiatives.  
Being conducted and supported by this European programme ensured 
MODER’s credibility and confidence in the results and tools developed, 
and alignment with the goals of Horizon 2020.  

Address 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

District level renovation projects supported by the MODER tools can 
help address: 

• 

• 

Increased sustainable infrastructure in the built environment 
(including enhanced resilience of building) 
Increase smart readiness of buildings 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

•  Strengths: 

-  District-scale refurbishment is in line with sustainable, 

low-carbon and infill strategies of growing cities 

-  District approaches support a rapid transition towards 

energy efficiency and renewable energy  

-  MODER tools can help to communicate (and visualise) 
information about potential solutions for district-scale 
projects requiring deep and realistic analyses of 
potentials.  

•  Weaknesses: 

-  Collective projects can lead to possible disagreement 

between owners 

-  Lack of skilled actors to initiate large-scale projects. 

Skills required include: 
o  understanding  platform-based  approaches  and 

methods to empower people  

87 

 
 
 
Annex III: Good practice examples 

o  organising  participative  processes,  inquiries  and 
workshops  gathering  potential  groups  of  housing 
companies 

o  helping end-users to define requests based on their 

own life and living situations 

- 

Institutional and legal obstacles related to town 
planning and building permission practices. 

•  Opportunities: 

-  Huge backlog of renovation (especially for residential 
buildings) that district scale refurbishment can drive. 

-  MODER tools can help to identify new optimal 

- 

refurbishment solutions (e.g. optimal design and 
operation of energy systems) 
Identifying specific district profiles where the need for 
district-scale refurbishment is highest (e.g. growing 
urban areas, districts where the value of flats is high, 
suburban districts). 

-  Proactive municipalities are key partners, being 

neutral and providing objective information about 
benefits and opportunities. They can be local 
facilitators, supporting collaboration with owners, 
owner-occupants, contractors and others. In addition, 
the municipality should support the platform-based 
approach, encourage participation of all, and provide 
open data. Municipalities could also provide a small 
incentive for forerunner housing companies, together 
with extensive information about benefits of 
refurbishment. Finally, the rental housing companies 
owned by the municipality should show strong 
leadership, demonstrate, and invite others to 
participate.  

-  Opportunities for green funding 

•  Threats: 

-  Need to raise market interest and potential customers. 

Contractors, project managers and engineering 
companies must see the essential role they can play 
to ensure the success of district-scale refurbishment.  

Not applicable 

https://projectsites.vtt.fi/sites/moder/www.vtt.fi/sites/moder/Pages/
Brochures.html 
https://ec.europa.eu/easme/en/section/horizon-2020-energy-
efficiency/h2020-
programme#:~:text=Horizon%202020%20is%20the%20EU's,leade
rship%20and%20tackling%20societal%20challenges. 

88 

Synergies 

Bibliography 

 
 
 
 
 
 
Annex III: Good practice examples 

7  Good practice examples: engaging transformation  

The  following  pages  provide  examples  of  good  practice  policies  in  the  strategic  area  of 
engaging transformation and phasing out inefficient buildings.  

7.1  England  and  Wales  (UK)  –  Minimum  Energy  Efficiency  Standard  (MEES) 

regulations 

Policy/initiative 

Minimum Energy Efficiency Standard (MEES)  

Location 

Start year 

Regional (England and Wales) 

2018 

Building types 

Residential buildings in the rental sector 

Status  

Type of policy 

Short description 

Ongoing 

Regulation 

The MEES prescribes that all privately rented property must have 
an EPC level E to rent out the property on the rental market [2]. 

The MEES is made possible by the Energy Efficiency (Private Rented 
Property) (England and Wales) Regulations, which were amended 
in 2019 [1]. The regulation is applicable to buildings with specific 
types of tenancy agreements and that are legally obliged to have 
an EPC [2]. 

The UK government provides suggestions of measures that building 
owners  can  take  to  meet  the  requirement.  Building  owners  are 
never  required  to  invest  more  that  £3,500  on  energy  efficiency 
improvements unless more external funding has been secured [2]. 

Various exemptions exist for building owners depending on the type 
and value of buildings and the cost-effectiveness of the measures. 

Primary energy savings   No information was found about primary energy savings. 

CO2 emission savings 

Increased renovation rate 
and depth  

Ease of implementation 

Expected emission savings are 4.3 MtCO₂-eq [5] 

All private rental properties that have to comply with the regulation 
need to meet EPC rating E as of 1 April 2020 [2]. 

The  degree  of  transferability  of  the  policy  depends  on  whether 
Member States have functioning EPC infrastructure and information 
about  privately  rented  property.  If  this  is  in  place,  transferability 
can be high. 

The government of England and Wales has written the legislation, 
but  it  will  be  local  governments  that  are  responsible  for  the 
implementation and compliance checks amongst landlords. 

EU 

policy 

EU Renovation Wave 

Matching 
framework 

Costs 

Address 

•  Energy poverty 
•  Improve  health  and 

wellbeing 
•  Increased 

sustainable 
structure 

infra-
in  built 

Landlords are never required to invest more than £3,500 [2]. Total 
costs to the private sector are estimated at £986 million, equalling 
on average £34.5 million annually [5]. 

Upgrade the urban context  

Improve health and wellbeing 

89 

 
 
 
 
 
Annex III: Good practice examples 

environment 
(including  enhanced 
resilience of building) 
smart 
of 

•  Increase 
readiness 
buildings 

•  Secure fair transition 
•  Upgrade  of  urban 
context 
(including 
access to sustainable 
mobility) 

Lessons learned 

•  Success factors, strength and opportunities 

-  The fines are high enough to stimulate landlords to comply 

with the regulations [4]. 

-  The regulation is perceived to be affecting behaviour of 
investors and created awareness amongst portfolio 
managers [4]. 

-  The policy helps to address market failures like the split-

incentive dilemma [5]. 

-  Additional benefits related to health and comfort can be 

achieved [5].  

-  Many smaller portfolio managers have taken action to 

improve the quality of their buildings [4]. 

•  Challenges of implementation (weaknesses and threats) 

-  Compliance with MEES is considered too easy and the 
targets not sufficiently ambitious [4], which makes it 
unlikely that the MEES regulation will result in significant 
decarbonisation.  

-  Enforcing compliance remains challenging due to lack of 
capacity of local authorities, lacking registration and 
licensing of landlords, and insufficient empowerment of 
tenants [3]. 

-  Little evidence was found that deep-retrofits were achieved 

[4]. 

-  Compared to the Scottish MMR for privately rented 

properties the English and Wales case has no significant 
financial support schemes in place, which might discourage 
building owners to invest in (deep) renovations [6]. 

Digital  technology  and  data  analysis  are  mentioned  as 
opportunities to improve compliance with the policy [4].  
Furthermore, the policy might have positive side effects related to 
health and wellbeing. 

[1] https://www.legislation.gov.uk/uksi/2019/595/contents/made 
[2]https://www.gov.uk/guidance/domestic-private-rented-
property-minimum-energy-efficiency-standard-landlord-
guidance#when-you-need-to-take-action-to-improve-your-
property-to-epc-e 
[3]https://assets.publishing.service.gov.uk/government/uploads/
system/uploads/attachment_data/file/825485/enforcing-
enhancement-energy-efficiency-regulations-English-private-
rented-sector.pdf 
[4]https://assets.henley.ac.uk/defaultUploads/MEES-RREF-
Report.pdf?mtime=20200310154440 
[5]https://assets.publishing.service.gov.uk/government/uploads/
system/uploads/attachment_data/file/760313/IA_-
_Energy_Efficiency__Private_Rented_Property___England.pdf 
[6]https://www.gov.scot/publications/energy-efficiency-private-
rented-property-scotland-regulations-2019-guidance/pages/3 

90 

Synergies 

Bibliography 

 
 
 
Annex III: Good practice examples 

7.2  Brussels (Belgium) – Mandatory minimum requirements linked to BRP 

Policy/initiative 

Mandatory  minimum  requirements  linked  to  a  building  renovation 
passport 

Location 

Start year 

Regional level (Brussels) 

Adoption 2021 / enforcement 2030 

Building types 

Residential buildings in the rental sector 

Status  

Planned 

Type of policy 

Regulation 

Short description 

The regional government of Brussels plans to implement mandatory 
renovation  measures  for  residential  and  non-residential  buildings  to 
ensure a minimum energy performance of the building stock in 2050 
[1]. 

The  plan  includes  the  formulation  of  five  renovation  measures  to 
improve  the  energy  performance,  of  which  building  owners  must 
implement one on a five-year interval basis starting in 2030.  

The  type  of  measures  and  the  final  performance  requirements  are 
based on the building typology and ownership [1]. 

energy 

Primary 
savings  
CO2 emission savings  Not specified. 

Not specified. 

Increased 
rate and depth  

renovation 

No  information  on  the  expected  depth  of  each  renovation  step  is 
provided [1]. The goal is, however, to create ‘energy neutral buildings’ 
(NZEBs) in 2050. 

The  concepts  of  a  building  renovation  passport  and  mandatory 
minimum requirements are applied in other countries already, which 
suggest that this policy could be transferred relatively easily to other 
countries. 

The  regional  government  in  Brussels  is  responsible 
implementation of the policy [1]. 

for  the 

Other measures the policy interweaves with are [1]: 

•  Establishing a single point of information for building owners 

and professionals 

•  Establishing a renovation roadmap for residential buildings 
•  Establishing a building passport 

Renovation Wave 

EPBD  article  20  –  Informing  inhabitants  about  energy  savings 
measures  they  can  take  to  improve  the  energy  performance  of 
buildings  

No costs have been specified yet.  

The renovation of all buildings in Brussels will lead to an upgrade of 
the urban context.  

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Costs 

Address 

•  Energy poverty 
•  Improve health and 

wellbeing 
•  Increased 

infra-
in  built 

sustainable 
structure 
environment 
(including 

91 

 
 
 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

•  Secure 

transition 

of 

smart 
of 

fair 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Annex III: Good practice examples 

•  Success factors, strength, and opportunities 

-  The plan links a mandatory minimum requirement 
with a long-term target while providing concrete 
stepwise options to building owners to meet this 
target. 

•  Challenges of implementation (weaknesses and threats) 

-  The plan does not include specific financial enabling 

measures.  

The building renovation passport could also include information about 
circularity  of  renovation  measures, 
the  built 
environment  sustainability  and  adaptation  to  climate  change 
strategic area. 

linking 

to 

it 

Bibliography 

[1]https://ec.europa.eu/energy/sites/ener/files/documents/bruxelles
_capitale_2020_ltrs.pdf  

92 

 
 
 
 
 
Annex III: Good practice examples 

7.3  Baden-Württemberg (Germany) – Support for serial renovation 

Policy/initiative 

Förderprogramm Serielle Sanierung von Wohngebäuden - Support for 
serial renovation in Baden-Württemberg  

Location 

Start year 

Regional level 

2019 

Building types 

Residential buildings 

Status  

Ongoing 

Type of policy 

Grant 

Short description 

The  grants  from  the    Baden-Württemberg  government  aim  to 
stimulate  the  renovation  rate  through  industrial  pre-fabrication  of 
building parts like  façades, windows, doors and roofs for  residential 
buildings constructed before 2002 [1]. 

The grant is provided per square metre of usable floor area and varies 
for different individual interventions, e.g. roofs or walls, or complete 
renovations [1]. The grant may not exceed 40% of the costs. Eligible 
complete renovations must amount to a minimum of €200,000 [1].  

The grant programme is active until the end of 2023 [4] 

energy 

Primary 
savings  
CO2 emission savings  No information available 

No information available 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No estimates or other information available 

The  Ministry  of  Environment,  Climate  and  Energy  of  Baden-
Württemberg  is  providing  the  funding  and  has  made  the  Karlsruher 
Institute  of  Technology  responsible  for  the  implementation  of  the 
programme [1]. 

The  measure  is  connected  to  the  KfW  efficiency  house  standard.  If 
renovations  comply with the KfW standard 55  or 70, the grant sum 
increases [1]. 

The  support 
administrative regulation in BW [2].  

is  enabled  through  the 

implementation  of  an 

Matching  EU  policy 
framework 

Serial  renovation  could  be  a  key  policy  within  the  context  of  the 
Renovation Wave initiative from the European Commission.  

The grant provided by the government of Baden-Württemberg relates 
to Article 20 EED – Financing of Energy Efficiency.  

€3M public funding is made available for the project [3] 

The upgrading of the existing building stock is a form of upgrading 
of the urban context.  

Because  housing  associations  are  one  of  the  most  suitable  starting 
points for industrial prefabrication and serial renovation, residents of 
social  houses  have  a  larger  chance  to  see  their  living  environment 
being upgraded. If the serial renovation is applied to social housing, 
this would contribute to securing a fair transition.  

Renovation  may  also  improve  smart  readiness  through  links  to 
building automation [1]. 

Costs 

Address 

•  Energy poverty 
•  Improve  health 
and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 

of 

93 

 
 
 
Annex III: Good practice examples 

•  Increase 
readiness 
buildings 

•  Secure 

transition 

smart 
of 

fair 

•  Upgrade of urban 

context 
(including  access 
to 
sustainable 
mobility) 

Lessons learned 

•  Success factors, strength and opportunities 

-  The grant from the government in Baden-

Synergies 

Bibliography 

Würtemmberg has contributed to initial market 
development of serial renovations in Germany [6]. In 
2019, the first volume deal for serial renovation in 
Germany was signed, which could kick-start the 
market [5]. 

•  Challenges of implementation (weaknesses and threats) 

-  Costs of implementation have to be reduced after the 

initial investment stage. 

Industrial  production  of 
facades  and  walls  requires  digital 
technology like BIM and 3D printing, thus relating to the digitisation 
of the supply chain in the construction sector [5]. 

[1]https://um.baden-wuerttemberg.de/de/energie/informieren-
beraten-foerdern/foerdermoeglichkeiten/foerderprogramm-serielle-
sanierung-von-wohngebaeuden 
[2]https://um.baden-wuerttemberg.de/fileadmin/redaktion/m-
um/intern/Dateien/Dokumente/5_Energie/Beratung_und_Informatio
n/190207_VwV_Serielle_Sanierung_GABLBW.pdf 
[3]https://www.baden-
wuerttemberg.de/de/service/presse/pressemitteilung/pid/drei-
millionen-euro-fuer-serielle-sanierung-von-wohngebaeuden 
[4] https://www.ptka.kit.edu/serielles-sanieren.html 
[5]https://www.energiesprong.de/newsroom/meldungen/durchbruch
-fuer-serielle-sanierung-von-wohngebaeuden 
[6]https://www.energiesprong.de/newsroom/meldungen/umweltmin
isterium-baden-wuerttemberg-foerdert-serielle-sanierung-von-
wohngebaeuden 

94 

 
 
 
 
Annex III: Good practice examples 

7.4  Lithuania – Renovation [modernisation] of multi-apartment buildings 

Policy/initiative 

Location 

Start year 

Daugiabučių  namų  atnaujinimo  (modernizavimo)  programa  –Multi-
apartment building renovation (modernisation) programme 

Lithuania 

2005 

Building types 

Multi-family buildings 

Status  

Ongoing 

Type of policy 

Grant and technical advice 

Short description 

The multi-apartment building renovation (modernisation) programme 
was initiated in 2005 to renovate multi-family buildings. The objective 
of  the  programme  was  to  renovate  4000  (out  of  38,000)  multi-
apartment buildings and save 1,000 GWh of energy annually between 
2005 and 2020 [8] 

To be eligible for support the building needs to be constructed before 
1993 and contain at least three apartments but may also include non-
residential  premises  [1].  This  accounts  for  roughly  90%  of  the 
apartment building stock in Lithuania [4]. Renovated buildings must 
obtain  a  minimum  EPC  rating  of  C  and  reduce  primary  energy 
consumption by at least 40% [5]. 

Building  owners  can  participate  in  the  programme  on  their  own 
initiative  or  when  the  municipality  has  identified  their  building  as 
appropriate  for  participation.  In  the  latter  case  an  administrator  is 
appointed  to  administer  the  renovation  of  the  building  and  building 
owners  do  not  assume  any  organisational  responsibilities,  credit 
obligations or implementation risks [1]. 

Third-party  financiers  (UAB  VIPA  and  Šiaulių  bankas)  provide  long-
term  renovation  loans  with  a  duration  of  up  to  20  years  and  fixed 
interest rate of 3% [2]. The Lithuanian government pays 100% of the 
project  preparation, 
costs. 
Additionally,  the  Lithuanian  government  funds  30%  of  the  costs  for 
proposed  measures  and  an  additional  10%  for  specified  heating 
installations [5]. If the annual interest rates of the soft loans provided 
by  the  third-party  financiers  exceed  3%,  the  government  pays  the 
difference [1]. 

supervision  and  administration 

For  disadvantaged  communities  the  government  also  pays  credit 
insurance  premiums  and  monthly  credit  and  interest  payments  [1]. 
This boils down to complete coverage of the costs [7]. 

Primary 
savings  

energy 

582.8  GWh/year  [3]  (2005-2018)  for  the  whole  programme.  Other 
sources mention 828 GWh/year [8]. 

CO2 emission savings 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

137.48 kton CO₂/year [3] (2005-2018) for the whole programme. 

No data on energy performance after  renovation was found, nor  on 
the total floor area covered. However, in 2018 the calculated energy 
reduction  was  on  average  70%  (kWh/m2)  per  project,  for  498 
apartment  buildings.  55%  of  buildings  got  upgraded  to  EPC  C  and 
44% to EPC B [6].  

The administration of the policy is the responsibility of the Lithuanian 
Housing Energy Saving Agency, which receives funding from the state 
budget  [5].  Their  responsibilities  include  checking  if  the  municipal 
programmes are in alignment with the national programme. 

Many  formalities  are  described  in  relation  to  the  decision-making 
procedures  of  condominium  associations,  and  forms  that  must  be 

95 

 
 
Annex III: Good practice examples 

completed and handed in at the Housing Energy Saving Agency before 
the  start  of  the  renovation  project  [1].  The  projects  have  to  be 
supervised and designed by qualitied engineers [7]. However, further 
compliance  checks,  e.g.  for  performance  after  renovation,  are  not 
mentioned.  

Relevant  policies  are  the  Law  for  Support  for  Renovation  of  Multi-
apartment  Buildings, 
the  Lithuanian  Construction  Technical 
Regulations,  the  Methodology  for  calculating  the  thermal  energy 
consumption of multi-apartment buildings, the Law on Condominium 
Associations, and the Lithuanian Housing Strategy [5]. 

Matching  EU  policy 
framework 

This  programme  contributes  to  achieving  the  targets  of  the 
Renovation  Wave  initiative,  for  which  it  could  be  integrated  as  a 
good practice example. 

2A – important for the LTRS - EPBD 

Costs 

Total investment from 2005-2013 was €368.5M [8] 

Costs in 2017 were on average €193/m2 [8] 

Total  investments  from  2005-2019  are  estimated  at  €600M  of  both 
private and public funds [9]. The European Investment Bank, which 
has provided funding for the programme, suggests a leverage factor 
of four for each public euro invested [9]. 

Address 

•  Energy poverty 
•  Improve health and 

wellbeing 
•  Increased 

The programme helps to upgrade the urban context in Lithuanian 
cities. 

Furthermore, the additional support from the Lithuanian government 
for disadvantaged residents supports a fair transition while reducing 
energy poverty.  

infra-
in  built 

sustainable 
structure 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

•  Secure 

transition 

of 

smart 
of 

fair 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

•  Success factors, strengths, and opportunities 

-  After 2013 standardised documentation and contracts, 

the possibility for interim payments, open credit lines 
from third-party financiers and the possibility for 
qualified administrators was introduced [7]. This 
increased the popularity of the programme amongst 
building owners. 

-  After 2013 municipalities mostly appointed the 
administrators of the renovation projects.  

•  Challenges of implementation (weaknesses and threats) 

-  Before 2013 there was a lack of standardisation, rigid 

payment options, no state funding and limited 

96 

 
 
Synergies 

Bibliography 

Annex III: Good practice examples 

possibilities to appoint an administrator beside the 
chairman of the condominium association, resulting in 
low popularity of the programme amongst building 
owners [7]. 

-  Success depends on the administrator appointed by 

the municipality or the building owner [7].  

The programme is also related to financing renovation because the 
funding for the programme was essential for its success [8] 

[1]http://www.betalt.lt/veiklos-sritys/programos/daugiabuciu-namu-
atnaujinimo-modernizavimo-programa/102?c-19/t-46 
[2]https://sb.lt/lt/verslui/finansavimas/pastatu-atnaujinimo-
modernizavimo-finansavimas/daugiabuciu-namu-atnaujinimo-
modernizavimo-programa/pagrindines-finansavimo-
salygos/projektai-suderinti-nuo-2017-11-01 
[3]http://www.betalt.lt/doclib/anp3k3em7idp2x4ggajvrje43u1fuz1e 
[4]https://www.e-
tar.lt/portal/lt/legalAct/TAR.AE67B6739526/plnWugajpq 
[5]https://e-
seimas.lrs.lt/portal/legalAct/lt/TAD/b585f210580311e78869ae36ddd
5784f 
[6]http://www.betalt.lt/veiklos-sritys/programos/daugiabuciu-namu-
atnaujinimo-modernizavimo-programa/102/?c-52/t-124  (see  state 
support agreements have been concluded). 
[7]https://www.interregeurope.eu/fileadmin/user_upload/tx_tevproj
ects/library/file_1516631962.pdf 
[8]https://www.epatee-toolbox.eu/wp-
content/uploads/2018/10/epatee_case_study_lithuania_renovation_
programme_with_eu_funding_ok.pdf 
[9]  https://www.eib.org/en/press/all/2019-001-new-financing-for-
energy-efficiency-loans-in-lithuania-with-siauliu-bankas 

97 

 
 
 
 
Annex III: Good practice examples 

7.5  Flanders (Belgium) – Digital building logbook 

Policy/initiative 

Woningpas (digital building passport).  

Location 

Start year 

National level 

2019 

Building types 

Single-family residential buildings [1] 

Status  

Ongoing  

Type of policy 

Informative policy instrument for building owners 

Short description 

The  Woningpas  is  a  free  digital  building  renovation  passport  that 
offers building owners an overview of building-related information on 
one  platform.  This  contains  information  on  insulation,  energy 
performance,  installations,  the  soil,  surroundings,  the  EPC,  and 
renovation steps suitable to achieve an EPC A rating in line with the 
Flemish LTRS[2][3].  

The  Flemish  government  wants  to  facilitate  building  sale  and 
renovation  for  citizens,  and  though  clear  communication  and 
coordination the required paperwork is made more accessible.  

The Flemish government wants to achieve three concrete goals with 
the Woningpas:  

1)  Reduce the complexity of administrative processes  
2)  Provide insight into the energy performance of buildings  
3)  Create  awareness  around  the  2050  targets  for  energy 

performance of the built environment.  

As such, the Woningpas supports the realisation of the Renovatiepact 
2050 (Renovation Pact) which has the goal of a climate-neutral built 
environment in 2050 [4]. 

Primary 
savings  

energy 

Because the Woningpas is an informative and enabling measure, the 
direct impact on primary energy savings is difficult to quantify. 

CO2 emission savings 

Because the Woningpas is an informative and enabling measure, the 
direct impact on CO2 emission savings is difficult to quantify. 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

The Woningpas is mentioned as an important instrument to achieve 
the targets  of the  LTRS [3] which aims to reduce CO2  emissions by 
75% for residential buildings [5]. 

No information was found with regard to the increased renovation rate 
and depth directly related to the Woningpas. 

The Woningpas has been launched through collaboration between four 
Flemish (regional) government departments and public agencies. The 
Flemish  Energy  Agency,  the  Public  Waste  Agency  Flanders  (OVAM), 
the Environment Department and the Housing Agency Flanders each 
contribute  building-related  information  to  the  digital  Woningpas 
platform [4].  

Initially the Woningpas only included construction/renovation permits 
and  the  EPC.  The  objective  is  to  support  evolution  of  the  tool  to 
integrate other data sources so it can support, inform and incentivise 
building owners to renovate energy  efficiently,  healthy,  comfortably 
and safely [4]. 

The Woningpas integrates various building-related data sources from 
different parties including the Flemish government, the building owner 
and the building sector supply chain. It will therefore contain different 
levels of information with varying credibility. Compliance checks take 

98 

 
 
Annex III: Good practice examples 

place on the level of input data, e.g. quality assurance of an EPC or 
compliance check of the building permit. Building owners can upload 
proof of energy performance renovation measures on the Woningpas, 
which in turn can recalculate the energy performance of the building 
[6].  

The  degree  of  transferability  is  theoretically  high.  In  practice  it 
depends  on  the  availability  of  related  buildings  data  and  the 
collaborative capacity of various government institutions involved.  

Enabling  policies  for  the  Woningpas  are  EPCs,  building  permits  and 
land register information that form the input data for the Woningpas. 
The measure weaves into other building renovation-related policies in 
Flanders like the Renovation Pact and the regional LTRS [5].  

Matching  EU  policy 
framework 

EPBD  Article  11  –  EPCs.  The  Commission  could  consider 
complementing article 11 and include (part of) the integral elements 
of the Woningpas as requirements for the EPC.  

Initiative:  Renovation  Wave.  The  clear  information  provision  and 
coordination  integrated  in  the  Woningpas  could  help  increase  the 
renovation  rate  in  the  EU  and  thereby  achieve  the  targets  of  the 
Renovation Wave.  

EED Article 17 – information and training. The Woningpas is a policy 
instrument that can support Member States to provide information to 
citizens  about  the  practicalities  and  benefits  of  making  energy 
efficiency improvements.  

For  building  owners  the  Woningpas  will  be  free  [2][4].  The  total 
budget  for  the  development  of  the  Woningpas  from  2018-2022 
(versions:  Light,  Medium,  Full,  2.0  and  Continued)  is  estimated  at 
€3.2M [6] 

The  Woningpas  supports  the  achievement  of  objectives  related  to 
smart  readiness,  upgrading  the  urban  context  and  increasing 
sustainable infrastructure in the built environment. 

The  Woningpas  will  allow  building  owners  to  digitally  update  their 
building renovation passport, which in turn can recalculate the EPC of 
a building [2]. In that way it addresses the needs of building owners 
through ICT, thereby contributing to smart readiness of buildings.  

The  Woningpas  also  integrates  data  about  the  surroundings,  e.g. 
related to cultural heritage value and sensitivity for flooding [2]. This 
type  of  information  might  support  the  improvement  of  the 
resilience of buildings. 

The  Woningpas  also  stores  the  Mobiscore  (Mobility  score)  of  the 
building  [2].  This  score  indicates  how  a  district/building  scores  in 
terms of accessibility of important facilities by foot or bike [7]. When 
building  owner  awareness  about  the  Mobiscore  increases  this  might 
lead to upgrading of urban contexts. 

•  Success factors, strength and opportunities 

-  A strength of the Woningpas is that it is integral, 

multi-functional and modular.  

-  The digital passport integrates data sources from 

various government departments that previously had 

99 

Costs 

Address 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

 
 
Annex III: Good practice examples 

to be contacted one by one, in addition to functioning 
as a storage folder for information uploaded by the 
building owner. 

-  Due to the modular nature of the Woningpas, 

additional functionalities can be added step by step. 
This allows for an iterative process in which new 
functionalities can be tested, evaluated and included 
to the Woningpas when proven effective.  

-  Consequentially, the Woningpas is multifunctional and 
can function as a comprehensive information platform 
for building owners, but also for other stakeholders in 
the building supply chain, e.g. architects, construction 
professionals and potential new buyers. 
•  Challenges of implementation (weaknesses and threats) 

-  The availability of data has to be secured and 

approved. Parliamentary questions in Flanders indicate 
that the release of the Woningpas was delayed due to 
regulatory checks and procedures related to the 
release of building-related data by the government 
[8]. 

-  The credibility of the information presented in the 
Woningpas is essential for its success [6]. The 
validation of the data presented is therefore 
important. 

-  The development of the Woningpas had to be in 

alignment with the privacy law of Belgium, especially 
in relation to information that can only be provided to 
others with the explicit consent of the building owner 
[6]. 

-  One important idea of the Woningpas is that it can 

save administrative process time and provide updated 
information on the Flemish building stock. This could 
be achieved if building owners update the information 
on their building, e.g. after a renovation. However, if 
this is made obligatory building owners might perceive 
it as another obligation. Therefore, the requirement to 
update the Woningpas has been postponed and could 
be phased progressively in the future [6]. 

Digital technology – the Woningpas functions as a centralised digital 
file accessible to the building owner. 

[1]  BEreel!  (2019).  ‘Flemish  houses  now  have  a  building  passport’. 
Link 
[2] Vlaanderen. (n.d.). ‘Over woningpas’. Flemish Government. Link 
[3]  LTRS.  (2020).  ‘Langetermijn  Strategie  Voor  de  Renovatie  van 
Vlaamse Gebouwen’. Flemish Government. Link  
[4]  Energiesparen  (2018).  ‘Woningpas  -  Persdossier’.  Flemish 
Government. Link. 
[5]  Energiesparen  (n.d.).  ‘Vlaamse  langetermijnrenovatiestrategie 
voor gebouwen 2050’. Flemish Government. Link. 
[6]  Energiesparen.  (2016).  ‘Draft  designnota  Woningpas’.  Flemish 
Government. Link 
[7] Mobiscore. (n.d.). ‘Woning zoeken? Mobiscore checken!’. Flemish 
Government. Link 
[8]  Flemish  Parliament.  (2018).  ‘Schriftelijke  vraag  201  –  Stefaan 
Sintobin’. Link 

100 

Synergies 

Bibliography 

 
 
 
 
Annex III: Good practice examples 

7.6  Germany – Individual renovation roadmap for residential buildings (iSFP) 

Policy/initiative 

Individueller  Sanierungsfahrplan 
Renovation Plan for Buildings) 

für  Wohngebäude  (Individual 

Location 

Start year 

National 

2017 [1] 

Building types 

Residential (single-family buildings, multi-family buildings, etc.) 

Status  

Ongoing 

Type of policy 

Grant / building renovation passport 

Short description 

The  Individueller  Sanierungsfahrplan  (iSFP)  is  a  tool  that  provides 
residential  building  owners,  condominium  associations  and  tenants 
with  a  tailored  building  renovation  passport  with  an  approach  to 
renovate their property. The Federal Ministry of Economic Affairs and 
Energy  (BMWi)  pays  80%  of  the  costs  for  an  energy  audit  by  a 
certified expert, up to €1,300 for single and two-family buildings and 
€1,700  for  multi-family  buildings  [2].  In  practice  building  owners 
simply  hire  an  energy  auditor,  who  in  turn  applies  for  the  financial 
support  and  provides  the  building  owners  with  a  reduced  rate.  This 
simplifies the procedures for the building owner. 

The certified expert provides the building owner with an overview of 
the energy performance of the building, the potential energy savings, 
recommendations for renovation steps and their cost-benefit ratio [2]. 
This provides building owners with trustworthy information about their 
energy consumption and the trade-offs between different renovation 
measures.  The  expert  also 
financial  support 
programmes are available. 

indicates  what 

The iSFP provides the energy auditors with a predetermined reporting 
format and tool which makes the auditing process more efficient [1]. 
This format includes seven steps and instructions with regard to the 
software used, conditions applicable and information provided to the 
homeowner [3]. 

Following  the  audit,  the  building  owner  receives  a  tailor-made 
renovation  schedule  for  their  property  in  line  with  their  wishes  and 
budget.  This  can  be  a  one-time  deep  renovation  or  stepwise 
renovation schedule [2]. This supports building owners to reduce their 
energy consumption. 

Primary 
savings  

energy 

Quantified primary energy savings estimates were not found for the 
iSFP  separately  but  for  the  broader  “energy  advice  for  residential 
buildings programme”. 

2018: 59,863 MWh [7] 

CO2 emission savings  Quantified  CO₂  emissions  savings  estimates  were  not  found  for  the 
iSFP  separately  but  for  the  broader  “energy  advice  for  residential 
buildings programme”. 

2018: 18,400 T CO₂ [7] 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No specific numbers were found describing the overall increase and 
depth of the renovation rate.  

The iSFP is part of the broader “Bundesförderung für Energieberatung 
für Wohngebäude” (Energy Advice for Residential Buildings) as a tool 
for  energy  auditors  and  is  administered  on  a  national  level  by  the 
BMWi  [4].  The  tool  is  also  linked  to  the  KfW  efficiency  standard, 
because the auditor has to explain to the building owner how a one-

101 

 
 
Annex III: Good practice examples 

time  renovation  can  help  achieve  the  KfW  standard  [8].  To  simplify 
the  process  for  building  owners,  the  energy  consultants  have  been 
made responsible for the grant application to make the iSFP. They can 
also inform building owners about other financial support programmes 
offered by the German federal government [2]. 

To  facilitate  the  use  and  implementation  of  the  tool,  the  ministry  is 
working closely together with the developers of accounting software 
in  the  construction  industry  to  integrate  the  tool  in  the  software 
already  used  by  architects  and  other  construction 
industry 
professionals  [5].  Furthermore,  the  add-on  module  in  this  software 
can be updated based on feedback from professionals in the field, as 
happened in 2020 [6]. 

In  principle  the  degree  of  transferability  of  the  idea  and  methods 
behind the iSFP is high.  

Matching  EU  policy 
framework 

EPBD Article 11 –  energy performance  certificates.  The  Commission 
could  consider  complementing  article  11  and  include  (part  of)  the 
integral elements of the iSFP as requirements for the EPC.  

Renovation  Wave  initiative.  The  clear  information  provision  and 
coordination integrated in the iSFP could help increase the renovation 
rate  in  the  EU  and  thereby  achieve  the  targets  of  the  Renovation 
Wave. 

EED  Article  17  –  information  and  training.  The  iSFP  is  a  policy 
instrument that can support Member States to provide information to 
citizens  about  the  practicalities  and  benefits  of  making  energy 
efficiency improvements.  

For  2014-2018  (Energy  Advice  for  Residential  Buildings)  total  costs 
were €32.2M, of which  €25.6M was for consultations and  €6.7M for 
programme management [7]. No specific figures were found for the 
development of the iSFP. 

•  Upgrade of urban context  

-  The iSFP stimulates residential building owners to 
renovate their buildings which might result in the 
upgrade of the urban context surrounding the 
building.  

Within  the  evaluation  of  the  iSFP  one  suggestion  for  improvement 
related to the inclusion of a comfort indicator to the schedule [9]. The 
inclusion of such an indicator could improve health and wellbeing. 

Costs 

Address 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

•  Success factors, strength and opportunities 

-  The integration of iSFP in calculation software for 

building sector professionals facilitates 

102 

 
 
Synergies 

Bibliography 

Annex III: Good practice examples 

implementation, which can be considered a success 
factor. The ease of use for building owners is high 
because the auditors are responsible for applying for 
funding.  

•  Challenges of implementation (weaknesses and threats) 
-  There is no comfort indicator in the current iSFP, 

which should be included [9]. 

-  The grant for the energy audit was increased from 

60% to 80% in 2020 to further increase the uptake of 
the iSFP [10]. 

Financing renovation – once building owners know which steps they 
can take, access to financing is essential to stimulate investments in 
renovation. 

(n.d.). 

“Individueller 

für  Energieberatung 

(n.d.).  “Bundesförderung 

[1]  DENA  (2017).  “Individueller  Sanierungsfahrplan  unterstützt 
Hauseigentümer  bei  Modernisierung”.  Deutsche  Energie-Agentur. 
Link. 
[2] BMWi (n.d.). “Deutschland-machts-effizient”.  Federal Ministry  of 
Economic Affairs and Energy. Link 
[3]  FEBS  (n.d.).  “Methodology  of  the  iSFP”.  Federal  Office  for 
Economics and Export Control. Link  
[4]  BWA 
für 
Wohngebäude”. Federal Office for Economics and Export Control. Link 
[5]  DENA 
für 
Wohngebäude”. Deutsche Energie-Agentur. Link 
[6]  FEBS  (2020).  “Upgrade  des  individuellen  Sanierungsfahrplans  – 
für  Haussanierungsvorhaben  und 
iSFP  2.0  steht  ab 
Energieberater  zur  Verfügung”.  Federal  Office  for  Economics  and 
Export Control. Link 
[7] PwC (2019). “Evaluation der Energieberatung für Wohngebäude” 
Link 
[8]  BAFA  (n.d.).  “Gegenüberstellung  der  Richtlinien  2017-2020”. 
Federal Office for Economics and Export Control. Link. 
[9]  DENA  (2018).  “Pilotproject  zur  Einführung  des  individuelles 
Sanierungsfahrplans”. Deutsche Energie-Agentur. Link 
[10]  FEBS  (2020).  “Förderung  Energieberatung”.  Federal  Office  for 
Economics and Export Control. Link. 

Sanierungsfahrplan 

jetzt 

103 

 
 
 
 
Annex III: Good practice examples 

7.7  New York City (USA) – Building Emissions Law  

Policy/initiative 

NYC Building Emissions Law 

Location 

Start year 

Local level – United States of America 

2019 

Building types 

Residential buildings  

Status  

Enacted 

Type of policy 

Regulation 

Short description 

The Building Emissions Law (Local Law 97) is a mandatory minimum 
requirement  which  sets  maximum  carbon  intensity  limits  (max 
CO2/m2/y) specified to building segments [1]. 

The policy focuses on larger buildings (>7,600m2) and affects 50,000 
residential and non-residential buildings [2]. The final aim is to reduce 
city-wide emissions from buildings by 80% in 2050 [4]. 

In 2030 the law should have resulted in an emission reduction of 40% 
from a 2005 baseline [5]. 

Primary 
savings  

energy 

No concrete numbers of primary energy savings are provided. 

CO2 emission savings 

In 2005 NYC had approximately 62 MtCO₂-eq emissions [6]. In 2030 
roughly 24.8 MtCO₂ (40%) should be reduced, and in 2050 this should 
be reduced by 49.6 MtCO₂-eq (80%). 

The table below describes the emission reduction targets per building 
segment [7] 

Occupancy group 

A – Assembly 

B – Business 

Carbon limit – kg CO2e/sf 

2024-2029 

2030-2034 

10.74 

8.46 

E  and  I-4  –  Educational  and  institutional 
custodial care facilities 

7.58 

I-1  –  Institutional  supervised 
personal care facilities 

living  and 

11.38 

F – Factory and industrial 

5.74 

B  civic  administrative  facility  for  emergency 
response 
non-production 
laboratory,  Group  B  ambulatory  health  care 
facility, H, I-2 or I-3 

services, 

B 

23.81 

M – Mercantile 

R-1 – Transient residential buildings 

R-2 – Residential 

S and U – Storage 

11.81 

9.87 

6.75 

4.26 

•  No specific renovation rates or depths are mentioned. 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

The Local Law 97 is part of a larger  overall policy framework called 
the Climate Mobilisation Act. Besides the cap on emissions for large 
buildings, assessments will be made to evaluate if heat supply can be 

104 

4.20 

4.53 

3.44 

5.98 

1.67 

11.93 

4.03 

5.26 

4.07 

1.10 

 
 
 
 
Annex III: Good practice examples 

made  sustainable  and  roofs  of  buildings  will  need  to  become  green 
roofs or be filled with solar panels [3]. 

Another law that facilitates the implementation of Local Law 97 is the 
NYC  Benchmarking  Law,  which  obliges  building  owners  of  large 
properties to annually report on their water and energy usage in the 
ENERGY STAR portfolio management system [2]. This data is used to 
identify if emission reductions are achieved.  

Local  Law  33  elaborated  on  the  benchmarking  law,  giving  each 
building a grade with an obligation for building owners to display this 
grade visibly in the building [2]. 

If  building  owners  do  not  comply,  high  penalties  are  enforced, 
equalling US$268 per tonne of CO₂ per year [5]. 

Matching  EU  policy 
framework 

N/a 

Costs for the NYC  administration were not found. Costs for  building 
owners depend on the conditions of their property. 

This policy leads to an upgrade of the urban context.  

Costs 

Address 

•  Energy poverty 
•  Improve health and 

wellbeing 
•  Increased 

infra-
in  built 

sustainable 
structure 
environment 
(including 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

•  Secure 

transition 

of 

smart 
of 

fair 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

•  Success factors, strength and opportunities 

-  Term targets provide clarity to building owners. 
-  Carbon cap leaves owners freedom to choose the most 

suitable solutions. 

-  The high fines will stimulate building owners to invest 
-  Emission reductions can also be achieved by energy 

efficiency measures, which reduces the bills 
-  Linked to already existing policies like the NYC 

benchmarking law 

•  Challenges of implementation (weaknesses and threats) 
-  Certain building owners that have already made 

efforts to reduce the environmental footprint of their 
buildings still do not comply with the targets [5]. 
These building owners might have to increase the rent 
to earn back their investments in energy renovations. 

Synergies 

n/a 

105 

 
 
 
Bibliography 

Annex III: Good practice examples 

[1]https://www.urbangreencouncil.org/content/nyc-building-
emissions-law-frequently-asked-questions 
[2] https://www1.nyc.gov/html/gbee/html/plan/ll84.shtml 
[3] https://council.nyc.gov/data/green 
[4] https://laws.council.nyc.gov/legislation/int-1253-2018 
[5]https://codegreensolutions.com/nyc-carbon-emissions-bill-
passed-into-law-local-law-97-what-it-means-for-commercial-
building-
owners/#:~:text=On%20May%2018th%20Intro%201253,2030%20
from%20a%202005%20baseline. 
[6] Link 
[7]  https://www.globest.com/2019/08/27/a-deeper-dive-into-nycs-
climate-mobilization-act-and-local-law-
97/?slreturn=20200717041014 

106 

 
 
Annex III: Good practice examples 

7.8  Denmark – Better Home programme 

Policy/initiative 

Bedre Bolig 

Location 

Start year 

National level – Denmark 

2014 

Building types 

Residential buildings 

Status  

Enacted 

Type of policy 

One-stop-shop 

Short description 

In 2015 a law was adopted by the Danish government that allows the 
establishment  of  one-stop-shops.  These  enable  companies  to  map 
building  energy  saving  options,  identify  the  impact  of  these  options 
on the energy performance of the building, draft plans for how energy 
performance can best be improved, and introduce building owners to 
companies who can implement these measures [1]. 

The  Danish  Energy  Agency  subsequently  launched  the  Bedre  Bolig 
(Better Housing) scheme in 2016 [2]. The initial plan was to create a 
market-based  mechanism  without  much  public  support.  The  Bedre 
Bolig  scheme  offered  building  owners  the  opportunity  to  buy  a 
renovation  plan  based  on  the  inspection  and  advice  of  a  qualified 
expert [3].  

The plan includes information about energy performance, renovation 
steps, energy efficiency priorities, advice on energy efficient living and 
behavioural  change  and  a  total  renovation  budget  and  investments 
required [3]. 

energy 

Primary 
savings  
CO2 emission savings  No CO2 emission savings have been found. 

No primary energy savings have been recorded in the evaluation.  

Increased 
rate and depth  

renovation 

No detailed data is available on the increase of renovation depth [3]. 

Ease 
implementation 

of 

The  principle  of  one-stop-shops  is  relatively  easily  transferable  to 
other countries.  

The Danish Ministry of Climate, Energy and Buildings implemented a 
Bedre Bolig awareness campaign [3]. 

The  Danish  Energy  Agency  is  responsible  for  the  operation  of  the 
Bedre Bolig scheme [2]. 

Qualified professionals and construction companies are responsible for 
the design and implementation of the renovation measures.  

•  Renovation Wave 

€2.015 million [3] 

Upgrade of the urban context 

Matching  EU  policy 
framework 

Costs 

Address 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment 
(including 

107 

 
 
 
 
enhanced 
resilience 
building) 
•  Increase 
readiness 
buildings 

•  Secure 

transition 

of 

smart 
of 

fair 

•  Upgrade  of  urban 
context  (including 
access 
to 
sustainable 
mobility) 

Lessons learned 

Annex III: Good practice examples 

•  Success factors, strength and opportunities 

-  Homeowners that bought a Bedre Bolig plan generally 
implemented more “innovative” renovations [3].  

-  400 qualified experts have been trained to provide 

advice and write Bedre Bolig renovation plans [3] 
•  Challenges of implementation (weaknesses and threats) 

- 

- 

In the view of the Danish government the programme 
did not live up to the initial expectations due to the 
relatively low amount of renovations (2016). A major 
reason is that homeowners are not used to paying for 
renovation advice [3]. Municipalities stepped in and 
provided many with up to 50% of the cost, which 
stimulated many to invest in a Bedre Bolig plan. 
Initially there was also no digital database set up to 
record the amount of Bedre Bolig renovation plans 
sold.  

-  The homeowners that implemented renovation 

measures were less interested in energy savings and 
more in health, comfort and wellbeing. The Danish 
government could have better tailored their national 
awareness campaign to these issues instead of energy 
efficiency [3]. The campaign should also be more 
tailored to homeowners experiencing changes in life 
(e.g. having children, children leaving home, etc.). 

-  An evaluation report from 2016 indicates that it 

should be clarified whether the programme is solely 
market-based or complemented by other (financial) 
schemes offered by Danish municipalities [3].  

Synergies 

Bibliography 

Financing  renovation  –  the  success  of  a  one-stop  shop  partially 
depends  on  how  easy  it  is  for  building  owners  to  get  access  to 
financing, which ideally is the one-stop-shop can facilitate. 

[1] https://www.retsinformation.dk/eli/lta/2015/1876 
[2] https://sparenergi.dk/forbruger/vaerktoejer/bedrebolig 
[3]https://ec.europa.eu/docsroom/documents/30288/attachments/3
/translations/en/renditions/pdf 

108 

 
 
 
 
Annex III: Good practice examples 

7.9  Ireland - Better Energy Communities 

Policy/initiative 

Better Energy Communities scheme (community energy grant) 

Location 

Start year 

Status 

Ireland 

2012 

Ongoing 

Building types 

Residential, non-residential, and public buildings in a community 

Type of policy 

Grant  

Short description 

The  Irish  community  grant  scheme  “Better  Energy  Communities” 
offers €20 million of funding (for 2020) to support energy efficiency 
upgrades  with  €50,000  to  €1,500,000  per  project  across  building 
types that  reduce energy consumption and achieve  various benefits 
throughout  the  community.  The  scheme  aims  at  demonstrating 
(large-scale)  renovation  project  models 
innovative 
approaches and can easily be replicated. Projects are selected based 
on a point-scoring system (minimum of 65 marks to be eligible) and 
assessed  on  a  first-come,  first-served  basis.  Evaluation  criteria  are 
value  for  money  (max.  40  marks),  community  and  partnership 
approach (max. 35 marks) and quality and delivery (max. 25 marks). 

that  use 

The  scheme,  implemented  by  the  Sustainable  Energy  Authority 
Ireland  (SEAI),  supports  insulation  measures,  renewable  energy 
installations  as  well  as  technology  and  system  upgrades  that  are 
integrated in comprehensive community projects and innovative and 
ambitious targets (single measures are not supported). The scheme 
focuses  on  community-based  partnerships  between  homeowners, 
communities, and private sector organisations, such as member of the 
SEAI’s  Sustainable  Energy  Community  (SEC)  network.  Single 
homeowners  cannot  apply,  and  beneficiaries  should  cover  different 
sectors (domestic, private, public, not-for-profit). Members of the SEC 
network have advantages in the evaluation process [1][2]. 

Primary 
savings  

energy 

2019 

€25.3  million  government  funding  invested;  €40.5  million  private 
resources mobilised to reach €65.8 million total project costs [5] 

4.8 kWh per Euro of public investment in 2019  

Programme up to now 

122.5  GWh  total  energy  credits  saved  (energy  credits  under  the 
energy efficiency obligation scheme) [5] 

CO2 emission savings 

34,676 t CO2 emissions reductions annually (2012-2019) [5] 

Costs 

In 2017 CO2  emissions  of the Irish building sector amounted to 7.7 
Mt, so the savings represent roughly 0.45%. According to the Climate 
Action Plan (2019) the indicative 2030 building sector target is to emit 
max. 5 Mt CO2. [6] 

€25.3  million  public  funding  in  2019,  €21  million  public  funding  in 
2020 
€65.8 million total project costs  
No information on renovation or administrative costs 

Increased 
rate and depth  

renovation 

Cumulatively the programme has now supported upgrades in 18,200 
homes and 2,570 non-domestic buildings [5] 

No information on renovation rate. 

109 

 
 
Ease 
implementtation 

of 

Annex III: Good practice examples 

•  Transferability: the scheme design can be transferred to other 
countries and is not limited to one climate zone. As it already 
supports multiple building types the degree of transferability is 
high.  

•  Administration: administered at national level by SEAI; 

administrative costs are shared with other grant schemes (all 
managed by SEAI, share code of practice and list of qualified 
contractors) 

•  Compliance checks: pre- and post EPCs (Building Energy 

Rating, BER) are required for all upgraded buildings; minimum 
BER after the renovation works is C1 (preferably B2); works 
must comply with Part L of the building regulations and Better 
Energy Homes Scheme Contractors Code of Practice, QADP 
(Quality Assurance and Disciplinary Procedures), Standards and 
Specification Guidelines; M&V requirements [1]. 

•  Complementary measures:  

-  The community grant scheme is part of the Better Energy 

Homes schemes which funds energy efficiency upgrades 
of the Irish building stock. The scheme follows the same 
guidelines and must meet the standards of the Building 
Regulations Part L (Conservation of Fuel and Energy). If 
a heat pump system is installed as part of a community 
project the heat loss indicator requirements of the heat 
pump grant needs to be followed [1], [12] 

-  The SEC is a SEAI network initiative accompanying the 

community grant to accelerate the exchange between 
communities and learn from each other. SEC members 
are prioritised in the grant application phase[1]. 
-  The scheme design recommends cooperation with a 

participating energy supplier under the energy efficiency 
obligation scheme to trade their amount of energy saved 
(1 kWh saved equals one energy credit) for support in 
the form of project management, financial contribution, 
provision of materials, installation of works, monitoring, 
energy audits or advice [1]. 

Matching  EU  policy 
framework 

As a grant scheme, the community energy grant could be integrated 
as a good practice policy for other financial schemes on national level 
or funding criteria of the EU ESI funds [7]. 

It  could  also  provide  good  examples  for  the  Community-led  Local 
Development programme of the European Structural and Investment 
Funds [8] 

•  The grant scheme supports residential projects of residents at 
risk of energy poverty with a special focus (up to 80% of 
the costs for energy-poor households, overall level of support 
only 50%) [1] 

•  Improve health and wellbeing: see case studies on 

healthier and more comfortable homes (SEAI, 2018) [3], no 
exact numbers available 

•  Secure fair transition: programme beneficial to a broad 

range of stakeholders 

Addressing 

•  Energy poverty 
•  Improve 

health 

and wellbeing 

•  Increased 

sustainable  infra-
structure  in  built 
environment  (incl. 
climate resilience) 
smart 
of 

•  Increase 
readiness 
buildings 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
(incl. 

context 

110 

 
 
 
access 
sustainable 
mobility) 

to 

Lessons learned 

Synergies 

Annex III: Good practice examples 

•  Success factors, strength and opportunities 

-  Community approach (benefits for the larger community) 
-  Fabric-first approach (prevents oversized supply-side 
measures (e.g. heat pumps) being implemented) [4] 

-  Supporting innovative approaches (demonstration 

projects to test and implement new business models and 
technologies) [1] 

•  Challenges of implementation (weaknesses and threats) 

-  Product manufacturers proposing projects which focused 
on their products (supply-side options) rather than what 
is necessary for the homes in question (reason to 
implement the fabric-first approach) 

-  Requirement of B2 BER after the intervention makes 

compliance with application criteria harder 

The  community-oriented  approach  of  the  grant  scheme  supports 
innovative, large-scale projects, creating synergies with the district 
approach policy area.  

The community grant also impacts the area of financing renovation 
as it unlocks financial means for end-users (including a higher share 
of  funding  for  energy-poor  users).  The  eligible  criterion  of  a 
sustainable financing model ensures that applicants have the financial 
resources in place to complete their project. 

The application guidelines of the grant scheme additionally require the 
applicants  to  adopt  smart  technologies  as  appropriate  which  might 
lead  to  increased  digital  technologies  and  smart  building  systems 
implemented  and  creates  synergies  with  the  digital  technology 
area. 

Bibliography 

[1] SEAI (2019). Communities Energy Grants Application Guidelines 
2020. Sustainable Energy Authority of Ireland  

[2] SEAI (2018a). Better Energy Communities Application Guidelines 
2018. Sustainable Energy Authority of Ireland. 

[3]  SEAI  (2018b).  How  communities  are  working  together  to  save 
energy. Case Study report, Sustainable Energy Authority of Ireland. 

[4]  SEAI  (2017).  Better  Energy  Communities  Application  Guidelines 
2017. Sustainable Energy Authority of Ireland  

Web sources: 

[5] SEAI webpage about the grants of the Better Energy Communities 
scheme: 
https://www.seai.ie/grants/community-grants/project-
criteria-and-funding 

[6] Climate Action Plan 2019, Ireland https://www.dccae.gov.ie/en-
ie/climate-
action/publications/Documents/16/Climate_Action_Plan_2019.pdf 

[7]  Common  Provisions  on  EU  funds,  EU  1303/2013  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R1303&from=EN 

[8]  EU  Commission,  Guidance  for  Member  States  and  Programme 
Authorities  on  Community-led  Local  Development  in  ESI  Funds 
https://ec.europa.eu/regional_policy/sources/docgener/informat/20
14/guidance_community_local_development.pdf  

111 

 
 
Annex III: Good practice examples 

7.10  France – Picardie Renovation Pass 

Policy/initiative 

Picardie Pass Rénovation (Picardie Renovation Pass) 

Location 

Start year 

Regional 

2013 

Building types 

Residential (single-family buildings, multi-family buildings, etc.) 

Status  

Ongoing 

Type of policy 

One-stop shop 

Short description 

The Picardie Pass offers building owners an integral service including 
energy  performance  advice,  technical  support,  financial  support, 
monitoring and links to construction professionals [1].  

The  management  team  of  the  Picardie  Pass  takes  responsibility  for 
payment of the companies, collection of the subsidies and setting out 
a  tender  for  the  renovation  amongst  construction  companies. 
Residents start paying a fixed monthly reimbursement for a duration 
ranging between 10 and 25 years with 2% interest rate [2]. Funding 
for  the  Picardie  Renovation  Pass  is  derived  from  the  European 
Investment  Bank  (EIB),  Interreg  and  the  Region  of  Picardie.  The 
programme aims to reduce primary energy consumption by 40-75% 
[1]. 

Primary 
savings  

energy 

18.25 GWh/y [3] - 45 GWh/y [2] 

CO2 emission savings 

3,400 tCO₂/y [3] – 6,000 tCO₂/y [2] 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

45% real energy savings per building on average [1] 

A regional public service company has been created to administer the 
implementation of the Picardie Pass. The “Régie Régionale du Service 
Public  de  l’Efficacité  Energétique  (SPEE)  en  Picardie”  has  14 
employees and collaborates with external partners in the construction 
sector and administrative sector [3]. 

Final investments are based on the results of energy audits as a form 
of compliance check.  

Matching  EU  policy 
framework 

The Picardie Rénovation Pass could contribute to achieving the targets 
of the Renovation Wave. 

Costs 

Address 

•  Energy poverty 
• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 

• 

Total  estimated  costs  of  the  project  were  €54.4M,  of  which  €45.4M 
was  for  the  renovation  activities  and  €9M  for  planning  and 
administration [2]. Real costs turned out to be  €35M for renovation 
measures. 

Division  of  costs  for  an  average  financial  renovation  package:  13% 
subsidies, 17% self-financing, 70% third-party financing [2]. Average 
investments were €42,000 for single-family houses, and €15,350 for 
apartments [3]. A leverage factor of 20 was achieved [3]. 

The  Picardie  renovation  programme  helps  to  upgrade  the  urban 
context in the region Hauts de France due to the renovation of mostly 
old buildings constructed before 1975. 

The Picardie renovation programme helps to achieve a fair transition 
because it resulted in 372 FTE, mostly local jobs [2][3].  

112 

 
 
Annex III: Good practice examples 

(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

• 

of 

smart 
of 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
to 
sustainable 
mobility) 

Lessons learned 

•  Success factors, strength and opportunities 

-  Technical support is highly appreciated by end-users 

[2]. 

•  Challenges of implementation (weaknesses and threats) 

-  Very old buildings are difficult to renovate due to the 

limited amount of qualified companies, difficult cost 
estimations and generally higher costs and longer 
renovation duration [2] 

-  Non-technical support, e.g. administrative support, for 

companies and end-users is underestimated but 
necessary to assure all actors know their role in the 
supply chain [2]  

-  Technical issues often occur related to the quality of 
the renovation measures and airtightness of the 
building. Consequentially, more measures may 
become necessary [2] 

-  Organisational and administrative difficulties occur 
related to communication between actors in the 
supply chain and related to receiving invoices and 
technical drawings and incorporating additional 
requests from residents [2]  

-  Renovating multi-apartment buildings is a lengthier 

process than single-family buildings [3] 

-  The Hauts de France region is completely responsible 
for the development and financial risks of third-party 
financing. Even if the risks prove manageable, further 
financial structuring should be pursued, e.g. by 
limiting third-party financing or a debt assignment 
mechanism to limit borrowing from the EIB [3]. 

Synergies 

Bibliography 

The  Picardie  Renovation  Pass  also  relates  to  the  strategic  area  of 
financing  renovation.  If  designed  properly  and  all  actors 
collaborate,  the  policy  could  lead  to  increased  funding  available  for 
building renovation. 

[1]  SPEE  (2019).  “La  Service  public  de  l’efficacité  énergétique  des 
Hauts-de-France”. Region Hauts de France. Link  
http://www.planbatimentdurable.fr/IMG/pdf/dp-bilanforumspee-
fev2019.pdf 
[2] Morcrette, A. (2018). “Experimental deployment of Picardie Pass 
Rénovation”. Picardie Renovation Pass. Link 
[3]  EIB  (2018).  “ELENA  Completed  Project  Factsheet  –  Picardie 
Renovation Pass”. European Investment Bank. Link  

113 

 
 
 
 
Annex III: Good practice examples 

7.11  Romania – National Thermal Rehabilitation Programme 

Policy/initiative 

National Thermal Rehabilitation Programme 

Location 

Start year 

National level - Romania 

2009 

Building types 

Residential buildings (Condominiums) 

Status  

Type of policy 

Short description 

Enacted 

Grant 

The National Thermal Rehabilitation Programme is based on grants for 
condominium associations to improve energy efficiency and wellbeing 
[1].  The  objective  of  the  programme  is  to  reduce  greenhouse  gas 
emissions and improve environmental, health and economic value in 
urban areas. 

Condominium  associations  have  to  pay  20%  of  the  costs,  the  other 
80% is paid by local and state budgets [1].  

The program was initiated in 2009, and in 2020 the new multi-annual 
budget for the programme from 2020 – 2022 was approved [2]. 

Renovation  measures  related  to  the  building  shell,  the  heating 
systems and the hot-water supply are eligible [5]. 

Primary 
savings  

energy 

No information was found for the period from 2009-2014. 

From 2014-2020 the programme resulted in CO2 emissions equal to 
0.7 Mtoe (11,630 GWh) [3]. 

CO2 emission savings  No information available 
No information available 

renovation 

Increased 
rate and depth  

Ease 
implementation 

of 

50% of the funding comes from the state budget through the Ministry 
of  Regional  Development  and  30%  of  the  costs  come  from  local 
government budgets [1]. 

Besides  the  grant  programme,  there  is  a  thermal  renovation  loan 
programme  that  provides  low-interest  financing  options  for  energy 
performance renovations [4].  

Matching  EU  policy 
framework 

•  Renovation Wave 

Costs 

Address 

Funding  is  allocated  per  building  blocks  in  specific  regions  and 
accounts  for  €10  million  (2020-2022)  (assuming  the  budget  is 
expressed in Romanian Leu) [6] 

Upgrade of the urban environment  

• 

•  Energy poverty 
• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 

of 

114 

 
 
 
 
• 

Increase 
readiness 
buildings 

smart 
of 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

Annex III: Good practice examples 

•  Success factors, strength and opportunities 

-  The high grant ratio encourages condominium 
associations to apply for the programme.  

•  Challenges of implementation (weaknesses and threats) 

[1] https://www.mlpda.ro/pages/pncrestereperformanta 
[2]http://lexcafe.ro/2020/06/15/a-fost-aprobat-programul-national-
multianual-privind-cresterea-performantei-energetice-a-blocurilor-
de-locuinte 
[3]https://ec.europa.eu/energy/sites/ener/files/documents/ro_neea
p_ro.pdf [p33]  
[4]https://ec.europa.eu/docsroom/documents/29812/attachments/4
/translations/en/renditions/native 
[5] http://legislatie.just.ro/Public/DetaliiDocument/103284 
[6] 
pentru-aprobarea-programului-national-multianual-privind-
cresterea-performantei-energetice-a-blocurilor-de-locuinte-cu-
finantare-in-perioada-2020-2022 

https://lege5.ro/Gratuit/gm3tinbsg44a/ordinul-nr-2154-2020-

115 

 
 
 
 
 
 
 
Annex III: Good practice examples 

7.12  Portugal – Energy Certification of Buildings 

Policy/initiative 

Certificação Energética dos Edifícios – Energy Efficiency Certification of 
Buildings 

Location 

Start year 

National level 

2007 

Building types 

Residential and non-residential 

Status  

Ongoing 

Type of policy 

Energy performance certification scheme 

Short description 

The Energy Efficiency Certification of Buildings scheme aims to improve 
energy performance, health and comfort [1]. Buildings receive a rating 
ranging from F to A+. The digital certificate specifies how the EPC affects 
categories  like  comfort,  health,  and  energy  consumption  of  hot  water 
and air conditioning [1]. EPCs in Portugal are issued by qualified experts 
that also suggest customised renovation measures to building owners to 
improve the energy performance and comfort of their properties. 

Different requirements apply to EPCs for buildings in the residential and 
non-residential sector [2]. EPC requirements apply for all new buildings 
and existing buildings. In case of sale, rent or major renovation, a valid 
EPC  must  be  presented.  If  a  building  does  not  have  an  EPC  before  a 
renovation  or  construction,  a  provisional  EPC  is  formulated.  This 
provisional  EPC  must  be  validated  after  the  renovation/construction  is 
finished [2]. Developers and real estate agents are also obliged to display 
the  EPC  in  advertisements,  in  addition  to  all  large  building  owners 
(>1000m2) [4]. 

The scheme’s website provides a clear overview with national statistics 
including  the  ratio  of  EPC  scores  in  all  Portuguese  regions  and  the 
amount of measures implemented [3]. 

energy 

Primary 
savings  
CO2 emission savings  No specific data on the impact of EPCs on CO2 emission savings has been 

No  specific  information  about  the  impact  of  EPCs  on  primary  energy 
savings has been found. 

found. 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

No specific information about the increase in renovation rate or depth of 
renovation was found. 

Energy efficiency certification schemes already exist in multiple European 
Member States, which suggests that the transferability of the measure 
is high. One issue could be the public display of EPC data, which might 
be more difficult in countries that prioritise data protection [9]. 

The policy is administered by ADENE, the Portuguese Energy Agency [7]. 
Compliance  checks  exist  for  the  experts  doing  the  EPCs.  These 
professionals  must  be  architects  or  engineers  with  at  least  five  years’ 
experience in the field of energy efficiency and pass an exam of ADENE 
[6]. Non-compliance of experts can be penalised with fines.  

The scheme is complemented by  other policy initiatives. These include 
the  energy  labelling  of  installations  and  products  with  the  voluntary 
CLASSE+ certification  and the  online portal  casA+. CLASSE+ indicates 
how energy efficient building products are (e.g. installations, windows, 
etc.).  casA+  functions  as  a  one-stop-shop  and  centralises  all  relevant 
information on the building in one accessible location besides providing 
building owners with potential renovation measures [1].  

116 

 
 
 
 
Annex III: Good practice examples 

Revenues for the EPC scheme outweighed the costs of administration in 
2018 and 2019 [7]. This could be related to the registration costs that 
need to be paid to put the EPC in the ADENE database, ranging between 
€35-65  for  residential  buildings  and  €2-5/m²  for  non-residential 
buildings. This registration fee is included in the EPC price and functions 
as income for ADENE [8].  

Costs for building owners that want to obtain an EPC range between €135 
- €465 [6]. 

The EPC displays building information related to health and wellbeing 
in  addition  to  energy  performance,  nudging  building  owners  e.g.  to 
improve indoor air quality. 

Costs 

Address 

•  Energy poverty 
• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

smart 
of 

of 

• 

• 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
to 
sustainable 
mobility) 

Lessons learned 

•  Success factors, strength and opportunities 

-  High uptake of EPCs, with more than 1.3 million EPCs 
issued and 15% of the building stock covered [6]. 
-  Centralised database that provides insight into national 

and regional building performance and generates 
awareness amongst building owners and tenants. 
-  Links with other policy programmes like casA+ and 

CLASSE+ that enhance public awareness about energy 
efficiency. 

•  Challenges of implementation (weaknesses and threats) 

-  Lack of awareness amongst building owners [5] 
-  Financial concerns related to energy efficiency [5] 
-  Training sufficient qualified experts that can perform 

energy audits [5] 

-  Privacy issues related to public EPC databases [9] 
-  The calculation methodology of the energy certification 

scheme has changed drastically in the past 10 years. As 
a result, buildings that were certified in 2010 will receive 
a significantly different score in terms of primary energy 
use and emissions. This might cause confusion about 
actual energy performance and might deteriorate trust in 
the rating [10]. 

Synergies 

Bibliography 

The  digital  EPCs  linked  to  online  platforms  like  casA+  rely  on  digital 
infrastructure and contribute to the digitalisation of the building sector. 

[1] https://www.adene.pt/edificios 
[2] https://www.buildingrating.org/jurisdiction/Portugal 

117 

 
 
 
 
Annex III: Good practice examples 

https://www.odyssee-mure.eu/publications/national-

[3] https://www.sce.pt/estatisticas 
[4] 
reports/energy-efficiency-portugal.pdf  
[5] http://ccap.org/assets/CCAP-Booklet_Portugal.pdf 
[6] 
content/uploads/2018/01/iBROAD_CountryFactsheet_PORTUGAL.pdf 
[7] 
2021/mobile/index.html 
[8] 
national-portugal-web.pdf 
[9] 
Certification-web.pdf 
[10] 
https://www.sciencedirect.com/science/article/pii/S235248471930472X 

https://www.epbd-ca.eu/outcomes/2011-2015/CA3-CT-2015-1-

http://www.buildup.eu/sites/default/files/content/ca3-2016-

https://www.adene.pt/Files/flipbook/ADENE-PAO-2019-

http://ibroad-project.eu/wp-

118 

 
 
 
 
Annex III: Good practice examples 

7.13  Poland – Catching Up Regions programme 

Policy/initiative 

Catching Up Regions programme 

Location 

Start year 

Regional level (Poland) 

2016 

Building types 

Single-family buildings 

Status  

Abandoned 

Type of policy 

Targeted subsidies and tax incentives 

Short description 

The objectives of the policy were to reduce air pollution and improve 
energy  efficiency  of  single-family  buildings  [1].  The  Malopolskie  and 
Śląskie regions were identified for a programme of thermal retrofitting 
and replacement of heating systems. These regions were selected due 
to the significant environmental pollution present, partially caused by 
inefficient fossil fuel heating systems [1]. 

The  World  Bank  was  commissioned  by  the  European  Commission  to 
support  the  government  of  Poland  in  the  design  of  financial 
instruments  to  replace  non-compliant  solid  fuel  boilers  and  energy 
efficiency  retrofits  of  single-family  buildings  [1].  The  World  Bank 
involvement in the project had two phases – phase one ended in 2017 
[1] and the second phase was in 2018-2019 [2]. 

During  the  first  phase  consensus  amongst  the  local  stakeholders 
resulted in the strategy to develop two tools [1]:  

1)  Public and financial support for poor single-family buildings with 
90-100% subsidy with municipal monitoring and administration 
2)  Commercial  financial  instruments  to  support  non-poor  single-
family  buildings  including  20%  subsidies  and  fiscal  incentive 
mechanisms. 

Primary 
savings  

Energy 

The potential savings for the regions are: 
2.14  TWh/year  (poor  single-family  buildings)  and  11.38  TWh/year 
(non-poor single family buildings [1] 

CO2 emission savings 

The potential savings for the regions are: 
451,884  tCO₂/year  (poor  single-family  buildings)  and  2,403,576 
tCO₂/year (non-poor single-family buildings) [1]  

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No information found 

The energy efficiency and anti-smog renovation programme was part 
of  a  broader  programme  of  not  directly  related  activities  in  Poland, 
which  included  food  inspection  practices,  establishing  an  innovation 
centre and improvement of spatial planning [2]. 

The  programme  was  a  pilot  project  in  the  EU-wide  “Catching  Up” 
initiative [4]. 

The Malopolskie and Śląskie regions had previously implemented anti-
smog regulations in order to phase out inefficient heating systems [1]. 

The  World  Bank  maintained  a  strong  coordination  team,  and 
collaborated with a multidisciplinary and autonomous team of experts 
that had regular contact with local (regulatory) stakeholders in Poland 
[1].  Furthermore,  the  European  Commission  monitored  the  progress 
and acted as a facilitator at times of tension.  

Matching  EU  policy 
framework 

Renovation Wave 

119 

 
 
Costs 

Address 

•  Energy poverty 
• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

smart 
of 

of 

• 

• 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
sustainable 
to 
mobility) 

Lessons learned 

Synergies 

Bibliography 

Annex III: Good practice examples 

Costs for the design of the plans were not found.  

Implementation of the plan for poor SFBs would range between €0.7–
1.1 billion and between €4-6 billion for the non-poor SFB [1]. 

An  explicit  aim  of  the  renovation  programme  was  to  improve  the 
health and wellbeing of Polish residents.  

Securing a fair transition by providing poor single-family buildings 
subsidies.  

•  Success factors, strength and opportunities 

-  Collaboration with local stakeholders [1] 
- 

Integration of the programme with existing policies [1] 

Financing renovation is essential to implement these plans.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               

[1] 
http://documents1.worldbank.org/curated/en/658171529401377521
/pdf/127333-WP-P131821-PUBLIC-envsingleweb.pdf  

[2]https://www.worldbank.org/en/country/poland/publication/catchin
g-up-regions 

[3]http://documents1.worldbank.org/curated/en/3215515613563140
44/pdf/Poland-Catching-Up-Regions-3-Overview-Report.pdf 

[4]https://ec.europa.eu/regional_policy/en/policy/how/improving-
investment/lagging_regions 

http://documents1.worldbank.org/curated/en/628751529413212282
/pdf/WP-P131821-PUBLIC-POLISH-plvsingleweb.pdf 

120 

 
 
 
 
Annex III: Good practice examples 

7.14  Ireland - ProEnergyHomes 

Policy/initiative 

ProEnergy Homes 

Location 

Start year 

National level - Ireland 

2018 

Building types 

Residential buildings  

Status  

Enacted 

Type of policy 

Short description 

A one-stop-shop initiative of the Sustainable Energy Agency Ireland 
(SEAI)  in  collaboration  with  private  credit  unions.  The  scheme 
includes  building-specific  energy  advice  by  a  qualified  expert  on 
renovation  actions  and  low-interest  renovation  loans  that  can  be 
supplemented with a grant of up to 35% from the SEAI [1]. 

After a pilot in 2018 with five participating credit unions in Dublin, the 
programme  was  expected  to  increase  the  amount  of  implemented 
renovation measures 10-fold for a loaned amount of €10 million [3]. 

The payback period is often short. For many cases net savings can be 
achieved  within  5-7  years  while  having  an  improved  and  healthier 
living environment [3]. 

energy 

Primary 
savings  
CO2 emission savings  No information found  

No information found 

Increased 
rate and depth  

renovation 

No specific information provided 

Ease 
implementation 

of 

The  scheme  is  implemented  by  The  Solution  Centre  (a  strategic 
development unit for credit unions), the SEAI, Retrofit Ireland (REIL) 
and 20 participating private credit unions [2].  

The Solution Centre ensures there is a dedicated project manager to 
support  applicants  with  each  step  in  the  renovation  process,  from 
applying  to  funding  to  the  implementation  of  the  renovation 
measures.  

Retrofit Ireland ensures that an energy audit is performed while SEAI 
provides  a  grant  and  the  credit  unions  ensure  that  low  interest 
financing is available [2].  

Matching  EU  policy 
framework 

Renovation Wave 

Costs 

Address 

The average loan in the pilot phase was €10,000 and total investment 
costs around €15,000 [2]. 

Upgrade of the urban context 

• 

•  Energy poverty 
• 

health 

Improve 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 

121 

 
 
 
Annex III: Good practice examples 

• 

resilience 
building) 
Increase 
readiness 
buildings 

of 

smart 
of 

•  Secure 

fair 

transition 

•  Upgrade  of  urban 
context  (including 
to 
access 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

•  Success factors, strength and opportunities 

-  The successful pilot indicates demand for the 

programme. 

-  Public-private partnership with public and private 

knowledge and funding [1]. 

-  Building owners indicate that they would now consider 

renovation while they did not do this before [2]. 
-  Energy renovation is made very easy for building 

owners, who only have to fill in an application form 
and approve the plan made by REIL [2]. 

Financing renovation is part of what makes the services of this one-
stop-shop attractive for building owners.  

[1]https://proenergyhomes.ie 
[2]https://www.solutioncentre.ie/2019/05/13/credit-unions-team-
up-with-seai-reil-to-provide-pro-energy-homes-scheme 
[3] 
unions-to-loan-up-to-10m-for-home-energy-upgrades-1.3889800 

https://www.irishtimes.com/business/financial-services/credit-

122 

 
 
 
 
Annex III: Good practice examples 

7.15  Sweden – Carbon tax 

Policy/initiative 

Carbon tax (Koldioxidskatt) 

Location 

Start year 

National – Sweden 

1991 

Building types 

Residential and non-residential 

Status  

Ongoing 

Type of policy 

Regulation – Tax 

Short description 

Primary 
savings  

energy 

CO2 emission savings 

Increased 
rate and depth  

renovation 

The  Swedish  carbon  tax  is  levied  on  combustion  of  fossil  energy 
carriers [1]. The tax is based on the carbon content of the fuel because 
the  emissions  are  proportional  to  the  carbon  content.  As  such,  it  is 
not necessary to measure the actual emissions. Sustainable biofuels 
are not taxed [1].  

Since  the  carbon  tax  was  introduced  in  the  1990s  it  has  increased 
from €23 to €110/tCO₂ in 2020. 

All economic sectors outside of the electricity sector are covered by 
the tax [3]. Emissions in the building sector are subject to the carbon 
tax, which has resulted in significant emission reductions [3]. These 
reductions were mostly achieved by a change in fuels (from fossil to 
sustainable  biomass  and  electricity),  scaling  up  district  heating 
systems and electrification of heat sources. 

Emissions for heating have decreased by 80% since the introduction 
of the carbon tax in 1991 [3]. 

No information about renovation depth.  

Ease 
implementation 

of 

The  transferability  of  the  policy  is  high,  especially  if  Member  States 
already have systems of energy or fuel taxation in place [1]. 

The  carbon  tax  is  part  of  a  wider  set  of  environmental  policies 
including the energy tax, the VAT on energy, and taxes for nitrogen 
oxide and sulphur [3]. Close interlinkages exist with the energy tax, 
where increases in the carbon tax are synchronised with reductions of 
the  energy  tax.  This  reduces  the  increase  of  the  overall  tax  burden 
but  simultaneously  provides  customers  with  a  clear  price  signal  for 
carbon usage [3]. 

Matching  EU  policy 
framework 

Renovation Wave 

Costs 

Address 

In 2017, the revenues of the carbon tax were €2.4 billion. Combined 
with the energy tax the total revenues accounted for €7.2 billion [3]. 

Increase sustainable infrastructure in built environment  

• 

•  Energy poverty 
• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 

123 

 
 
 
 
 
 
 
 
 
• 

resilience 
building) 
Increase 
readiness 
buildings 

of 

smart 
of 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
to 
sustainable 
mobility) 

Lessons learned 

Annex III: Good practice examples 

•  Success factors 

-  Low administrative costs for the authorities [1] 
-  Simple design and common units (carbon content) for 

calculation of tax rates facilitated monitoring, 
evaluation and compliance [2]. 

-  Significant exemptions were provided to industries to 

reduce double-taxing and protect competitiveness [2]. 
These exemptions did not, however, result in missing 
significant abatement opportunities and improved the 
cost-effectiveness of the tax [3]. Additional 
exemptions were provided based on geographic and 
social grounds [2]. 

-  Public acceptance and support for high tax rates are 
present in Sweden, while adverse economic impacts 
have been reduced by strategic exemptions [3].  
-  The carbon tax has succeeded in increasing demand 

for alternative fuels [2]. 

Synergies 

Bibliography 

n/a 

[1]  Government  Offices  of  Sweden  (2020).  “Sweden’s  carbon  tax”. 
Link 
[2] https://es.catapult.org.uk/wp-content/uploads/2018/10/Sweden-
Case-Study-FINAL.pdf 
[3] 
carbontax-se.pdf 

https://www.euki.de/wp-content/uploads/2018/09/fact-sheet-

124 

 
 
 
 
 
 
 
Annex III: Good practice examples 

7.16  Scotland – Historic Environment climate action plan 

Policy/initiative 

Historic Environment climate action plan 2020-25  

Location 

Start year 

Regional level – Scotland  

2020 

Building types 

Cultural heritage  

Status  

Type of policy 

Short description 

Enacted 

Initiative 

Strategic action plan from Historic Environment Scotland (HES), the 
public body responsible for research into and maintenance of historic 
sites in Scotland [1]. The plan addresses seven priority areas for the 
management and preservation of historic sites, of which one relates 
to  energy  and  carbon  management  [1].  This  includes  the  target  to 
become “net-zero” in 2045, elimination of gas heating and transition 
to  100%  renewable  heat  in  2032,  historic  sites  as  energy  hubs  in 
populated areas, and the improvement of energy efficiency of all sites. 

The plan also sets out targets and goals in relation to climate change 
adaptation, circularity, biodiversity and landscapes. 

HES annually invests in many conservation and renovation projects in 
Scotland [2]. 

No information found. 

Energy 

Primary 
savings  
CO2 emission savings  No  information  was  found  on  the  CO2  emission  reductions  from  the 
climate  action  plan.  However,  over  the  period  2015-2019  GHG 
emissions dropped by 23% [2]. 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

No information found.  

Historic Environment Scotland is responsible for the implementation 
of the strategy. HES is a non-departemental public body that manages 
over 300 historic sites of national and cultural importance. The board 
is appointed by Scottish ministers.  

Next  to  the  climate  action  plans,  HES  is  running  an  overarching 
strategy for cultural heritage, “Our Place in Time”.  

The wider policy framework includes important laws like the Climate 
Change  Act  (2009),  the  Climate  Change  (Emission  Reduction 
Targets)(Scotland)  Act  2019,  Our  Place  in  Time,  the  Historic 
Environment  Strategy  for  Scotland  (2014-2024),  the  Historic 
Environment  (Scotland)  Act  2014,  the  Climate  Change  (Duties  of 
Public  Bodies:  Reporting  Requirements)(Scotland)  Order  2015  and 
Scotland’s National Performance Network [1]. 

The  transferability  of  the  programme  depends  on  the  governance 
structures for cultural heritage in place in other Member States. 

Compliance is checked because HES produces annual reports with the 
yearly environmental performance [2]. 

Matching  EU  policy 
framework 

Renovation Wave 

EU European Heritage Strategy for the 21st Century 

Costs 

Costs for the implementation still have to be calculated [1].  

125 

 
 
 
Annex III: Good practice examples 

In  2018-19  HES  invested  £7,8  million  in  its  own  properties  and 
provided  £14.5  million  in  grants  for  renovation/restauration  and 
archaeology [1]. 

Address 

Secure a fair transition  

•  Energy poverty 
• 

Increased  sustainable 
(including climate resilience). 

infrastructure 

in  the  built  environment 

• 

• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

•  Success factors, strength and opportunities 

-  Many measures in the plan make financial sense by 

offering cost-reduction potential, e.g. through reduced 
waste, travel and energy use [1]. At Edinburgh Castle, 
for example, a £480,000 investment in energy 
efficiency reduced final energy consumption by 30% 
and emissions by 40% and had a payback time of five 
years. 
Improving the climate resilience of cultural heritage 
helps to avoid high financial costs in the future [1]. 

- 

- 

•  Challenges of implementation (weaknesses and threats) 
It is a challenge for HES to reduce emissions and 
impact while simultaneously having to facilitate and 
welcome increasing numbers of visitors to cultural 
heritage buildings [1]. 

-  Climate change makes managing vulnerable buildings 

and landscapes more costly and complex [1]. 

[1]https://www.historicenvironment.scot/archives-and-
research/publications/publication/?publicationId=94dd22c9-5d32-
4e91-9a46-ab6600b6c1dd 
[2]https://www.historicenvironment.scot/archives-and-
research/publications/publication/?publicationId=0652b7cd-7482-
4425-81a9-aad2010ea614 

126 

 
 
 
 
 
 
 
 
 
 
 
Annex III: Good practice examples 

8  Good practice examples: built environment and adaptation to climate 

change 

The following pages provide examples of good practice policies in the strategic area of built 
environment and adaptation to climate change. 

8.1  Croatia – Croatian Building Act 

Policy/initiative 

Croatian Building Act (Zakon o gradnji) 

Location 

Start year 

National level 

2013  (December);  most  recent  version  in  force  since  28  December 
2019 

Status  

Ongoing  

Building types 

According  to  Article  2  of  the  Building  Act,  its  provisions  apply  to  all 
construction  works  in  the  territory  of  the  Republic  of  Croatia 
(excluding mining structures and facilities, military construction works 
and  other  construction  works  regulated  under  special  regulations/a 
special act) [2]. The provisions apply to new construction works and 
to  the  reconstruction,  removal  and  maintenance  of  existing 
construction works, unless otherwise specified. [2] 

Article 3, No. 27. of the Building Act defines a building as “a closed 
and/or covered construction work which is intended for the residence 
of  human  beings  or  for  the  accommodation  of  animals,  plants  and 
things. […]”. Article 3, No. 28. defines a public building as “a building 
or  a  part  thereof  used  by  public  authorities  for  performing  their 
activities,  a  building  or  a  part  thereof  used  for  residential  purposes 
and  a  non-residential  building  or  part  thereof  in  which  a  number  of 
people  are  present  or  a  larger  number  of  people  are  provided  a 
service.” [2] 

Therefore, the Building Act covers residential (single-family buildings, 
multi-family  buildings,  etc.),  non-residential  and  public  buildings 
alike. 

Type of policy 

Reguation (Act) 

Short description 

Article  15  of  the  Building  Act,  in  force  since  28  December  2019, 
stipulates that “buildings must be designed, constructed and removed 
in such a way that the use of natural resources is sustainable, and in 
particular must guarantee the following: 

1)  reuse  or  recyclability  of  the  building,  its  materials  and  parts 

after removal 

2)  durability of the building 
3)  use  of  environmentally  friendly  raw  materials  and  secondary 

materials in buildings.” [1] 

Such a legal stipulation to design buildings for reuse and recyclability 
and for durability sets an effective framework to foster circular design 
and buildings, and is seldom found across the countries analysed. 

energy 

No information available 

Primary 
savings  
CO2 emission savings  No information available 
No information available 

Costs 

Increased 
rate and depth  

renovation 

No information available 

127 

 
 
Ease 
implementation 

of 

Annex III: Good practice examples 

The Building Act seems to be transferable across countries and climate 
zones,  because  stipulations  can  be  adapted  to  the  specific  climatic, 
socio-demographic  and  socio-cultural  context  of  different  countries. 
As  the  Building  Act  encompasses  a  wide  diversity  of  building  types, 
transferability appears high in this regard, too. 

The Building Act is administered on the national level by the Ministry 
of Construction and Physical Planning. It is responsible for supervision 
of the implementation of the Act and regulations adopted on the basis 
of it, and of the legality of activities and actions of the administrative 
bodies  of  local  self-government  or  regional  units  and  legal  persons 
(see Article 156). Building permits and use permits are issued by the 
Ministry and the administrative body of a major city, city of Zagreb or 
a  county  competent  for  carrying  out  administrative  construction 
activities (see Article 99). 

In case of misconduct and misdemeanour of actors along the building 
value  chain,  e.g.  if  administrative  bodies  or  legal  persons  fail  to 
comply with the stipulations of the Building Act, fines will be imposed 
and in case of grave misconduct criminal charges could be instigated. 

Matching  EU  policy 
framework 

•  The Building Act transposes Directive 2010/31/EU on the 
energy performance of buildings into the legislation of the 
Republic of Croatia. 

In addition, the Building Act fits the foci and objectives of recent EU 
policies  addressing  the  Circular  Economy  in  the  buildings  sector,  in 
particular the:  

•  European Green Deal (e.g. chapter 2.1.4 Building and 

renovating in an energy and resource efficient way) from 
December 2019; 

•  New Circular Economy Action Plan ‘For a cleaner and more 
competitive Europe’ from March 2020 (e.g. chapter 3.6. 
Construction and buildings) 

•  Circular Economy Principles for Building Design from 2019 

(e.g. fostering the use of recycled materials). 

The Building Act stipulates as essential requirements for construction 
works (see Article 8): 
“1. mechanical resistance and stability; 
2. fire safety; 
3. hygiene, health and the environment; 
4. safety and accessibility in use; 
5. noise protection; 
6. energy economy and heat retention; 
7. sustainable use of natural resources.” [2] 
Therefore, the Building Act in particular addresses the objective of the 
strategic  area  “increased  sustainable  infrastructure  in  the  built 
environment (including enhanced resilience of buildings)” by fostering 
both  circular  building  design  and  the  use  of  recycled  materials  in 
buildings.  

There  is  no  information  on  the  extent  to  which  the  objectives  have 
been tackled. 

•  Success factors: 

-  Building Act covers environmental and health-related 
issues (see Article 8), which renders its stipulation 
relevant for several objectives and thus increases 
acceptance among citizens 

•  Challenges for implementation 

128 

Strategic 
addressed  

area(s) 

Lessons learned 

 
 
Annex III: Good practice examples 

- 

Insufficient communication and coordination between 
local and central authorities on building enforcement 
issues [3] 

Synergies 

According  to  the  essential  requirements  for  construction  works  laid 
down in Article 8, the stipulations of the Building Act could also have 
a positive effect on the strategic areas: 

• 

• 

• 

• 

• 

“Improve health and wellbeing”, because construction works 
must be designed and built in such a way that  
“[over its entire life-cycle] it will not be a threat to the 
hygiene or health and safety of workers, occupants or 
neighbours […]” (see Article 11)  
“it does not present unacceptable risks of accidents or 
damage in service or in operation such as slipping, falling, 
collision, burns, electrocution, injury from explosion, and 
burglaries. In particular, construction works must be 
designed and built taking into consideration accessibility and 
use for disabled persons.“ (see Article 12)  
“noise perceived by the occupants or people nearby is kept to 
a level that will not threaten their health and will allow them 
to sleep, rest and work in satisfactory conditions” (see Article 
13) [2] 
“Energy poverty”, because “construction works and their 
heating, cooling, lighting and ventilation installations must be 
designed and built in such a way that the amount of energy 
they require in use shall be low, when account is taken of the 
occupants and of the climatic conditions of the location of the 
construction work. Construction works must also be energy-
efficient, using as little energy as possible during their 
construction and dismantling.” (see Article 14) [2] 

Bibliography 

[1] Zakon  HR (2020).  Zakon o gradnji, pročišćeni tekst zakona, NN 
153/13,  20/17,  39/19,  125/19,  na  snazi  od  28.12.2019. 
https://www.zakon.hr/z/690/Zakon-o-gradnji  
[2]  Croatian  Parliament  (2013).  Decision  promulgating  the  Building 
Zagreb. 
Act. 
https://mgipu.gov.hr/UserDocsImages/dokumenti/Propisi/Building_A
ct.pdf  
[3]  Jovanović  T.,  Aristovnik  A.  and  Rogić  Lugarić  T.  (2016).  A 
comparative analysis of building permits procedures in Slovenia and 
Croatia:  development  of  a  simplification  model.  Theoretical  and 
Empirical Researches in Urban Management 11(2). 

Translation. 

Provisional 

129 

 
 
 
 
 
 
Annex III: Good practice examples 

8.2  Denmark – Circle House Lab 

Policy/initiative 

Circle House Lab Denmark (native language and English)  

Location 

Start year 

Municipal level, but bringing together and being accessible to actors 
from across Denmark 

International outreach via annual Circle House Summit  

2018, with actual Circle House building expected to be completed in 
2020. 

Status  

Ongoing 

Building types 

Type of policy 

Short description 

Residential (single-family buildings, multi-family buildings, etc.), non-
residential public buildings 

Exchange  platform  for  capacity  building  and  scaling-up  of  circular 
building 

The  Circle  House  Lab  is  a  multi-stakeholder  exchange  platform  and 
laboratory for experimenting with circular building solutions across the 
industry. It is located in the Circle House (60 social housing units in 
Lisbjerg outside Aarhus), designed to be the world’s first residential 
building  constructed  according  to  circular  principles  (90%  of  the 
project’s materials must be able to be reused without loss of value-
use [1]). With the Circle House, BLOXHUB (as physical and digital host 
of  the  Circle  House),  Realdania  and  the  Danish  Environmental 
Protection  Agency’s  Development  and  Demonstration  Pool  (MUDP) 
aim to offer a circular example built on market conditions. [2] 

The  Circle  House  Lab  aims  to  accelerate  the  transition  to  a  circular 
economy in the Danish building industry by: 

•  Developing solutions and standards such as digital building 

logbooks on selective demolition, design for disassembly and 
circular construction (adapt the building stock to demographic 
fluctuations) 

•  Providing advice to renew traditional business models and to 
ensure that the legislation supports recycling and circular 
construction 

•  Providing a platform for exchange between different actors 
•  Serving as a scalable demonstration project to provide new 
knowledge to the construction industry on the experience of 
circular building and to encourage scaling-up. 

Tackling the key challenges requires multi-stakeholder dialogue along 
the building value chain. The Circle House Lab provides a promising 
platform for such dialogue and for joint progress. [3] 

Primary 
savings  

energy 

No information available Lab. 

CO2 emission savings 

The demonstrator building Circle House achieves CO2 emission saving 
sthrough various circular material uses: 

•  Using reusable carpet tiles as part of the concept of the 

Circular House helps save 66% of CO2 emissions – based on 
the assumption that 100% of the carpeting materials are 
reusable.  

•  Using reusable plasterboard for walls saves 45% CO2 
compared with a conventional plasterboard wall.  

•  Using easily demountable and recyclable acoustic ceilings 

reduces carbon emissions by 65% compared with 
conventional acoustic ceilings – based on the assumption that 
90% of the panels can be reused directly. 

130 

 
 
Annex III: Good practice examples 

•  Using façade tiling systems with clay shingles, where tiles can 
easily be disassembled and reused, provides a carbon saving 
of 45% – based on the assumption that 90% of the clay 
shingles can be reused directly. 

•  Using precast concrete structures that are easy to 

disassemble and reuse delivers a saving of 45% CO2 as 
compared with conventional precast structures, based on the 
assumption that 90% of the precast concrete structure can 
be reused directly [1]. 

No information available 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

smart 
of 

of 

• 

• 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

The  Circle  House  Lab  could  have  synergies  with  the  strategic  area 
“Improve health and wellbeing”, because circular construction allows 
taking into account health and wellbeing aspects of building materials 
and  building  design  (e.g.  adaptive  design  for  family  vs.  singles  vs. 
elderly). 

[1] GXN and Responsible Assets (2018). Circle House  — Denmark’s 
first circular housing Project. KLS PurePrint. https://gxn.3xn.com/wp-
content/uploads/sites/4/2019/02/CircleHouse_ENG_2018.pdf 
[2]  BLOXHUB  (2020).  Who  is  behind  the  Cirlce  House  Lab? 
https://bloxhub.org/circle-house-lab-activities-in-circle-house-lab  
[3] 
https://bloxhub.org/circlehouselab 

BLOXHUB 

(2020). 

House 

Circle 

Lab. 

131 

 
 
 
 
 
 
 
 
 
 
Annex III: Good practice examples 

8.3  The Netherlands – Transition Agenda Circular Construction Economy 

Policy/initiative 

Dutch  Transition  Agenda  Circular  Construction  Economy  (Transitie-
Agenda Circulaire Bouweconomie)  

Location 

Start year 

Status  

National  

2018 

Ongoing  

Building types 

Residential and non-residential buildings 

Type of policy 

Short description 

Programme  and  stakeholder  agenda 
experimenting,  cooperating  and  sharing  knowledge 
stakeholder exchange along a joint transition agenda 

for  capacity  building, 
through 

The transition agenda describes the strategy for achieving a circular 
construction  economy  in  2050  in  the  Netherlands,  and  constain 
specific recommendations for the period 2018-2021. It was drawn up 
by a transition team of experts from science, government and market 
parties. The agenda’s recommendations encompass: 

•  A decision on the use of a materials passport by 2020 
•  That all government procurement must be circular by 2030 
•  That circular construction be an integral part of education by 

2021 
Introducing circularity in building codes. 

• 

Integrating  circular  design  into  building  codes  and  education  of 
building  professionals  promises  long-term  effects  towards  making 
circular buildings the new default. 

No information available 

energy 

Primary 
savings  
CO2 emission savings  No  current  information,  but  the  transition  team  highlights  the 
potential contribution of circular building to the reduction of CO2 in the 
extraction, manufacture and transport of materials in the construction 
industry. Aiming to halve CO2 emissions in the construction industry 
by  2030  and  to  completely  eliminate  emissions  by  2050  over  the 
entire lifecycle from production and manufacturing to the use phase 
and transport, this will result in “a reduction of about 107 megatons 
of  CO2-eq  (per  annum  for  both  civil  engineering  and  utility 
construction and ground, water and road construction). In 2030, the 
total emission will be halved, resulting in a reduction of 53 megatons 
CO2-eq.” [1, p. 7/8]  

Costs 

Increased 
rate and depth  

renovation 

Not available 

Not available 

Ease 
implementation 

of 

Not available 

Matching  EU  policy 
framework 

Not available 

Address 

Not available 

•  Energy poverty 
• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 

• 

132 

 
 
Annex III: Good practice examples 

of 

environment 
(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

• 

smart 
of 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
sustainable 
to 
mobility) 

Lessons learned 

Synergies 

Bibliography 

The  Transition  Agenda  Circular  Construction  Economy  could  have 
synergies  with  the  strategic  area  ‘increase  smart  readiness  of 
buildings”,  because  smart  buildings  constitute  a  component  of 
strategic research foreseen under the transition agenda. 

[1] Transition Agenda Circulair Economy (2018). Circular Construction 
Economy. 
https://hollandcircularhotspot.nl/wp-
content/uploads/2019/09/Circular-Construction-Economy.pdf  

133 

 
 
 
 
 
 
Annex III: Good practice examples 

8.4  United Kingdom – Aggregates Levy 

Policy/initiative 

Aggregates Levy  

Location 

Start year 

Status  

Building types 

National level (UK) 

2002  

Ongoing  

The Aggregates Levy is not specific to building types (e.g., residential, 
non-residential, public) because it is charged on any aggregate used 
for  construction  purposes  (e.g.,  as  part  of  a  building).  Use  for 
construction purposes is assumed when the aggregate:  

(1) serves  “as  material  or  support  in  the  construction  or 

improvement of any structure 

(2) is  mixed  with  anything  as  part  of  a  process  of  producing 
mortar,  concrete,  tarmacadam,  coated  roadstone  or  any 
similar construction material” [1] 

According  to  the  UK  government,  structures  include  “buildings, 
bridges, roads, paths, the way on which any railway is laid (or is to 
be  laid),  and  embankments”  [1].  Building  types  are  not  further 
specified. 

Type of policy 

Tax (economic instrument) 

Short description 

The Aggregates Levy is a tax on the commercial exploitation of sand, 
gravel and rock, which has been dug from the ground, dredged from 
the  sea  in  UK  waters  or  imported  (exports  are  excluded).  [1]  It  is 
levied per tonne of sand, gravel and rock extracted, but does not apply 
to recycled aggregates [2]. 

Anyone responsible for commercially exploiting aggregates in the UK, 
including  quarry  operators,  is  obliged  to  register  for  and  pay  the 
Aggregates Levy [1]. 

The Aggregates Levy pursues two objectives:  

1)  First and foremost to tackle environmental and health impacts 
and  costs  associated  with  extraction  activities  (quarrying 
operations), such as noise, dust, loss of amenity and damages 
to biodiversity and ecosystems.  

2)  Secondly,  to  reduce  the  demand  for  virgin  aggregates  and 
encourage  the  use  of  alternative  materials,  e.g.,  recycled 
construction materials. [2] 

As aggregates are a key building material, increasing their prices by 
taxing  them  provides  incentives  for  (instead  or  in  addition)  using 
secondary materials from domestic sources for construction projects. 

Primary 
savings  

energy 

There  are  no  figures  on  primary  energy  savings  related  to  the 
introduction of the Aggregates Levy.  

In general, trends in the UK show an increase in construction output 
between 1980 and 2005 and a decline in aggregates output between 
the  late  1980s  and  2005  (see  Figure  1  below).  While  a  general 
downturn in road-building since 1990 was a driving force behind this 
decline,  the  Aggregates  Levy  –  and  to  a  much  greater  extent  the 
introduction of the landfill tax in 1996 – contributed to a more efficient 
use of aggregates in construction works [3].  

134 

 
 
 
 
Annex III: Good practice examples 

Figure 1: Trends in construction output and primary aggregate sales in the 
UK 

Source: [3], p. 27 

Together  with  the  landfill  tax,  the  Aggregates  Levy  incentivised 
modest increases in the demand for recycled aggregates, rising from 
around 2 million tonnes per annum before the introduction of the levy 
to  3  million  tonnes  per  annum  after  its  introduction  [3].  In  2005, 
recycled aggregates accounted for almost 25% of the UK aggregates 
market [3].  

CO2 emission savings  No information available. 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

The levy charges £2 per tonne of sand, gravel or rock. The levy is a 
specific one stage tax, which is non-deductible and therefore cannot 
be reclaimed as input tax (unlike VAT) [1]. 

In 2008/2009 state revenues from the Aggregates Levy amounted to 
€380  million  [4].  All  state  revenues  from  the  Aggregates  Levy  are 
earmarked and transferred back to businesses. Transfer mechanisms 
encompass (i) a 0.1% reduction in employer contributions to national 
insurance and (ii) the so-called Aggregates Levy Sustainability Fund 
(ALSF),  which  promotes  greater  use  of  recycled  aggregates  and 
provides  funds  to  support  better  environmental  management  at 
aggregate sites [2, 3]. 

Annual  administrative  costs  related  to  the  Aggregates  Levy  are 
estimated  to  stand  around  €1.1  million,  while  compliance  costs  for 
industry are estimated to be less than 0.6 cents per tonne extracted 
[4]. 

No information available. 

The  Aggregates  Levy  seems  transferable  to  other  countries,  as 
examples  from  Denmark  and  Sweden  show,  where  similar  taxation 
has been put in place [2, 3]. Aggregates covers sand, gravel and rock, 
which are relevant building materials in most countries – it does not 
cover biotic building materials (e.g. wood) nor steel.  

135 

 
 
 
Annex III: Good practice examples 

The  policy  is  administered  on  the  national  level  by  Her  Majesty’s 
Revenue and Customs (HMRC), with all actors commercially exploiting 
sand, gravel or rock having to register and pay the levy to HRMC. In 
case  of  failure  to  register  and  pay,  different  levels  of  fines  can  be 
imposed (e.g. when not notifying  for  registration,  fines are £250  or 
5%  of the levy involved, whichever is the greater) or  even  criminal 
sanctions in case of evading the levy. 

The landfill tax, introduced in 1996, is a key enabler because it already 
provided an incentive for greater reuse of construction and demolition 
waste,  e.g.  by  using  more  recycled  aggregates.  As  the  Aggregates 
Levy  exempts  recycled  aggregates,  there  is  a  double  incentive  for 
greater  use  of  recycled  aggregates.  It  was  partly  this  policy  mix  of 
landfill tax and Aggregates Levy which proved to be effective. 

UK experience with the Aggregates Levy shows that tax rates need to 
consider potential distortions across country borders. In the UK case, 
the proximity between Northern Ireland (part of the UK, Aggregates 
Levy in place) and Ireland (no aggregates taxation) yielded large tax 
differentials  and  triggered  illegal  trade  across  country  borders  from 
Ireland to the UK [3]. 

Matching  EU  policy 
framework 

There  is  no  clearly  linked  EU  policy  framework.  However,  the 
Aggregates Levy does fit the foci and objectives of recent EU policies 
addressing the circular economy in the buildings sector, in particular 
the:  

•  European Green Deal (e.g. chapter 2.1.4 Building and 

renovating in an energy and resource efficient way) from 
December 2019 

•  New Circular Economy Action Plan ‘For a cleaner and more 
competitive Europe’ from March 2020 (e.g. chapter 3.6. 
Construction and buildings) 

•  Circular Economy Principles for Building Design from 2019 

(e.g. fostering the use of recycled materials). 

“Increased sustainable infrastructure in built environment (including 
enhanced  resilience  of  buildings)”  –  fostering  the  use  of  recycled 
materials in buildings. Together with the landfill tax, the Aggregates 
Levy  incentivised  modest  increases  in  the  demand  for  recycled 
aggregates,  raising from around 2 million tonnes per annum before 
the  introduction  of  the  levy  to  3  million  tonnes  per  annum  after  its 
introduction [3].  

•  Success factors: 

-  Combination with the landfill tax as part of a policy 

mix seems effective, measured by increase in demand 
for recycled aggregates 

-  Recycling of tax revenues back to businesses and to 

support them in increasing use of recycled aggregates 
increases acceptance of Aggregates Levy 
-  Due to mostly national use of aggregates the 

Aggregates Levy has no or only negligible competitive 
impacts [2, 3]. 

•  Challenges of implementation: 

-  Tax rate differentials between neighbouring countries 
need border tax adjustments in order to discourage 
illegal trade 

Although  there  is  hardly  any  effect  on  noise  and  dust  emission 
reduction through the Aggregates Levy (and use of its state revenues 
through  the  ALSF)  (see  [3]),  effects  on  the  strategic  area  ‘improve 
health and wellbeing’ are conceivable. 

136 

Strategic 
addressed 

area(s) 

Lessons learned 

Synergies 

 
 
Bibliography 

Annex III: Good practice examples 

[1] UK government (2017, February). Excise Notice AGL1: Aggregates 
https://www.gov.uk/government/publications/excise-notice-
Levy. 
agl1-aggregates-levy/excise-notice-agl1-aggregates-levy 
[2] Söderholm, P. (2011).  Taxing  virgin  natural  resources:  Lessons 
from  aggregates  taxation  in  Europe.  Resources,  Conservation  and 
Recycling 55, 911– 922 
[3] EEA (2008). Effectiveness of environmental taxes and charges for 
managing sand, gravel and rock extraction in selected EU countries. 
EEA Report No 2/2008, Copenhagen 
[4] Ecorys et al. (2011).  The  role  of  market-based  instruments  in 
achieving a resource efficient economy. Rotterdam. 

137 

 
 
 
 
 
 
Annex III: Good practice examples 

8.5  Germany – Circular Economy Act 

Policy/initiative 

Germany Circular Economy Act (Kreislaufwirtschaftsgesetz KrWG) 

Location 

Start year 

Status  

National 

2012 

Ongoing 

Building types 

No building types specified 

Type of policy 

Regulation (Act) 

Short description 

Section 45 “Obligations of the public sector” of the Circular Economy 
Act  obliges,  among  others,  authorities  and  agencies  to  contribute, 
through their conduct, including procurement, to promote the circular 
economy  in  order  to  conserve  natural  resources  and  to  ensure  the 
protection  of  human  health  and  the  environment  in  the  generation 
and management of waste. For this purpose, they shall examine “[…] 
in construction projects and other contracts […] to what extent 

1. products can be used, 

a)  that  are  particularly  durable,  are  easy  to  repair,  reusable  or 

recoverable, 

b)  that result in less waste or less-polluting waste in comparison 

to other products, or 

c)  that are made from waste in the process of preparation for re-

use or recycling, and 

2. the waste occurring after the use of the products can be recovered, 
particular consideration being given to the priority of preparing for re-
use and of recycling.” [1] 

Green  public  procurement  is  a  key  instrument  to  push  demand  for 
secondary materials in buildings and to build up secondary markets. 
Stipulating  that  public  procurers  examine  purchasing  of  products 
made from secondary materials fosters circular procurement. 

Furthermore, Section 14 sets the following target in relation to non-
hazardous  construction  and  demolition  waste  (CDW):  “The 
preparation  for  re-use,  recycling  and  the  other  material  recovery  of 
non-hazardous  construction  and  demolition  waste  […]  should  be  a 
minimum  of  70  %  by  weight  at  the  latest  from  1  January  2020 
onwards.  Other  material  recovery  in  accordance  with  the  first 
sentence shall include backfilling operations using waste to substitute 
other materials. […]” [1]  

The Circular Economy Act prioritises material use of CDW and uses, 
inter  alia,  green  public  procurement  to  foster  the  demand  for 
secondary building materials obtained from CDW.  

energy 

No information available  

Primary 
savings  
CO2 emission savings  No information available  
 No information available 

renovation 

Increased 
rate and depth  

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

138 

 
 
 
 
 
Annex III: Good practice examples 

•  Energy poverty 
• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

smart 
of 

of 

• 

• 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

Fostering green public procurement for secondary building materials 
via the Circular Economy Act could have synergies with the strategic 
area “Secure fair transition”, when usually cheaper  costs  for buying 
and  transporting  secondary  building  materials  could  result  in  lower 
overall costs for construction and might increase the fairness of the 
transition for public bodies. 

[1] Deutscher Bundestag (2012). Act Reorganising the Law on Closed 
Cycle  Management  and  Waste  (Gesetz  zur  Neuordnung  des 
Kreislaufwirtschafts-  und  Abfallrechts)  *)  of  February  24th  2012. 
https://www.bmu.de/fileadmin/Daten_BMU/Download_PDF/Abfallwir
tschaft/kreislaufwirtschaftsgesetz_en_bf.pdf  

139 

 
 
 
 
 
 
 
Annex III: Good practice examples 

8.6  Spain – Demolition Waste National Plan for 2016-2022 

Policy/initiative 

Spanish Demolition Waste National Plan for the period 2016  – 2022 
(Plan Estatal Marco de Gestión de Residuos 'PEMAR' 2016-2022)  

Location 

Start year 

Status  

National  

2016 

Ongoing  

Building types 

Not specified 

Type of policy 

National plan  

Short description 

The national plan aims to reduce resource use, increase the recycling 
rate and improve resource efficiency. The plan has a specific chapter 
targeting  construction  waste  and  demolition  in  order  to  promote 
actions  for  reutilisation  and  recycling  of  construction  material  to 
ensure that Spain complies with EU legal objectives.  
The  plan  pursues  a  diversity  of  objectives,  suggesting  an  effective 
policy mix of, inter alia: 

•  Research, development and innovation regarding the 

durability and recycling possibility of the materials, which will 
play an important role in achieving EU recycling targets 
Increasing taxes (economic disincentives)  
• 
•  Encouraging the use of sustainable products. 

 No information available 

energy 

Primary 
savings  
CO2 emission savings  No information available 
No information available 

Costs 

No information available 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

smart 
of 

of 

• 

• 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 

140 

 
 
 
 
 
  
Annex III: Good practice examples 

(including  access 
sustainable 
to 
mobility) 

Lessons learned 

Synergies 

Bibliography 

The policy appears not explicitly or directly linked to other strategic 
areas. 

[1]  BIO  by  Deloitte,  BRE,  FCT,  ICEDD,  RPS  and  VTT  (2014). 
Construction  and  Demolition  Waste  management 
in  Spain. 
https://ec.europa.eu/environment/waste/studies/deliverables/CDW_
Spain_Factsheet_Final.pdf  
[2] Ministeriode Agricultura, Alimentación y Medio Ambiente (2015). 
Plan  Estatal  Marco  de  Gestión  de  Residuos  (Pemar)  2016-2022. 
https://www.miteco.gob.es/es/calidad-y-evaluacion-
ambiental/planes-y-
estrategias/pemaraprobado6noviembrecondae_tcm30-170428.pdf 

141 

 
 
 
 
 
 
 
Annex III: Good practice examples 

8.7  Ireland – Building Regulation Part L (technical guidance) 

Policy/initiative 

Building Regulation Part L - technical guidance document (Ireland) 

Location 

Start year 

Status  

National 

2019 

Ongoing 

Building types 

Residential (dwellings) 

Type of policy 

Technical guidance 

Short description 

Avoiding overheating due to solar gain is a key design requirement to 
minimise  the  use  of  mechanical  cooling  and  reduce  energy 
consumption by cooling systems. Good low-energy design will seek to 
minimise the effect of excessive solar gains in summer by appropriate 
orientation,  massing  and  selection  of  the  building  façade.  However, 
additional measures may still be required to provide solar shading to 
the  building  to  reduce  solar  gains  and  the  associated  risk  of 
overheating. 

As one of the aims, the document gives guidance on “Limiting Heat 
Gains:  ensuring  that  the  building  is  appropriately  designed  to  limit 
heat gains through the fabric.”  

Energy 

Primary 
savings  
CO2 emission savings  No  information.  Supports  passive  ventilation  and  low  energy 

No  information.  Supports  passive  ventilation  and  low  energy 
measures. 

measures. 

Costs 

Increased 
rate and depth  

renovation 

No information 

No information 

Ease 
implementation 

of 

• 

It is transferable to other countries with problems of 
overheating, which is relevant for a larger number of urban 
areas in the EU. 

•  Policy is designed as national guidance. 
• 

It is a technical guidance to support implementation of the 
building regulation. 
It refers to the “Technical Guidance: Design for improved 
solar shading control, CIBSE TM37” which includes more 
details. 

• 

•  Technical guidance of COM 

• 

Improve health and wellbeing: decreasing heat within 
dewllings leads to a higher wellbeing and can avoid health 
issues due to heat stress.  

142 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
• 

• 

• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

smart 
of 

of 

 
 
•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
sustainable 
to 
mobility) 

Lessons learned 

Synergies 

Bibliography 

Annex III: Good practice examples 

•  The document relates to a guidance document with more 

details from the UK, which is already in use since 2006 and 
can be seen as a well-established document. 

•  No enforcement possibilities because of character of technical 
guidance – the aim within the building regulation is stated in 
broad sense. 

Links to the strategic area  of “health and wellbeing”, which has the 
aim to achieve a healthy indoor environment. 

[1]  Government  of  Ireland  (2019):  Building  Regulation  -  Technical 
Guidance  Part  L  2019.  Prepared  by  the  Department  of  Housing, 
Planning 
Government, 
https://www.housing.gov.ie/sites/default/files/publications/files/tgd_
l_dwellings_2019.pdf  

Local 

and 

[2] CIBSE (2006): Design for improved solar shading control. TM37: 
2006. The Chartered Institution of Building Services Engineers. 

143 

 
 
 
 
Annex III: Good practice examples 

8.8  Gräfelingen (Germany) – Support programme for rainwater utilisation 

Policy/initiative 

Location 

Start year 

Status  

Gräfelfingen support programme for rainwater utilisation (Municipality 
of 
zur 
Regenwassernutzung) 

Förderprogramm 

(Gräfelfinger 

Gräfelfing) 

Municipal level 

2020 

Building types 

Private owners and tenants - residential, non-residential 

Type of policy 

Grant 

Short description 

The municipality of Gräfelfing is promoting the construction of cisterns 
to collect and use rainwater for garden irrigation and/or service use. 
The amount of funding depends on the size of the cistern. Eligible to 
apply are building owners (private owners, owners' associations) and 
tenants,  provided  that  the  landlord's  declaration  of  consent  is 
available. The municipality of Gräfelfing supports the construction of 
rainwater  cisterns,  devices  for  the  supply  of  rainwater  and  the 
necessary installations for the use of rainwater. 

energy 

No information. Not objective of measure. 

Primary 
savings  
CO2 emission savings  No information. Not objective of measure. 
No information.  

Increased 
rate and depth  

renovation 

Synergies 

Bibliography 

Not applicable 

Gräfeling:  Gräfelfinger  Förderprogramm  zur  Regenwassernutzung 
2020. 
https://www.graefelfing.de/fileadmin/user_upload/Energie_und_Um
welt/F%C3%B6rderprogramme/Foerderprogramm_Regenwassernutz
ung_2020_neu_02.pdf 

144 

 
 
 
 
 
Annex III: Good practice examples 

8.9  Norway – Technical building regulations 

Policy/initiative 

Norway technical builiding regulations ( Forskrift om tekniske krav 
til byggverk (Byggteknisk forskrift -TEK17)  

Location 

Start year 

Status  

National 

2017 

Ongoing 

Building types 

Residential, non-residential, public buildings (construction work) 

Type of policy 

Technical regulation 

Short description 

The  regulation  is  intended  to  ensure  that  projects  are  planned, 
designed  and  executed  on  the  basis  of  good  visual  aesthetics, 
universal  design,  and  in  a  manner  that  ensures  that  the  project 
complies with the technical standards for safety, the environment, 
health and energy. Construction works are to be sited, designed and 
constructed  to  ensure  satisfactory  protection  against  damage  or 
significant nuisance from acts of nature. 

The  building  code  prescribes  minimum  measures  that  need  to  be 
taken  to  protect  against  natural  stresses  (e.g.  flooding  and 
landslides).  The  technical  regulation  also  includes  a  section  on 
thermal comfort which describes the recommended temperatures, 
passive measures and opening of windows and doors. 

Primary Energy savings   No information. Not main objective of measure. 
No information. Not main objective of measure. 

CO2 emission savings 

Increased renovation rate 
and depth  

No information 

Synergies 

Bibliography 

The  aspect  on  thermal  comfort  has  links  to  the  strategic  area 
“health  and  wellbeing”,  which  aims  to  achieve  a  healthy  indoor 
environment. 

Direktoratet for Byggkvalitet (2017): Byggteknisk forskrift (TEK17) 
med 
https://dibk.no/byggereglene/byggteknisk-
veiledning. 
forskrift-tek17/13/vi/13-11  

Norwegian  Building  Authority  (2017):  Regulations  on  technical 
requirements 
for  construction  works.  An  unofficial  English 
translation of the regulation “Forskrift om tekniske krav til byggverk 
(Byggteknisk forskrift - TEK17)” for information purposes.  

145 

 
 
 
 
 
 
Annex III: Good practice examples 

8.10  Bavaria (Germany) – Support for rainwater use 

Policy/initiative 

Information  on  rainwater  uses  in  homes  related  to  the  financial 
support,  advantages,  costs  and  benefits,  basis  for  calculation. 
(Homeowners'  Association  Bavaria  e.V.)  (Regenwassernutzung  im 
Haus Niederschlagswasser: Vom lästigen Abwasser zum geschätzten 
Rohstoff) 

Location 

Start year 

Status  

Regional level 

No date 

Ongoing  

Building types 

Residential  

Type of policy 

Information portal 

Short description 

Information  on  rainwater  uses  in  homes  related  to  the  financial 
support, advantages, costs and benefits, basis for calculation. 

It  describes  the  reasons  for  rainwater  storage  in  homes;  details 
preconditions,  advantages,  possible  water  use  and  possibilities  for 
financial  support  (including  links  to  provider  of  support);  gives 
examples for calculation of cistern volume for different building types.  

Primary Energy savings   No information. Not objective of measure. 
No information. Not objective of measure. 

CO2 emission savings 

Increased 
rate and depth  

renovation 

No information.  

Synergies 

Bibliography 

No links can be seen 

Eigenheimerverband  Bayern  e.V.:  Regenwassernutzung  im  Haus 
Niederschlagswasser:  Vom  lästigen  Abwasser  zum  geschätzten 
Rohstoff.  
https://www.eigenheimerverband.de/tipps-fuer-recht-garten-
haus/haus-wohnung/themenarchiv/regenwassernutzung  

146 

 
 
 
 
 
Annex III: Good practice examples 

8.11  Denmark – Climate Atlas 

Policy/initiative 

Climate Atlas (Klimaatlas), Denmark 

Location 

Start year 

Status  

National level 

No date 

Ongoing  

Building types 

Residential, non-residential, public 

Type of policy 

Information portal 

Short description 

The  tool  is  a  nationwide  Climate  Atlas  based  on  own  data  and  data 
from the IPCC. Data is free and available on DMI's website, both at 
national and municipality levels – and down to a 1 km grid scale. 

The  Danish  Climate  Atlas  provides  data  on  municipality,  drainage 
basin  and  coastal  stretch  levels  showing  future  changes  in 
temperature,  precipitation,  extreme  precipitation,  relative  sea  level 
and storm surge heights. It thereby gives an indication of areas with 
a  particular  future  risk  of  being  impacted  by  extremes.  The  tool 
provides the fundamental climate data so municipalities can take the 
necessary precautions and guard citizens, infrastructure and buildings 
against the expected extreme weather in the future. 

In Denmark, the municipalities are responsible for climate adaptation, 
for  example,  building  dykes  or  securing  exposed  areas  from 
cloudbursts. The Danish Climate Atlas therefore has the municipalities 
and their climate adaptation as its primary focus, but it is also relevant 
for  the  regions,  utility  companies, 
infrastructure,  agriculture, 
emergency  management,  insurance,  consultants  and  many  other 
sectors. The Climate Atlas is developed in a valuable collaboration with 
the municipalities and other relevant stakeholders working on climate 
adaptation. 

Energy 

No information. Not objective of measure. 

Primary 
savings  
CO2 emission savings  No information. Not objective of measure. 
No information  

Increased 
rate and depth  

renovation 

Synergies 

Bibliography 

No links can be seen 

ClimateChangeAdaptation: 
Climate 
https://en.klimatilpasning.dk/tools/climate-atlas 
DMI: Klimaatlas. https://www.dmi.dk/klimaatlas  

Atlas. 

147 

 
 
 
 
 
Annex III: Good practice examples 

8.12  USA – Watersense programme 

Policy/initiative 

WaterSense programme, USA 

Location 

Start year 

Status  

National level 

2012 

Ongoing  

Building types 

Residential (single-family, multi-family) 

Type of policy 

Voluntary partnership programme/label 

Short description 

WaterSense  is  a  voluntary  partnership  sponsored  by  the  U.S. 
Environmental  Protection Agency (EPA), which  labels  water-efficient 
products,  new  homes  and  programmes  and  provides  resources  on 
how  to  save  water.  For  WaterSense  labelled  homes,  the  following 
issues are included: 

• 

Indoor criteria: leaks, service pressure, hot water delivery, 
plumbing fixtures, dishwashers and clothes washers 

•  Outdoor criteria: landscape design, irrigation system, pools 

and spas. 

Several  revisions  and  expansions  have  come  into  force  since  2012, 
e.g.  having  started  with  single-family  homes,  the  programme  now 
includes multi-family homes. 

The  programme  offers  a  number  of  additional  tools,  e.g.  a  Water 
Budget  Tool,  information  on  water-smart  landscapes,  and  an 
information page for kids. 

Primary 
savings  

Energy 

No information. Water efficiency is main objective of programme, but 
criteria  also  include  energy  efficiency  of  dishwashers  and  clothes 
washers.  

CO2 emission savings  No information. Water efficiency is main objective of programme, but 
criteria  also  include  energy  efficiency  of  dishwashers  and  clothes 
washers. 

Increased 
rate and depth  

renovation 

No information.  

Synergies 

Bibliography 

No links can be seen 

EPA: WaterSense - Homes. https://www.epa.gov/watersense/homes 

148 

 
 
 
 
 
 
Annex III: Good practice examples 

8.13  Tyrol (Austria) – Climate-friendly construction 

Policy/initiative 

Measures catalogue: Climate-friendly construction, Tyrol 

Location 

Start year 

Status  

Regional level 

2012 

Ongoing  

Building types 

Residential, non-residential, public buildings 

Type of policy 

Information material 

Short description 

The measures catalogue includes synergy measures between climate 
protection,  climate  change  adaptation  and  living  comfort  (heat  and 
cold insulation and ventilation concepts), as well as measures to adapt 
to  a  changed  natural  hazard  potential  (flood  protection)  or  include 
adequate dimensioning of drainage infrastructures. 

The  catalogue  includes  measures  for  energy-efficient  buildings  and 
restoration  of  buildings.  It  includes  information  on  total  costs  for 
different  house  types  (e.g.  Klima-Haus,  1  litre  house,  etc.)  and 
amortisation of these investment costs. It includes also soft measures 
such  as  financial  support  programmes,  advice  and  knowledge,  and 
covers different labels and good practice examples. 

No information   

energy 

Primary 
savings  
CO2 emission savings  No information  
No information  

renovation 

Increased 
rate and depth  

Synergies 

Bibliography 

Includes links to strategic area “health and wellbeing”  

CIPRA 
(2009).  Bauen  und  Sanieren 
Hintergrundbericht der CIPRA. COMPACT; 02/2009.  

im  Klimawandel.  Ein 

149 

 
 
 
 
 
 
 
Annex III: Good practice examples 

8.14  City of Portland (USA) – Green Building Policy 

Policy/initiative 

City of Portland Green Building Policy (City of Portland) 

Location 

Start year 

Status  

Building types 

Municipal level, Portland 

Implemented in 2001 and updated in 2015 with Resolution 37122 

Ongoing 

Construction  and  rehabilitation  projects  of  affordable  multifamily 
residential and mixed-use buildings that have a minimum of 20 units 
receive  at  least  10%  of  total  project  funding  from  the  Portland 
Housing Bureau 

Type of policy 

Policy 

Short description 

The  policy  obligates  new,  occupied  city-owned  buildings  to  achieve 
Leadership  in  Energy  and  Environmental  Design  (LEED)  Building 
Design and Construction (BD+C) at the Gold level. They should also 
include eco roofs and storm water management strategies and related 
watershed  enhancement  strategies  in  their  design,  and  provide 
adequate bicycle parking opportunities (equal to 25% of the target in 
the city's climate action plan). In addition, all city-owned, occupied, 
existing buildings must achieve LEED Silver certification and all new 
commercial  or  mixed-use  buildings  over  10,000  square  feet  that 
receive 
the  Portland  Development 
from 
Commission of US$300,000 or more and that also equals 10% of the 
total project cost must achieve LEED Silver certification. Since 2007, 
Portland has the highest number of LEED-certified buildings in the US. 

financial  assistance 

Primary 
savings  

energy 

The  goal  is  to  reach  net  zero  energy  consumption  in  affordable 
housing projects by 2050 

Year 

2025 

2030 

2035 

2040 

2045 

2050 

Net EUI  23 

18 

12 

8 

4 

0 

As part of the certification requirement for new construction, 28% net 
EUI of projects under the policy must be met in 2020. The projects 
must include charging stations at 4% of the parking spaces on site or 
be electric vehicle-ready at 10% of parking spaces. 

CO2 emission savings5  Building  construction  and  operations  account  for  35%  of  US  CO2 
emissions. Green buildings increase energy efficiency, reduce, reuse, 
and  recycle  materials,  and  promote  transit-oriented  development, 
which helps meet CO2 emissions-reduction goals. 

Costs 

Increased 
rate and depth  

renovation 

Ease 
implementation 

of 

The  construction  cost  data  shows  a  moderate  difference  (4.6%)  in 
average  cost  between  the  green-rated  buildings  and  standard 
buildings. While green buildings mostly have a similar or lower cost 
than  conventional  buildings,  upfront  investments  in  green  features 
may  be  higher.  However,  savings  in  operations  and  maintenance 
expenses  make  up  for  construction  costs  quickly,  with  initial 
investments paid back in one to ten years.  

•  15% energy savings beyond the applicable Oregon Energy 

Efficiency Specialty Code 

•  Projects for which the policy applies are awarded a letter 

from the Portland Housing Bureau stating the requirements. 
However, the policy explicitly acknowledges the need for 
flexibility, workability and cost reduction. 

150 

 
 
 
 
Annex III: Good practice examples 

•  The policy is administered at the municipal level and should 

easily be transferable to other cities 

•  Compliance: Upon receipt of the PHB award letter, the 

developer submits an application for third-party certification. 
As applicable, the developer submits a LEED Checklist or 
Earth Advantage Points Worksheet each time they are 
updated to PHB indicating: 

a.  Progress towards meeting the requirements of this Policy 
b.  Likelihood that the respective certification requirements will 

be met or exceeded 

c.  c.  Any  issues  or  circumstances  that  may  prevent  the 
from  meeting  this  Policy  or  certification 

developer 
requirements. 

•  This example does not apply under the EU framework 

•  The policy aims to yield long-term savings through efficient 
management of energy, water, waste and stormwater, as 
well as improving the health, comfort and productivity of 
building occupants. 
In the years since implementation, Portland has constructed 
or improved 11 buildings to meet LEED standards. 

• 

The  state  of  Oregon  founded  the  Oregon  Built  Environment  and 
Sustainable  Technologies  Research  Centre  in  2007  as  it  recognised 
the  potential  economic  opportunities  linked  to  green  buildings.  In 
addition,  the  Oregon  Ecnomic  and  Community  Development 
Department has been in an exchange with the green building industry 
to  identify  how  best  to  support  development  of  an  economically 
competitive  cluster.  This  is  an  example  where  municipal  policy 
successes informed the state level. 

The  policy  is  linked  to  the  climate  action  plan  of  Portland  and 
Multnomah  County.  The  city  of  Portland’s  2009  climate  action  plan 
mandated  that  buildings  within  the  city  get  their  energy  from 
renewable  sources;  15%  of  which  is  to  be  from  on-site  renewable 
energy generation 

– 

 [1]  Allen  J.H.  and  T.  Potiowsky  (2008).  Portland’s  Green  Building 
DOI: 
Trends 
Cluster 
10.1177/0891242408325701  
[2]  City  of  Portland  (2015).  ENB-9.01  Green  Building  Policy 
https://www.portlandoregon.gov/citycode/article/54355 

Economic 

Impacts. 

and 

151 

Matching  EU  policy 
framework 

Address 

•  Energy poverty 
• 

• 

• 

Improve  health 
and wellbeing 
Increased 
sustainable  infra-
structure  in  built 
environment 
(including 
enhanced 
resilience 
building) 
Increase 
readiness 
buildings 

smart 
of 

of 

•  Secure 

fair 

transition 

•  Upgrade of urban 

context 
(including  access 
to 
sustainable 
mobility) 

Lessons learned 

Synergies 

Bibliography 

 
 
 
Annex III: Good practice examples 

8.15  Germany – Green in the City 

Policy/initiative 

Bundesweite  Initiative  „Grün  in  der  Stadt“  (nationwide  initiative  - 
Green in the City) 

Location 

Start year 

Status  

Building types 

Type of policy 

Short description 

Primary 
savings  

energy 

CO2 emission savings 

Increased 
rate and depth  

renovation 

Synergies 

Bibliography 

National level, put into practice on the municipal level 

2015 

Ongoing 

Various 

Initiative 

The  "Green  in  the  City"  initiative  and  the  new  urban  development 
support  programme  "Zukunft  Stadtgrün"  (Future  City  Green)  put  a 
spotlight on the importance of urban green infrastructure in Germany. 
For the first time in Germany, the intiative opens up the possibility of 
an  area-wide  promotion  of  green  roofs  and  facades  within  the 
framework  of  urban  development  funding.  The  programme  of 
measures  does  not  directly  set  out  funding  for  green  roofs  and 
facades; however, they are indirectly eligble for public funding. As the 
administrative agreements between the federal government and the 
federal  states  are  of  a  very  general  nature,  the  federal  states  have 
room for interpretation to include their own political objectives.  

Doesn’t apply to green roofs, unless combined with solar energy on 
roofs.  In  Germany,  photovoltaic  plants  made  up  6.5%  of  energy  in 
2015. Three-quarters of photovoltaic power in Germany stems from 
modules installed on roofs. 

Assuming  that  only  10%  of  the  annually  sealed  area  can  be 
renaturalised by extensive green roofs, which corresponds to an area 
of about 1,600 ha in Germany, it is possible that up to 19,000 tonnes 
of CO2 could be permanently bound again in the form of carbon by the 
above-ground vegetation alone. 

No information available. 

Green roofs and facades are usually viewed in combination with other 
green  infrastructure  (e.g.  parks  and  urban  trees),  so  a  combined 
concept  makes  sense.  Due  to  urban  green’s  potential  to  increase 
biodiversity and lessen the risks linked to climate change, a combined 
approach would be useful. 

[1]  Institut  für  Agrar-  und  Stadtökologische  Projekte  (IASP)  an  der 
Humboldt-Universität  zu  Berlin  (2012):  CO2-Bindungsvermögen  der 
für die Bauwerksbegrünung typischen Pflanzen - Bericht. Berlin.  
[2] 
und 
Fassadenbegrünung  –  neue  Lebensräume  im  Siedlungsbereich,  BfN 
Skripten 528, Leipzig. 

(2019).  Dach-u 

für  Naturschutz 

Bundesamt 

152 

 
 
 
 
 
Annex III: Good practice examples 

8.16   The Netherlands – City Deal Climate Adaptation 

Policy/initiative 

City Deal Klimaatadaptatie (City Deal Climate Adaptation) 

Location 

Start year 

Status  

Building types 

National level (Netherlands) 

2016 

Ongoing 

Type of policy 

Cooperation agreement 

Short description 

Cooperation  agreement  between  17  public  partners  and  17 
(semi)private  cooperation  partners  and  the  central  government  to 
implement  pilot  projects  to  develop  new  forms  of  governance  and 
financing structures and innovative solutions. Two of four focus areas 
concentrate  on:  climate  resilient  area  development  (for  public  and 
private  parties 
and 
in  development,  design, 
management);  development  and  integratation  of  nature-based 
solutions  and  ecosystem  services  (examine  added  value  and 
demonstrate feasibility). 

renovation 

Primary 
savings  

energy 

Information unavailable (in English language) 

CO2 emission savings 

Increased 
rate and depth  

renovation 

Synergies 

Information unavailable (in English language) 

Information unavailable (in English language) 

The lessons learned within the city deal are shared with other parties, 
such  as  educational  institutes  and  water  management  bureaus. 
Further,  the  city  deal  on  climate  adaptation  is  part  of  the  “Agenda 
Stad” (Urban Agenda). 

Bibliography 

[1] Website: https://www.citydealklimaatadaptatie.nl  

153 

 
 
 
 
 
 
 
 
 
 
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Lessons learned to inform 
integrated approaches for the 
renovation and modernisation 
of the built environment 

Annex IV: Analysis of the relevance, feasibility and 
possible scope of mandatory minimum requirements for 
existing buildings 

ENER C3_2019-468_03

Written by:  
Buildings Performance Institute Europe ASBL (BPIE)  
and CLIMACT SA 

January – 2021 

 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
Authors 

Jonathan Volt (BPIE) & Quentin Jossen (CLIMACT SA) 

Contributors 

Sibyl Steuwer, Rutger Broer & Mariangiola Fabbri (BPIE) 

Louis Louvet, Caroline Sabbe, Pascal Vermeulen & Julien Pestiaux (Climact) 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

EXECUTIVE SUMMARY 

This report presents the outcomes of the analysis of the scope, timeline and phasing of 
a progressive implementation of mandatory minimum requirements (MMR) for existing 
buildings in Europe, including the need for accompanying support policies. This report 
is one outcome of the wider study Lessons learned to inform integrated approaches for 
the renovation and modernisation of the built environment.  

The analysis shows that, if designed properly and embedded in a wider supportive policy 
framework, MMR can overcome many of the barriers the renovation market is facing, 
including  lack  of  interest  in  energy  renovations,  insufficient  awareness  of  energy  and 
cost-saving potential and the split-incentives dilemma.1 The highlighted MMR models in 
this report would all have a considerable  renovation impact on the European building 
stock  if  designed  and  implemented  effectively.  This  report  also  shows  that  MMR  is  a 
collective name for a broad number of policies that can be implemented, and combined 
with other instruments, flexibly. 

MMR definition   

MMR is a regulation that mandates certain buildings within a defined territory to meet 
a  certain  performance  standard,  by  a  specified  compliance  date  or  according  to 
natural trigger points in the building’s lifecycle (e.g. time of sale). The requirement 
can apply to all buildings or particular building segments. The underlying metrics of 
the requirement is typically based on energy performance standards (kWh/m²/year) 
but  can  also  incorporate  broader  aspects  (e.g.  climate  performance  standards 
(CO₂/m²/year,  whole-life  carbon  and  wider  environmental,  social  and  governance 
factors).   

The same concept is referred to as mandatory minimum energy performance standard 
(MEPS)  in  the  Renovation  Wave,  while  it  is  sometimes  referred  to  as  renovation 
obligation or just minimum performance standards. 

This explorative report has been developed to provide the European Commission with 
knowledge about the concept of MMR, existing experiences and four policy pathways to 
consider.  The  analysis  and  conceptual  work  are  based  on  a  comprehensive  literature 
study, review of existing cases and extensive stakeholder contributions.   

Why do we need mandatory minimum requirements for existing buildings? 

The  decarbonisation  of  the  European  building  stock  needs  a  considerable  boost  to 
become climate-neutral by 2050. Despite this target, the current renovation rate lingers 
at 1% and the deep renovation rate is only around 0.2%.2 This is significantly deviating 
from the path to meet the EU’s climate targets, which require a renovation rate of 3%3, 
whereof  the  majority  must  be  deep  renovations.4  In  the  first  step,  the  European 
Commission’s  Renovation  Wave  strategy  aims  to  at  least  double  annual  energy 
renovation rates in the next ten years. MMR for existing buildings, in combination with 
other enabling measures and financial support, could make this happen.  

1 One important type of split incentive corresponds to the situation on the rental market where those getting 
the  benefits  from  the  renovation  (i.e.  the  tenant)  are  not  the  same  people  as  those  making  the  capital 
investment (i.e. the landlord or building owner). 
2 Ipsos & Navigant (2019) Comprehensive study of building energy renovation activities and the uptake of 
nearly zero-energy buildings in the EU. European Commission. (Available: Online) 
3 EUCalc (2020) Long-Term Renovation Strategies: How the building sector can contribute to climate neutrality 
in the EU. European Commission – Horizon 2020 project. (Available: Online) 
4 Deep renovations are renovations that reduce the energy need with, at least, 50-70%.  

3 

 
 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

MMR has already been implemented in various jurisdictions for this purpose, especially 
across  Europe  and  the  United  States.  For  example,  the  UK,  France,  the  Netherlands, 
and Belgium (Flanders and Brussels) have implemented, or have far-reaching plans to 
implement, MMR for existing buildings. The common purposes of these regulations are 
to  phase-out  the  worst-performing  buildings  and  trigger  renovations.  The  concept  of 
MMR is also gaining ground in the United States, where several cities and municipalities 
are implementing MMR for specific building segments (see case studies in Appendix 1).  

The implementation of MMR to build on energy performance certificates 

All  EU  Member  States  have  implemented  and  enforced  national  energy  performance 
certificate  (EPC)  schemes,  making  these  the  most  obvious  starting  point  and  design 
choice  for  MMR5,  especially  as  most  building  owners  know  about  EPCs  and  the 
infrastructure (experts, compliance, databases etc.) is already in place. The UK was first 
to  set  a  minimum  energy  efficiency  standard  based  on  the  EPC  rating,  followed  by 
France, Belgium and the Netherlands.  

The EPC framework is the most obvious reference point for introducing MMR for existing 
buildings.  The  purpose  of  the  EPC  is  to  provide  information  on  a  building’s  energy 
performance status and to offer suggestions for cost-effective improvements, while less 
suited  for  considering  whole-life  carbon  aspects.  On  an  aggregate  level,  they  offer 
information about the building stock and how it can be decarbonised. The comparability 
of EPCs across the EU (in terms of aspects like calculations, control and data availability) 
needs further improvement. EPCs already have a link to voluntary carbon metrics, where 
a change in the main scope would require additional legislative efforts,  in addition to 
the  significant  reinforcement  and  harmonisation  already  planned  in  the  Renovation 
Wave strategy.  

EPC schemes need to significantly improve in terms of quality and coverage to be able 
to effectively facilitate an MMR built around them. The remaining issues include:  

•  The availability of registered EPCs per capita is still too low for the instrument to 
be used as the universal assessment criteria of the MMR. Only the UK, Ireland, 
Portugal, Denmark and Belgium have more than 1 EPC registered per 10 
inhabitants6. Even in England and Wales, where the highest frequency of EPCs 
can be found, the share of buildings without an EPC is seen as a barrier for any  
MMR implementation. MMR may be impossible to deploy unless the large 
majority of targeted buildings have an EPC. 

•  EPC frameworks differ across Europe, with various approaches that have led to a 
diverse set of instruments, differing in terms of scope, available information and 
impact. An MMR based on the national EPC schemes will, therefore, trigger a 
variety of impacts.  

•  The reliability of EPCs remains the subject of scrutiny and leaves room for 
improvement, especially if they were to credibly facilitate an MMR – the 
reliability, quality control and attainability of the threshold, which can be 
operationalised by an EPC rating, are the most important prerequisites for MMR. 

5  The  main  alternative  to  use  the  EPC  as  a  proxy  for  the  minimum  standard,  is  to  use  the  actual  energy 
consumption/carbon use, which can be derived from smart meters and/or utility bills.  
6  X-tendo  (2020)  Energy  Performance  Certificates  –  Assessing  their  status  and  potential.  European 
Commission – Horizon 2020 project. (Available: Online) 

4 

 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Potential impact on carbon emissions  

Existing  MMR  have  predominantly  been  focused  on  improving  a  building’s  energy 
performance during its use phase. There are good  reasons  for prioritising operational 
energy savings as, currently, this represents the main source of emissions in  existing 
buildings.  Renovating  buildings,  and  increasing  the  overall  energy  performance,  will 
reduce the energy required for heating and other end-uses, and thus also reduce the 
related carbon emissions. However, due to the incremental decarbonisation of energy 
supplies  and  the  improvement  of  operational  energy  performance  levels  in  buildings, 
the importance of embodied emissions has grown and will continue to do so. Considering 
the  whole-life  carbon  impact  in  new  constructions,  and  in  renovations  of  existing 
buildings, is key to reduce the overall impact of the building sector.   

As soon as lifecycle and embodied carbon data becomes more readily available, MMR 
could  evolve  to  consider  whole-life  carbon  emissions,  including  emissions  from 
manufacturing and construction through to the end of life and disposal of buildings. An 
instrument  like  the  building  renovation  passport,  setting  out  a  tailored  renovation 
roadmap for an individual building, could identify the best path for the specific building 
to become “2050 ready”, taking into account all related carbon emissions. The MMR can 
gradually include whole-life carbon considerations, defined concerning widely accepted 
lifecycle  assessment  (LCA)  and  CEN/TC350  standards,  the  Level(s)  framework, 
Environmental Products Declaration and digital building logbooks.7 

Integrating lifetime carbon emission considerations in MMR is a viable and worthwhile 
strategy. Significant carbon reductions are achievable however with a certain additional 
effort from the building value chain. It should be noted, however, that LCA is currently 
used  to  only  a  very  limited  extent  in  the  building  sector  mainly  due  to  the  lack  of  a 
common  industry  standard  and  reliable  datasets;  addressing  these  gaps  ahead  of 
integrating carbon emission considerations in MMR  should be a priority. Furthermore, 
as embodied carbon is a relatively less established metric than operational energy, more 
awareness-raising,  training,  guidance  and  simplification  will  be  required  to  ensure 
successful implementation and market transformation.  

Potential impacts on the real estate market 

MMR can have significant effects on shaping business models and investment decisions 
in the real estate sector.  

First, the introduction of MMR will mean that real estate managers and practitioners will 
find it easier to draw up decarbonisation strategies, identify reliable targets and actions 
to  improve  performance,  as  well  as  communicate  and  demonstrate  compliance  with 
MMR in a consistent way. Certainty around MMR makes the business case of investing 
in energy performance improvements more compelling.  

Second,  MMR  will  incentivise  property  markets  to  differentiate  according  to  energy 
performance  and  will  likely  make  the  link  between  energy  performance  and  market 
value (or investment worth) more visible and direct. In this sense, MMR can contribute 
to a price correction to reflect the performance of the building and/or affect the cash 
flow  of  non-compliant  stock.  Such  effects  are  beneficial  because  often  energy 

7 The setting of MMR thresholds could follow a similar approach to the EU sustainable finance taxonomy. The 
purpose  of  the  taxonomy  is  to  identify  assets  which  are  significantly  contributing  to  climate  change 
mitigation/adaptation, whereas the main purpose of the MMR is to identify the worst-performing segments. 
Setting  the  right  MMR  level  will  need  to  be  proportional  with  compliance  costs.  Overall,  considering  the 
importance  and  urgency  of  improving  the  energy  performance  and  decarbonising  the  building  stock,  the 
impact of compliance costs can be considered proportionate, especially given significant positive social and 
economic impacts the implementation of MMR can have. 

5 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

performance  is  not  adequately  reflected  in  property  valuations,  investment  and 
financing decisions, as well as the by real estate markets in general. 

MMRs  are  primarily  aimed  at  increasing  the  rate  of  upgrades  to  existing  inefficient 
properties  and  raising  awareness  of  energy-related  issues.  In  the  Netherlands,  a 
significant  increase  of  investments  in  renovation  works  of  commercial  properties  has 
been observed in anticipation of the regulation – which requires office buildings to have 
an EPC of C – scheduled to come into force in 2023. On the other end, MMR will also 
provide  a  clear  signal  to  the  market  that  non-compliant  assets  are  at  risk  of  value 
depreciation  or  becoming  stranded  assets.  Real  estate  investors  and  landlords  may 
discriminate against buildings with low ratings within their portfolio strategies and seek 
to  divest  of  stock  that  is  either  at  risk  or  fails  to  meet  the  MMR  standards  (or  is  too 
expensive to renovate?). Others might acquire non-compliant properties and bring them 
up to standard if this is economically feasible. Properties in prime locations are less likely 
to be affected negatively in value terms by MMR, but all properties of poor specification 
and energy performance, which are expensive to upgrade, may face a value correction 
to reflect these.  

Third,  beyond  the  changing  market  preferences,  lenders,  investors  and  insurers  may 
also  start  factoring  in  the  risk  implications  of  MMR.  Better  performing  properties  can 
attract  cheaper  financing,  this  could  positively  impact  the  value  of  such  properties. 
Conversely, if financing and insuring sub-standard properties become more difficult or 
more expensive, it could negatively impact their market value. 

The introduction of an MMR scheme is not regarded as counteracting article 17 (1) of 
the Charter of Fundamental Rights of the European Union (2012/C 326/02) on property 
rights.  The  introduction  of  an  MMR  will  not  deprive  any  property  owner  of  his  or  her 
building.  It  rather  serves  the  general  interest  since  MMR  are  considered  as  a  key 
instrument to decarbonize the building stock and secure sustainable energy supply to 
citizens  of  the  European  Union.  In  addition,  the  measures  will  lead  to  an  increase  in 
health and well-being of a significant share of  the population and general increase  of 
the property value, especially in view of rising carbon prices. 

Social implications  

The  MMR  has  the  potential  to  make  sure  all  Europeans  have  a  decent  home  and  a 
bearable  energy  bill,  by  alleviating  the  worst-performing  dwellings.  34  million 
households (or 13.90% of the population) are living in inadequate dwellings throughout 
the  EU,  defined  as  dwellings  with  leaking  roofs,  damp  walls,  etc.  These  buildings 
correlate strongly with the worst-performing buildings, which in addition to the health 
issues  comes  with  high  energy  costs  for  the  occupants.  Renovating  these  buildings 
would reduce energy poverty levels as well as related health-care costs.   

At the same time, policymakers need to consider the financial burden that comes with 
an MMR, as many landlords and private building owners will struggle to cover the extra 
cost. Therefore, affordability of renovations and prevention of energy poverty should be 
guaranteed by an enabling framework with financial measures for building owners and 
residents, especially the most vulnerable ones.  

The landlords should be able to recoup the renovation investments through an increase 
in the rent which corresponds to the energy costs saved by the tenants. The extra cost 
for the tenants ought to be limited, in order to avoid adverse effects on the energy-poor 
(e.g. by causing ‘renovictions’).   

6 

 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Development since the EPBD Impact Assessment [SWD(2016) 414 final] 

The  potential  and  feasibility  of  MMR  for  existing  buildings  (Measure  1B:  Oblige  the 
renovation of buildings to reach a given standard before transactions), was evaluated 
in  2016  EPBD  Impact  Assessment.  While  viewed  as  effective  in  increasing  the 
renovation rate and in reducing energy poverty, an MMR was considered not feasible 
due  to  “uncertain  impact  on  the  real  estate  market  and  probably  stepping  out  of 
subsidiarity  and  proportionality  limits  of  EU  intervention”.  It  was  also  noted  that 
“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.”.  

The identified issues remain in place and have been discussed in this report. Below is a 
summary of these considerations.  

1.  The impact on the real estate market remains uncertain but the lessons learned 
we  can  draw  at  this  point,  suggest  the  impact  will  be  positive.  In  the 
Netherlands,  a  significant  increase  of  investments  in  renovation  works  of 
commercial  properties  has  already  been  observed  in  anticipation  of  the 
regulation scheduled to come into force in 2023, which requires office buildings 
to have an EPC of C. Furthermore, MMR will also provide a clear signal to the 
market that non-compliant assets are at risk of value depreciation or becoming 
stranded assets. Having a clearer value differentiation and implicitly, a stronger 
link  between  energy  performance  and  property  value  will  help  improving  the 
business case and decision marking for investing in renovations. 

2.  The  issue  of  subsidiarity  and  proportionality  will  depend  on  how  the  MMR  is 
regulated and enforced by the EU. A uniform MMR would neither be in line with 
the subsidiarity and proportionality principles, nor desirable because the design 
options  of  an  MMR  ought  to  be  adapted  to  the  local  context  and  needs.  The 
experts  consulted  in  this  study,  do  not  see  the  issue  of  subsidiarity  and 
proportionality  as  major  obstacle,  if  the  MMR  principle  is  established  and 
enforced  through the EPBD, and then designed and implemented by the Member 
States  within  certain  defined  boundaries.  While  a  one-size-fits-all  approach  is 
not  possible,  the  EU  and  its  Member  States  should  strive  for  as  much 
harmonisation as possible because the signal to the real estate market would be 
stronger and more unambiguous, while also increasing synergies and learnings 
across borders.  

3.  The lack of reliable and granular data of the building stock is still a large obstacle. 
Most  Member  States  rely  on  the  EPC  databases  for  information  about  their 
building stock, while few databases have been designed for this purpose. Since 
2016, a large number of advanced EPC databases have appeared and evolved 
(e.g. Denmark and Ireland), together with digital building logbooks (Woningpas 
in  Flanders  and  Casa+  in  Portugal),  material  passports  (Madaster  in  the 
Netherlands and Basta  in Sweden) and a whole-life carbon database  (Climate 
declaration  database  in  Sweden).  The  Renovation  Wave  strategy  set  out  to 
further  improve  the  EPC  databases  and  introduce  digital  building  logbooks, 
which are needed to underpin the introduction of an MMR.  

7 

 
 
 
 
 
 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Identification of 6 archetypical MMR models 

For  this  report,  29  MMR  cases  in  Europe,  the  United  States  and  Oceania  have  been 
identified and analysed. The approaches taken in these cases share many similarities 
but also differences. Six archetypical MMR models targeting the performance of entire 
buildings (i.e. not component-based) have been derived from the analysis of existing 
cases and stakeholder input. The models are archetypes or simplifications of how MMR 
can be designed, enforced and implemented.  

MMR model 1: Progressive minimum energy performance 
requirements

•Building types: All buildings 
•Metric: kilowatt-hours per square meter (kWh/m2) based on asset rating (i.e. 
theoretical, as designed energy efficiency)  

•Vehicle for implementation: Current energy performance certificates schemes (with 

improvements of reliability and data gathering and storage approaches)  

•Long-term objective: gradual increase of minimum requirement until EPC B by 2050

MMR model 2: Progressive minimum carbon performance 
requirements

•Building types: All buildings 
•Metric: Carbon dioxide emissions per square meter (CO2/m2) based on asset rating 
(i.e. theoretical, as designed carbon efficiency)  

•Vehicle for implementation: Updated energy performance certificates schemes 

showing the  operational carbon performance

•Long-term objective: gradual increase of minimum requirement until EPC B by 2050

MMR model 3: Progressive real carbon emissions budget

•Building types: Primarily larger residential and non-residential buildings 
•Metric: Carbon dioxide emissions per square meter (CO2/m2) based on operational 
rating

•Vehicle for implementation: smart meter data and fuel mix 
•Long-term objective: gradual increase of carbon budget until zero carbon by 2050. 

MMR model 4: Mandatory improvements trigger by indoor 
environmental quality deficiencies 

•Building types: Primarily schools, hospitals and offices
•Metric: Indoor environmental quality (air quality, thermal comfort, ligthing, 

acoustics) standards  

•Vehicle for implementation: energy audit  
•Long-term objective: none

MMR model 5: Progressive implementation of pre-defined 
renovation steps based on a building renovation passport

•Building types: All buildings 
•Metric: Carbon dioxide emissions per square meter (CO2/m2) based on asset rating 
and eventually consider whole-life carbon aspects 

•Vehicle for implementation: building renovation passport (a detailed and tailored 

renovation roadmap for the individual building based on an audit)

•Long-term objective: the steps of the roadmap ought to align with the 2050 

objectives 

MMR model 6: Renovation obligation linked to real estate 
transactions for all building non-compliant in 2050

•Building types: All buildings 
•Metric: kilowatt-hours per square meter (kWh/m2) based on asset rating (i.e. 
theoretical, as designed energy efficiency) 

•Vehicle for implementation: current energy performance certificates. All buildings not 

being "2050-ready", must be upgraded in conjunction with property transfer 

•Long-term objective: all buildings are moving towards the long-term target

Figure 1: Six archetypical MMR models 

8 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Potential paths forward 

Europe’s efforts to  support  the  uptake  of MMR  for  existing  buildings can  be described 
in different policy pathways. The policy pathways outline a sequence of policy actions, 
legislative  and  non-legislative,  together  with  supporting  measures  that  over  time 
achieve a set of pre-defined objectives. The existing cases demonstrate the many ways 
an  MMR  can  be  designed  and  implemented.  While  there  may  be  numerous  plausible 
paths  forward,  four  pathways  have  been  derived  to  represent  the  most  realistic 
approaches.  Much of the impact of the different pathways will, in the end, depend on 
how it is enforced by the EU and what is required by the Member States.  

There  is  no  silver  bullet  for  how  MMR  can  be  implemented  and  enforced.  It  needs  to 
combine various key ingredients, which can be different for the various Member States, 
while continuously improving the policy based on new  and emerging lessons learned. 
Successful  MMR  introduction  must  be  supported  by  a  wider  policy  framework.  The 
analysis of existing cases shows that the introduction of MMR must be accompanied by 
several supportive measures depending on the local context, including:  

•  Financial support schemes to make the requirement more palatable for key 

stakeholders and lessen the potential upfront financial burden put on certain 
groups. Vulnerable citizens like the energy-poor should not experience this as an 
extra burden to avoid “renovictions”. Many people living in the worst-performing 
buildings, which would be subject to an MMR, are vulnerable to a cost increase. 
Real estate investors and owners considering deep renovations should be 
incentivized, through instruments like subsidies and green bonds, to go beyond 
the minimum requirements and to avoid a steep increase in demand just before 
the compliance date.    

•  Skills and capacity of the construction value chain. The renovation boost that will 

be triggered by MMR will require a skilled workforce, while the shortage of 
workers has been flagged as a constraint, especially in some Member States. 
Investments are needed in training and capacity building, as well as in attracting 
new talents and improving the image of the construction sector, to make sure 
there are enough workers with the right skills, to deliver the renovation wave.  
•  Public awareness and acceptance are key for effective implementation of MMR. 
People should be aware of and understand the requirement as well as the 
purpose and clear short and long-term benefits behind them in terms of climate 
mitigation and alleviation of energy poverty. Lessons learnt from existing cases 
show that it is difficult to get the right information out there to the citizens. 
Support can be given to the Member States to carry out tailored communication 
campaigns and integrated renovation services, such as one-stop-shops, to make 
the renovation journey smoother.  

The following pages describe four policy pathways, outlining the main approaches for 
how MMR can be introduced and enforced in the EU.  

9 

 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Policy pathway 1: Progressive minimum energy performance requirement   

Policy  Pathway  1  aims  to  alleviate  the  worst-performing  building  in  terms  of  energy 
efficiency by introducing a progressive minimum energy performance requirement for 
the existing buildings. The pathway has been designed to utilise existing infrastructure 
(esp. the EPC schemes) and existing directives (esp. the EPBD). The boost in demand 
for energy renovations will drive change in the construction value chain by requiring an 
improvement of the worst-performing building segments.   

pathway 

performance 
Policy 
requirements (expressed  in  kWh/m2/year)  and  can,  therefore,  build  on  the  existing 
policy framework. This MMR may be deployed via a new article in the EPBD and linked 
to the EPCs and long-term renovation strategies (LTRS).  

progressive  minimum 

energy 

sets 

1 

The  existing  cases  show  that  successful  MMR  must  be  integrated  into  a  wider  policy 
framework and be based on long-term progressive enforcement perspectives. To make 
policy pathway 1 effective, the EU and its Member States must support it through:  

• 

• 

Improvement of the penetration, reliability and awareness of EPCs, for example 
through higher and more harmonised requirements by the EU.  
Investment in skills in the construction value chain to make sure there are 
enough certified workers to carry out the additional work.  

•  Promoting the deployment of appropriate financing schemes, to ensure the 

accessibility and affordability of the renovation investments.  

•  Directing financial support to limit the negative effect on vulnerable groups, as 
well as to incentivise people to upgrade their building beyond the minimum 
requirement.  

•  Facilitating forums for good practice exchange. 
• 
•  Setting up a systematic approach to address the ‘performance gap’8 

Investing in awareness-raising activities among the public.   

Pros  

Cons 

+ Relatively easy to implement  
+ Builds on existing cases  
+ Easy for end-users to grasp 

- The performance gap is a risk 
-  Risk  that  whole-life  carbon  emissions 
may    be  overlooked  if  not  addressed  by 
another measure 

8 The performance gap, referred to here, is the disparity that can be found between the energy use predicted 
in the design stage of buildings and the energy use of those buildings in operation. 

10 

 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the renovation and modernisation of the built environment  

Figure 2: Policy pathway 1 - Timeline 

11 

2050EU enabling measures EU policy instrumentsStrengthen EPC schemesTraining of energy expertsCapacity buildingIntroduce in EPBDEncourage through LTRSProgressive energy performance requirementProgressive energy performance requirementMMR ModelResidentialNon-residential 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Policy pathway 2: Progressive minimum carbon performance requirement    

Policy  pathway  2  aims to  get  carbon  emissions  related  to  operational  energy 
consumption down to zero by 2050. MMR linked to carbon emissions, instead of energy 
performance, can better align the requirement with the long-term  climate objectives, 
which are expressed in carbon emission levels. This MMR can drive increased demand 
for  renovations,  with  an  optimal  balance  between  energy  efficiency  and  renewable 
energy investments.  

Policy  pathway 2 sets  progressive  minimum carbon  performance requirements 
(expressed  in  CO2/m2/year  and  relating  to  operational  energy  consumption). For 
residential buildings, the pathway foresees that EPCs are updated to feature the carbon 
performance  of  the  building  more  reliably. For  non-residential  buildings,  the  carbon 
performance is derived from the actual energy consumption (e.g. as displayed by smart 
meters) and the local energy mix and the CO2 emission factor.  Carbon performance, in 
this  pathway,  focuses  on  the  emissions  as  a  result  of  the  operational  energy 
consumption. It does not include embodied carbon emissions, which a whole-life carbon 
approach would do (see Policy pathway 3). This carbon-oriented MMR would, however, 
require a broader regulatory framework.  

To  make  policy  pathway 2 effective,  the  EU  and  its  Member  States  must  support  it 
through:  

•  Updating EPCs to feature the building’s carbon performance, while also 

improving the instrument’s penetration, reliability and awareness. Under the 
EPBD, Member States already have the possibility to define additional numeric 
indicators to express the energy performance of buildings, including in terms of 
carbon emission produced (expressed in kgCO2eq/m2/year), in addition to 
primary energy use. 

•  Exploring how to set a carbon performance requirement that balances energy 

• 

efficiency and renewable energy investments.  
Investing in skills, communication, financial support and good practice forums, 
as described under policy pathway 1.  

Pros  
+ Aligned with 2050 target   
+ Easy for end-users to grasp  
+  Cost-optimal  balance  between  energy 
efficiency and renewables 

Cons  
- Requires  considerable  revisions  of  the 
existing legislative basis 
- Some multiple benefits (better comfort, 
health  and  productivity  gains)  of  energy 
efficiency improvements at  risk of being 
missed   
-  Whole-life  carbon  emissions  are  not 
included 

12 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the renovation and modernisation of the built environment  

Figure 3: Policy pathway 2 - Timeline

13 

2050MMR ModelEU enabling measures Progressive carbon performance requirementEU policy instrumentsStrengthen EPC schemesTraining of the value chainCapacity buildingIntroduce in EPBDEncourage through LTRSReal carbon performance budget Encourage funding through OP/ESIFResidentialNon-residentialProgressive energy performance requirement 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Policy  pathway 3: Progressive  minimum  carbon  performance  requirement, 
considering whole-life carbon aspects 

Policy pathway 3 aims to get all carbon emissions down to zero by 2050 by integrating 
all  related  carbon  emissions. An  MMR  linked  to  carbon  emissions can  better  align  the 
requirement with the long-term climate objectives, yet is more complex to design and 
put in practice, because there is no common standard9 for how data can be gathered 
and  stored,  and  no  database  of  whole-life  carbon  data10  that  can  be  used  for 
benchmarking purposes. A whole-life carbon standard would have circularity as a key 
principle and would tend to favour the reuse of buildings and their materials as much 
as possible, and influence design decisions in both renovations and new constructions.    

Policy  pathway 3 sets  progressive  minimum carbon  performance requirements. The 
carbon  performance  requirement  should  gradually  go  on  to  also  consider  lifecycle 
performance  when  the  renovation  plan  is  developed  for  the  individual  buildings. The 
pathway  relies  on  reliable  building  data  being  available  and  attainable,  and  tailored 
renovation  recommendations  for  the  end-users,  which  can  be  ensured  by  the 
introduction  of  digital  building  logbooks11  and  building  renovation  passports12.  The 
whole-life  carbon  aspect  might  influence  the  renovation  stages  of  the  building,  what 
materials and strategies are suggested and when the measures will be carried out.  

To  make  policy  pathway 3 possible,  the  EU  and  its  Member  States  must  support  it 
through a number of enabling actions.  

Immediate actions 

•  Collecting and storing information on buildings’ life-cycle emissions, based on a 

common operational standard is needed and would increase transparency and 
awareness about embodied carbon. The life-cycle information should be 
compiled in a publicly available database, starting with public and new buildings.  
Introducing a whole-life carbon performance indication in the EPC and their 
renovation recommendations. The EPBD already makes it possible to the 
Member States to express the building performance using indicators additional 
to primary energy. One indicator could be whole-life carbon using a light LCA 
approach.  
Introducing and continuing the development of building renovation passports 
and digital building logbooks – these are an important link to enable whole-life 

• 

• 

9  The  EU  Level(s) framework  is  a  protocol  that brings  together  all  relevant  standards  on  whole-life  carbon 
(and  other  aspects).  The  framework  could  be  evolved  to  enable  benchmarking  of  the  whole-life  carbon 
performance  and  thus  support  this  policy  pathway.  The  European  Standard  [EN  15978]  specifies  the 
calculation  method,  based  on  LCA  and  other  quantified  environmental  information,  to  assess  the 
environmental performance of a building, and gives the means for the reporting and communication of the 
outcome  of  the  assessment.  Several  other  European  and  ISO  standards  do  address  whole-life  carbon  and 
sustainability of buildings. See compilation in Bionova Ltd (2018) The Embodied Carbon Review (Available: 
Online).  While  most  existing  whole-life  carbon-standards  are  considered  too  “high-level”  by  industry 
professional, some are already considered operational and commonly used, one example is RICS (2017) RICS 
professional statement: Whole life carbon assessment for the built environment. (Available: Online).      
10 Sweden is currently introducing a climate declaration requirement for new constructions, which will enter 
into force on 1 January 2022 (see link). It includes “developing a national database containing climate data 
and  taking  measures  to  promote  carefully-considered  requirement  specifications  from  a  life-cycle 
perspective”. Databases like this are needed to support the inclusion of whole-life carbon considerations in 
new buildings and renovatin of existing buildings.  
11 A digital building logbook is a common repository for all relevant building data. It facilitates transparency, 
trust,  informed  decision  making  and  information  sharing  within  the  construction  sector,  between  building 
owners and occupants, financial institutions and public authorities.  
12  A  Building Renovation  Passport  is defined  as  a  document  outlining  a  long-term  step-by-step renovation 
roadmap for a specific building, resulting from an on-site energy audit and fulfilling specific quality criteria 
and indicators established in dialogue with building owners. As the passport is based on a detailed energy 
audit  it  is  well  placed  to  integrate  LCA  considerations.  See  European Commission’s  Technical  study  on  the 
possible introduction of optional building renovation passports (see link) 

14 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

carbon assessments and informed decision-making and could store all the 
relevant life-cycle building data.  
Introducing LCA reporting requirements for larger public buildings and new 
constructions  

• 

•  Significant investments in skills, communication, financial support and good 

practice forums, as described under policy pathway 1.  

Subsequent actions  

•  Exploring how LCA and related validation/compliance can be included cost-
effectively. Pilot cases can help testing and validation of the approach.  
•  Continuing the development of Level(s)13 which is based on established LCA 

assessment tools and, implicitly, whole-life carbon.  
Introducing LCA reporting requirements for all buildings in connection with EPC   

• 

Existing cases to learn from:   

No existing case is currently integrating whole-life carbon considerations.  

Pros  

Cons  

to 

into 
carbon 
thereby  contributes 
carbon 

+ Takes  whole-life 
account   and 
further 
reduction targets 
+  LCA  will  steer  the  market  towards 
more  sustainable  options,  resulting  in 
wider benefits 

the  national 

time 

require 

the  whole-life  carbon  data 
and 

-Setting  up 
infrastructure  will 
considerable investments   
-  Requires  considerable  revisions  of  the 
existing regulatory framework  
- More  difficult  for  homeowners  to  grasp  and 
more difficult to communicate broadly  
-  Technically  and  administratively  more 
complex  
- Require additional training for energy experts 
and construction professionals  

13 Level(s) is a common European approach to assess and report on the sustainability of buildings. 

15 

 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the renovation and modernisation of the built environment  

Figure 4: Policy pathway 3 - Timeline

16 

 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Policy pathway 4: Moving all buildings towards the objective of a decarbonised 
building stock by 2050 

The  focus of  the  policy  pathway  4  is  to  capture the  key  trigger  points  in  a 
building’s lifetime in addition to progressive enforcement of minimum requirements. The 
pathway goes beyond tackling just the worst-performing buildings, as it applies to 97% 
of  all  buildings14.  Trigger  renovation  concerning  property  transfers  could foster  an 
effective and smooth transition towards the 2050 objective. The additional cost for the 
property  buyer  to  upgrade  the  building’s  EPC  label  with  1-2  steps,  will  amount  to  a 
fraction, on average, of the cost of buying the property, which can be incorporated in 
the total cost.  Prospective building owners would be made aware of this requirement 
and can thus plan accordingly. A link with energy efficiency mortgages15 could reduce 
the  extra  financial  burden  of  this  requirement.  Policy  pathway 4  combines  two  MMR 
models:  

1.  The first sets a renovation obligation for all properties that are being sold and do 
not  already  have  an  EPC  label  A  (or  what  rating  is  required  for  the  specific 
building to be compliant with the 2050 requirement).  

2.  The  second  set  progressive  minimum  energy  performance  requirement  for 
operational energy consumption for all buildings to make sure that all the worst-
performing buildings are being upgraded (as in policy pathway 1).  

To  make  policy  pathway 4 effective,  the  EU  and  its  Member  States  must  support  it 
through:  

•  Updating EPCs and improving the instrument’s penetration, reliability and 

• 

• 

awareness.  
Improving the information available on the real estate market and raise 
awareness of all stakeholders involved in real estate transactions. 
Investing in skills, communication, financial support, and good practice forums, 
as described under policy pathway 1.  

Pros  
+ Boosts the renovation activities   
+  All  buildings  (except  the  highest-
performing ones) must comply, which 
can increase the overall acceptance 

Cons  
- Possible  negative  effect  on  the 
housing  market,  as  the  buildings 
would  be  relatively  more  expensive 
with this requirement  
- 
Confusing  mix 
requirements, 
understand and communicate 

of 
challenging 

different 
to 

14 See BPIE’s analysis of EU’s building stock based on EPC data, where only 3% of existing buildings have an 
EPC label A.  

15 An energy efficient mortgage is a loan product that allows borrowers to reduce their utility bill costs by 
allowing  them  to  finance  the  cost  of  incorporating  energy-efficient  features  into  a  new  purchase.  See: 
https://energyefficientmortgages.eu/ 

17 

 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the renovation and modernisation of the built environment  

Figure 5: Policy pathway 4 - Timeline

18 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Key lessons learned  

MMR  can  be  a  powerful  tool  to  address  both  the  low  rate  and  depth  of  renovations. 
Experiences from the Member States with MMR already in place provide useful lessons 
for the future design of the instrument, which can be tailored to the different segments 
of the building stock and ownership tenures. Coupled with adequate financial support, 
MMR can contribute to decent homes for the more vulnerable. 

•  A clear overview of the building stock is the starting point to design 

effective MMR. This includes, for example, having a comprehensive 
understanding of the energy and climate performance of the building stock, 
particularly the worst-performing buildings, the different tenure statuses as well 
as of the different building typologies, to which the obligation will apply. Ideally, 
MMR is linked to already established frameworks, like the EPCs in Europe or the 
Energy Star Portfolio Management tool in the USA. 

•  An effective MMR needs to be embedded in a wider policy framework, 
including adequate and targeted financial support, capacity building and 
information measures.  

•  EPC schemes need to improve and evolve in scope to effectively facilitate 
an MMR built around them, including their reliability, comparability, availability 
as well as data gathering and the functionality of EPC databases. 

•  While MMR is introduced to improve the worst-performing buildings, voluntary 
standards can be defined up to the 2050-standard (e.g. a net-zero carbon 
building) and linked with additional financial support. The MMR can then be 
progressively tightened over time until the 2050-standard has been reached. 

•  Different building types can be treated differently within an MMR 

scheme. Larger, non-residential or public buildings could lead by example by 
having to comply with the MMR before other building typologies. The MMR for 
these buildings could also be more sophistically elaborated, as better data 
gathering opportunities and more granular data generally exist.  

•  Special attention must be paid to vulnerable citizens who live in inadequate 

dwellings to make sure they are not “punished” twice. The risk of “renovictions”, 
where people cannot afford to pay their rent, due to rent increases after 
renovations should be evaluated and addressed by an appropriate supporting 
framework, such as targeted financial support and avoiding disproportionate 
rent increases.  

•  Stakeholder involvement is essential from the very early stages in the 
design of an MMR and to build understanding, support and acceptance around 
the policy. Policymakers can gather valuable insights and tailor MMR design 
choices to the characteristics of local buildings, different tenures, and the built 
environment.  

•  Communicate on multiple benefits of energy renovations (beyond carbon and 
energy), such as better comfort, health, productivity, and overall wellbeing.  
•  Gradually including carbon performance and embodied carbon metrics can 
contribute significantly to achieving GHG emission reductions, though at the 
short term challenges remain with regard to data gathering and benchmarking.   

•  The MMR ought to be coupled with tailored renovation advice (such as a 
building renovation passport) to avoid technical and economical lock-in effects. 

•  Ensure sufficient lead time and administrative capacity to implement MMR. 
The public authorities must show that they are serious with the enforcement but 
also give the market time to adapt. In addition, the availability of a skilled 
workforce is also an important precondition. 

•  The policy design should be aimed at simplicity. Too complex regulation, 
such as many exemptions, make the MMR enforcement less likely to succeed. 

19 

 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

CONTENTS  

EXECUTIVE SUMMARY ................................................................................................... 3 

CONTENTS .................................................................................................................. 20 

TERMINOLOGY ............................................................................................................ 21 

1. 

2. 

3. 

INTRODUCTION ................................................................................................... 23 

RESEARCH APPROACH .......................................................................................... 31 

STEP 1: POLICY CONSIDERATIONS......................................................................... 34 

3.1.  Contributing to the 2050 target ..................................................................... 34 
3.2.  Relation to existing and new strategies .......................................................... 35 
3.3.  Wider policy framework ................................................................................ 36 
3.4.  MMR needs a facilitating infrastructure ........................................................... 39 
3.5.  MMR is a flexible instrument thanks to a diversity of design options ................... 43 

4. 

STEP 2: SHORTLIST OF THE MOST RELEVANT MMR MODELS BASED ON KEY DESIGN 
OPTIONS ............................................................................................................. 50 

4.1.  MMR model 1: Progressive minimum energy performance requirements............. 51 
4.2.  MMR model 2: Progressive minimum carbon performance requirements ............. 54 
4.3.  MMR model 3: Progressive real carbon emissions budget ................................. 58 
4.4.  MMR  model  4:  Mandatory  improvements  trigger  by  indoor  environmental 

quality deficiencies ...................................................................................... 61 

4.5.  MMR  model  5:  Progressive  implementation  of  pre-defined  renovation  steps 

based on a building renovation passport......................................................... 65 

4.6.  MMR model 6: Renovation obligation linked to real estate transactions for all 

building non-compliant in 2050 ..................................................................... 70 
4.7.  Overview of the impact and feasibility of the MMR models ................................ 73 

5. 

STEP 3: POLICY PATHWAYS TO ESTABLISH MMR FOR EXISTING BUILDINGS IN THE 
EU ...................................................................................................................... 75 

5.1.  Policy pathway 1: Progressive minimum energy performance requirement ......... 77 
5.2.  Policy pathway 2: Progressive minimum carbon performance requirement ......... 79 
5.3.  Policy  pathway 3: Progressive  minimum  carbon  performance  requirement, 

considering whole-life carbon aspects ............................................................ 81 

5.4.  Policy pathway 4: Moving all buildings towards the objective of a decarbonised 

building stock by 2050 ................................................................................. 84 

6. 

STEP 4: IMPACT AND FEASIBILITY DISCUSSION ...................................................... 86 

6.1.  What can the EU do to introduce MMR for existing buildings? ............................ 86 
Impact of the policy pathways ...................................................................... 88 
6.2. 
6.3.  Feasibility of the policy pathways .................................................................. 90 

STEP 5: CONCLUSION ........................................................................................... 92 

REFERENCES ....................................................................................................... 98 

APPENDIX 1: CASE STUDIES ............................................................................... 100 

7. 

8. 

9. 

10.  APPENDIX 2: STAKEHOLDER VIEWS ..................................................................... 116 

11.  APPENDIX 3: IMPACT AND FEASIBILITY OF THE MMR MODELS ................................ 122 

20 

 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

TERMINOLOGY 

Building  renovation  passport  (BRP)  -  A  BRP  provides  a  long-term,  tailored 
renovation  roadmap  for  a  specific  building,  following  a  calculation  based  on  available 
data and/or an on-site  audit by an expert.  The instrument identifies and outlines  the 
deep renovation scenario(s), including steps to implement energy-saving measures that 
could improve the building’s performance to a significantly higher level over a defined 
period. The instrument can be complementary to energy performance certificates and/or 
combined with digital building logbooks. 

Building stock – All buildings, residential and non-residential, that exist in a certain 
area, which can be regional, country-wide or the whole European Union.  

Final  energy  consumption  –  Total  energy  consumed  by  end-users,  such  as 
households,  industry,  and  agriculture.  It  refers  to  the  energy  that  reaches  the  final 
consumer's door and excludes that which is used by the energy sector itself. 

Embodied  carbon  -  Carbon  emissions  associated  with  materials  and  construction 
processes throughout the whole lifecycle of a building  

Enabling policy framework – Comprises policies that are not directly related to the 
mandatory  minimum  requirement  but  enable  it  to  function  (more  effectively).  The 
enabling  policy  framework  can  include  measures  like  training  of  experts,  financial 
support, communication, and awareness-raising activities.  

Energy Efficiency Directive (EED) – Under this directive, EU countries are required 
to  use  energy  more  efficiently  at  all  stages  of  the  energy  chain,  including  energy 
generation, 
transmission,  distribution,  and  end-use  consumption.  The  2018 
amendments outlined a target for 2030 to improve energy efficiency by at least 32.5% 
for the EU, compared to 2007 levels.  

Energy  performance  certificate  (EPC)  –  A  rating  scheme  indicating  the  energy 
performance of a building in the European Union. Each Member State (and, in certain 
cases,  region)  has  developed  its  EPC  according  to  the  framework  given  by  the  EPBD 
[2010/31/EU – Article 2 (12)]. 

Energy Performance of Buildings Directive (EPBD) – The objective of this directive 
[2010/31/EU] is to promote the improvement of the energy performance of buildings 
within the Community, taking into account outdoor climatic and local conditions, as well 
as indoor climate requirements and cost-effectiveness.  

Digital building logbook (DBL) - A DBL is a digital repository for all building-related 
data on individual buildings, which facilitates information sharing within the construction 
sector,  and  between  building  owners  and  tenants,  financial  institutions  and  public 
authorities. 

Indoor environmental quality (IEQ) – A general indicator of the quality conditions 
inside  a  building.  It  most  commonly  refers  to  indoor  air  quality,  thermal  comfort, 
aesthetics, ergonomics, biophilia, acoustics and lighting. Several of these elements have 
a significant impact on our health, comfort, and productivity. 

Level(s)  -    a  new  European  approach  to  assess  and  report  on  the  sustainability 
performance of buildings, throughout the full life cycle of buildings. 

Lifecycle  assessment  (LCA)  –  The  methodological  framework  to  quantify  all 
environmental impact caused during the life cycle of a building.  

Long-term  renovation  strategies  (LTRS)  –  These  strategies  must  be  established 
and implemented by the Member States according to Article 2a of the EPBD to support 

21 

 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

the renovation of the national stock of buildings into a highly efficient and decarbonised 
building stock by 2050, and will form part of Member States’ integrated national energy 
and climate plans. 

Mandatory minimum requirements (MMR) – Examples of MMR for existing buildings 
include requiring a minimum EPC class for sale, rental or other property transactions or 
that a building must comply with a certain energy performance level by a given year .  

Minimum energy performance standards (MEPS) – also referred to as mandatory 
minimum requirement (MMR – see above), MEPS are regulations that mandate certain 
buildings  within  a  defined  territory  to  meet  a  certain  performance  standard,  by  a 
specified compliance date or according to natural trigger points in the building’s lifecycle 
(e.g. time of sale) 

MMR  model  -  The  principal  archetypes  of  mandatory  minimum  requirements, 
describing the different MMR design options, including policy design, targeted building 
typologies or trigger points.  

Operational  energy/carbon  use  -  The  energy/carbon  use  associated  with  energy 
used to operate the building (e.g. energy for heating and hot water)  

Policy package – The  policy package is a derived policy approach including a policy 
option, appropriate EU policy tools and a tailored enabling policy framework.  

Residential building – A building 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  as  a  non-residential  building  following  its  purpose-oriented  design.  The 
residential building category can be further divided, e.g. depending on the ownership 
and the tenure status. 

Whole-life carbon - Emissions from all lifecycle phases  of a building, encompassing 
both embodied and operational carbon emissions  

Whole-life carbon consideration – Taking into account all related emissions in  the 
decision-making process, such as BRP or renovation advice.   

22 

 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

1.  INTRODUCTION 

The latest review of the Energy Performance of Buildings Directive (EPBD) [2018/844] 
sets out to achieve a ‘highly energy-efficient and decarbonised building stock’ by 2050. 
The  directive  obliges  Member  States  to  develop  and  implement  long-term  renovation 
strategies (LTRS), including milestones and forthcoming policy measures to achieve the 
long-term  objective.  The  impact  assessment  of  the  EPBD  declared  that  mandatory 
minimum requirements (MMR) could have a significant impact on increasing renovation 
activity and trigger energy savings across the EU. It was, however, not retained in the 
preferred options due to concerns regarding practicality.  

The Renovation Wave strategy, published on October 14 2020, is comprehensive and 
far-reaching.  Its  premise  is  to  contribute  to  a  higher  2030  climate  target  and 
decarbonise the building sector, a wide range of policies, measures and tools must be 
put in place at all levels to overcome existing barriers and mobilise all actors, including 
citizens, local authorities, investors and the construction value chain. 

The Renovation Wave rightly highlights many different intervention points, with a clear 
timeline.  One  of  the  central  intervention  points  is  to  introduce  “mandatory  minimum 
energy  performance  standards  as  part  of  the  revision  of  the  Energy  Performance  of 
Buildings Directive (EPBD) by the end of 2021”.  

This  report  presents  the  findings  of  the  current  study  which  has  explored  the  scope, 
timeline and impact of an MMR framework at EU level. While relevant links are made to 
the Renovation Wave, and its provisions, throughout the report, it was largely developed 
before the Renovation Wave strategy was disclosed.   

Setting up MMR for the entire building stock (on a regional or country level), or specific 
parts of it (e.g. public or rental buildings), can be a very effective instrument to achieve 
fast and long-lasting emissions reductions.16 MMR can be designed to specifically target 
deep renovations and be aligned with the long-term objective for the built environment. 
The  best-known  existing  MMR  approach  is  the  Minimum  Energy  Efficiency  Standards 
introduced in England and Wales, where landlords are not allowed to rent out dwellings 
with an EPC class lower than E. Similar approaches exist in France (though not enforced 
yet), the Netherlands (EPC C for office buildings), in the Flanders region of Belgium (a 
mix of minimum requirements for building equipment and the envelope), as well as in 
the  United  States  where  cities  like  New  York  are  frontrunners  (with  carbon  emission 
budgets/thresholds for larger buildings).  

Practical implementation across the EU is, however, challenging at present. The energy 
performance certificates (EPC) framework17 would be the most obvious reference point 
for introducing MMR. But the comparability across Europe concerning the EPC, in terms 
of  general  availability,  calculations,  control  and  data  availability,  needs  further 
improvement. Subsidiarity issues also come with this instrument, suggesting that the 
EU  policy  can  be  a  framework  only,  leaving  enough  flexibility  for  Member  States’ 
implementation.18  

MMR  can  also  be  linked  to  various  trigger  points,  such  as  property  transfers  or  non-
energy renovation works.  According to Article 2a (1)b of the EPBD, Member States will 
have to identify cost-effective approaches to renovation, including potentially relevant 

16C40 (2019) “How to set energy efficiency standards for existing buildings”. C40 Cities Climate Leadership 
Group. (Available: Website) 
17  The  certificates  play  a  central  role  in  the  EPBD  [2010/31/EU]  as  EU  countries  are  asked  to  provide 
information on the certificates and inspection reports. In addition to purpose and objectives, the certificates 
should also disclose cost-effective ways and, where appropriate, available financial instruments to improve 
the energy performance of the building to the owners or tenants of the buildings.  
18  See  e.g.  European  Commission  (2016)  Impact  Assessment  of  the  EPBD  2016,  [SWD  (2016)  414  final] 
(Available: Online) 

23 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

trigger points in their LTRS. The LTRS are thus an opportunity for the Member States to 
consider this instrument and how to best introduce it19. 

The objective of this study is to analyse the relevance, feasibility, and possible scope of 
additional measures at EU level in favour of MMR. These may be related to sale, rental 
or  other property transactions based  on a minimum EPC class, but are not limited to 
this. They may also include accompanying measures that help to overcome barriers for 
implementing MMR related to practical implementation and subsidiarity. 

Existing MMR cases provide some useful learnings  

Figure 6: Jurisdictions analysed in Europe 

In  recent  years  MMR  for  existing  buildings  has  received  increasing  attention  as  a 
powerful policy tool to decarbonise the building stock in Europe and the USA. The MMR 
field  is  dynamic  and  continuously  developing  and  policymakers  have  designed  and 
implemented various forms of MMR in different regions of the world. The overview of 
cases  analysed  in  Europe  is  presented  in  Figure  6  and  Table  1  below.  Appendix  1 
provides an overview and in-depth analysis of MMR in Europe, the USA and Oceania.  

In  North-West  Europe,  the  most  common  trend  is  to  introduce  MMR  linked  to  EPCs, 
which fall in the category of ‘asset rating’20. Buildings should achieve a minimum EPC 
rating at specific trigger points in the building lifetime or by predefined years. Examples 
can be found in the Netherlands, Belgium, France and the UK. 

Policy  innovation  is  also  taking  shape  in  local  and  regional  jurisdictions.  In  Brussels, 
Belgium,  the  planned  MMR  is  setting  out  a  progressive  implementation  of  renovation 
measures based on a building renovation passport (BRP). In this passport, a stepwise 
approach tailored to a specific building is devised that outlines the required measures 
to  achieve  a  decarbonised  building  by  2050.  In  Baden-Württemberg,  Germany,  they 
have  introduced  a  renewable  heating  obligation,  requiring  building  owners  to  get,  at 

19 BPIE’s (2020) review of the Member States’ LTRS shows “that Member States need to immediately step up 
effort to rapidly decarbonise the building stock. Many Member States still do not seem to prioritise action in 
the  building  sector,  which  is central  to climate  mitigation and  to  improving  living  conditions  of  Europeans, 
with the urgency that is needed”. (Available: Online).  
20  Asset  rating  determines  the  energy  performance  of  buildings  based  on  calculated  estimates,  whereas 
operational rating determines performance on actual energy consumption. 

24 

 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

least, 15% of their heating from renewable energy sources. The requirement is triggered 
when the individual heating systems is old and needs to be replaced21.  

Name/description of 
requirement 
Mandatory progressive 
implementation of 
renovation steps 

Mandatory energy 
consumption reductions 
(PLAGE) 

Minimum energy 
performance standard 
for all tertiary 
buildings22  

Location 

Brussels, 
Belgium 

Building 
type 
Residential 

Metric 

Asset rating 

Effective/ 
Enforced 
2030 

Compliance 
category 
Enforcement 
calendar 

Brussels, 
Belgium 

Non-
residential 

Operational 
rating 

2019 

Enforcement 
calendar 

Flanders, 
Belgium 

Non-
residential 

Asset rating*  2030 

Change of 
owner 

Minimum energy 
performance standard 
for residential buildings  

Flanders, 
Belgium 

Residential 

Asset rating 

2021 

Minimum quality 
standards for basic 
comfort, safety and 
health  

Travaux embarqués 
(embedded work) 

Minimum energy 
standard  

Flanders, 
Belgium 

Residential 

Asset rating 

2021 

France 

All  

n/a 

2017 

France 

Residential 

Asset rating 

2028 

Tertiary Renovation 
Decree 

France 

Non-
residential 

Operational 
rating 

2030 

Minimum Energy 
Efficiency Standard 

England and 
Wales 

Residential 

Asset rating 

2018 

Minimum Energy 
Efficiency Standard 

Scotland 

Residential 

Asset rating 

2020 

Minimum standard for 
all office buildings 

Netherlands 

Renewable heating and 
efficiency obligation 

Germany, 
Baden 
Württemberg 

Non-
residential 

Residential 
and most 
non-
residential 

Asset rating 

2023 

Asset rating 

2008 (with 
updates 
2015) 

Table 1. Overview of the MMR cases in Europe 

Change of 
owner 

Complaints 
by tenants  

Implementat
ion of other 
works 

Enforcement 
calendar/ 
change in 
tenancy 

Enforcement 
calendar 

Change in 
tenancy/Enfo
rcement 
calendar 

Change in 
tenancy/Enfo
rcement 
calendar 

Enforcement 
calendar 

Trigger point 

21 Pehnt, M et al. (2019) Evaluating the renewable heating and efficiency obligation for existing buildings – 
insights into the mechanisms of mandatory building requirements. ECEEE summer study. (Available: Online)  
22 All non-residential and non-industrial buildings. 

25 

 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Lessons learned from the case studies  

MMR  are  already  existing 
forms,  which  shows  the 
in  many  shapes  and 
flexibility/adaptability  of  this  policy  concept.  To  allow  for  a  comparison,  MMR  can  be 
categorised  based  on  characteristics  like  the  enforcement  framework,  metrics  used, 
trigger points, awareness and building segments targeted,  (see these characteristics 
described  for  several  case  studies  in  Appendix  1).  The  following  paragraphs  are 
summarizing the main lessons learned from existing cases. 

Metric  

The most common metrics are energy performance (kWh/m2) and carbon performance 
(CO2/m2). The main difference is that the energy performance metric is not dependent 
on the fuel mix, while the carbon metric is aligned with long-term climate objectives. 
While energy performance is the most common metric, especially in Europe, New York 
City’s MMR is targeting carbon emissions derived from actual energy consumption. Table 
2 below summarises some pros and cons of different approaches.  

In the EU, the EPC label is commonly used as a proxy for the energy efficiency rating 
(see the UK, France and the Netherlands). Similarly, in the US, the Energy Star score is 
used in several jurisdictions to indicate the performance level.  

Approach 

Pros 

Cons 

Energy 
consumption 

use 

Can 
established 
programs  such  as  the  EPC 
and American ENERGY STAR 
rating.  Many  users  are 
already  familiar  with  these 
metrics and tools. 

It  only  addresses  energy  use, 
harder  to  develop  targets  that  can 
achieve  the  long-term  objectives 
(i.e. a decarbonised sector).  

GHG emissions  Addresses  the  objective  of 
reducing  GHG  emissions. 
Easier  to  set  and  align  with 
long-term goals. 

If  emissions  from  the  grid  are 
included  in  the  calculations,  this  is 
typically  nothing 
the  building 
owners can address.   

efficiency 

Enables  more  flexibility,  as 
energy 
and 
renewables can be combined 
to  cost-optimally  reach  the 
objective.  

Could 
energy 
de-emphasize 
efficiency  if  “offsets”  are  widely 
available. 

Table 2: Pros and cons of the most common performance standard approach. Source: ACEEE, 
202023.  

One underlying issue is whether the metric should be based on measured energy and 
carbon use (i.e.actual consumption) or an asset score (i.e. theoretical calculation). The 
operational metric is heavily influenced by user behaviour, which can change with new 
owners, but also reflects the actual situation. The benefit of an asset score is that the 
comparison between buildings becomes fairer,  even though the actual energy/carbon 
use  can  differ  quite  substantially.  Asset  score  is  most  used  in  the  EU  (commonly 
underlying the EPCs), yet there are exceptions like the French ‘Décret Tertiaire’, which 
sets  targets  based  on  measured  consumption,  for  the  targeted  tertiary  buildings. 
Measured energy/carbon use is the preferred metric in the US.  

23 Nadel, S & Hinge A (2020) Mandatory Building Performance Standards: A Key Policy for Achieving Climate 
Goals. ACEEE (Available: Online) 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

While this study focuses on whole-building MMR, some minimum standards are defined 
as the presence of a minimum set of building fabric and heating system measures. 

Monitoring and enforcement  

The requirement must be perceived as impartial and rational (and achievable?). Action 
from building owners might be limited if the enforcement is perceived as flawed.  

A database of all buildings and their performance enables a better compliance check. In 
Boulder, the landlords need to renew their license every four years and were given two 
license-renewing-cycles  to  comply24.  The  EPC  databases  could  be  used  to  check 
compliance in the EU but need to cover most buildings and be up-to-date.  

A lack of resources and know-how within the responsible local authorities can limit the 
impact  of  the  requirement.  In  the  UK,  the  practical  challenges  in  identifying  non-
compliant properties, contacting landlords, and resourcing the activity make it difficult 
for local authorities to enforce the MEES efficiently. The impact has been hampered by 
insufficient  technical  capacity  (no  database  to  identify  non-compliant  landlords  and 
properties) and lack  of  financial resources (not able to cover the enforcement costs), 
which  left  some  local  authorities  incapable  of  properly  enforcing  the  minimum 
standard25.  The  evidence  also  suggests  that  this  is  easily  solvable  through  financial 
support and capacity building programmes for the local (implementing) bodies.  

The penalty of not complying ought to be high enough to discourage non-compliance. 
The penalty can be monetary, with a standard penalty or concerning the magnitude of 
the violation (i.e. kWh or CO2 exceeding the minimum threshold), or operational, such 
as not being able to use the dwelling until it meets the standard.  

Trigger points  

A  trigger  point  refers  to  a  specific  date  or  event,  at  which  the  building  owner  must 
comply with the defined requirement. The most common trigger point for compliance is 
a specific date by which the buildings must comply with the standard. Compliance can 
also be based on trigger points in a building’s life cycle, as in the German Renewable 
Heating  Obligation,  in  which  the  building  owner  ensure  the  renewable  heating  share 
exceeds 15% when the heating system is scheduled to be updated. Besides, the trigger 
point  could  link  to  complaints  by  tenants,  as  in  Flanders,  where  the  pointing  out  of 
inadequate indoor environment could force the landlord to carry out certain measures.  

Awareness  

Limited awareness and understanding of the required actions for compliance or about 
certain exemptions, can adversely influence the effectiveness of MMR. In England, 35% 
of the landlords with the lowest EPC labels (E, F and G) were “not at all aware” of the 
requirement26.    One  reason  for  the  lack  of  awareness  for  MEES  in  the  UK  relates  to 
insufficient communication and awareness-raising activities. This is partially the result 
of the large administrative burden.27  To increase awareness the UK government has 
issued  several  guidance  documents  for  landlords  on  complying  with  the  minimum 

24  Sunderland  et  al.  (2020).  “Filling  the  policy gap:  Minimum  energy performance  standards  for  European 
buildings”. RAP. (Available: Online)  
25  RSM  (2019)  Enforcing  the  Enhancement  of  Energy  Efficiency  Regulations  in  the  English  Private  Rented 
Sector. (Available: Online)  
26  BEIS  (2020)  Evaluation  of  the  Domestic  Private  Rented  Sector  Minimum  Energy  Efficiency  Standard 
Regulations. (Available: Online)  
27  Sayce,  S  &  Marji  Houssain,  S.  (2020).  “Minimum  Energy  Efficiency  Standards  (MEES):  one  year  on:  A 
Progress Report”. (Available: Online)  

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
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standard, thereby informing them of the requirements, funding options and the possible 
penalties, as well as providing examples.28 

While  the  large  real  estate  investors  will  be  aware  of  an  MMR,  adapt  their  portfolio 
accordingly, the small private landlords might not.   

In addition to extensive awareness-raising, regular sharing of best practices (e.g. what 
measures  did  my  neighbour  implement)  and  progress  would  incentivise  compliance. 
Details  on  improvements  made  to  various  types  of  single-family  buildings  can  be 
published digitally so potential new owners have ready access to information that will 
support planning future building renovations. This is part of a variety of complementary 
programmes (including technical and financial support) to motivate property owners to 
achieve the energy efficiency targets for the housing sector.29 One-stop shops could be 
a good platform to communicate with property owners as well. Regional one-stop-shops 
are appearing throughout Europe to assist the regional decarbonisation effort, such as 
Oktave  in  Grand  Est  (France),  SuperHomes  in  the  Tipperary  region  (Ireland)  and 
RenoWatt in Wallonia (Belgium).  

Lead time  

Most of the MMR offer lead times of 5-10 years to allow the building owners to plan for 
compliance, as well as signal to market actors the need to adapt. Thereby early impact 
can be facilitated, which can be further leveraged through financial incentives for early 
compliance. In the Netherlands, even though compliance will only be enforced by 2023, 
early notification  of  the programme has  already set in motion a significant change in 
banks’  lending  behaviours  and  an  increase  in  investment  in  the  renovation  and 
transformation  of  commercial  properties.30  The  Dutch  government  has  taken  several 
measures  to  make  this  happen.  They  developed  an  online  tool  that  enables  building 
owners to explore investment costs, annual savings, payback times and CO2 savings as 
guidance  to  meeting  the  office  building  performance  standard  currently  in  place.  In 
addition  to  this,  the  Dutch  government  has  certified  energy  advisors  to  assess  and 
recommend  improvements  and  has  established  a  grant  that  covers  the  cost  of  this 
advice. 

Financial support 

Providing  financial  support  and  linking  the  requirement  with  existing  funding 
mechanisms might be an additional motivator for property owners to comply with MMR. 
Furthermore,  a  comprehensive  framework  of  public  subsidies,  financial  incentives  is 
fundamental for the successful and equitable implementation of an ambitious renovation 
strategy.31  An  illustrative  case  in  France,  where  the  national  government  has 
implemented  a  variety  of  loans,  grants  and  refunds  to  help  property  owners  achieve 
MMR in the Climate and Energy Law.32 The UK initially also had financial support, with 
the  pay-as-you-save  finance  initiative  called  Green  Deal  Finance.  The  government 
withdrew  its  support  as  part  of  the  Green  Deal  abolishment.33  In  Boulder,  Colorado, 
nearly  US$1  million  was  invested  in  improving  rented  housing  through  rebates. 

28  Guidance  Website  Domestic  Private  Rented  Property  (2017).  Government  of  the  United  Kingdom. 
(Available: Online)  
29 Nadel, S & Hinge A (2020) Mandatory Building Performance Standards: A Key Policy for Achieving Climate 
Goals. ACEEE (Available: Online) 
30 Nadel, S & Hinge A (2020) Mandatory Building Performance Standards: A Key Policy for Achieving Climate 
Goals.  ACEEE  (Available:  Online)  &  Sunderland  et  al.  (2020).  “Filling  the  policy  gap:  Minimum  energy 
performance standards for European buildings”. RAP. (Available: Online) 
31  Sunderland  et  al.  (2020).  “Filling  the  policy  gap:  Minimum  energy  performance  standards  for  European 
buildings”. RAP. (Available: Online) 
32 Nadel, S & Hinge A (2020) Mandatory Building Performance Standards: A Key Policy for Achieving Climate 
Goals. ACEEE (Available: Online) 
33 Ibid 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Combined with technical assistance, this has led nearly all 23,000 licensed rental units 
to comply with the energy efficiency standard.34 

Financial  support  can  also  be  used  to  make  the  requirement  more  palatable  for  key 
stakeholders.  The  review  of  existing  cases  shows  that  the  requirement  is  generally 
accompanied  by  financial  support  (grants,  low-interest  loans)  and  technical  support 
(such as free energy advice). 

•  The MEES in England and Wales was one part of the Green Deal package, which 
also included free energy advice and the opportunity to pay for energy efficiency 
measures through savings on future energy bills (i.e. on-bill financing).  
•  The planed MMR in Scotland will be accompanied by financial and technical 

support for private homeowners. This includes free advice, interest-free loans, 
and extra subsidies for low-income households.35 

•  The Dutch MMR for office buildings is supported by technical assistance to help 
the owners to comply with the requirement. Additional support includes grants 
for energy advice, tax deductions for the renovation investment,, green 
investment allowances and green loans with preferential interest rates.36  
•  The French MMR, which sets a minimum standard at EPC E for all residential 

buildings, is accompanied by several support programmes, including the Energy 
Transition Tax Credit (CITE), interest-free eco-loans, the Better Living (Habiter 
Mieux) subsidy programme, the regional energy renovation platforms for 
technical assistance, and an Energy Renovation Guarantee Fund that provides 
government-backed loans to low-income households.37  

Targeted building segments   

The reviewed cases target different building typologies, based on their use or size. In 
the  EU,  the  divide  is  typically  between  residential  and  non-residential  buildings,  with 
most implementing Member States have implemented, or are planning to implement, 
two  versions  of  the  MMR  for  the  different  typologies  (see  the  UK,  France,  Flanders, 
Belgium).  This  binary  approach  can  cause  some  uncertainty  as  many  buildings 
incorporate  both  residential  and  non-residential  dwellings.  In  the  US,  the  size  of  the 
building in terms of floor area (or in terms of consumption?) (i.e. several MMR focus on 
“larger buildings”) is the determining factor.  

The  analysis  of  the  cases  shows  that  there  are  many  ways  public  authorities  can 
implement  and  enforce  MMR  for  existing  buildings.  A  common  objective  of  almost  all 
cases is to mitigate the climate impact and reduce the energy need from the building 
sector. Most cases in the US target non-residential and larger building owners, while the 
focus is more evenly split in the EU between residential and non-residential buildings. 

Appendix 1 includes additional information and case studies.  

What do the stakeholders think?  

The  findings  of  this  study  have  been  guided  by  stakeholder  input  and  feedback.  113 
stakeholders answered the detailed questionnaire on MMR and its potential, while over 
100  participants  joined  the  online  workshop.  The  stakeholders  represent  different 
sectors and professions, including building owner representatives, tenant organisations, 

34 Ibid  
35  Sunderland  et  al.  (2020).  “Filling  the  policy  gap:  Minimum  energy  performance  standards  for  European 
buildings”. RAP. (Available: Online) 
36 Nadel, S & Hinge A (2020) Mandatory Building Performance Standards: A Key Policy for Achieving Climate 
Goals. ACEEE (Available: Online) 
37 Ibid 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

installation manufacturers, construction sector, financial sector, public administration, 
(energy) service providers, civil society, and research institutes.  

Three-quarters  (74%,)  of  survey  respondents  say  MMR  should  focus  on  the  overall 
energy performance  of  the building, while  more than half (53%) think MMR could be 
linked  to  certain  building  components.  50%  say  it  should  be  linked  to  the  building’s 
overall  climate  performance  (i.e.  cap  in  GHG/m2/year)  and  44%  think  it  should 
encompass whole-life carbon too.  During the workshop, support was more expressed 
for carbon efficiency as an MMR parameter because this aligns better  with long-term 
objectives and offers more freedom to end-users on how to fulfil the requirement.  

The stakeholders think the MMR can best be applied to the worst-performing buildings, 
excluding  heritage  buildings.  This  will  achieve  the  highest  impact  in  the  short  term. 
Additionally,  the  building  owners’  ability  to  comply  with  the  requirement  should  be 
considered.  The  most  widespread  view  (57%  of  respondents)  is  that  MMR  should 
encompass all building typologies. 

Most stakeholders want the MMR to include both progressive enforcement of milestones 
and  various  trigger  points,  something  reaffirmed  in  the  workshop  discussion.  In  the 
multiple-choice question on when the MMR should come into effect, most participants 
say MMR enforcement based on progressive milestones (66%) and trigger points (55%) 
are the best solutions. 

See more details in Appendix 2.  

30 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

2.  RESEARCH APPROACH  

The central aim of this study is to identify plausible ways for the European Commission 
to introduce MMR for existing buildings in the EU. In order to identify the best possible 
options,  the  potential  impact  and  feasibility  of  different  options  are  assessed  and 
discussed. Figure 7 gives an overview of the steps in the analysis, which are detailed 
and explained in this chapter.  

Figure 7: Research flow diagram 

Step  1:  Presentation  of  the  most  crucial  policy  considerations  related  to  MMR  for 
existing buildings,  including the role in achieving 2050 target, interlinks with  existing 
and  future  strategies,  wider  policy  framework  conditions,    the  vehicles  for 
implementations,  and  various  policy  design  features.  The  key  aspects  of  each 
consideration are described, and the pros and cons are highlighted.  

Step 2: Identification and presentation of the most suitable MMR models. The ‘models’ 
are archetypes of the most realistic ways MMR can be implemented, in terms of policy 
objective,  metrics,  targeted  building  segments  and  compliance  mechanisms.  The 
potential impacts and feasibility of these different models are discussed.  

A qualitative impact and feasibility assessment are presented for each model, including:  

•  The techno-economic impacts are discussed based on the impacts of the 

model on the renovation rate, renovation depth, renovation quality and cost-
optimality of the triggered renovations. 

•  The socio-economic impacts are discussed in terms of fairness, the split-

incentive dilemma and access to housing. 

•  The impacts on EU climate targets are discussed based on the theoretical 

capacity of the model to contribute to EU climate targets for 2030 and the 
climate neutrality goal in 2050, whether the model integrates or supports 
renewable energy supply to buildings, and sustainability in terms of embodied 
carbon. 

•  The feasibility assessment looks at the practicability for a theoretical 

implementing body to introduce the specific MMR model, through the indicators 
of “ease of compliance”, “simplicity” and “maturity of tools”. The “ease of 
compliance” refers to how easy it would be to set up a compliance system for 
this MMR model and “simplicity” is how easy it is for the public body to explain 
(and end-users to understand), while the “maturity of tools” refers to the 
availability of existing instruments (e.g. EPC schemes) that can facilitate the 
implementation of the foreseen MMR model.    

The impact and feasibility assessment are presented in radar charts (see an example in 
Figure 8). The score, based on evaluation of existing cases and expert views, indicates 
the potential of the models where 0 = poor, 1 = moderate, 2 = good and 3 = excellent. 
An in-depth analysis of the criteria is provided in an appendix.   

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Impact and Feasibility of the MMR Models 

Renovation rate

Ease of compliance

Simplicity

Maturity of tools

3

2

1

0

Renovation depth

Renovation quality

Cost-optimality

Renewables

Split incentive

Carbon neutrality
2050

Acces to housing

2030 GHG milestone

Figure 8: Example feasibility and impact assessment of MMR model 

A quantitative impact assessment is also included to support the discussion of the main 
features of the MMR models (see example in Figure 9). The evolution of the final energy 
demand for heating and the related GHG emissions is modelled for each MMR  model, 
considering  the  residential  building  stock  of  two  Member  States  (France  and 
Germany)38,  which  were  chosen  because  of  the  available  data  and  the  size  of  the 
countries. Assumptions are further detailed in the Appendix.   

Figure 9: Exemplary quantitative impact assessment 

Step  3:  Based  on  the  conclusions  of  Step  1  and  Step  2,  four  policy  pathways  are 
developed  showing  four  reasonable  ways  the  EU  can  support  the  uptake  of  MMR  for 
existing  buildings.  The  pathways  are  illustrated  through  timelines  (See  Figure  10), 
exemplifying  when  an  EU-wide  MMR  can  become  reality,  how  the  EU  can  regulate  or 
support an introduction of MMR, and what supportive measures are needed to achieve 
this.  

38 Given the data availability, it was not possible to perform the modelling on the complete EU building stock 
within the timeframe of the present study. 

32 

 
 
 
 
 
 
 
 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Figure 10: Illustrative policy pathway timeline 

Step 4: The impact and feasibility assessment are performed throughout Step 2 and 
Step 3, and then summarised in Step 4. The impact and feasibility are first assessed for 
the MMR models, only taking into account the types of MMR. This analysis allows for a 
fair comparison between the different ways MMR can be implemented.  The discussion 
on  the  policy  pathways  broadens  the  assessment  to  also  include  the  policy  process: 
when and how can it be introduced? what is the optimal combination of different models? 
and what supportive measures are needed?  

Table 3 outlines the impact and feasibility parameters.  

Impact parameters 

Feasibility parameters 

MMR model 

Renovation rate 
Renovation depth 
Renovation quality39 
Cost-optimality 
Split incentives 
Access to housing and 
affordability 
2030 GHG milestone 
Carbon neutrality by 2050 
Renewables 

Applicability of existing 
policy instruments 
Simplicity 
Ease of compliance  

Impact parameters 

Feasibility parameters 

Policy pathways  Emission reductions (CO2) 
Final energy consumption 
reduction (kWh) 

Enabling measures  
Operationalisation based on 
timelines 
Subsidiarity, proportionality 

Step 5: Conclude the main lessons learned for the EU to consider.  

Table 3. Impact and feasibility parameters 

39  Refers  to  the  reliability  of  the  renovation  measures  and  the  extent  to  which  the  building  performance 
improves as intended. 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

3.  STEP 1: POLICY CONSIDERATIONS  

This chapter outlines the main policy considerations around a European implementation 
of MMR for  existing buildings. It shows that MMR is a flexible instrument that can be 
easily integrated into a wide range of existing and planned national policy contexts and 
can fit into the existing and planned EU climate and energy frameworks.  

Figure 11: Research flow diagram - Step 1 

The first section discusses how MMR can connect with existing and pending strategies, 
such as the Renovation Wave and the Circular Economy Action Plan. The second section 
describes the role of a wider policy framework for the efficiency of MMR, and especially 
financial support, skills in the value chain and awareness by all stakeholders. The third 
section  discusses  the  role  of  EPCs,  building  renovation  passports  and  digital  building 
logbooks  as  an  important  ground  for  the  implementation  of  MMR.  The  last  section 
describes  the  key  design  options  of  MMRs,  including  metrics,  building  typology, 
compliance, and trigger points.  

3.1.  Contributing to the 2050 target  

More than 220 million building units, representing 85% of the EU’s building stock, were 
built before 2001. 85-95% of the buildings that exist today will still be standing in 2050. 
Decarbonising the building stock is a necessity for the EU to become a net-zero economy 
by 2050. To increase the rate and depth of building renovation to achieve this objective, 
policy needs to provide the right incentives, provide the needed framework conditions 
and remove barriers to renovations. The existing EU and national policies have shown 
to be insufficient40. This includes the existing MMR cases in Europe, which either has not 
yet been implemented or have not yet proven to be successful enough in triggering a 
large  number  of  renovations41  or  has  not  been  in  implementation  (yet  or  for  long 
enough) to allow evaluation. Despite this, MMR for existing buildings stands out as one 
of the few policies that could achieve effective decarbonisation of the building stock.  

The  MMR  can  support  the  EU’s  decarbonisation  effort  by  establishing  the  2050 
destination and by raising the lower bar.  

•  The MMR can be used to send a signal that anchor investors and business 

expectations, especially on the real estate market, clearly outlining what is 
required from the buildings. The requirement should already now declare what is 
the long-term objective for each building segment, or buildings types, by 2050 
to allow the market to adapt. Some real estate investors would steer their 
investments towards future-proof buildings, i.e. the buildings complying with the 

40 See European Commission’s assessment of National Energy & Climate Plans, which concludes “as far as 
energy efficiency is concerned, although the ambition level is higher than in the draft NECPs, the cumulative 
impact of the different NECPs still falls short of the existing energy efficiency target of 32.5%.” 
41  See  e.g.  RSM  (2019)  Enforcing  the  Enhancement of  Energy  Efficiency Regulations  in  the  English  Private 
Rented Sector. (Available: Online) 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

• 

2050 standards. The 2050 destination could also be aligned with green 
mortgages to further incentivise frontrunners.  
It would also act directly on renovating the worst-performing buildings. The 
requirement would effectively overturn many of the barriers to renovation and 
ensure that owners improve their buildings.  

3.2.  Relation to existing and new strategies 

In  the  Renovation  Wave  strategy,  the  European  Commission  stated  it  will  “propose 
mandatory minimum energy performance standards as part of the revision of the Energy 
Performance  of  Buildings  Directive  (EPBD)  by  the  end  of  2021”.  Beyond  the  EPBD, 
synergies can be made with other initiatives, including the New Industrial Strategy for 
Europe, the SME Strategy for a Sustainable and Digital Europe, as well as the Circular 
Economy  Action  Plan  and  disclosures  relating  to  sustainable  investments  and 
sustainability risks.  

The Renovation Wave strategy aims “to at least double the annual energy renovation 
rate  of  residential  and  non-residential  buildings  by  2030  and  to  foster  deep  energy 
renovations. Mobilising forces at all levels towards these goals will result in 35 million 
building units renovated by 2030.”  The strategy sets out measures to solve several key 
challenges,  such  as  market  failures  (e.g.  split  incentives,  the  mismatch  between 
financing  needs  and  financial  products  offered),  lack  of  expertise  (e.g.  insufficient 
workforce, lack of digital and green skills) and regulatory barriers (e.g. piecemeal and 
overlapping policies and laws, insufficient compliance with existing requirements).  

MMR for existing buildings is a cornerstone in the Renovation Wave strategy and is also 
accompanied  by  a  wider-policy  framework,  as  being  stressed  in  this  study,  including 
financial  support,  capacity  building,  a  2050  roadmap  for  whole  life  carbon  reduction, 
Level(s), digital building logbook, and the building renovation passport.   

The  New  Industrial  Strategy  for  Europe42  launched  by  the  European  Commission 
addresses the twin challenges of the green and the digital transformation of the EU’s 
industry sector. It has been set out as one of the main enablers and accelerators for the 
European Green Deal. Its three key priorities are maintaining the European industry’s 
global  competitiveness  and  a  level  playing  field;  making  Europe  climate-neutral  by 
2050; and shaping Europe’s digital future. One of the focal points of the EU Industrial 
Strategy  is  to  address  the  sustainability  of  construction  products  and  to  improve  the 
energy efficiency and environmental performance of built assets – in essence, striving 
for a more sustainable built environment.  

This  strategy  could  provide  an  important  opportunity  to  link  with  the  introduction  of 
MMR.  Small  and  medium-sized  enterprises  (SMEs)  are  essential  in  making  MMR 
operational. The Renovation Wave also emphasises the role of SMEs and digitalisation 
and  suggest  several  provisions  to  improve  the  European  competitiveness  through 
digitalisation,  including  “Horizon  Europe,  Digital  Innovation  Hubs  and  Testing  and 
Experimentation Facilities”. The European Commission’s SME Strategy for a Sustainable 
and Digital Europe43 will further support the further development of SMEs’ role in the 
green and digital transition.  

42 Communication from the Commission to the European Parliament, the European Council, the Council, the 
European Economic and Social Committee and the Committee of the Regions. A New Industrial Strategy for 
Europe, COM(2020) 102 final,  
43 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions. An SME Strategy for a sustainable and digital Europe, 
COM(2020) 103 final. 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Linked to this strategy is the Circular Economy Action Plan44 adopted on 11 March 2020 
by  the  European  Commission.  The  Action  Plan  was  announced  the  day  after  the  EU 
Industrial Strategy was presented, to mobilise the industrial sector. The ‘Communication 
on A New Circular Economy Action Plan’ has identified construction and buildings as one 
of  the  key  product  value  chains  in  which  comprehensive  and  coordinated  action  is 
needed.  Greater  material  efficiency  could  significantly  reduce  current  GHG  emissions 
from  material  extraction,  manufacturing  construction  products,  construction  and 
renovation of buildings. The Strategy for a Sustainable Built Environment (planned for 
2021)  will  ensure  that  action  across  several  policy  areas  is  coherent.  It  will  promote 
circularity principles throughout the lifecycle of buildings, through  e.g. addressing the 
sustainability performance of construction products in the context of the revision of the 
Construction Products Regulation, developing digital logbooks for buildings to monitor 
durability  and  adaptability,  and  using  the  Level(s)  tool  to  integrate  LCA  in  public 
procurement and the EU sustainable finance framework.  

The Circular Economy Action Plan could provide strong means to achieve the targets set 
by  MMR,  such  as  minimum  carbon  efficiency  requirements  for  existing  buildings,  by 
translating them into circular economy actions in some way. If linked to this Action Plan, 
the  implementation  of  MMR  could  greatly  benefit  from  the  support  provided  by  the 
European Commission in accelerating the transition to a circular economy, in terms of 
skills development, funds and other enabling measures.  

The EU taxonomy  framework published in 2020 establishes  criteria for determining if 
economic  activities  qualify  as  environmentally  sustainable.45  The  purpose  of  this 
regulation is to drive investments in sustainable alternatives. It states ‘The renovation 
of  existing  buildings  to  improve  their  energy  performance  makes  a  substantial 
contribution  to  climate  change  mitigation  by  reducing  energy  consumption  and  GHG 
emissions  for  the  remaining  operational  phase  of  the  buildings,  and  by  avoiding 
emissions that would be associated with the construction of new buildings.’ It requires 
a first step to integrating life cycle thinking, by requiring reporting on whole-life carbon 
for  large  new  buildings  and  including  whole-life  carbon  benchmarks  once  developed. 
The taxonomy is important because it can drive investments toward the long-term goal 
of  making  buildings  compliant  with  the  2050  target,  while  the  MMR  is  elevating  the 
bottom floor (i.e. the worst-performing buildings).  

The regulation on disclosures relating to sustainable investments and sustainability risks 
could potentially be relevant for MMR as it requires financial market actors to disclose 
sustainability risks and impacts. Given that real estate has a long tenure and can make 
up a significant asset class in investment portfolios, the sustainability risks and impacts 
emerging from these investments will need to be assessed and disclosed according to 
the  new  regulation.  As  a  consequence,  financial  market  actors  are  expected  to  look 
much  more  closely  at  the  activities  they  are  financing  and  investing  in.  The  need  to 
disclose  carbon-related  risks  and  massive  stranded  assets  will  hardly  make  non-
sustainable investments an attractive deal. This will further contribute to the accelerated 
value depreciation of assets that have not been improved as the market will increasingly 
recognise  that  inefficient  buildings  may  start  to  present  an  economic  and  regulatory 
risk.  

3.3.  Wider policy framework 

MMR introduction must be embedded in a wider policy framework, at the national level, 
to become successful. Each Member States will need to tailor its wider policy framework 

44 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions. A new Circular Economy Action Plan for a cleaner and 
more competitive Europe, COM(2020) 98 final. 
45 Regulation (EU) 2020/852 of the European Parliament and the Council. Establishment of a framework to 
facilitate sustainable investment, and amending Regulation (EU) 2019/2088.  

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

to  support  the  introduction  of  MMR,  as  much  of  the  success  of  the  implementation 
depends on national factors and specificities (see the section on existing cases).   

3.3.1.  Financial support programmes  

The European Commission estimates that to achieve the proposed 55% climate target 
by 2030, around EUR 275 billion of additional investments are needed per year46. The 
Renovation Wave is included in the European Green Deal, which together with the EU 
recovery plan unveil new funding opportunities for the renovation of the least efficient 
building stock. The upcoming long-term budget (2021-2027) can also be used to steer 
funds for this building renovation. 

The Recovery and Resilience Facility, which is currently under negotiation and which the 
European  Council  agreed  to  endow  with  EUR  672.5  billion,  37%  of  which  would  be 
targeted to climate-related expenditure, can support renovation investment and energy 
and resource efficiency-related reforms across the Member States. 

The Renovation Wave strategy outlines several provisions for “reinforced, accessible and 
more  targeted  funding”,  which  can  directly  or  indirectly,  support  the  introduction  of 
MMR:  

• 

•  The cohesion policy funds will remain the main source of EU public funding, from 
which millions of EUR are directed towards energy efficiency of the building 
stock. The Member States channel and directs these funds through Operational 
programmes, which could be used to support the objectives of an MMR. The 
Renovation Wave suggest that the programme objectives are derived from the 
national NECP and LTRS.  
InvestEU will act as a single EU-level investment support programme to provide 
technical assistance and financing backed by an EU budget guarantee to unlock 
private investments. The programme can enable energy service companies to 
offer energy performance contracting solutions, possibly enabling building 
owners to renovation beyond the minimum standard, with a small or no upfront 
cost. The programme is also available to support life cycle performance. 
•  The strategy document also concludes that “the Commission stands ready to 
advise Member States that are considering using revenues from the EU 
Emissions Trading System (ETS) and funding opportunities under the ETS 
Modernisation Fund as a source of funding for building renovation programmes, 
in particular for lower-income households.” Czechia is currently using its ETS 
surplus to offer energy renovation subsidies through the New Green Savings 
Programme. Similar programmes could be used to support renovations linked to 
MMR.   
“Existing energy efficiency obligation schemes under Article 7 of the Energy 
Efficiency Directive can be effectively used for all types of buildings to engage 
new intermediaries like utilities, deliver technical expertise and offer aggregated 
services to reduce transaction and administrative costs”. Several existing one-
stop-shops are directly (e.g. ProEnergy Homes in Ireland) or indirectly (e.g. 
Heero in France) utilising the obligation to offer attractive renovation offers.  
“A renovation wave can also be an opportunity to spur the development of green 
loan and mortgage financing. An upgraded system of EPCs demonstrating 
efficiency gains will allow banks and other financial institutions to offer credit 
and mortgage financing to green their portfolios and to pool buildings as 
collateral for the issuance of covered bonds”. On the same note, “the 
Commission is developing the EU Taxonomy, with technical screening criteria for 
the buildings sector, to direct private capital towards sustainable investments in 

• 

• 

46 See “Identifying Europe’s recovery needs”, SWD(2020) 98 final and “Stepping up Europe’s 2030 climate 
ambition Investing in a climate-neutral future for the benefit of our people”, SWD(2020) 176 final. 

37 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

energy and resource renovation, relying on EPC and nearly zero-energy building 
standards”.  Energy efficiency mortgages and green loans could encourage 
building owners to implement additional renovation measures than what the 
minimum standards would require. Many benefits can be attained if both 
systems are linked to the EPC schemes.  

The  current  EPBD  requires  national  governments  to  establish  LTRS  for  mobilising 
investment  in  the  renovation  of  the  national  stock  of  residential  and  commercial 
buildings, both public and private. All Member States had to provide their new LTRS to 
the  European  Commission  by  10  March  2020.  As  a  crucial  part  of  the  LTRS,  Member 
States must support the mobilisation of investments into the renovation levels required 
to achieve the goals set by the directive. The LTRS should be used to holistically plan 
the  renovation  of  the  building  stock,  which  could  include  a  mix  of  MMR  for  existing 
buildings and targeted financial support.  

BPIE’s analysis of the LTRS shows that the Member States did not follow the structure 
of  Article  2a  or  the  Commission’s  guidance  when  it  comes  to  “mobilisation  of 
investments”, which comprises five specific dimensions:  most cases Member States did 
not present their financial measures according to these dimensions. The analysis also 
concludes  that  “while  Member  States  generally  provided  reasonable  details  on  their 
renovation policies (existing or proposed), few explicitly geared these towards achieving 
deep renovation”. 47 

While  financial  support  is  needed  for  all  concerned  building  owners,  special  attention 
should be put on two groups:  

•  Groups vulnerable to energy poverty: A considerable share of the worst-

performing building stock is owned/rented by people who are vulnerable to a 
cost increase. The financial support programmes should reduce the possible 
negative effect of MMR on this group.  

•  Real estate investors and owners considering deep renovations and/or early 

compliance: Building owners and investors should be incentivised to go beyond 
the minimum requirements, as defined by the MMR. This can be achieved 
through premiums for one-stage deep renovations that directly meet the long-
term requirements, which can be specified in the EU taxonomy or certain 
climate/green bonds48. As with MMR requirements, the trick with climate bonds 
is that the threshold is gradually tightened, so the issuer of the bond needs to 
continuously demonstrate that the underlying asset pool meets the new climate 
criteria.  

3.3.2.  Skills in the construction value chain  

One of the main challenges for driving transformational change within the construction 
sector is the transition and consolidation of the workforce.49 A well-equipped and trained 
workforce is required to realise the building decarbonisation objectives, as set out in the 
EPBD  and  the  Renovation  Wave.  For  example,  new  techniques  like  industrial 
prefabrication,  building  information  modelling  (BIM),  and  industrial  3D  printing  are 
innovations  that  require  different  skills  from  traditional  construction  works.  Similarly, 
different skills are required to guide a building owner towards a net-zero energy/carbon 
renovation than issuing an EPC. The transition to climate-neutral building stock will also 
demand an increase in green and circular skills. Building sector federations should play 

47 BPIE (2020) A review of EU Member States’ 2020 Long-Term Renovation Strategies. (Available: Online)  
48 Climate or green bonds raise funds for climate oriented projects, including investments in renewables and 
energy efficiency in buildings. Aligning the specifications of these bonds with EU’s long-term climate objective, 
would funnel investments towards this objective.   
49  BPIE  &  I2-4C  (2016).  “Driving  Transformational  Change  in  the  Construction  Value  Chain”.  (Available: 
Online) 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

a  defining  role  in  this,  besides  stimulus  and  education  programmes  from  public 
authorities.  

The European Construction Sector Observatory also acknowledges that the availability 
of higher- and lower-skilled workforce is amongst the most significant obstacles for the 
future  development  of  the  building  sector.50  In  a  changing  construction  sector,  the 
transformation  of  the  existing  workforce  through  the  acquisition  of  new  skills  is 
essential.  

3.3.3.  Public awareness and a simple renovation journey  

Public  awareness,  understanding  and  acceptance  of  MMR  are  key  for  effective 
implementation. People should be aware of the requirement itself as well as the purpose 
behind it. Lessons learned from a couple of the existing cases show that it is difficult to 
get the right information out there. Authorities at all governance levels (EU, national, 
regional and local) should, therefore:  

•  Deliver communication campaigns targeted at the building owners that will be 
affected by the requirement. The information must be easy to grasp when 
explaining the reasons behind the requirements and the associated benefits, as 
well as when and how to comply, including links to energy experts, one-stop-
shops or financial support programmes.  

•  Continue to support the development of one-stop-shops, and other renovation 

services, to simplify the process of complying with MMR. One-stop-shops, public 
and private models alike, are market-driven and will adapt their services to 
MMR. 

3.4.  MMR needs a facilitating infrastructure  

The policy infrastructure in which MMR will be launched needs to be able to carry the 
requirement.  This  section  discusses  the  role  of  three  central  instruments,  which  can 
facilitate better implementation of an EU MMR framework:  

•  EPCs, which are the most obvious benchmark for MMR, indicate the performance 

level of a building.  

•  Building renovation passports, which set out a staged renovation roadmap for an 

individual building and thus help the building owners to avoid technical and 
economic lock-ins  

•  Digital building logbooks, a digital repository for all building-related data, which 
can allow public authorities to monitor the progress and enable recycling of 
materials.  

3.4.1.  Energy performance certificates 

All  EU  Member  States  have  now  implemented  national  EPC  regimes.  Different 
implementation approaches have led to a diverse set of instruments, varying in terms 
of  scope  and  available  information,  resulting  in  some  cases  in  limited  reliability, 
compliance, market penetration, availability and acceptance.  

The most important feature of MMR for existing buildings is that  they are comparable 
and  based  on  reliable  calculation  methodologies.  EPCs  have  struggled  with  reliability 
and comparability since their introduction. When two identical buildings receive different 
EPC  ratings,  due  to  inconsistencies  in  the  EPC  methodology,  poorly  qualified    EPC 

50  ECSO.  (2020).  “Analytical  report.  Improving  the  human  capital  basis”.  European  Construction  Sector 
Observatory. (Available: Online)  

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

issuers, or something else51, it hampers the instrument’s impact and people’s trust in 
them.    

EPCs  themselves  have  not  been  effective  in  driving  renovations.  Cost  and  time 
constraints often result in EPCs containing poorly-tailored recommendations. Evidence 
suggests  that  an  onsite  visit,  including  the  chance  for  the  user  to  interact  with  the 
expert, influences the perceived quality and reliability of the recommendations and the 
chance that they will be implemented.52 The EPC can also be integrated with the building 
renovation passport. 

The Renovation Wave strategy envisages the EPC schemes to be  the enabling vehicle 
for implementation of an MMR. It also recommends several provisions to improve the 
existing EPC schemes, focusing on their reliability, market penetration and availability. 
The  strategy  proposes  to  “introduce  a  stronger  obligation  to  have  EPC  alongside  a 
phased introduction of mandatory minimum energy performance standards for existing 
buildings”.  Furthermore,  it  notes  that  “the  Commission  considers  that  EPC  and  their 
availability in databases improve  the transparency of the performance of the building 
stock.  At  the  building  level,  EPCs  inform  about  energy  performance,  the  share  of 
renewables  and  energy  costs.  At  district,  regional,  national  or  Union  level,  they  are 
crucial for identifying the worst-performing buildings in urgent need of renovation.”  

Metrics 

The  existing  EPC  ratings  are,  in  most  Member  States,  difficult  for  building  owners  to 
fully grasp. EPC methodologies tend to be 
complex  and  rarely  properly  explained, 
making it difficult for the building owner to 
understand  how  different  measures  will 
influence their rating.    

EPCs have been developed to display the 
energy  performance  rating  of  a  building, 
typically  in  annual  primary  energy  use 
(i.e.  kWh/m²/year).  Among  the  27  EU 
Member  States,  12  have  adopted  the 
methodology  exclusively  based  on  asset 
rating (theoretical energy use), while the 
other  countries  integrate  both  the  asset 
rating and measure energy use, in various 
calculation  methodologies. 
Several 
Member  States  apply  both  the  asset  and 
which  makes 
measured 
comparability  between  different  EPC 
labels,  with  different  methodologies, 
difficult.    While  EPC  methodologies  still 
differ  across  the  EU,  the  amended  EPBD 
[2018/844/EU] requires Member States to 
‘describe 
calculation 
methodology 
the  national 
following 
annexes  of  the  overarching  standards’ 
set  out  in  the  ISO  52000  series,  which 
could  be 
towards 
harmonisation of methodologies.  

first  step 

national 

energy, 

their 

the 

Figure 12: Total number of registered EPCs per capita. 
(Source: X-tendo based on EPC numbers from EPBD CA 
Key Implementation Decisions and information 
provided by X-tendo partners. 2018 population number 
from Eurostat. Map design: Showeet. 

51 See work by the Qualicheck project. (Available: Website)  
52  X-tendo  (2020)  Energy  Performance  Certificates  –  Assessing  their  status  and  potential. 
European Commission – Horizon 2020 project. (Available: Online) 

40 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Market penetration  

The effectiveness of the MMR implementation relies on a universal introduction of EPC, 
as the ratings are used to check compliance.  

The Horizon 2020 project X-tendo conducted a compilation of how many registered EPCs 
each country had in its database. Figure 12 shows the number of registered EPCs per 
capita, which reveals that only the UK, Ireland, Portugal, Denmark and Belgium have 
more than one EPC registered per 10 inhabitants. England and Wales, where the highest 
frequency of EPCs is found, have about one EPC per five dwellings – meaning that even 
here, the large majority of buildings are still without an EPC. This is seen as a major 
barrier hampering the potential impact.  

If just a fraction of targeted buildings  has an EPC, it will make an MMR impossible to 
function  effectively.  Policymakers  can  reduce  this  problem  by  making  sure  that  all 
targeted buildings have an EPC a couple of years before the MMR threshold comes into 
place.  

Quality and reliability  

Maybe  the  most  important  prerequisite  for  MMR,  after  the  availability  of  EPCs,  is  the 
reliability and quality control of the EPC rating, as it is foreseen to be the MMR threshold. 
The  reliability  of  EPCs  remains  the  subject  of  scrutiny  and  leaves  room  for 
improvement53. When EPCs were first introduced in the EPBD in 2010, quality control 
and  reliability  were  not  addressed  sufficiently.54  To  achieve  energy  performance 
objectives,  the  2018  revision  of  the  EPBD  stated  that  ‘the  transparency  of  energy 
performance certificates should be improved by ensuring that all necessary parameters 
for calculations, both for certification and minimum energy performance requirements, 
are  set  out  and  applied  consistently.’55  The  technical  annex  of  the  EU  taxonomy 
regulation  also  highlights  the  absence  of  comparable  building  stock  data  for 
benchmarking, which EPCs could provide, as a challenge for the development of climate 
mitigation  criteria  for  the  built  environment.56  The  Renovation  Wave  strategy  also 
emphasises this potential role of the EPC.  

The  reliability  of  EPCs  depends  on  various  factors  including  the  methodology, 
independent  quality  control,  the  qualification  and  accreditation  of  certifiers,  and  the 
compliance system. Balancing these factors while assuring affordability of EPCs remains 
a challenging task, which Member States try to address in different ways.57 Following 
the EPBD legislation, all countries perform random quality checks of the EPC input. How 
this  quality  assurance  is  conducted  differs  between  the  Member  States.  Data 
inaccuracies can be caused by lack of competence  of the EPC  expert,  procedures not 
being properly followed, incorrect on-site measurements or wrong pre-calculated values 
in the methodology.58 

The implementation of effective systems of quality assurance is a challenging task. It 
needs to be considered at every stage of the certification process, including training and 
control  of  auditors,  quality  checks  in  the  software,  and  verification  of  the  certificates 
issued.  At  the  same  time,  the  cost  of  the  system  should  be  balanced  to  avoid  a 

53 For example, Wales announced on 30 September 2020 that the success of a strategy to combat energy 
poverty will be measured in reduction of kWh instead of impact on EPC rating. (Available: Website) 
54X-tendo  (2020)  Energy  Performance  Certificates  –  Assessing  their  status  and  potential.  European 
Commission – Horizon 2020 project. (Available: Online) 
55  Directive  (EU)  2018/844  of  the  European  Parliament  and  Council.  Amending  the  energy  performance  of 
buildings Directive.  
56 EU Technical Expert Group on Sustainable Finance (2020). “Technical annex to the TEG final report on the 
EU taxonomy”. (Available: Online) 
57  X-tendo  (2020)  Energy  Performance  Certificates  –  Assessing  their  status  and  potential.  European 
Commission – Horizon 2020 project. (Available: Online) 
58 Ibid 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

significant increase. Increasing trust and establishing a good reputation for EPCs among 
building owners, potential tenants and other market actors is a challenge that still needs 
to be improved. 

3.4.2.  Building renovation passport  

Deep renovation is a complex process that involves a complete overhaul of the energy 
performance of a building. Most people are aware that better insulation of walls, roofs 
and  basements  will  lower  the  energy  consumption  of  the  household.  However,  many 
people are not aware of the issue of air leakages59, allowing heat to escape the building 
through weak points in the building envelope. Achieving a successful deep renovation 
requires expertise and careful detailing of the renovation measures, especially when a 
deep renovation is achieved in several stages. The building renovation passport (BRP) 
can  facilitate  this  by  providing  a  tailored  renovation  roadmap  for  a  specific  building, 
which can be carried out in one stage or multiple steps over several years.60 

A  BRP  can  be  seen  as  an  evolution  of  the  EPC,  as  it  supports  building  owners  with 
tailored  renovation  advice.  This  results  from  an  on-site  energy  audit  fulfilling  specific 
quality criteria and indicators established in dialogue with the owner. The BRP presents 
a staged renovation plan, outlining the roadmap to a low-carbon building. It is not just 
a technical intervention, as it integrates the occupant’s needs and specific situation (e.g. 
age, financial situation, the composition of the household, etc.) and outlines each step 
and links proposed measures.  

A feasibility study of the possible introduction of optional BRPs concluded that ‘existing 
Building Renovation Passports have proven that the instrument is effective in providing 
renovation  advice  taking  into  account  the  long-term  vision  for  the  building  stock.  It 
influences  the  renovation  rate  (number  of  energy  renovations),  renovation  depth 
(magnitude  of  the  renovations),  the  timing  of  the  works  (people  with  a  BRP  tend  to 
renovate  earlier  than  they  previously  planned)  and  the  quality  of  the  works  (fewer 
mistakes and unwise renovation decisions).’61 

As the BRP sets out tailored renovation advice based on an energy audit, it could also 
integrate an LCA to also incorporate whole-life carbon emissions. 

3.4.3.  Digital building logbook 

A  digital  building  logbook  (DBL)  is  a  digital  repository  for  all  building-related  data  on 
individual buildings, which facilitates information sharing within the construction sector, 
and between building owners and tenants, financial institutions and public authorities. 
The  digital  building  logbook  should  include  all  building-related  data,  such  as 
‘administrative  documents,  plans,  description  of  the  land,  the  building  and  its 
surrounding,  technical  systems,  traceability  and  characteristics  of  construction 
materials,  performance  data  such  as  operational  energy  use,  indoor  environmental 
quality, smart building potential and lifecycle emissions’62.  

The DBL is instrumental to gain a better overview of the building stock at all levels. At 
the same time as it is an enabler of circularity for the construction sector and the built 
environment, it allows to better assess the effectiveness of energy efficiency measures 
on  a  larger  scale.  It  can  tailor  support  measures,  set  benchmarks  and  strategies, 
monitor  progress  towards  climate  goals.  Comprehensive  information  about  buildings 

59 Leakages often occur through junctions between walls and other walls and between walls and windows 
60  Fabbri,  M  et  al.  (2020).  “Final  report  –  Technical  study  on  the  possible  introduction  of  optional  building 
renovation passports”. European Commission. (Available: Online) 
61 Ibid 
62  Volt,  J  &  Toth,  Z  (2020). “Definition  of  the Digital Building  Logbook”.  European Commission.  (Available: 
Online) 

42 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

means that DBL users and value chain actors can make better decisions about how and 
when to renovate buildings. 

The  introduction  of  a  Digital  Building  Logbook  can  support  the  MMR  in  several  ways, 
including:  

•  Logging each material used in the construction/renovation of buildings in the 
digital building logbook, including the exact location, allows for recycling and 
traceability of chemicals.  

•  Tracking performance along the life cycle. Improving the overall transparency, 

• 

trust and collaboration among different stakeholders. 
It enables public authorities to monitor the progress towards decarbonisation 
and to better tailor requirements for certain building typologies. 

•  Availability of granular performance and maintenance data in addition to the EPC 

and smart readiness indicator could provide a more robust and reliable 
indication of energy performance and reduce performance gaps. 

Figure 14: Role of the Digital Building Logbook (Source: BPIE) 

The  Renovation  Wave  strategy  declares  that  “the  Commission  will  introduce  Digital 
Building Logbooks that will integrate all building-related data provided by the upcoming 
Building Renovation Passports, Smart Readiness Indicators, Level(s) and EPCs to ensure 
compatibility and integration of data throughout the renovation journey.” 

3.5.  MMR is a flexible instrument thanks to a diversity of design options 

The  design  options  consist  of  the  main  aspects  of  how  MMR  can  be  implemented  in 
practice, including the metrics, building typology, compliance and trigger points.  

3.5.1.  Metrics  

A well-designed metric – tailored to the specific purpose of the MMR – is crucial for its 
success. A metric serves to express the performance of a building in a specific category, 
for example, an energy metric in kWh or a carbon metric in CO2. For the building sector, 

43 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

metrics are mainly used to evaluate the energy performance of the building, its climate 
impact, or indoor environmental quality.63  

Metrics  are  used  for  national  policy  targets  for  emission  reductions,  but  also  for 
determining  the  emission  reductions  of  a  renovation.  Whereas  the  former  is  often 
expressed as a reduction in tonnes of CO2 at a specific time, there are many different 
ways in which the performance of a renovation could be expressed. For example, one 
could  assess  the  efficiency  of  heating,  ventilation  and  air  conditioning  (HVAC) 
installations, the thickness of windows or even the embodied emissions of construction 
materials. These metrics can be applied for a whole country or one single building or 
measure. For whole countries, these are often expressed in terms of tonnes of carbon 
equivalent. For single buildings, however, metrics can get more specific and relate to 
construction materials, installations, or building elements. 

Another important metric differentiation is between asset-based ratings and measured-
based ratings: 

•  Asset-based ratings refer to a calculated energy efficiency level, which often 

aggregates the designed performance of the different building components 
(heating system efficiency, the thermal resistance of the envelope etc.). Most 
EPCs are fully, or predominantly, based on asset ratings. The main strengths are 
that it allows for a more reliable comparison between buildings, as the buildings 
with the same components should get the same rating. The main weakness is 
that the calculated energy performance is usually not aligned with the actual 
energy performance (i.e. the energy performance gap), due to the calculation, 
installation and/or user behaviour.64  

•  Measured-based ratings65 include metrics based on actual energy consumption, 

which can be done through utility bills or smart meter data. A prominent 
example of an operational rating is the Energy Start Score in the USA, which is 
based on smart meter data.  

Whole-life carbon metric  

Embodied  carbon  is  carbon  emissions  associated  with  materials  and  construction 
processes throughout the whole lifecycle of a building66. 

A  low  carbon  transformation  of  the  supply  chain  has  the  potential  to  decrease  the 
embodied carbon emission intensity by around 75%.67 This potential could be fostered 
by  appropriate  design  of  MMR,  integrating  whole-life  carbon  considerations  based  on 
reliable  data,  calculations  and  standards,  which  needs  to  be  further  evolved  and 
operationalised before they effectively can underpin an MMR.  

Besides the reduction of GHG emissions related to the energy used to heat and cool the 
building, the embodied carbon emissions of a deep energy renovation project amount 
to  around  312kgCO2e/m²  for  a  normal  single-family  building.68  Considering  a  3% 
renovation a year of the European residential building stock, this would correspond to 
about 100MtCO2-eq of annual embodied emissions. 

63 Fawcett & Topouzi. (2020). “Residential retrofit in the climate emergency: the role of metrics”. Buildings 
and Cities. (Available: Online).   
64  IEA  (2019)  EBC  Annex  71.  Building  Energy  Performance  Assessment  Based  on  In-situ  Measurements. 
(Available: Website) 
65 Also referred to as “operational rating” 
66 World Green Building Council (2019) Bringing Embodied Carbon Upfront. (Available: Online)  
67 Own analysis based on EU Calc data 
68  Röck  et  al.  (2020).  ‘Embodied  GHG  emissions  of  buildings  –  The  hidden  challenge  for  effective  climate 
change mitigation’. Applied Energy. (Available: Online)   

44 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Figure 15: Accumulated 2020-2050 embedded GHG emissions corresponding to the deep 
renovation of 90% of the 25,000 million m² of European residential buildings [in GtCO2e]. 

MMR considering whole-life carbon emissions will help to limit the shift of GHG emissions 
from the energy used to heat buildings (i.e. operational energy) to upstream emissions 
in the value chain and potentially foster a low-carbon transformation of the value chain.  

3.5.2.  Building typology  

MMR is often designed to target specific building segments. The design can be tailored 
to a building typology, specified to e.g. detached houses, terrace houses or apartment 
buildings.  The  building’s  function  can  also  be  a  criterion  for  the  design  of  MMR,  e.g. 
residential  or  non-residential  buildings.  Another  possible  option  is  to  target  a  specific 
segment of the housing market, e.g. privately owned, the rental sector or social housing, 
or e.g. buildings constructed before a given year. Furthermore, a common criterion used 
in certain jurisdictions is a minimum building (portfolio)  size in terms  of  floor area in 
square metres.  

The  age  of  existing  buildings  in  the  total  stock  is  a  good  indicator  of  the  average 
efficiency  of the building stock.  The higher the share of new dwellings, i.e. built with 
more efficient standards, the higher the energy performance of the stock. In most EU 
countries, half of the residential stock was built before 1970 (i.e. before the first thermal 
regulations)69. 

Figure 16: European residential building stock according to year built 

69 EU Building Stock Observatory. (Available: Website)  

45 

 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

In the European Union, there are approximately 215 million residential buildings and 46 
million  non-residential  buildings.70  From  the  residential  buildings,  around  65%  were 
constructed  before  1980.  Moreover,  roughly  140  million  dwellings  are  part  of  multi-
family  buildings.  Non-residential  buildings  (e.g.  education,  healthcare,  hotels  and 
restaurants, public offices, private offices, trade and wholesale) account for 24% of the 
total floor area.71 To achieve a significant impact, MMR might target with priority older 
residential  buildings  which  have  lower  energy  performance.  Larger  multi-family 
buildings and non-residential buildings are also relevant as target building segments.  

Figure 17 shows that the residential sector is  responsible for almost 75% of the EU’s 
building stock’s heating energy demand, in which single-family and terraced houses are 
most demanding. 

Figure 17: Heating energy demand - building use. Apartment blocks are multi-family buildings 
with five or more dwellings. Source: Hotmaps database 

In  multiple-ownership  apartment  buildings  in  most  Member  States,  deep  renovation 
decisions lie with homeowner associations.72 MMR focused on triggering renovation at 
property  transfer  may  not  be  as  effective  in  multi-ownership  buildings  compared  to 
single-ownership  ones.  The  complex  decision-making  process  in  multi-ownership 
buildings maybe a considerable barrier to deep renovations. Mandatory implementation 
of  renovation  steps  according  to  a  BRP  would  demand  action  from  homeowners 
associations (which need to have a clearly defined legal status and rely on agile decision 

70 EU Building Stock Observatory. (Available: Website) 
71  Entranze  Project.  Policies  to Enforce  the  Transition  to  Nearly  Zero  Energy  Buildings  in  the  EU.  European 
Commission - Intelligent Energy Europe programme. (Available: Website) 
72 The purpose, governance and frequency of homeowner association varies across the EU and well-functioning 
homeowners  associations  is  not  a  given.  See  for  example:  Economidou  M  et  al  (2018)  Energy  efficiency 
upgrades in multi-owner residential buildings - Review of governance and legal issues in 7 EU Member States, 
European Commission JRC. (Available: Online)  

46 

 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

procedures), where existing and new owners  are aware of the upcoming requirement 
and  can  plan  and  budget  accordingly.  The  defined  renovation  steps  in  the  BRP  could 
alleviate ambiguities and disagreements of which measures to invest in.  

Finally,  heritage  buildings  bring  specific  values  and  challenges,  discussed  in  the 
European Framework for Action on Cultural Heritage.73 The cultural and aesthetic value 
of  these  buildings  can  make  them  more  challenging  to  renovate.  For  example, 
alterations of the facades or roof might not be possible without negatively affecting the 
outside  appearance.  Furthermore,  these  older  buildings  are  often  extra  vulnerable  to 
the effects of climate change.74 As such, the applicability of MMR to heritage buildings 
should  be  tailored  at  the  national  or  local  level,  where  policymakers  have  the  most 
knowledge on the local climate conditions and the cultural significance and sensitivities. 
A tailored renovation tool, like the BRP, could define the renovation stages to a target 
that is reasonable for these buildings.  

3.5.3.  Compliance  

The  existing  MMR  cases  emphasise  the  need  for  effective  communication  channels 
between  different  organisations  and  authorities.  The  national/federal  authorities  are 
likely to regulate MMR and have overarching responsibility, while local authorities will 
be responsible for the groundwork, including informing citizens, checking compliance, 
collecting data and issuing penalties. Monitoring and evaluation are essential to ensure 
that  energy  performance  is  achieved.  Good  monitoring  simultaneously  facilitates 
compliance checks by providing regulators with insight into the energy performance of 
existing  buildings.  Sufficient  administrative  capacity  is  a  pre-requisite  to  achieve 
qualitative monitoring and effective compliance. 

In many existing cases, compliance is stimulated and enforced [carrot and stick] with 
on the one hand financial subsidies and grants, combined with financial penalties in case 
of non-compliance. The fine can increase depending on the duration of non-compliance 
and can be embedded in a bonus-malus scheme. These funds can be used for grants 
stimulating building owners to reach the 2050 target (i.e. deep renovation) as early as 
possible. Financial support programmes are often introduced alongside MMR to improve 
compliance and foster early action.  

Furthermore,  most  jurisdictions  have  set  up  educational  programmes  for  technical 
assistance. A barrier to enforcement in England and Wales was the lack of administrative 
capacity  in  the  municipalities  to  carry  out  the  enforcement  and  follow-up  work.  This 
illustrates  the  importance  of  well-equipped  and  trained  local  administrations  and 
practical design for the effectiveness of MMR.  

3.5.4.  Trigger points  

In the lifetime of a building, certain events lend themselves well to trigger a renovation. 
For instance, when a house is sold this provides an opportunity to renovate at the time 
when the new owners structure long-term financing (mortgage) and before they move 
in,  thereby  reducing  the  nuisance  of  the  construction  work.  Additionally,  a  switch  of 
tenants or a change of function of a building (section) can function as a suitable moment 
to renovate with least inconvenience for the building owners and users. MMR can target 
these ‘trigger points’ by requiring building owners to improve building performance. In 
the  Flanders  Energy  Plan  Draft,  for  example,  non-residential  building  owners  are 
required to renovate their building within five years of purchase.75. Other trigger points 

73 European Framework for Action on Cultural Heritage. (2018). European Union. (Available: Online) 
74 Historic Environment Scotland. (2020). “Climate Action Plan 2020-25”. (Available: Online) 
75 Flanders Government (2018). “Ontwerp Vlaams Energieplan”.  (in Eng: Flemish Energy Plan). (Available: 
Website)  

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

relate to regular maintenance works or personal circumstances of the inhabitants, such 
as a newborn family member or retirement.  

The  research  institute  CE  Delft  indicates  in  a  report  on  zero-carbon  buildings  that 
utilizing trigger points for building renovation can contribute significantly to achieve a 
zero-carbon building stock in 205076. Moreover, research from the Energy Saving Trust 
indicates  that  the  majority  of  British  building  owners  are  willing  to  invest  additional 
funds  in  energy  efficiency  measures  when  during  already  planned  renovation 
measures77. This illustrates the relevance of harnessing the power of trigger points to 
improve building performance, and the potential the European Commission can tap into 
by integrating trigger points in the MMR design.  

Figure 18 illustrates that the required renovation rate and depth can be reached with 
different means. ‘If the energy demand of dwellings can be reduced by an average of 
60% when changing owners (representing 1.7% of the dwellings per year), renovation 
associated with other key moments would not need to happen at as high a renovation 
depth.’78 The activation of renovation requirements can be based on a country-specific 
analysis of the impacts and potential of different trigger points.  

Figure 18: Different renovation rates and depths at key moments reach different average 
energy savings in four scenarios. The renovation depth is associated with three key moments 
(left-hand purple bars) and four scenarios (right-hand green bars) illustrate the required 
increase in the renovation rate resulting from lowered renovation depth following the untapped 
potential of key moments. The first scenario captures the full potential of key moments, leading 
to a 2.9%/year renovation rate with 51% average energy savings. Staged renovations outside 
of key moments would require a 7.3%/year renovation rate to provide similar energy savings. 
The bottom purple bars provide the average renovation depth corresponding to each scenario. 
Source: Kruit et al. (2020) Bringing buildings on track to reach zero-carbon by 2050 

76 European Climate Foundation. (2020). “Zero Carbon Buildings 2050”. Modelling by Climact based on  EU 
Calc data. (Available: Online) 
77 Energy Saving Trust. (2011). “A convenient truth – Promoting energy efficiency in the home”. (Available: 
Online) 
78 European Climate Foundation. (2020). “Zero Carbon Buildings 2050”.  Modelling by Climact based on  EU 
Calc data. (Available: Online) 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

3.5.5.  Enforcement calendars 

MMR could also be based on an enforcement calendar, which sets out a timeline for the 
affected buildings, defining when they need to comply with the specific requirements. 
Most commonly, and as implemented in the MEES in the UK, MMR increases the level of 
ambition  over  time,  guiding  the  market  towards  a  long-term  target.  In  each 
enforcement step certain requirements are enacted, e.g. an EPC rating, specified carbon 
emission level, or something else.  

Error! Reference source not found.19Error! Reference source not found. is a th
eoretical exercise to show how an enforcement calendar works. It has been created by 
Climact for the Flemish Energy Agency and their work on the LTRS for Flanders. 79 This 
example illustrates that by 2030, all buildings with an EPC label F have been renovated 
(or demolished), while by 2035 all buildings with label E have been upgraded, etc. By 
2050 all buildings have reached an EPC A label (or the best possible scenario for that 
building given technical and/or financial limitations).  

Figure 19: Distribution of EPC labels – Possible time evolution toward label A by 2050 (source: 
Climact and the Flemish Energy Agency). 

Enforcement  calendar  schemes  can  be  applied  to  all  building  segments,  types  and 
ownership structures. For non-residential and larger building owners, the enforcement 
calendar can be applied to their portfolio of buildings (i.e. assets). The owner/investor 
can  then  plan  their  portfolio  investments  in  line  with  future  MMR  thresholds,  which 
incentivises  investments  in  high-performing  buildings.  Certain  building/ownership 
types,  such  as  public  or  non-residential  buildings,  could  be  mandated  to  meet  the 
requirement a couple of years in advance and thus lead by example.  

79 This is a theoretical exercise as Flanders’ actual LTRS goal for 2050 has not yet been agreed by the 
government. 

49 

 
 
 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

4.  STEP 2: SHORTLIST OF THE MOST RELEVANT MMR MODELS BASED ON KEY 

DESIGN OPTIONS 

This section outlines the concept of six theoretical MMR models, based on the existing 
cases, literature review and stakeholder input. The models are generalisations of how 
MMR  can  be  designed  and  enforced,  from  progressive  minimum  energy  performance 
requirements  to  carbon-oriented  requirements,  indoor  environmental  quality,  and 
renovation  obligation  at  property  transfers.  Four  central  questions  are  answered  for 
each model:  

•  What are the main policy objectives and the metric in which the requirement is 

expressed?  

•  When is action required? (timeline and trigger points)  
•  To which building segments and owner groups is the model applicable?  
•  How is compliance assured? 

A qualitative and quantitative impact indication is provided for each model, based on a 
number of assumptions (specified in Appendix 3). The overall feasibility of the models 
is also qualitatively assessed and briefly discussed.  

Figure 20: Research flow diagram - Step 2 

The identified MMR types are divided into two categories, of which the first is linked to 
a predefined timeline (enforcement calendar), while the other relates to trigger points 
in the life of a building (see Figure 21), as discussed in Step 1. 

Enforcement calendar

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4.1.  MMR  model  1:  Progressive  minimum  energy  performance 

requirements  

The first model mirrors the existing cases in the UK, France and the Netherlands, where 
the  performance  thresholds  are  mainly  defined  by  the  building’s  energy  performance 
level,  defined  through  existing  EPCs.  The  minimum  performance  threshold  is 
progressively increased where all buildings below this threshold must be progressively 
upgraded before the hard deadlines (e.g. comply with EPC E by 2030, EPC D 2035 etc.). 
The  long-term  and  progressive  ‘enforcement  calendar’  could  alleviate  most  split-
incentive barriers and give the construction supply chain and real estate investors time 
to anticipate change and adapt to the upcoming requirements.  

The  effectiveness  of  MMR  model  1  varies  depending  on  the  quality  of  the 
regional/national EPC scheme, in terms of the share of building stock covered, reliability 
and existing database.  

What: 

When: 

Who: 

Description 

The  threshold  could  be  expressed  through  the  primary  energy 
consumption  of  the  building  (kWh/m²/year),  which  is  captured  in  the 
EPC.  

The  first  milestone  could  be  set  by  2030,  to  allow  market  players  and 
building  owners  to  anticipate  and  prepare  for  MMR.  As  a  precondition, 
most  of  the  targeted  buildings  must  have  an  EPC.  Subsequently,  the 
minimum  requirement  is  progressively  tightened  and  enforced  in  five-
year intervals, i.e. 2035, 2040, 2045, 2050. 

The  model  could  apply  to  all  building  and  ownership  types,  but 
enforcement (e.g. time of compliance) and the compliance method (e.g. 
penalties) could differ depending on the building type (residential, non-
residential, commercial, public buildings etc.), building use (home, office, 
industry, education), or ownership type (single owner, mixed ownership 
and real estate investors).  

The existing cases show that there is a value of keeping the requirement 
simple and straightforward. Therefore, the same milestone for all building 
types  is  preferred,  although  different  building  typologies  can  have 
different (lower/higher) requirements. For example, some building types 
that are less cost-optimal to renovate, such as heritage buildings,  may 
have a lower threshold. It is also preferable that all building categories 
follow the same trajectory but with differentiated ambitions.  

How: 

This requires all buildings to have an EPC, as it is used to check eligibility 
and compliance. The EPCs ought also to be stored centrally in a digital 
database,  to  allow  public  authorities  to  check  compliance  and  monitor 
progress.  

Compliance is verified based on the EPC rating. All buildings that are not 
complying with the requirement should present a valid reason or face a 
penalty. Compliance checks and EPC verification can be performed on a 
system level, using the existing EPC checks, which typically are based on 
random selection (e.g. spot checks on 5% of EPCs issued in a given year), 
or at trigger points in the building lifetime like property transfers.  

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Meeting the requirement can also be a precondition to be allowed to rent 
out the building. Ensuring regular control is key to avoid rented buildings 
going to the black market. 

Most 
prominent 
existing 
cases:  

•  The UK – The MEES in England and Wales sets minimum 

performance ratings for landlords (i.e. private rented properties). 
The standard is currently set at EPC rating E. There is also a 
pending regulation in Scotland.   

•  The Netherlands – New requirement mandating EPC label C for 

office buildings from 2023.  

•  France – The primary energy consumption of residential buildings 
(kWh/m2/year), defined by an EPC, may not exceed 330 kWh by 
2028.  

Table 4. Description of MMR Model 1 

Evaluation 

Figure 22 provides an overview of the impact of MMR model 1 in the pre-defined impact 
and feasibility categories. See Appendix 3 for a detailed analysis. 

Impact and Feasibility MMR Model 1

Renovation rate

Ease of compliance

Simplicity

Maturity of tools

3

2

1

0

Renovation depth

Renovation quality

Cost-optimality

Renewables

Split incentive

Carbon neutrality…

Acces to housing

2030 GHG milestone

Figure 22: Impact and feasibility of MMR model 1 

Impact evaluation: GOOD 

MMR model 1 activates renovation  of the worst-performing building stock, focusing 
mainly on the building’s energy performance level. The EPC infrastructure is already 
in place, enabling an immediate impact on the market as building owners are at least 
partly aware of the EPC and its purpose. Yet problems remain with EPC quality and 
market  penetration  (with  most  buildings  lacking  an  EPC),  which  could  hamper  the 
overall impact.  The ‘performance gap’  could undermine the impact if not tackled in 
parallel, with the risk that the estimated energy savings do not materialise in actual 
energy savings.  

The metric can build on the existing regulatory framework. 

Feasibility evaluation: EXCELLENT 

The  simplicity  is  the  main  advantage  of  this  option,  and  vulnerabilities  like  the 
reliability of EPCs can be addressed by harmonising the methodology. This MMR model 

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has already been tested in the UK and is planned in the Netherlands and France, which 
demonstrates its feasibility.  

Illustrative impact assessment of MMR model 1 (on the French residential building 
stock80) 

Modelled as a progressive ban on the  worst-performing buildings from 2035 onwards 
towards an average 100kWh/m²/year by 2050, MMR model 1 reduces, by 2050 relative 
to  2020,  the  final  energy  consumption  for  heating  by  39%  and  GHG  emissions  by 
between 39% and 56% (see Figure 23). The model also assumes a ‘performance gap’, 
that the achieved savings are lower than the estimated savings, reducing the impact by 
16% for the final energy consumption and 7% for GHG emissions. 

Figure 23: Illustrative impact assessment of MMR model 1 on the French residential building 
stock 

Short-term actions to make it successful  

•  The EPC schemes need to be further developed and improved, to cover more 

buildings, and ensure higher availability, quality and reliability.  

•  The EPC data ought to be stored in a digital database to ensure an effective 

compliance procedure.  

•  Public buildings can lead by example, with enforcement calendar ahead of the 

other buildings.  

•  The EPC can be linked to other instruments to further improve its usability and 
the overall impact, including BRPs (as done in Flanders, Belgium), one-stop-
shops (which is being done in Portugal) or the smart readiness indicator. 

•  Setting clear and long-term targets for the EPC requirement threshold will send 
a signal to the real estate market. Building owners should be informed about 
what is required from their building in 5, 10 and 20 years.  

•  Tailored recommendation advice instruments, such as BRPs, are needed to avoid 

economic and technical lock-in effects.  

80 Further details are provided in Appendix 3.   

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4.2.  MMR  model  2:  Progressive  minimum  carbon  performance 

requirements 

This  model  mirrors  the  first  but  shifts  the  focus  from  energy  performance  to  carbon 
performance  associated  with  operational  energy  emissions.  The  MMR  threshold  is 
defined  by  the  building’s  carbon  dioxide  (CO2)  emissions  instead  of  the  energy 
consumption  level  (kWh).  The  model  assumes  the  carbon  performance  to  be  defined 
based on the estimated carbon emissions, taking into account the energy performance 
level and energy mix, which can be defined by the EPC, energy audit, or through utility 
bills  and  applying  CO2  emission  factors.  The  model  leaves  room  for  building-specific 
trade-offs between energy efficiency upgrades and renewable energy investments.  

What: 

When: 

Who: 

How: 

Description 

The  MMR  threshold  is  expressed  in  terms  of  carbon  performance  of 
heating needs (i.e. CO2-eq/m²/year). It could be based on an EPC but 
using carbon performance as an indicator instead of the energy need 
(i.e.  kWh/m²/year).  Some  EPCs  would  need  to  be  adapted  for  this 
purpose.81   

Alternatively,  the  target  can  be  expressed  as  primary  energy 
consumption  (kWh/m²/year)  after  subtracting  on-site  renewable 
energy  production.  The  basic  implementation  confines  the  scope  of 
the  model  to  direct  emissions,  i.e.  fuels  burned  on-site  to  produce 
heat.82 

The model can be further developed to consider the whole-life carbon 
impact  of  the  building,  taking  into  account  the  embodied  carbon  of 
materials and related processes.  

The first milestone could be set by 2030, to allow market players and 
building owners to anticipate and prepare for MMR. As a precondition, 
all  the  targeted  buildings  must  have  an  EPC.  Subsequently,  the 
minimum requirement is progressively tightened and enforced in five-
year intervals, i.e. 2035, 2040, 2045, 2050. The 2050 target could be 
aligned with the long-term decarbonisation goal.  

The  model  can  apply  to  all  building  and  ownership  types,  but 
enforcement (e.g. time of compliance) and compliance method (e.g. 
penalties)  could  differ  depending  on  the  building  type  (residential, 
non-residential,  commercial,  public  buildings  etc.),  building  use 
(home, office, industry, education), or ownership type (single owner, 
mixed ownership and real estate investors). 

This  requires  all  buildings  to  have  an  EPC,  as  it  is  used  to  check 
eligibility and compliance. The EPCs ought also to be stored centrally 
in a digital database, to allow public authorities to check compliance 
and  monitor  progress.  The  EPC  must  also  be  adapted  to  reliably 
include and display the carbon performance level.  

81  Several  EPC  schemes  do  indicate  the  CO2  impact  the  building  has,  which  is  often  a  simple 
conversion from the energy need figure.  
82 Alternative scopes can include embodied emissions from the production of consumed 
electricity and heat (in case of heat networks) and embodied emissions from materials and 
products used in the renovation. 

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Compliance is verified based on the EPC rating. All buildings that are 
not complying with the requirement should present a valid reason or 
face  a  penalty.  Compliance  checks  and  EPC  verification  can  be 
performed at a system level using existing EPC checks, which typically 
are  based  on  random  selection  (e.g.  5%  of  EPCs  issued  in  a  given 
year),  or  at  trigger  points  in  the  building  lifetime  like  property 
transfers.  

If  the  EPC  includes  indirect  emissions  from  electricity  and  heat 
production,  the  national  primary  energy  factors  can  be  used  by 
default. The building owner could have the possibility to provide proof 
of lower carbon intensity through their energy purchase contracts. 

Existing 
cases:  

Two existing cases do not exactly match this model but contain key 
design elements. 

•  New York: Local law 97 (for larger buildings) which specifies 

annual building emission limits per m2. 

Table 5. Description of MMR Model 2 

Figure 24 provides an overview of the impact of MMR model 2 in the pre-defined impact 
and feasibility categories. See Appendix 3 for a detailed analysis. 

Impact and Feasibility MMR Model 2

Ease of compliance

Simplicity

Maturity of tools

Renovation rate

3

2

1

0

Renovation depth

Renovation quality

Cost-optimality

Renewables

Split incentive

Carbon neutrality 2050

Acces to housing

2030 GHG milestone

Figure 24: Impact and feasibility of MMR model 2  

Evaluation 

Impact evaluation: GOOD 

The  model  focuses  on  carbon  emissions,  rather  than  building  performance, 
encouraging  techno-economic  solutions  towards  this  goal.  At  the  same  time,  the 
model could create false confidence that the building envelope does not need to be 
upgraded to reach the future requirement and thus depraving end-users from some 
major benefits of a renovation. The model can also be seen as the first step to include 
whole-life carbon aspects, once there is one common standard for reporting and data 

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collection.  A  database  gathering  whole-life  carbon  data  of  the  building,  enabling 
benchmarking, is another important precondition.  

The  EPC  infrastructure  is  already  in  place,  enabling  an  immediate  impact  on  the 
market and high ease of implementation. Most Europeans are now aware of EPCs and 
have  a  basic  understanding  of  their  purpose.  Yet  major  problems  remain  with  their 
quality  and  market  penetration  (with  most  buildings  lacking  an  EPC),  which  could 
hamper the overall impact.  

The larger focus on renewables could reduce the (multiple) benefits of the renovation 
of the building envelope. For example, replacing fossil-based energy with renewable 
energy without improving the envelope may not bring a positive impact on comfort 
and wellbeing.  

Feasibility evaluation: MODERATE 

The model defines the threshold through CO2 and is, therefore, better aligned with the 
EU’s long-term objectives. The model could have a negative effect on data simplicity 
and  compliance,  even  though  CO2  emissions  already  feature  in  the  EPCs  of  some 
Member States, for example in France, Portugal and Poland.   

Illustrative  impact  assessment  of  MMR  model  2  (on  the  French  residential 
buildings stock)83 

Compared to MMR model 1, the further deployment of low-carbon and high-efficiency 
heating technologies leads to slightly greater final energy consumption reductions. As 
carbon  neutrality  is  set  as  a  long-term  target  for  the  renovation  of  existing  buildings 
(for each building or similarly an average target for the building stock), GHG emissions 
are progressively reduced to zero through the deployment of renewable heat solutions 
– in complement to  energy  efficiency investments – to comply with  minimum carbon 
performance  requirements.84  The  modelling  is  based  on  the  basic  version  of  model  2 
(i.e. not including whole-life carbon) (See Figure 25).  

83 Further details are provided in Appendix 3 

84 See also Table  in Appendix 2 

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Figure 25:  Illustrative impact assessment of MMR model 2 on the French residential building 
stock. 

Short-term actions   

•  The EPC schemes need to be further developed and improved to cover more 
buildings, data gathering and storage while ensuring higher quality and 
reliability.  

•  The EPC data ought to be stored in a digital database to ensure an effective 

compliance procedure.  

•  The EPC must be adjusted to make it reliably display CO2 emissions, which is 

already the case in several of the Member States.  

•  The MMR model will generate a boost of on-site renewable energy production, 

which might increase the need to stabilise the grid.  

•  Public buildings can lead by example, meeting their targets ahead of other 

buildings.  

•  Setting clear and long-term targets for the EPC requirement threshold will send 
a signal to the real estate market. Building owners should be informed about 
what is required from their building in 5, 10 and 20 years.  

Medium-term actions 

•  The EPC can be coupled with other instruments to further improve its usability 

and the overall impact, including BRPs (as done in Flanders, Belgium), one-stop-
shops (which is being done in Portugal) and the smart readiness indicator. 
•  A common standard is needed for how whole-life carbon impacts are calculated 

and data generated. This could be an extension of the existing Level(s) 
framework, and should:  

-  Have a clear definition of CO2 emissions related to the production of 

electricity and heat from the energy supplier.  

-  Have a clear definition of CO2 emissions related to renovation 

materials and processes. This should build on the existing database 
and collect data from the current renovation market to validate and 
improve these databases.   

-  The MMR can gradually include lifecycle assessment (LCA) 

considerations defined concerning widely accepted LCA and 

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CEN/TC350 standards, Level(s) framework, and digital building 
logbooks. 

4.3.  MMR model 3: Progressive real carbon emissions budget  

MMR model 3 defines a carbon emission budget for all targeted buildings. The emission 
metric  is  converted  from  total  energy  consumption  and  the  energy  mix  of  this 
consumption. The ‘budget’ can be defined based on an estimated carbon dioxide need 
for a certain building (e.g. x tonnes CO2/m2/year) or relative to its previous consumption 
levels  (e.g.  a  reduction  of  20%  of  the  consumption  compared  to  2020  levels).  The 
individual  building  budget  could  be  derived  from  the  national  LTRS  and  local 
decarbonisation plans, to make sure the building contribute to the long-term objective. 
The  emission budget limit ought to be ‘normalised’, depending on the building’s size, 
usage,  number  of  occupants  and  external  factors  (e.g.  climate  zone).  This  model 
alleviates the adverse impact of the ‘performance gap’. Its purpose is to promote and 
ensure  actual  carbon  emission  reductions,  which  can  be  achieved  through  energy 
efficiency measures, renewables or changes in behaviour.  

What: 

When: 

Who: 

How: 

Description 

The requirement applies to the  GHG  emissions per building, resulting 
from the real energy consumption during the building’s operations (as 
a minimum scope). The CO2 should be measured though smart meter 
data  (heating  and  electricity)  or  utility  bills  if  smart  meters  have  not 
been rolled out. The emission factors of the heating sources need to be 
commonly agreed.  

The model can evolve to consider the whole-life carbon impact of the 
building,  taking  into  account  the  embodied  carbon  of  materials  and 
related processes.  

The first milestone could be set for 2030, to allow market players and 
building owners to anticipate and prepare for MMR. Subsequently, the 
minimum requirement is progressively tightened and enforced in five-
year intervals, i.e. 2035, 2040, 2045, 2050. The 2050 target could be 
aligned  with  the  long-term  decarbonisation  goal,  which  would  be 
simplified with the real carbon emission metric.  

Existing cases of this model have focused on larger or non-residential 
buildings,  as  it  can  be  sensitive  to  set  a  limit  like  this  for  private 
homeowners.  The  model  can,  however,  apply  to  all  building  and 
ownership  types;  enforcement  (e.g.  time  of  compliance)  and 
compliance  method  (e.g.  penalties)  could  differ  depending  on  the 
building type (residential, non-residential, commercial, public buildings 
etc), building use (home, office, industry, education), or ownership type 
(single owner, mixed ownership and real estate investors). 

The  baseline  against  which  carbon  reduction  is  measured  is  first 
estimated based on smart meter data or utility bills (e.g. it could be an 
average from the last three years). With regular updates (at least every 
month) about carbon emissions, the building owner could get warnings 
and suggestions on how to reduce consumption.  

Monitoring and control would be based on energy bills or smart meters. 
If  the  scope  embeds  indirect  emissions  from  electricity  and  heat 
production,  the  energy  mix  of  energy  providers  should  also  be 
considered.  The  ease  of  monitoring  would  be  improved  if  product 
(including  materials  and  chemicals)  and  energy 
declarations 

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consumption data were embedded in a digital building logbook. Controls 
could be automated and take place regularly. Non-compliance to bring 
a fine.  

Existing 
cases:  

New York City: Local law 97 (for larger buildings) which specifies annual 
building emission limits per m2 

Boulder: uses a point-based energy metric, but with some adjustments 
for the carbon intensity of specific fuels85. 

Table 6. Description of MMR Model 3 

Figure 26 provides an overview of the impact of MMR model 3 in the pre-defined impact 
and feasibility categories. See Appendix 3 for a detailed qualitative analysis. 

Impact and Feasibility MMR Model 3

Renovation rate

Ease of compliance

Simplicity

Maturity of tools

3

2

1

0

Renovation depth

Renovation quality

Cost-optimality

Renewables

Split incentive

Carbon neutrality 2050

Acces to housing

2030 GHG milestone

Figure 26. Feasibility and Impact analysis of MMR Model 3. 

Evaluation  

Impact evaluation: EXCELLENT 

MMR model 3 alleviates the ‘performance gap’ by focusing on the actual carbon use, 
which is converted from energy consumption. The requirements set under this model 
would  drive  down  carbon  emissions  in  a  cost-optimal  way.  As  with  MMR  model  2, 
there is a risk that some of the multiple benefits from energy improvements would 
not be attained.  

Feasibility evaluation: MODERATE  

The  indicator  relates  more  to  real  energy  savings  and  carbon  emission  reductions. 
Data privacy might be a barrier in some Member States. The model might not solve 
the split-incentive dilemma, as the responsibility for reducing energy use is not clearly 
defined.  Landlords  might  encourage  tenants  to  reduce  their  heating,  instead  of 
renovating.  This  model  will  be  more  difficult  to  implement  for  residential  buildings. 

85 Nadel, S & Hinge A (2020) Mandatory Building Performance Standards: A Key Policy for Achieving Climate 
Goals. ACEEE (Available: Online) 

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However,  it  has  been  introduced  in  the  United  States  for  larger  buildings, 
demonstrating its relative feasibility in the context of certain building segments.  

Illustrative impact assessment  

MMR  model  3  is  designed  specifically  to  tackle  the  ‘performance  gap’,  highlighted  in 
Figure 27, thanks to the reliance on actual energy consumption in the operation phase 
of a building and the related carbon emissions. No illustrative impact assessment  has 
been made for model 3, given the theoretical scenario is similar to model 2 but without 
the risk of the “performance gap”.   

Short term actions:  

•  A just and fair definition of the ‘carbon budget’ is of utmost importance. The 

budget cannot simply be linear to the size of the building: for example, the 
increase in energy consumption from a one-person household to a two-person 
household is probably larger than from a five-person to a six-person household.  
•  The objective to achieve ‘carbon neutrality’ provides a clear long-term target for 
the market. It is necessary, however, to define the intermediate milestones. 
These can be set in relative terms compared to the current level of carbon 
emissions, or in absolute levels to be reached by certain milestones. Building 
owners should be informed about what is required from their building in 5, 10 
and 20 years.  

•  Roll out smart meters to cover all buildings targeted with this model. EPCs could 
again be integrated as they provide useful and coherent additional information 
about the building’s performance. Member States could enlarge their EPC 
scheme to also reflect real energy consumption, measured through smart 
meters rather than utility bills. This is already done in some cases (such as in 
Estonia and Sweden for certain buildings). 

•  Tailored recommendation advice instruments, such as BRPs, are needed to avoid 

• 

economic and technical lock-in effects.  
If vulnerable groups are targeted with this model, adverse effects should be 
avoided with supporting measures (e.g. extra financial support) to avoid people 
simply turning off their heating to comply with the requirement.  

Medium-term actions 

•  A common standard is needed for how whole-life carbon emissions are 

calculated, integrated and how thedata is generated. This could be an extension 
of the existing Level(s) framework, and should:  

-  Have a clear definition of CO2 emissions related to the production of 

electricity and heat from the energy supplier.  

-  Have a clear definition of CO2 emissions related to construction 
materials and processes. This should build on the existing 
experiences (e.g. EU’s Level(s) framework and Buildings As Materials 
Banks project, as well as the Dutch Madaster and Swedish BASTA 
logbooks) and collect data from the current renovation market to 
validate and improve these databases. 

•  The MMR can gradually include lifecycle assessment (LCA) considerations 
defined with reference to widely accepted LCA and CEN/TC350 standards, 
Level(s) framework, Environmental Products Declaration and digital building 
logbooks.86     

86 The setting MMR thresholds could follow a similar approach to the EU sustainable finance taxonomy. The 
purpose of the taxonomy is to identify assets which are significantly contributing to climate change 

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4.4.  MMR  model  4:  Mandatory 

improvements  trigger  by 

indoor 

environmental quality deficiencies  

The model triggers renovations based on IEQ metrics, including indoor air quality, noise, 
sufficient  light  and  temperature.  The  minimum  requirement  can  be  set  for  the  whole 
building based on an aggregated score or for each building component. The purpose of 
MMR  model  4  is  to  trigger  the  renovation  of  unhealthy  buildings  first;  it  can  then  be 
combined with one of the first MMR models. While many renovation measures improve 
both the IEQ and the building’s carbon/energy footprint, combining them in the cost-
optimal calculation would make sure MMR contributes to both.  

Including  IEQ  indicators  will  help  to  raise  awareness  of  other  benefits  of  renovations 
beyond energy and carbon savings – benefits related to comfort, health and well-being 
as  well  as  energy  poverty  alleviation.  It  could  facilitate  a  more  convincing  narrative 
around MMR and its purposes.  

What: 

When: 

Who: 

How: 

Description 

The minimum requirement is expressed in terms of IEQ indicators, such 
as air quality87, thermal comfort88, lighting89 and noise90.91 The metric, 
if set for the whole building or certain components, should determine if 
the  building  is  offering  the  occupants  a  decent  living/working 
environment. The suggested renovation measure could be presented as 
an opportunity to improve the indoor environment and thus the quality 
of  life  of  building  occupants,  while  at  the  same  time  reducing  energy 
needs.  

The first IEQ milestone could be set for 2030, to allow market players 
and building owners to anticipate and prepare for MMR. Subsequently, 
the model can be merged with MMR model 1-3 to broaden the scope.  

The model  can be applied to all building types and usages. It applies 
particularly  well  to  certain  building  segments,  including  schools, 
hospitals,  social  housing  and  the  private  rental  housing  market,  as 
these are segments where IEQ shortfalls have been identified and the 
societal costs estimated.92  

Member States can evolve their EPC schemes to ensure the quality of 
the  indoor  environment  is  considered.  A  few  countries  (e.g.  Portugal 
and  Greece)  do  already  indicate  the  comfort  level  on  their  EPC  label. 
EPCs  have  the  potential  to  become  effective  instruments  to  track  not 
only  a  building’s  energy  performance  but  also  its  overall  IEQ  by 

mitigation/adaptation, whereas the main purpose of the MMR is to identify the worst-performing segments. 
Setting the right MMR level will need to be proportional with compliance costs. Overall, considering the 
importance and urgency of improving the energy performance and decarbonising the building stock, the 
impact of compliance costs can be considered proportionate, especially given significant positive social and 
economic impacts the implementation of MMR can have. 
87 A building’s ventilation rates are expressed in units of air flow rates per floor area, air flow rates per number 
of people, flow rates and air changes per hour (ACH). 
88 A comfortable temperature is typically around 21-24 degrees Celsius. A healthy building ought to be able 
to offer a comfortable temperature in cold winters and hot summers.  
89 Lighting includes both natural and artificial lighting. Illuminance levels (lux) and temperature of the lighting 
(Kelvin) are typically used as a metric of lighting. 
90 The acoustic environment must be designed to avoid these harmful effects. The criteria used to specify an 
acceptable  acoustic  environment  are  expressed  in  sound  levels  in  decibels  or  sound  frequencies  like  noise 
rating or noise criteria. 
91 BPIE (2018). “The Inner Value of a Building”. (Available: Online) 
92  Buildings2030.  (2018).  “Quantifying  the  impact  of  a  better  indoor  environment  in  schools,  offices  and 
hospitals”. (Available: Online) 

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renovation and modernisation of the built environment  

Existing 
cases:  

providing  evidence-based  information  (e.g.  measurements,  building 
occupant surveys, dynamic computer simulations). Measurements form 
the  basis  of  quantitative  indicators  for  the  evaluation  of  the  relevant 
parameters that can be included in EPCs.93  

Alternatively,  an  energy  check/audit,  potentially  targeting  priority 
households  at  risk  of  energy  poverty,  can  determine  if  a  building 
exceeds some certain defined ‘health indicators’, which could be indoor 
CO2 levels, dampness or volatile organic compounds.  

•  Denmark introduced renovation classes in its building regulation 
(BR2018) requiring the renovation of existing buildings to meet 
the same level as new buildings on certain IEQ parameters to be 
classified in the best EPC class.  

•  The Active House, a worldwide quality stamp for comfortable and 
sustainable buildings, advises on elements important to people’s 
lives  and  living  conditions  in  their  home.  It  issues  its  label  for 
buildings  that  meet  three  specified  requirements  for  indoor 
comfort, energy efficiency and the environment. 

Table 7. Description of MMR Model 4 

Figure 27 provides an overview of the impact of MMR model 4 in the pre-defined impact 
and feasibility categories. See Appendix 3 for a detailed analysis. 

Impact and Feasibility MMR Model 4

Renovation rate

Ease of compliance

Simplicity

Maturity of tools

3

2

1

0

Renovation depth

Renovation quality

Cost-optimality

Renewables

Split incentive

Carbon neutrality 2050

Acces to housing

2030 GHG milestone

Figure 7: Impact and feasibility of MMR model 4 

93 For more information: BPIE. (2019). “How to integrate indoor environmental quality within national long-
term renovation strategies” (Available: Online) 

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renovation and modernisation of the built environment  

Evaluation 

Impact evaluation: MODERATE 

Tackles the renovation by introducing a more holistic approach. By requiring minimum 
IEQ levels, co-benefits such as lower health costs and increased productivity will be 
achieved  and  become  more  explicit.  However,  shares  most  of  the  weaknesses 
mentioned  in  the  first  model,  e.g.  the  disconnect  with  the  energy  and  carbon 
narrative.  

Feasibility evaluation: POOR 

The  holistic  approach  comes  at  the  price  of  simplicity.  The  EPC  tools  and 
methodologies would need to be adapted to include IEQ although there is currently 
no universal standard for how this can be done. Integrating IEQ metrics in the EPC 
would demand a more in-depth on-site visit and thus inflate the cost.   

Illustrative impact assessment (on the French residential buildings stock)94 

MMR model 4 is modelled as triggering the renovation of unhealthy buildings by 2030, 
beyond what is already triggered by MMR model 1 (the results are cumulated). Given 
that reasons to renovate go beyond energy efficiency, it is considered that the model 
will  trigger  deep  renovations  (both  two-stage  and  one-stage  renovations  are 
considered). The impacts of this MMR model derive from deeper and earlier renovations 
(see Error! Reference source not found.28). It has the potential to increase the results r
eached by 2030, further reducing the final energy consumption and the GHG emissions 
by up to 7% and 9% respectively compared to the 2020 level. 

Figure 8: Illustrative impact assessment of MMR model 4 on the French residential buildings 
stock 

94 Further details are provided in Appendix 3 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Short-term actions 

•  Clear links should be defined between IEQ and long-term renovation targets and 

strategies. The definition of what constitutes a ‘healthy building’ is a 
prerequisite, including indicators and metrics of how this could be evaluated.  

•  Training is needed for energy experts and other actors in the value chain to 

consider IEQ aspects in every phase of a building’s lifetime. 

•  With remote working potentially becoming more frequent during and after the 

COVID-19 pandemic, IEQ becomes even more important for residential buildings 
as people spend more time at home.  

•  EPC schemes need to be further developed to integrate IEQ. EPCs should also be 
improved to cover more buildings and ensure higher quality and reliability.  
•  Public schools and hospitals can lead by example, as a good indoor environment 

is vital for learning and recovery from diseases.    

•  Setting clear and long-term targets for the IEQ requirement threshold will send 

a signal to the real estate the market. Building owners should be informed about 
what is required from their building in 5, 10 and 20 years.  

•  Tailored recommendation advice instruments, such as BRPs, are needed to avoid 
economic and technical lock-in effects while integrating the personal views of 
what a good indoor environment comprises for the specific tenants.  

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4.5.  MMR  model  5:  Progressive 

implementation  of  pre-defined 

renovation steps based on a building renovation passport 

This  model  sets  up  a  progressive  implementation  calendar  of  renovation  measures 
according to a BRP (i.e. individual renovation roadmaps), taking into account whole-life 
carbon  considerations95.  The  renovation  roadmap  sets  out  the  renovation  steps  the 
building owner must implement, in order for the building to become “2050 compliant”. 
In contrast to the other models, the standard is individualised and can be adapted to 
the  technical  renovation  possibilities  of  the  building,  as  well  as  the  preferences  and 
financial constraint of the building owner.  

What: 

Description 

MMR  Model  5  is  defined  in  terms  of  renovation  steps  that  need  to  be 
implemented  by  the  building  owner  The  renovation  steps  are  clearly 
outlined in a BRP, which has been developed by an energy expert, and 
needs  to  be  implemented  within  a  certain  timeframe  (instead  of  all 
buildings meeting the EPC rating E, all targeted buildings must implement 
the first renovation step which are different for all building owners.  

An  energy  audit  is  a  prerequisite  for  a  BRP  but  also  an  opportunity  to 
make a light LCA of the building. The whole-life carbon consideration will 
just inform the renovation decisions/steps to make sure they are taken 
to  optimise  the  carbon  reduction  potential  of  the  building  (e.g.  locally 
sourced  material,  natural  components,  and  secure  an  end-of-life 
recycling of materials).   

The model also allows for a tailormade approach on a societal level, where 
the aggregated progress is aligned with the long-term target, as specified 
in the LTRS. The energy/carbon-saving per building then depends on the 
relative economic and technical feasibility for that building to reach net-
zero. This top-down approach allows the public authorities to  steer the 
decarbonisation effort so that it balances investments in energy efficiency 
and renewables.  

The  model  would  also  allow  urban  planners  to  better  design  district 
approaches  where,  for  example,  energy  renovations  are  coupled  with 
low-temperature district heating systems.  

When: 

Building  owners  are  required  to  implement  pre-defined  renovation 
activities  every  five  years:  2030,  2035,  2040,  2045,  2050,  until  the 
building is ‘future-proof’, meaning it performs as it should by 2050. The 
first requirement is to get a BRP.  

95 Other environmental, social and governance aspects (e.g. resource efficiency, construction and occupational 
health  impacts,  labour  rights)  and  indoor  environmenta  quality  aspects  can  also  be  included  in  the 
requirement. 

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renovation and modernisation of the built environment  

Preferably,  the  target  for  each  building  should  be  pegged  to  the  2050 
decarbonisation target, where each building contributes to this according 
to its relative ability. The BRP will define the  best-possible  scenario for 
the individual building, considering the 2050 target but also the technical 
and economical feasibilities. Each building could contribute individually or 
at a district level.   

Current BRPs are not based on carbon performance, which means these 
instruments would have to be adapted for this purpose to be  ready for 
implementation by 2030.  

Who: 

The model can apply to all building segments, types and owners. 

How: 

The  first  requirement  for  non-compliant  buildings  could  be  to  obtain  a 
BRP,  which  sets  out  the  long-term  renovation  and  renewable  sourcing 
steps for the individual building. Financial support could be linked to the 
steps in the passport.  

Existing 
cases:  

The digital building logbook could be used to utilise the full potential of 
this model, such as allowing for public authorities to tailor policies to the 
actual needs of the building stock and monitor the progress towards the 
long-term target. It can also facilitate the integration of whole-life carbon 
by  gathering  and  dispensing  information  on  building  components  and 
materials.  

Most prominent building renovation passports are:  

•  The Brussels LTRS foresees the implementation of a MEPS and 

roadmap for residential buildings (i.e. BRP). From 2030, 
sustainability criteria will be included in the region’s EPC and BRP, 
which then could inform the MEPS triggered renovation measures.   

•  The German Individueller Sanierungsfahrplan is a detailed 

building renovation passport based on an energy audit, focusing 
on measured energy.  

•  The Flemish EPC features an automatic renovation roadmap, 

which means that all residents with an EPC also have a suggested 
roadmap for their building, focusing on measured energy.96  

Table 8. Description of MMR Model 5 

Figure 29. provides an overview of the impact of MMR model 5 in the pre-defined impact 
and feasibility categories. See Appendix 3 for a detailed analysis.  

96 See additional cases in Fabbri et al. (2020). “Technical study on the possible introduction of optional building 
renovation passports”. European Commission. (Available: Online) 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Impact and Feasibility MMR Model 5

Renovation rate

Ease of compliance

Simplicity

Maturity of tools

3

2

1

0

Renovation depth

Renovation quality

Cost-optimality

Renewables

Split incentive

Carbon neutrality 2050

Acces to housing

2030 GHG milestone

Figure 9: Impact and feasibility of MMR model 5 

Evaluation  

Impact evaluation: EXCELLENT 

The model relies on the BRP, which defines clear renovation steps that need to be 
implemented and their costs for each building to comply with the MMR. The overall 
quality of the implemented measures is higher  because of the tailored advice and 
aligned  with  the  long-term  target  set  out  in  the  countries  LTRS.  The  BRP  avoids 
economic  and  technical  lock-in  effects,  where  the  cost-optimal  path  to  a  2050-
compliant  building  no  longer  is  viable.  The  model  includes  renewable  on-site 
production  as  part  of  the  renovation  steps  identified  in  the  BRP,  meaning  that  an 
energy expert balances the energy efficiency and renewable improvements that are 
needed.  The  model  also  allows  building  owners  to  make  better  decisions  because 
tailored renovation advice.  

Feasibility evaluation: MODERATE 

Implementing this model would not be that complex, as some of the conditions of 
producing a BRP are already in place and a few examples already exist, which could 
be  replicated.  The  whole-life  carbon  consideration  ought  to  based  on  a  common 
standard  for  the  data  and  reporting  procedures  and  build  on  existing  experiences 
with  LCA,  which  will  require  some  extra  training  for  the  auditors.  While  several 
countries are looking to implement a BRP in some capacity, there is a long way to 
go to reach the same market penetration as EPCs (which also might not be enough). 
Requesting  building  owners  to  get  a  BRP  would  create  a  challenging  demand  for 
certified auditors who can perform this work.  

Illustrative impact assessment (on the French residential buildings stock)97 

MMR model 5 is expected to trigger earlier renovations thanks to the provision of quality 
information  to  households  via  the  deployment  of  BRPs.  However,  assuming  that  the 
“energy efficiency first” principle applies to the implementation steps of the renovation 

97 Further details are provided in Appendix 3 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

passport (i.e. the first steps consist of energy efficiency measures and the switch to low-
carbon heat solutions occurs later), large carbon emission reductions are only obtained 
during the last part of the time horizon (see Figure 30). The orange line indicates the 
added impact from MMR model 5, relative to model 1 and 2.  

Figure 10: Illustrative impact assessment of MMR model 5 on the French residential buildings 
stock 

68 

 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Short term actions:  

•  Evolve existing BRPs to integrate a light LCA, considering the whole-life carbon 
aspects based on Level(s). This will require extra training for auditors but 
require that much extra time on-site.  

•  The BRP ought to be ‘user-friendly’ and contribute to making the renovation 

• 

process more comprehensible for the building owner. 
Integrated renovation services, like one-stop-shops, can facilitate a smoother 
process for the building owner, by directing them to the appropriate expert, 
installer or financial institutions.  

•  Member States should be encouraged to subsidise the cost for the development 

of the BRP to a level where it becomes attractive to building owners. The 
subsidy can be reduced when the instrument has penetrated the market. Quality 
of the BRP is crucial to gain trust for the instrument and its usability.98 

•  The success of the implementation of the BRP and related MMR is dependent on 

an increase in competence and skills of the construction workforce. 

•  Public buildings can lead by example, meeting their targets ahead of other 

buildings.  

98 See additional cases in Fabbri et al. (2020). “Technical study on the possible introduction of optional building 
renovation passports”. European Commission. (Available: Online) 

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renovation and modernisation of the built environment  

4.6.  MMR  model  6:  Renovation  obligation 

linked  to  real  estate 

transactions for all building non-compliant in 2050 

This  model  foresees  buildings  being  renovated  in  conjunction  with  real  estate 
transactions.  Both  residential  and  non-residential  buildings  could  be  subject  to 
progressively more demanding MMR when the building changes owner. For example, all 
owners of buildings with an EPC rating of B, or worse, must improve their building, if 
sold. The MMR Model will boost the demand for high-performing buildings.  

Buildings that are not sold or rented out do not have to be upgraded under this MMR 
model.  MMR  model  6  can  easily  be  combined  with  either  MMR  model  1,2  or  3,  as  a 
complementary requirement. 

What: 

When: 

Who: 

How: 

Description 

All buildings below a certain threshold, which could be defined according 
to the EPC rating, must be upgraded to a better standard when there is 
a  change  of  occupancy  as  a  pre-condition  for  any  real  estate 
transaction. The threshold, defined by the building’s energy efficiency 
or climate performance level, should be higher than in MMR models 1 
and 2. Preferably the threshold should be aligned with the 2050 climate 
target, which could be defined in the country’s LTRS, aligned with nearly 
zero-energy  building  standards,  or  correspond  to  the  EU  Taxonomy 
Regulation.  

The  requirement  applies  after  the  sale  deed  has  been  signed  (i.e. 
building officially has a new owner). The MMR should allow for a grace 
period, giving the new owner time to comply with the requirement.  

Homeowners or real estate investors, who buy a building not complying 
with the minimum threshold.  

The  (local)  public  authorities  are  typically  informed  about  property 
transfers in their region, which should be accompanied by an EPC. The 
buyer of the building is aware of the requirement before the purchase 
and is given a grace period until a certain date by which the upgrade 
ought to be completed. Preferably these steps are defined by a BRP or 
an EPC with tailored renovation advice.  

The updated EPC, including the completed renovation, can be used to 
prove  compliance with  the requirements. Financial subsidies linked to 
the MMR model should  focus  on  fostering  renovations that go deeper 
than the minimum requirement – for example, to incentivise people to 
make their building ‘future proof’ in one deep renovation.  

Existing 
cases:  

Flanders  –  as  of  2021,  all  non-residential  buildings  are  required  to 
undergo a thorough energy renovation within five years after purchase 
to reduce their climate footprint. See the case study in Appendix 1. 

Table 9. Description of MMR Model 6 

Figure 31 provides an overview of the impact of MMR model 6 in the pre-defined impact 
and feasibility categories. See Appendix 3 MMR model 6 for a detailed analysis. 

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Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Impact and Feasibility MMR Model 6

Renovation rate

Ease of compliance

Simplicity

Maturity of tools

3

2

1

0

Renovation depth

Renovation quality

Cost-optimality

Renewables

Split incentive

Carbon neutrality 2050

Acces to housing

2030 GHG milestone

Figure 11: Impact and feasibility of MMR model 6 

Evaluation 

Impact evaluation: GOOD 

Triggering renovations in conjunction with property transfers can contribute to half of 
the targeted renovation rate (i.e. 3%/year deep renovations), which would initially be 
slowed down by the grace period99. The most logical metric for this model is energy 
need (i.e. kWh/m²) but it can also be linked to carbon impact (CO₂/m²).   The model 
does not influence buildings that are not being sold, or rented out, before 2050. The 
requirement could have a negative effect on the real estate market, as it brings an 
additional cost to most purchases.  

Feasibility evaluation: EXCELLENT 

Using  real  estate  transactions  as  the  trigger  point  simplifies  the  compliance 
procedures, as these are already reported to the local authorities. Most Member States 
also require the building to have an EPC when being sold or rented out.  

Illustrative impact assessment (on the French residential buildings stock100) 

MMR  model  5  is  modelled  as  capturing  the  1.9%/year  sales  from  2025  onwards  to 
trigger deep energy renovations (see Figure 32). Beyond what is already triggered by 
MMR model 1, MMR model 5 fosters earlier and deeper energy renovations. It has the 
potential  to  increase  the  results  reached  by  2030,  further  reducing  the  final  energy 
consumption by between 6% (two-stage renovations) and 8% (one-stage renovations), 
and  GHG  emissions  by  between  7%  (two-stage  renovations)  and  12%  (one-stage 
renovations) from the baseline in 2020. 

99 House transactions cover to ~2.3% of the housing stock (5 million dwellings a year including new builds) 
[source:  European  Central  Bank];  new  builds  contribute  0.5%/year  [source:  Deloitte  2017  Completed 
dwellings]. 
100 Further details are provided in Appendix 3 

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renovation and modernisation of the built environment  

Figure 12: Illustrative impact assessment of MMR model 5 on the French residential buildings 
stock cumulative to the MMR model 1. 

Short-term actions 

•  Since this MMR model targets real estate transactions that will take place in the 

short term, and on average once for each building by 2050, clear 
communication between all stakeholders is very important. There must be clear 
and effective communication between the real-estate sector, public authorities, 
renovation professionals and building owners. The role of the real-estate sector 
is essential, and effort should be made to make sure they understand the goals 
and societal benefits of the policy instrument.  

•  Clear communication of estimated renovation costs on top of the housing price 

during sales is crucial for building owners to understand the real costs. 

•  To foster one-time deep renovations, the renovation is ideally implemented at 
purchase and not within a predefined time frame after the transaction. For this 
to be possible, the quality and availability of deep renovation services need to be 
drastically improved (quality professionals easy to find, quick and qualitative 
project definition, quick implementation of the works).  

•  For step-by-step renovation approaches, the mandatory energy performance of 
building components should be related to the levels identified in the BRP.  

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renovation and modernisation of the built environment  

4.7.  Overview of the impact and feasibility of the MMR models  

Table 10 summarises the qualitative impact and feasibility assessment of the six MMR 
models. 

Excellent 

Good 

Moderate 

Poor 

MMR Model  

Impact  

Feasibility  Discussion of the impact  

1 

MMR  based 
on 
energy 
performance  

2 

MMR  based 
on 
carbon 
performance  

3 

MMR  based 
on  a 
real 
consumption 
carbon 
budget  

4 

MMR  based 
IEQ 
on 
indicators  

The implementation of the first MMR model can be 
based  on  existing,  yet  improved,  EPC  regimes. 
The  impact  can  be  considerable  but  depends  on 
the  policy  design,  including  the  level  of  the 
requirement,  exemptions  and  monitoring  and 
compliance  framework.  The  model  does  not 
integrate  operational  or  embedded  carbon 
emissions,  which  might  cause  an  unbalance 
between  energy  efficiency  and 
renewable 
investments. 

The implementation of this MMR can be based on 
existing, yet adjusted and improved, EPC regimes. 
The  model  focuses  on  carbon  emissions,  rather 
than  energy  performance,  enabling  cost-optimal 
solutions.  At  the  same  time,  the  model  could 
create  a  false  belief  that  the  building  envelope 
does not need to be upgraded to reach the future 
requirement. The model can also be  seen as the 
first  step  to  include  whole-life  carbon  aspects, 
which  needs  to  evolve  further,  in  terms  of  a 
common  standard  and  a  database,  to  be  able  to 
underpin this MMR model. The model can have a 
negative effect on data simplicity and compliance, 
even  though  CO2  emissions  from  operational 
energy are already featured in the EPCs of some 
Member States. 

MMR model 3 alleviates the ‘performance gap’ by 
focusing  on  actual  carbon  consumption.  The 
requirements  set  under  this  model  would  drive 
down  carbon  emissions  in  a  cost-optimal  way. 
Data  limitations  might  be  a  barrier  in  some 
Member States. The model will not solve the split-
incentive  dilemma,  as  the  responsibility  for 
reducing  energy  use  is  not  defined.  Landlords 
might  encourage  tenants  to  reduce  their  energy 
use instead of renovating. 

A  minimum  IEQ  requirement  would  trigger 
multiple benefits, such as lower health costs and 
increased  productivity.  There  is  a  risk  that  the 
renovations would be fragmented and designed to 
fix the specific IEQ deficit (e.g. improve ventilation 
if  air  quality  is  too  bad).  The  holistic  approach 
comes at the price of simplicity. The EPC tools and 
methodologies  would  need  to  be  adapted  to 

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renovation and modernisation of the built environment  

5 

MMR  based 
on a building 
renovation 
passport 

6 

MMR 
linked 
to  property 
transfers  

include  IEQ  although  there  is  currently  no 
universal  standard  of  how  this  can  be  done. 
Integrating IEQ metrics in the EPC would demand 
a more in-depth on-site visit and thus inflate the 
cost.   

The model relies on the BRP, which defines clear 
renovation steps that need to be implemented and 
their costs for each building. The overall quality of 
the implemented measures is higher and aligned 
with  the  long-term  target  (i.e.  avoids  economic 
and  technical  lock-in  effects).  Implementing  this 
model would not be too complex, as some of the 
conditions of producing a BRP are already in place 
and a few examples already exist, which could be 
replicated. An energy audit is a prerequisite for a 
BRP but also an opportunity to make a light LCA 
of the building., which will require some additional 
training  for  the  auditors.  The  whole-life  carbon 
consideration  will  just  inform  the  renovation 
decisions/steps  to  make  sure  they  are  taken  to 
optimise  the  carbon  reduction  potential  of  the 
building  (e.g.  locally  sourced  material,  natural 
components,  and  secure  an  end-of-life  recycling 
of materials).   

renovations 

Triggering 
in  conjunction  with 
property  transfers  can  contribute  to  half  of  the 
targeted  renovation  rate  (i.e.  3%/year  deep 
renovations).  The  most  logical  metric  for  this 
model is energy need (i.e. kWh/m²) but it can also 
be linked to  carbon impact (CO₂/m²). Using real 
estate transactions as the trigger point simplifies 
the compliance procedures, as these  are already 
reported  to  the  local  authorities.  Most  Member 
States  also  require  the  building  to  have  an  EPC 
when being sold or rented out. 

Table 10. Overview of feasibility and impact of MMR models 

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5.  STEP 3: POLICY PATHWAYS TO ESTABLISH MMR FOR EXISTING BUILDINGS 

IN THE EU  

Step  3  identifies  paths  the  EU  can  take  to  enforce  or  support  the  development  and 
formulation  of  MMR  for  existing  buildings,  including  the  wider  policy  framework,  as 
discussed in Step 1. While there are many ways forward for the EU, this section outlines 
four  pathways  that  would  be  effective  while  showcasing  the  flexibility  and  difference 
between different MMR models. 

Figure 13: Research flow diagram - Step 3 

The  decarbonisation  of  the  European  building  stock  needs  a  considerable  boost  to 
achieve  a  climate-neutral  Europe  by  2050.  The  improvement  of  existing  buildings 
remains too slow, with a renovation rate that lingers at 1%, while the deep renovation 
rate  is  only  around  0.2%.101  Many  barriers  are  hampering  a  transformation  of  the 
building stock, including lack of interest, insufficient understanding of energy use and 
savings, ‘split incentives’102, and the current capacity of the construction value chain. 
MMR for existing buildings has gained traction as a solution to overcome many of these 
obstacles.  

All the EU Member States must establish an LTRS to support the transformation of their 
building stocks to become highly energy efficient and decarbonised by 2050, including 
milestones for 2030 and 2040. LTRS must include an overview of the national building 
stock policies and actions to stimulate cost-effective deep renovation of buildings and 
to target the worst-performing buildings.  

The  recently  submitted  LTRS  and  the  national  energy  and  climate  plans  will  likely 
confirm that the new and planned measures are not enough to be on track for the 2050 
objectives.103  104There is a window of opportunity to introduce more stringent policies 
and  measures  to  meet  the  2050  target,  including  MMR  for  existing  buildings.  The 
Renovation Wave strategy also introduces a number of provisions, which will introduce, 
and support, MMR (see Figure 34).  

101 Ipsos & Navigant (2019) Comprehensive study of building energy renovation activities and the uptake of 
nearly zero-energy buildings in the EU. European Commission. (Available: Online) 
102 Split incentives occur when those responsible for paying energy bills (often the tenant) are not the same 
person as those making the capital investment decisions (often the landlord or building owner). 
103  See  review  of  the  first  12  LTRS  by  BPIE.  (2020).  “A  review  of  EU  Member  States’  2020  Long-term 
Renovation Strategies.” Available: Online) 
104 See European Commission’s assessment of National Energy & Climate Plans, which concludes “as far as 
energy efficiency is concerned, although the ambition level is higher than in the draft NECPs, the cumulative 
impact of the different NECPs still falls short of the existing energy efficiency target of 32.5%.” 

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Figure 14: Renovation Wave Strategy - relevant provision for MMR 

As discussed in Step 1, MMR for existing buildings could contribute to the objective of 
several  ongoing  and  new  strategies.  MMR  could  contribute  significantly  to  the 
Renovation  Wave  by  triggering  renovation  works  and  providing  a  clear  signal  to  the 
market. There are synergies with other initiatives, including the New Industrial Strategy 
for Europe, the SME Strategy for a Sustainable and Digital Europe, as well as the Circular 
Economy  Action  Plan  and  disclosures  relating  to  sustainable  investments  and 
sustainability risks.  

The objectives of the policy pathways are the same, but their approaches differ.  

•  Policy Pathway 1 aims to remove the worst-performing building in terms of 

energy performance by introducing a progressive minimum energy performance 
requirement for the existing buildings. The pathway has been designed to utilise 
existing infrastructure (esp. the EPC schemes) and existing directives (esp. the 
EPBD). The boost in demand for energy renovations will drive change in the 
construction value chain by requiring an improvement of the worst-performing 
building segments.  

•  Policy pathway 2 aims to get carbon emissions related to operational energy 

consumption  down to zero by 2050. MMR linked to carbon emissions, instead of 
energy performance, can better align the requirement with the long-term 
climate objectives, which are expressed in carbon emission levels. This MMR can 
drive increased demand for renovations, with an optimal balance between 
energy efficiency and renewable energy investments.  

•  Policy pathway 3 aims to get all carbon emissions down to zero by 2050 by 
considering whole-life carbon emissions. An MMR considering all carbon 
emissions can better align the requirement with the long-term carbon 
objectives, yet is much more complex to design and put in practice. A whole-life 
carbon standard would tend to favour the reuse of buildings and their materials 
as much as possible, and influence design decisions in both renovations and new 
constructions.    

•  Policy pathway 4: this pathway focus on capturing the trigger points in the 
building’s lifecycle to foster renovations through natural trigger points in a 
buildings life-cycle.  A renovation obligation linked to property transfers for all 
buildings, together with an MMR based on progressive energy performance 
requirements, will trigger even greater demand for renovation works and move 
all buildings towards the 2050 target.  

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5.1.  Policy  pathway  1: Progressive  minimum  energy  performance 

requirement 

Policy  Pathway  1  aims  to  alleviate  the  worst-performing  building  in  terms  of  energy 
efficiency by introducing a progressive minimum energy performance requirement for 
the existing buildings. The pathway has been designed to utilise existing infrastructure 
(esp. the EPC schemes) and existing directives (esp. the EPBD). The boost in demand 
for energy renovations will drive change in the construction value chain by requiring an 
improvement of the worst-performing building segments.   

pathway 

Policy 
performance 
requirements (expressed  in  kWh/m2/year)  and  can,  therefore,  build  on  the  existing 
policy framework. This MMR may be deployed via a new article in the EPBD and linked 
to the EPCs and LTRS.  

progressive  minimum 

energy 

sets 

1 

The  existing  cases  show  that  successful  MMR  must  be  integrated  into  a  wider  policy 
framework and be based on long-term progressive enforcement perspectives. To make 
policy pathway 1 effective, the EU and its Member States must support it through:  

• 

• 

Improvement of the penetration, reliability and awareness of EPCs, for example 
through higher and more harmonised requirements by the EU.  
Investment in skills in the construction value chain to make sure there are 
enough certified workers to carry out the additional work.  

•  Promoting the deployment of appropriate financing schemes, to ensure the 

accessibility and affordability of the renovation investments.  

•  Directing financial support to limit the negative effect on vulnerable groups, as 
well as to incentivise people to upgrade their building beyond the minimum 
requirement.  

•  Facilitating forums for good practice exchange. 
• 
•  Setting up a systematic approach to address the ‘performance gap’105 

Investing in awareness-raising activities among the public.   

Existing cases to learn from:  

•  The MEES in England and Wales set minimum performance ratings for landlords 
(i.e. private rented properties). The standard is currently set at EPC rating E. 
There is also a pending regulation in Scotland.   

•  The Netherlands – New requirement mandating EPC label C for office buildings 

from 2023.  

•  France – The primary energy consumption of residential buildings 

(kWh/m2/year), defined by an EPC, may not exceed 330 kWh by 2028. 

Pros  
+ Relatively easy to implement  
+ Builds on existing cases  
+ Easy for end-users to grasp 

Cons  
- The performance gap is a risk 
-  Risk  that  whole-life  carbon  emissions 
may    be  overlooked  if  not  addressed  by 
another measure 

105 The performance gap, referred here, is the disparity that can be found between the energy use predicted 
in the design stage of buildings and the energy use of those buildings in operation. 

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Figure 15: Policy pathway 1 - Timeline

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5.2.  Policy  pathway 2: Progressive  minimum  carbon  performance 

requirement    

Policy  pathway  2  aims to  get  carbon  emissions  related  to  operational  energy 
consumption down to zero by 2050. MMR linked to carbon emissions, instead of energy 
performance, can better align the requirement with the long-term  climate objectives, 
which are expressed in carbon emission levels. This MMR can drive increased demand 
for  renovations,  with  an  optimal  balance  between  energy  efficiency  and  renewable 
energy investments.  

Policy  pathway 2 sets  progressive  minimum carbon  performance requirements 
(expressed  in  CO2/m2/year  and  relating  to  operational  energy  consumption). For 
residential buildings, the pathway foresees that EPCs are updated to feature the carbon 
performance  of  the  building  more  reliably. For  non-residential  buildings,  the  carbon 
performance is derived from the actual energy consumption (e.g. as displayed by smart 
meters) and the local energy mix and the CO2 emission factor.  Carbon performance, in 
this  pathway,  focuses  on  the  emissions  as  a  result  of  the  operational  energy 
consumption. It does not include embodied carbon emissions, which a whole-life carbon 
approach would do (see Policy pathway 3). This carbon-oriented MMR would, however, 
require a broader regulatory framework.  

To  make  policy  pathway 2 effective,  the  EU  and  its  Member  States  must  support  it 
through:  

•  Updating EPCs to feature the building’s carbon performance, while also 

improving the instrument’s penetration, reliability and awareness. Under the 
EPBD, Member States already can define additional numeric indicators to 
express the energy performance of buildings, including in terms of greenhouse 
gas (GHG) emission produced in kgCO2eq/(m2/year), in addition to primary 
energy use. 

•  Exploring how to set a carbon performance requirement that balances energy 

• 

efficiency and renewable energy investments.  
Investing in skills, communication, financial support and good practice forums, 
as described under policy pathway 1.  

Existing cases to learn from:  

•  New York City, The United States: Local law 97 (for larger buildings) which 

specifies annual CO2 emission caps per building, depending on their size, number 
of occupant and use.   

•  France:  The Tertiary Renovation Decree (Décret Tertiaire) requires all buildings 
used by the tertiary sector to reduce their energy consumption by 40% by 2030. 
Similar to the New York case but sets the threshold in energy use instead of 
carbon emissions.  

•  Boston, Massachusetts, The United States: The city is planning to introduce 
mandatory carbon emissions targets by building type that decreases over 
time106.  

Pros  
+ Aligned with 2050 target   
+ Easy for end-users to grasp  
+  Cost-optimal  balance  between  energy 
efficiency and renewables 

Cons 
- Requires  considerable  revisions  of  the 
existing legislative basis 
- Some multiple benefits (better comfort, 
health  and  productivity  gains)  of  energy 
efficiency improvements at  risk of being 
missed   

106 See Nadel, S & Hinge A (2020) Mandatory Building Performance Standards: A Key Policy for Achieving 
Climate Goals. ACEEE (Available: Online) 

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Figure 16: Policy pathway 2 - Timeline

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5.3.  Policy  pathway 3: Progressive  minimum  carbon  performance 

requirement, considering whole-life carbon aspects 

Policy pathway 3 aims to get all carbon emissions down to zero by 2050 by integrating 
all  related  carbon  emissions. An  MMR  linked  to  carbon  emissions can  better  align  the 
requirement with the long-term climate objectives, yet is more complex to design and 
put in practice, because there is no common standard107 for how data can be gathered 
and  stored,  and  no  database  of  whole-life  carbon  data108  that  can  be  used  for 
benchmarking purposes. A whole-life carbon standard would have circularity as a key 
principle and would tend to favour the reuse of buildings and their materials as much 
as possible, and influence design decisions in both renovations and new constructions.    

Policy  pathway 3 sets  progressive  minimum carbon  performance requirements. The 
carbon  performance  requirement  should  gradually  go  on  to  also  consider  lifecycle 
performance  when  the  renovation  plan  is  developed  for  the  individual  buildings. The 
pathway  relies  on  reliable  building  data  being  available  and  attainable,  and  tailored 
renovation  recommendations  for  the  end-users,  which  can  be  ensured  by  the 
introduction  of  digital  building  logbooks109  and  building  renovation  passports110.  The 
whole-life  carbon  aspect  might  influence  the  renovation  stages  of  the  building,  what 
materials and strategies are suggested and when the measures will be carried out.  

To  make  policy  pathway 3 possible,  the  EU  and  its  Member  States  must  support  it 
through a number of enabling actions.  

Immediate actions 

•  Collecting and storing information on buildings’ life-cycle emissions, based on a 

common operational standard is needed and would increase transparency and 
awareness about embodied carbon. The life-cycle information should be 
compiled in a publicly available database, starting with public and new buildings.  
Introducing a whole-life carbon performance indication in the EPC and their 
renovation recommendations. The EPBD already makes it possible to the 
Member States to express the building performance using indicators additional 
to primary energy. One indicator could be whole-life carbon using a light LCA 
approach.  
Introducing and continuing the development of building renovation passports 
and digital building logbooks – these are an important link to enable whole-life 

• 

• 

107 The EU Level(s) framework is a protocol that brings together all relevant standards on whole-life carbon 
(and  other  aspects).  The  framework  could  be  evolved  to  enable  benchmarking  of  the  whole-life  carbon 
performance  and  thus  support  this  policy  pathway.  The  European  Standard  [EN  15978]  specifies  the 
calculation  method,  based  on  LCA  and  other  quantified  environmental  information,  to  assess  the 
environmental performance of a building, and gives the means for the reporting and communication of the 
outcome  of  the  assessment.  Several  other  European  and  ISO  standards  do  address  whole-life  carbon  and 
sustainability of buildings. See compilation in Bionova Ltd (2018) The Embodied Carbon Review (Available: 
Online).  While  most  existing  whole-life  carbon-standards  are  considered  too  “high-level”  by  industry 
professional, some are already considered operational and commonly used, one example is RICS (2017) RICS 
professional statement: Whole life carbon assessment for the built environment. (Available: Online).      
108 Sweden is currently introducing a climate declaration requirement for new constructions, which will enter 
into force on 1 January 2022 (see link). It includes “developing a national database containing climate data 
and  taking  measures  to  promote  carefully-considered  requirement  specifications  from  a  life-cycle 
perspective”. Databases like this are needed to support the inclusion of whole-life carbon considerations in 
new buildings and renovatin of existing buildings.  
109 A digital building logbook is a common repository for all relevant building data. It facilitates transparency, 
trust,  informed  decision  making  and  information  sharing  within  the  construction  sector,  between  building 
owners and occupants, financial institutions and public authorities.  
110 A Building Renovation Passport is defined as a document outlining a long-term step-by-step renovation 
roadmap for a specific building, resulting from an on-site energy audit and fulfilling specific quality criteria 
and indicators established in dialogue with building owners. As the passport is based on a detailed energy 
audit  it  is  well  placed  to  integrate  LCA  considerations.  See  European Commission’s  Technical  study  on  the 
possible introduction of optional building renovation passports (see link) 

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carbon assessments and informed decision-making and could store all the 
relevant life-cycle building data.  
Introducing LCA reporting requirements for larger public buildings and new 
constructions  

• 

•  Significant investments in skills, communication, financial support and good 

practice forums, as described under policy pathway 1.  

Subsequent actions  

•  Exploring how LCA and related validation/compliance can be included cost-
effectively. Pilot cases can help testing and validation of the approach.  
•  Continuing the development of Level(s)111 which is based on established LCA 

assessment tools and, implicitly, whole-life carbon.  
Introducing LCA reporting requirements for all buildings in connection with EPC   

• 

Existing cases to learn from:   

No existing case is currently integrating whole-life carbon considerations.  

Pros  

Cons  

to 

into 
carbon 
thereby  contributes 
carbon 

+ Takes  whole-life 
account   and 
further 
reduction targets 
+  LCA  will  steer  the  market  towards 
more  sustainable  options,  resulting  in 
wider benefits 

the  national 

time 

require 

the  whole-life  carbon  data 
and 

-Setting  up 
infrastructure  will 
considerable investments   
-  Requires  considerable  revisions  of  the 
existing regulatory framework  
- More  difficult  for  homeowners  to  grasp  and 
more difficult to communicate broadly  
-  Technically  and  administratively  more 
complex  
- Require additional training for energy experts 
and construction professionals  

111 Level(s) is a common European approach to assess and report on the sustainability of buildings. 

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Figure 17: Policy pathway 3 - Timeline

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5.4.  Policy  pathway  4:  Moving  all  buildings  towards  the  objective  of  a 

decarbonised building stock by 2050 

The  focus of  the  policy  pathway  4  is  to  capture the  key  trigger  points  in  a 
building’s lifetime in addition to progressive enforcement of minimum requirements. The 
pathway goes beyond tackling just the worst-performing buildings, as it applies to 97% 
of  all  buildings112.  Trigger  renovation  concerning  property  transfers  could foster  an 
effective and smooth transition towards the 2050 objective. The additional cost for the 
property  buyer  to  upgrade  the  building’s  EPC  label  with  1-2  steps,  will  amount  to  a 
fraction, on average, of the cost of buying the property, which can be incorporated in 
the total cost.  Prospective building owners would be made aware of this requirement 
and can thus plan accordingly. A link with energy efficiency mortgages113 could reduce 
the extra financial burden of this requirement.  

Policy pathway 4 combines two MMR models:  

1.  The first sets a renovation obligation for all properties that are being sold and 
does not already have an EPC label A (or what rating is required for the specific 
building to be compliant with the 2050 requirement).  

2.  The  second  sets  progressive  minimum  energy  performance  requirement  for 
operational energy consumption for all buildings to make sure that all the worst-
performing buildings are being upgraded (as in policy pathway 1).  

To  make  policy  pathway 4 effective,  the  EU  and  its  Member  States  must  support  it 
through:  

•  Updating EPCs and improving the instrument’s penetration, reliability and 

• 

• 

awareness.  
Improving the information available on the real estate market and raise 
awareness of all stakeholders involved in real estate transactions. 
Investing in skills, communication, financial support, and good practice forums, 
as described under policy pathway 1.  

Existing cases to learn from:   

•  France: The Energy and Climate Law (Loi 2019-1147), which states that if the 

building does not meet the minimum standard, at the point of sale or rent, from 
2028 (primary energy consumption exceeds 330 kWh/m2/year), an energy audit 
must be performed which includes suitable renovation measures to meet the 
minimum standard. 

Pros  
+ Boosts the renovation activities   
+  All  buildings  (except  the  highest-
performing ones) must comply, which 
can increase the overall acceptance 

Cons  
- Possible  negative  effect  on  the 
housing  market,  as  the  buildings 
would  be  relatively  more  expensive 
with this requirement  
Confusing  mix 
- 
requirements, 
understand and communicate 

of 
challenging 

different 
to 

112 See BPIE’s analysis of EU’s building stock based on EPC data, where only 3% of existing buildings have an 
EPC label A. (Available: Website) 
113 An energy efficient mortgage is a loan product that allows borrowers to reduce their utility bill costs by 
allowing  them  to  finance  the cost of  incorporating  energy-efficient features  into  a  new purchase.  See:  the 
work of the Energy Efficiency Mortgage Initiative (Available: Webiste) 

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Figure 18: Policy pathway 4 - Timeline

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6.  STEP 4: IMPACT AND FEASIBILITY DISCUSSION  

This chapter summarises the impact and feasibility assessment of different MMR models 
and  identified  policy  pathways.  The  chapter  first  recaps  the  central  EU  policy  options 
followed by an impact and feasibility discussion. The subsequent section describes the 
impact  of  the  identified  policy  pathways,  followed  by  a  section  that  summarises  the 
impact  and  feasibility  of  the  MMR  models.  The  sections  on  impact  and  feasibility  are 
followed by a short discussion.  

Figure 39. Research flow diagram 

6.1.  What can the EU do to introduce MMR for existing buildings?  

The impact of the MMR depends on how any regulatory requirements will be defined in 
the EU regulatory framework and, more importantly, how any EU regulatory framework 
will be transposed and implemented by the Member States. Several broad alternatives 
exist. The EU could:  

•  Encourage Member States to implement MMR for existing buildings and support 
the development of existing cases. The encouragement could, for example, 
comprise of financial streams dedicated to implementing MMR or strong 
recommendations based on policy gaps identified in NECP and LTRS.   

•  Mandate Member States, through the EPBD revision, to implement MMR for their 
building stock (or parts thereof), while leaving flexibility to the Member States to 
design the requirement (similar to the EPC regulations).  

•  Set an energy-saving or renovation obligation for the Member States based on 

results (as with article 5 or 7 of the EED). MMR could then be one way to 
achieve this result.  

To contribute effectively to the 2050 target,  MMR needs to become fully operational in 
the next 5-7 years, as a later introduction would require a  steep and sudden increase 
of  the  renovation  rate  that  would  be  impractical  for  the  construction  value-chain  to 
materialise.  The  implementation  date  should  be  carefully  balanced  between  the  need 
for  immediate  impacts,  the  need  for  a  well-designed  MMR  and  the  readiness  of  the 
market. 

Regardless  of  how  and  when  and  at  what  level  MMR  is  introduced,  it  needs  to  be 
supported by a  wider policy  framework. Many  of the  supportive measures depend on 
the local context, but the analysis of existing cases shows that the introduction of MMR 
must be accompanied by several supportive measures to become feasible.  

•  Financial support schemes to make the requirement more palatable for key 

stakeholders, especially the building owners.  The review of existing cases shows 
that the requirement should be accompanied by financial support (grants, low-
interest loans) and technical support (such as free energy advice). Financial 
support could also be used to lessen the additional burden on vulnerable groups 
and stimulate early compliance. Often a considerable share of the worst-
performing building stock is owned/rented by people that are vulnerable to a 
cost increase. Finally, financial support can incentivise real estate investors and 
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building owners to renovate beyond the minimum requirement and do so earlier 
rather than later.  

•  Reliability and usability of the EPC must be improved to enable successful 

implementation and enforcement of MMR. The EPC schemes, in most Member 
States, will need to be improved and adjusted for the specific purpose. The 
Renovation Wave strategy proposes the introduction of the novel instruments of 
Building Renovation Passports and Digital Building Logbooks, which currently 
only exist in a few Member States. These instruments could support and 
strengthen the EPC schemes, by offering better renovation advice and 
facilitating links to third-parties, such as one-stop-shops.  

•  Public awareness and acceptance are key for effective implementation of MMR. 
People should be aware of the requirement itself as well as the purpose and 
most importantly the benefits behind it. Lessons learnt from existing cases show 
that it is difficult to get the right information out there. Support can be given to 
the Member States to carry out tailored communication campaigns and 
integrated renovation services, such as one-stop-shops, to make the ‘renovation 
journey’ smoother.  

•  Skills in the construction value chain. A skilled workforce is required to realise 

the renovation boost that will be triggered by MMR. Investments are needed in 
training and capacity building, to make sure there are enough skilled workers to 
carry the Renovation Wave when it arrives.  

Consistency with subsidiarity and proportionality principles 

The EU’s ability114 to decide  over  the Member States  on  energy and climate issues is 
guided  by  the  principles  of  subsidiarity  and  proportionality.  The  subsidiarity  principle 
states that the EU shall act only if and in so far as the objectives of the proposed action 
cannot be sufficiently achieved by the Member States. This principle thus aims to ensure 
that  decisions  are  taken  as  closely  as  possible  to  the  citizens.  The  development  of 
integrated  common  energy  and  climate  policies  has  been  found  compliant  with  this 
principle,  to  ensure  that  the  region  achieves  its  agreed  objectives.  It  therefore  only 
seems feasible to have an EU-wide generic MMR provision in respect of subsidiarity and 
proportionality if it leaves the flexibility to the Member States decide on the details (e.g. 
the specific performance standard below which it would mandatory to renovate). 

The principle of proportionality is twofold. It aims to ensure that the proposed action is 
capable of attaining the intended objective (‘appropriateness’) and does not go beyond 
what  is  necessary  to  attain  the  objective  (‘indispensability’).  This  means  that  the 
proposed  action  cannot  be  replaced  by  an  alternative  form  of  action  with  equal 
effectiveness, but which would be less far-reaching in terms of the effect on the residual 
powers of the Member States.  

Impact  assessments  form  a  key  part  of  the  Commission's  better  regulation  agenda, 
which  seeks  to  design  and  evaluate  EU  policies  and  laws  so  that  they  achieve  their 
objectives most efficiently and effectively. The revision of the EPBD will be accompanied 
by an impact assessment, which is expected to also address the introduction of MEPS.  

Property Rights 

According to article 17 (1) of the Charter of Fundamental Rights of the European Union 
(2012/C 326/02), “Everyone has the right to own, use, dispose of and bequeath his or 
her lawfully acquired possessions. No one may be deprived of his or her possessions, 
except in the public interest and the cases and under the conditions provided for by law, 
subject  to  fair  compensation  being  paid  in  good  time  for  their  loss.”  It  further  states 

114 The EU’s ability to take action on energy and energy efficiency issues is enshrined in  Article 194 of the 
Treaty on the Functioning of the European Union 

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that  “The  use  of  property  may  be  regulated  by  law  in  so  far  as  is  necessary  for  the 
general interest.” 

The introduction of an MMR will not deprive any property owner of his or her building. 
In  line  with  many  stakeholders’  view,  apart  from  allowing  sufficient  lead  time,  it  is 
recommended to provide financial support alongside an MMR scheme, which could partly 
compensate for  financial investments the MMR  requires the property  owner to make. 
Financial  support  is,  however,  not  considered  as  necessary  to  allow  for  intervention 
under  the  Charter  of  Fundamental  Rights  of  the  European  Union,  since  more 
importantly,  the  introduction  of  an  MMR  in  the  Member  States  will  serve  the  general 
interest. MMR is considered as a key instrument to decarbonize the building stock and 
secure sustainable energy supply to citizens of the European Union addressing one of 
the  most  persistent  barriers  against  deep  energy  renovation,  the  split  incentive 
dilemma. In addition, the measures will lead to an increase in health and well-being of 
a significant share of the population and a general increase of the property value, also 
in view of rising carbon prices. 

6.2. 

Impact of the policy pathways  

The policy pathways build on ideas from existing MMR cases, a wider analysis of the EU 
directives and instruments, as well as stakeholder inputs.115 As discussed in the previous 
section, the impact of the policy pathways will, to a large extent, depend on the scope 
and  form  of  the  legal  provision.  If  the  MMR  is  mandated  by  the  EPBD  (or  another 
directive)  it  will  be  more  effective  than  if  MMR  comes  in  the  format  of  best  practice 
exchange and encouragement by the EU. Table 4 discusses the relative impact of the 
different models, given their timelines and included MMR models.   

Excellent 

Good 

Moderate 

Poor 

Policy pathway 

Discussion of the potential impact  

Policy pathway 1: 
Progressive 
minimum 
performance 
requirement  

energy 

The  potential  impact  of  the  pathway  based  on  energy 
performance  requirements  is  good.  The  pathway  utilises 
existing  infrastructure  (i.e.  EPC  regimes)  and  directives 
(i.e.  EPBD),  which  could  make  the  required  preparation 
time shorter and communication easier. The sole focus on 
energy  performance  will  reduce  the  energy  need  in 
buildings  but  might  not  necessarily  result  in  the  required 
carbon emission reductions due to the “rebound effect” (i.e. 
performance  gap).  The  EU  can  mitigate  these  adverse 
effects  by  researching  how  the  performance  gap  can  be 
alleviated and with other measures supporting the uptake 
of 
sources.  Triggering  partial 
renovations, without the support of a BRP, there is a risk 
that MMR will lock out future cost-optimal measures.116  

renewable  energy 

Policy pathway 2: 
Progressive 
minimum 

carbon 

The  estimated  impact  of  the  pathway  based  on  carbon 
performance requirements is excellent. The scope focuses 
on  the  carbon  emissions  stemming  from  the  use  of  the 

115 The stakeholder input includes the results of the online survey and the workshop on 14 May, at which 94 
stakeholders participated. A few stakeholders have also shared their statements in a bilateral correspondence 
with the consortium.  
116  This  will  rarely  by  the  case  with  incremental  improvements  of  the  worst-performing  buildings,  such  as 
when improving the building from an EPC F to an EPC E. For the building to become a low-energy building, 
the renovation sequence ought to planned as early as possible.  

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performance 
requirement 

carbon 

Policy pathway 3: 
Progressive 
minimum 
performance 
requirement, 
considering 
whole-life 
footprint   

the 
carbon 

Policy Pathway 4: 
Moving all buildings 
the 
towards 
a 
objective 
decarbonised 
building  stock  by 
2050 

of 

building.  The  pathway  requires  a  more  substantial 
modification  of  the  existing  infrastructure  (i.e.  EPC 
regimes)  and  directives  (especially  EPBD  and  Renewable 
Energy Directive (RED)), which will cause a longer starting 
distance.  The  pathway  assumes  higher  carbon  reductions 
than the first pathway because of the shift in metrics of the 
requirement,  from  energy  to  carbon  performance.  The 
performance  gap  will  remain  a  barrier.  The  triggered 
measures will directly aim to reduce the carbon footprint of 
the building. As with pathway 1, without the support of a 
BRP, there is a risk that the MMR will lock out future cost-
optimal measures.117  

The  projected  impact  from  the  pathway  based  on  whole-
life carbon requirements is excellent. The scope focuses on 
all carbon emission stemming from the whole life-cycle of 
the  building.  The  pathway  requires  a  very  substantial 
modification  of  the  underlying  logic  of  the  existing 
infrastructure  (i.e.  EPC  regimes),  directives  (especially 
EPBD,  RED,  Waste  Framework  Directive)  and  operational 
whole-life  carbon  standard  (e.g.  built  on  Level(s)),  which 
will cause a longer starting distance, exacerbated also by 
e.g. data and methodological gaps, delaying the impact. 

 The  pathway  assumes  economy-wide  carbon  reductions 
because  all  carbon  emissions  are  integrated  into  the 
requirement.  A  whole-life  carbon  standard 
trigger 
circularity as a key principle and would tend to favour the 
reuse of buildings and their materials as much as possible, 
and influence design decisions in both renovations and new 
constructions. Finally, the requirement would send a very 
strong  signal  to  the  construction  value  chain  to  improve 
resource efficiency and adopt climate-friendly processes.  

The  estimated  impact  of  the  pathway  focusing  on  trigger 
points  is  good.  The  pathway  requires  adjustments  of  the 
existing  infrastructure  (i.e.  EPC  regimes)  and  directives 
(especially  EPBD  and  RED),  which  will  cause  a  longer 
starting  distance.  The  renovation  obligation  at  property 
transfer for all buildings, except the ones already complying 
with  the  long-term  objective,  would  trigger  additional 
renovation works. The impact assessment of MMR model 6 
indicates  that  adding  a  renovation  obligation  to  a 
progressive  timeline,  as  suggested  in  this  pathway,  will 
increase  the  final  energy  reductions  with  6%  and  8%  on 
top  of  the  savings  made  by  the  progressive  minimum 
requirement model. 

Table 11. Overview of the impact of policy packages 

117  This  will  rarely  by  the  case  with  incremental  improvements  of  the  worst-performing  buildings,  such  as 
when improving the building from an EPC F to an EPC E. For the building to become a low-energy building, 
the renovation sequence ought to planned as early as possible.  

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6.3.  Feasibility of the policy pathways  

The feasibility assessment comprises an analysis of the possibility for the EU to introduce 
this specific pathway, including how it can be incorporated and operationalised based 
on existing directives, as well as how it complies with the subsidiarity and proportionality 
principles. The assessment does also reflect how easily it can be  implemented by the 
Member  States,  including  its  applicability  to  existing  instruments,  simplicity  of  the 
suggested MMR and its ease of compliance.  

The feasibility of the first pathway is the highest, which foresees progressive minimum 
energy performance requirement, as it is a practical and natural evolution of the existing 
policy  framework,  including  the  EPC  and  LTRS.  The  other  pathways  require  more 
substantial work, both in terms of legislative developments and improving and setting 
up supporting structures and frameworks. As indicated at the beginning of this chapter, 
the  political  feasibility  will  depend  on  the  stringency  of  the  provision  and  which 
supporting measures accompany the provision. Table 5 summarises the key points.  

Excellent 

Good 

Moderate 

Poor 

Policy pathway 

Discussion of the feasibility  

Policy  pathway  1: 
Progressive  minimum 
energy  performance 
requirement  

Policy  pathway  2: 
Progressive  minimum 
carbon  performance 
requirement 

Policy  pathway  3: 
Progressive  minimum 
carbon  performance 
requirement, 
considering 
whole-life 
footprint   

the 
carbon 

The feasibility is good. The EU can introduce a general 
obligation while leaving flexibility to the Member States 
to  decide  on  exact  implementation.  The  MMR  model 
suggested in the pathway would be a natural extension 
of  the  current  EPBD.  The  EPC  schemes  will  have  to  be 
improved  across  the  EU,  in  terms  of  reliability  of  the 
ratings  and  their  availability.  Most  countries  EPC 
databases must also be updated to ensure it can be used 
to check compliance with the minimum standard.   

The  feasibility  is  moderate.  The  EU  can  introduce  a 
general obligation while leaving flexibility to the Member 
States to decide on exact implementation. The carbon-
oriented pathway would change in the scope of the EPBD 
and  shift  focus  from  primary  energy  to  carbon.  The 
revision  of  Article  11  of  the  EPBD  could  introduce  a 
requirement to also measure and display the operational 
carbon emission level, which then could be used in the 
MMR. As with Pathway 1, the EPC schemes will have to 
be improved across the EU, in terms of reliability of the 
ratings  and  their  availability.  Most  countries  EPC 
databases must also be updated to ensure it can be used 
to check compliance with the minimum standard.   

The  feasibility  is  moderate.  The  EU  can  introduce  a 
general obligation while leaving flexibility to the Member 
States  to  decide  on  exact  implementation.  The  whole-
life  carbon-oriented  pathway  would  require  changes  in 
the scope of the EPBD. The first step would require public 
authorities  and  the  construction  value-chain  to  start 
collecting  data  to  this  end  through  e.g.  a  common 
standard. An MMR linked to carbon emissions can better 
align  the  requirement  with  the  long-term  climate 
objectives, yet is much more complex to design and put 

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Policy  Pathway  4: 
Moving  all  buildings 
towards  the  objective 
of  a  decarbonised 
building 
by 
2050 

stock 

in practice, because there is no common standard118 for 
how data can be gathered and stored, and no database 
of  whole-life  carbon  data119  that  can  be  used  for 
benchmarking purposes. ).  

The proposed introduction of Digital Building Logbooks, 
could  together  with  the  Level(s) 
framework  and 
Construction  Product  Declaration,  comprise  and  carry 
the  required  information  related  to  embodied  carbon. 
Yet, these frameworks are still novel and would require 
a substantial preparation time, which is foreseen in the 
pathway timeline.     Energy experts and auditors would 
need  the  training  to  be  able  to  consider  the  whole-life 
carbon impact in their EPC/BRP recommendations.  

The  feasibility  is  moderate.  The  EU  can  introduce  a 
general obligation while leaving flexibility to the Member 
States  to  decide  on  exact  implementation.  MMR  based 
on  property  transfers  could  face  difficult  acceptance 
among  stakeholders.  At  the  same  time, 
if  the 
requirement  applies  to  almost  all  building  owners, 
people will perceive it as more ‘fair’ as everyone will have 
to contribute to the common goal of mitigating climate 
change  through  energy  renovations.  The  enabling 
infrastructure is already in place on most MS. Most local 
authorities  have  registries  of  property  owners  in  their 
jurisdictions, which in many regions are obliged to pay 
property  tax  (and/or  property  purchase  tax).  As  with 
Pathway 1, the EPC  schemes will have to be improved 
across the EU, in terms of reliability of the ratings and 
their  availability.  Most  countries  EPC  databases  must 
also  be  updated  to  ensure  it  can  be  used  to  check 
compliance with the minimum standard.   

Table 12. Overview of the feasibility of policy pathways 

118 The EU Level(s) framework is a protocol that brings together all relevant standards on whole-life carbon 
(and  other  aspects).  The  framework  could  be  evolved  to  enable  benchmarking  of  the  whole-life  carbon 
performance  and  thus  support  this  policy  pathway.  The  European  Standard  [EN  15978]  specifies  the 
calculation  method,  based  on  LCA  and  other  quantified  environmental  information,  to  assess  the 
environmental performance of a building, and gives the means for the reporting and communication of the 
outcome  of  the  assessment.  Several  other  European  and  ISO  standards  do  address  whole-life  carbon  and 
sustainability of buildings. See compilation in Bionova Ltd (2018) The Embodied Carbon Review.  
119 Sweden is currently introducing a climate declaration requirement for new constructions, which will enter 
into  force  on  1  January  2022  (Available:  Website).  It  includes  “developing  a  national  database  containing 
climate data and taking measures to promote carefully-considered requirement specifications from a life-cycle 
perspective”. Databases like this are needed to support the inclusion of whole-life carbon considerations in 
new buildings and renovatin of existing buildings.  

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7.  STEP 5: CONCLUSION  

The decarbonisation of the European building stock needs a considerable boost to meet 
the  net-zero  ambition  by  2050.  The  improvement  of  existing  buildings  remains  slow, 
with a renovation rate that lingers at 1%, while the deep renovation rate is only around 
0.2%.120 There are many reasons for these low rates, including low energy prices, split 
incentives,  the  current  capacity  of  the  construction  value  chain,  the  ambiguous  link 
between the building’s performance and the real estate value, and the lack of awareness 
of the benefits stemming from energy renovations.  

This closing chapter summarises the main findings of this report.  

Figure 40: Research flow diagram – Step 5 

All EU countries must establish LTRS to support the renovation of their national building 
stock into a highly energy-efficient and decarbonised building stock by 2050, including 
milestones for 2030, 2040 and 2050. The LTRS must include, among other things, an 
overview  of  the  national  building  stock,  and  policies  and  actions  to  stimulate  cost-
effective deep renovation of buildings and to target the worst-performing segments. The 
recently submitted LTRS and the national energy and climate plans might confirm that 
the new and planned measures are not enough to be on track for the 2050 objectives.121 
This shows the need for better implementation of existing policies and measures along 
with  introducing  more  stringent  policies  and  measures  to  meet  the  2050  target, 
including MMR for existing buildings. 

The analysis in this report shows that, if designed properly and embedded in a wider 
policy  framework,  MMR  can  overcome  many  of  the  barriers  the  renovation  market  is 
facing, including lack of interest in energy renovations, insufficient awareness of energy-
saving potential and the split-incentives dilemma.  

All the MMR models would have a considerable impact on the European building stock.  

• 

• 

Introducing a progressive minimum energy performance requirement would 
trigger the renovation of the worst-performing buildings and send a clear signal 
to the real estate market. Not aligning the underlying with operational carbon 
use or whole-life carbon, risk some suboptimal investments if the main objective 
of this policy tool is to reduce carbon emissions.  
Introducing a progressive minimum carbon performance requirement would 
better align with the long-term climate objectives, which are expressed in 
carbon emission levels. This MMR can drive increased demand for renovations, 

120 Ipsos & Navigant (2019) Comprehensive study of building energy renovation activities and the uptake of 
nearly zero-energy buildings in the EU. European Commission. (Available: Online) 
121 See review of the first 12 LTRS by BPIE (2020) A review of EU Member States’ 2020 Long-term Renovation 
Strategies. (Available: Online) 

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• 

with an optimal balance between energy efficiency and renewable energy 
investments. 
Introducing a progressive minimum carbon performance requirement, 
considering whole-life carbon aspects, would have the potential to get all carbon 
emissions down to zero by 2050 by integrating all related emissions. Yet, this 
MMR is more complex to design and put in practice. This MMR would require a 
decisive and concerted effort between different ongoing policy initiatives 
supporting the circular economy. It would moreover necessitate public 
authorities in MS and the construction value-chain to start collecting data. A 
whole-life carbon standard would tend to favour the reuse of buildings and their 
materials as much as possible, and influence design decisions in both 
renovations and new constructions.    

•  Moving all buildings towards the objective of a decarbonised building stock by 
2050 by capturing the key trigger points in a building’s lifetime in addition to 
progressive enforcement of minimum requirements. The MMR goes beyond 
tackling just the worst-performing buildings, as it applies to 97% of all buildings.  

MMR  for  existing  buildings  is  also  being  implemented  around  Europe  and  the  United 
States and described as a policy tool with the potential to increase the renovation rate. 
The UK, France, the Netherlands and two regions in Belgium (Flanders and Brussels) 
have implemented or are planning to implement MMR for existing buildings to improve 
the quality of the worst-performing buildings. In France and Flanders, their 2050 targets 
drive the introduction and implementation of MMR as part of the delivery mechanism. 
MMR for existing buildings is also gaining ground in the United States, with several cities 
and municipalities implementing carbon emission limits for certain buildings.  

The EPC framework is the most obvious reference point for introducing MMR for existing 
buildings.  The  purpose  of  the  EPC  is  to  provide  information  on  a  building’s  energy 
performance status and to offer suggestions for cost-effective improvements, while less 
suited for considering whole-life carbon aspects at present. On an aggregate level, they 
offer  information  about  the  building  stock  and  how  it  can  be  decarbonised.  The 
comparability of EPCs across the EU (in terms of aspects like calculations, control and 
data  availability)  needs  further  improvement.  EPCs  already  have  a  link  to  voluntary 
carbon metrics, where a change in the main scope would require additional legislative 
efforts, in addition to the significant reinforcement and harmonisation already planned 
in the Renovation Wave strategy.  

Alternatively, MMR can be linked to real energy consumption or climate footprint, which 
can be derived through smart meters and/or utility bills. The MMR can also be defined 
as a renovation obligation linked to specific trigger points, such as property transfers or 
non-energy renovation works, which is not reliant on the standard of the building. The 
most  effective  MMR  policy  packages  combine  an  enforcement  calendar  (i.e.  the 
requirement is set by a specific year and enforced according to a defined timeframe) 
with specific trigger points.  

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Development since the EPBD Impact Assessment [SWD(2016) 414 final] 

The potential and feasibility of MMR for existing buildings (Measure 1B: Oblige the 
renovation of buildings to reach a given standard before transactions), was evaluated 
in  2016  EPBD  Impact  Assessment.  While  viewed  as  effective  in  increasing  the 
renovation rate and in reducing energy poverty, an MMR was considered not feasible 
due  to  “uncertain  impact  on  the  real  estate  market  and  probably  stepping  out  of 
subsidiarity  and  proportionality  limits  of  EU  intervention”.  It  was  also  noted  that 
“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.”.  

The identified issues remain in place and have been discussed in this report. Below 
is a summary of these considerations.  

1.  The  impact  on  the  real  estate  market  remains  uncertain  but  the  lessons 
learned we can draw at this point, suggest the impact will be positive. In the 
Netherlands,  a  significant  increase  of  investments  in  renovation  works  of 
commercial  properties  has  already  been  observed  in  anticipation  of  the 
regulation  scheduled  to  come  into  force  in  2023,  which  requires  office 
buildings  to  have  an  EPC  of  C.  Furthermore,  MMR  will  also  provide  a  clear 
signal  to  the  market  that  non-compliant  assets  are  at  risk  of  value 
depreciation  or  becoming  stranded  assets.  Having  a  clearer  value 
differentiation and implicitly, a stronger link between energy performance and 
property value will help improving the business case and decision marking for 
investing in renovations. 

2.  The issue of subsidiarity and proportionality will depend on how the MMR is 
regulated and  enforced by the EU. An uniform design risks  departing from 
the subsidiarity and proportionality principles and not capturing local context 
and  needs.  The  experts  consulted  in  this  study,  do  not  see  the  issue  of 
subsidiarity  and  proportionality  as  major  obstacle,  if  the  MMR  principle  is 
established  and  enforced  through  the  EPBD,  and  then  designed  and 
implemented by the Member States within certain defined boundaries. While 
a  one-size-fits-all  approach  is  in  all  likelihood  not  possible,  the  EU  and  its 
Member States should strive for as much harmonisation as possible because 
the  signal  to  the  real  estate  market  would  be  stronger  and  more 
unambiguous, while also increasing synergies and learnings across borders.  
3.  The  lack  of  reliable  and  granular  data  of  the  building  stock  is  still  a  large 
obstacle. Most Member States rely on the EPC databases for information about 
their building stock, while few databases have been designed for this purpose. 
Since 2016, a large number of advanced EPC databases have appeared and 
evolved (e.g. Denmark and Ireland), together with digital building logbooks 
(Woningpas in Flanders and Casa+ in Portugal), material passports (Madaster 
in  the  Netherlands  and  Basta  in  Sweden)  and  a  whole-life  carbon  database 
(Climate declaration database in Sweden). The Renovation Wave strategy set 
out  to  further  improve  the  EPC  databases  and  introduce  digital  building 
logbooks, which are needed to underpin the introduction of an MMR.  

Potential impacts on the real estate market 

MMR can have significant effects on shaping business models and investment decisions 
in the real estate sector.  

First, the introduction of MMR will mean that real estate managers and practitioners will 
have  to  consider  the  performance  of  buildings  and  find  it  easier  to  draw  up 
decarbonisation strategies, identify reliable targets and actions to improve performance, 
as  well  as  communicate  and  demonstrate  compliance  with  MMR  in  a  consistent  way. 

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Certainty  around  MMR  makes  the  business  case  of  investing  in  energy  efficiency 
improvements more compelling.  

Second,  MMR  will  incentivise  property  markets  to  differentiate  according  to  energy 
performance  and  will  likely  make  the  link  between  energy  performance  and  market 
value (or investment worth) more visible and direct. In this sense, MMR can contribute 
to a price correction to reflect the performance of the building and/or affect the cash 
flow  of  non-compliant  stock.  Such  effects  are  seen  as  beneficial  because  energy 
performance  is  not  yet  adequately  reflected  in  property  valuations,  investment  and 
financing decisions, as well as the by real estate markets in general. 

MMRs  are  primarily  aimed  at  increasing  the  rate  of  upgrades  to  existing  inefficient 
properties  and  raise  awareness  of  energy-related  issues.  In  the  Netherlands,  a 
significant  increase  of  investments  in  renovation  works  of  commercial  properties  has 
already been observed in anticipation of the regulation – which requires office buildings 
to have an EPC of C – scheduled to come into force in 2023. On the other end, MMR will 
also provide a clear signal to the market that non-compliant assets are at risk of value 
depreciation  or  becoming  stranded  assets.  Real  estate  investors  and  landlords  may 
discriminate against buildings with low ratings within their portfolio strategies and seek 
to divest of stock that is either at risk or fails to meet the MMR standards. Others might 
acquire non-compliant properties and bring them up to standard if this is economically 
feasible. Properties in prime locations are less likely to be affected negatively in value 
terms by MMR, but all properties of poor specification and energy efficiency, which are 
expensive to upgrade, may reduce in value.  

Third,  beyond  the  changing  market  preferences,  lenders,  investors  and  insurers  may 
also  start  factoring  in  the  risk  implications  of  MMR.  This  can  take  the  form  of  either 
preferential  financing  conditions  for  better  performing  assets  or  limited  access  to 
financing if they do not meet MMRs. If better-performing properties can attract cheaper 
financing,  this  could  positively  impact  the  value  of  such  properties.  Conversely,  if 
financing  and  insuring  sub-standard  properties  become  more  difficult  or  more 
expensive, it could negatively impact their market value. 

The introduction of an MMR scheme is not regarded as counteracting article 17 (1) of 
the Charter of Fundamental Rights of the European Union (2012/C 326/02) on property 
rights.  The  introduction  of  an  MMR  will  not  deprive  any  property  owner  of  his  or  her 
building.  It  rather  serves  the  general  interest  since  MMR  are  considered  as  a  key 
instrument to decarbonize the building stock and secure sustainable energy supply to 
citizens  of  the  European  Union.  In  addition,  the  measures  will  lead  to  an  increase  in 
health and well-being of a significant share of  the population and general increase  of 
the property value, especially in view of rising carbon prices. 

Social implications  

The  MMR  has  the  potential  to  contribute  to  ensuring  decent  homes  and  a  bearable 
energy  bill  for  Europeans,  by  alleviating  the  worst-performing  dwellings.  34  million 
households (or 13.90% of the population) are living in inadequate dwellings throughout 
the  EU,  defined  as  dwellings  with  leaking  roofs,  damp  walls,  etc122.  These  buildings 
correlate strongly with the worst-performing buildings, which in addition to the health 
issues comes with high energy costs for the tenants. Renovating these buildings would 
reduce energy poverty levels as well as related health-care costs.   

At the same time, policymakers need to consider the financial burden that comes with 
an MMR, as many landlords and private building owners may struggle to cover the extra 
cost. Therefore, affordability of renovations and prevention of energy poverty should be 

122 See EU’s Energy Poverty Obsevatory (Available: Website) 

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guaranteed by an enabling framework with financial measures for building owners and 
residents, especially the most vulnerable ones.  

The landlords should be able to recoup the renovation investments through an increase 
in the rent which corresponds to the energy costs saved by the tenants.  

Key lessons learned  

MMR  is  a  powerful  tool  to  address  both  the  low  rate  and  depth  of  renovations. 
Experiences from the Member States with MMR already in place provide useful lessons 
for the future design of the instrument, which can be tailored to the different segments 
of the building stock and ownership tenures. Coupled with adequate financial support, 
MMR can contribute to decent homes for the more vulnerable. 

•  A clear overview of the building stock is the starting point to design 

effective MMR. This includes, for example, having a comprehensive 
understanding of the energy and climate performance of the building stock, 
particularly the worst-performing buildings, the different tenure statuses as well 
as of the different building typologies, to which the obligation will apply. Ideally, 
MMR is linked to already established frameworks, like the EPCs in Europe or the 
Energy Star Portfolio Management tool in the USA. 

•  An effective MMR needs to be embedded in a wider policy framework, 
including adequate and targeted financial support, capacity building and 
information measures.  

•  EPC schemes need to improve to be able to effectively facilitate an MMR built 
around them, including their reliability, comparability, availability as well as data 
gathering and the functionality of EPC databases. 

•  While MMR is introduced to improve the worst-performing buildings, voluntary 
standards can be defined up to the 2050-standard (e.g. a net-zero carbon 
building) and linked with additional financial support to incentivise investments 
in the highest performing buildings. The MMR can then be progressively 
tightened over time until the 2050-standard has been reached. 

•  Different building types can be treated differently within the MMR 

scheme. Larger, non-residential or public buildings could lead by example by 
having to comply with the MMR before other building typologies. The MMR for 
these buildings could also be stricter and/or more sophistically elaborated, as 
better data gathering opportunities and more granular data generally exist.  
•  Special attention must be paid to vulnerable citizens who live in inadequate 

dwellings to make sure they are not “punished” twice. The risk of “renovictions”, 
where people cannot afford to pay their rent, due to rent increases after 
renovations should be evaluated and addressed by an appropriate supporting 
framework, such as targeted financial support and a legal framework that 
forbids disproportionate rent increases.  

•  Stakeholder involvement is essential from the very early stages in the 

design of an MMR and to build understanding, support and acceptance around 
the policy. Policymakers can gather valuable insights and tailor MMR design 
choices to the characteristics of local buildings, different tenures, and the built 
environment.  

•  Communicate on multiple benefits of energy renovations (beyond carbon and 
energy), such as better comfort, health, productivity, and overall wellbeing.  
•  Gradually including carbon performance and embodied carbon metrics can 
contribute significantly to achieving GHG emission reductions, though at the 
short term challenges remain concerning data gathering and benchmarking.   
•  The MMR ought to be coupled with tailored renovation advice (such as a 
building renovation passport) to avoid technical and economical lock-in effects. 

•  Ensure sufficient lead time and administrative capacity to design and 

implement MMR. The public authorities must show that they are serious with the 
enforcement but also give the market leading time to adapt.   

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•  The policy design should be aimed at simplicity. Too complex regulation, 

such as many different cases and exemptions, may make the MMR enforcement 
less likely to succeed. 

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8.  REFERENCES 

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BPIE (2018). “The Inner Value of a Building”. (Available: Online) 

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Online)  

BPIE  &  I2-4C  (2016).  “Driving  Transformational  Change  in  the  Construction  Value  Chain”. 

(Available: Online) 

Buildings2030 & BPIE (2018). “Quantifying the impact of a better indoor environment in schools, 

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C40 (2019)  “How to set energy efficiency standards for  existing buildings”. C40 Cities Climate 

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ECSO. (2020). “Analytical report. Improving the human capital basis”.  European Commission - 

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Economidou M (2018). “Energy efficiency upgrades in multi-owner residential buildings - Review 
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Energy Saving Trust. (2011).  “A convenient  truth  – Promoting energy  efficiency in the home”. 

(Available: Online) 

Entranze  Project.  Policies to  Enforce  the  Transition  to  Nearly  Zero  Energy  Buildings  in  the  EU. 

European Commission - Intelligent Energy Europe programme. (Available: Website) 

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(Available: Online) 

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on EU Calc data. (Available: Online) 

EUCalc  (2020)  Long-Term  Renovation  Strategies:  How  the  building  sector  can  contribute  to 
climate neutrality in the EU. European Commission – Horizon 2020 project. (Available: Online) 

EU  Technical  Expert  Group  on  Sustainable  Finance  (2020).  “Technical  annex  to  the  TEG  final 

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Fabbri,  M;  Volt,  Jonathan;  Zuhaib,  S;  (2020).  “Final  report  –  Technical  study  on  the  possible 
introduction  of  optional  building  renovation  passports”.  European  Commission.  (Available: 
Online) 

Fawcett & Topouzi. (2020). “Residential retrofit in the climate emergency: the role of metrics”. 

Buildings and Cities. (Available: Online).   

Government of Flanders (2018). “Ontwerp Vlaams Energieplan”. (Available: Website)  

Hinge  (2020)  International  Review  of  Minimum  Energy  Standards  for  Rented  Properties/ 

Available: Online) 

Historic Environment Scotland. (2020). “Climate Action Plan 2020-25”. (Available: Online) 

Ipsos & Navigant (2019) Comprehensive study of building energy renovation activities and the 
uptake of nearly zero-energy buildings in the EU. European Commission. (Available: Online) 

Nadel, S & Hinge A (2020) Mandatory Building Performance Standards: A Key Policy for Achieving 

Climate Goals. ACEEE (Available: Online) 

RICS  (2017)  RICS  professional  statement:  Whole  life  carbon  assessment  for  the  built 

environment. (Available: Online).      

RSM. (2019). “Enforcing the Enhancement of Energy Efficiency Regulations in the English Private 

Rented Sector. (Available: Online) 

Pehnt, M; Weiß, U; Fritz, S; Jessing, D; Bürger, V; Kenkmann, T; Lambrecht, K & Steinbach, J 
(2019)  Evaluating  the  renewable  heating  and  efficiency  obligation  for  existing  buildings  – 

98 

 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

insights  into  the  mechanisms  of  mandatory  building  requirements.  ECEEE  summer  study. 
(Available: Online) 

Röck, M; Ruschi, M; Saade, M;Balouktsi. M; Nygaard Rasmussen, F; Birgisdottir, H; 

Frischknecht, R; Habert, G & Passer, A . (2020). ‘Embodied GHG emissions of buildings – The 
hidden challenge for effective climate change mitigation’. Applied Energy. (Available: Online)   

Sayce, S & Marji Houssain, S. (2020). “Minimum Energy Efficiency Standards (MEES): one year 

on: A Progress Report”. (Available: Online) 

Stefan. T; Suerkemper, F; Adisorn,T; Hauptstock, D; Schäfersparenberg, C; Tholen, L; Vondung, 
F;  Becker,  D;  Tesniere,  L;  Bourgault,  C  &  Förster,  C  (2016).  “Energy  Efficiency  Policies  in 
Europe: Danish Building Code – Denmark”. (Available: Online) 

Sunderland, L & Santini, M (2020). “Filling the policy gap: Minimum energy performance 
standards for European buildings”. Regulatory Assistance Project (Available: Online) 

Volt,  J  &  Toth,  Z  (2020).  “Definition  of  the  Digital  Building  Logbook”.  European  Commission. 

(Available: Online) 

World Green Building Council (2019) Bringing Embodied Carbon Upfront. (Available: Online)  

X-tendo (2020) Energy Performance Certificates – Assessing their status and potential. European 

Commission – Horizon 2020 project. (Available: Online) 

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9.  APPENDIX 1: CASE STUDIES   

9.1.1.  Europe 

In Europe, the adoption of the EPBD has resulted in the implementation of requirements 
related to EPCs in the various EU Member States and minimum requirements for major 
renovations and new buildings. Some countries have implemented MMR going beyond 
what the EPBD requires. Examples of such cases are France, the Netherlands, Belgium, 
and the UK (see Table 13). Figure 41 indicates the type of compliance applicable in the 
different Member States. 

The metric used for the standards in many cases relates to a minimum EPC rating, a 
theoretical  calculation  known  as  ‘asset  rating’.  In  certain  regions,  e.g.  Brussels  and 
France,  examples  exist  that  focus  on  the  measured  energy,  known  as  ‘operational 
rating’.  The  building  segments  targeted  by  these  MMR  regimes  are  diverse,  including 
both  residential  and  non-residential  buildings.  Compliance  is  based  on  compliance 
cycles,  trigger  points  like  sale  or  renovation,  and,  in  the  case  of  Brussels,  building 
renovation passports. 

Figure 41. Overview of type of compliance in cases analysed in Europe 

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Name/description of 
requirement 

Location 

Building 
type 

Metric 

Effective/ 
Enforced 

Compliance 
category 

Mandatory progressive 
implementation of a 
renovation roadmap 

Mandatory energy 
consumption reductions 
(PLAGE) 

Brussels, 
Belgium 

Residential 

Asset 
rating 

2030 

Building 
renovation 
passport 

Brussels, 
Belgium 

Non-
residential 

Operational 
rating 

2019 

Enforcement 
calendar 

Minimum energy performance 
standard for all tertiary 
buildings123  

Flanders, 
Belgium 

Non-
residential 

Asset 
rating* 

Minimum energy performance 
standard for residential 
buildings  

Flanders, 
Belgium 

Minimum quality standards 
for basic comfort, safety and 
health  

Flanders, 
Belgium 

Residential 

Residential 

Asset 
rating 

Asset 
rating 

2030 

2021 

2021 

Travaux embarqués 
(embedded work) 

France 

All  

n/a 

2017 

Minimum energy standard  

France 

Residential 

Asset 
rating 

2028 

Tertiary Renovation Decree 

France 

Non-
residential 

Operational 
rating 

2030 

Minimum Energy Efficiency 
Standard 

England and 
Wales 

Residential 

Asset 
rating 

2018 

Minimum Energy Efficiency 
Standard 

England and 
Wales 

Non-
Residential 

Asset 
rating 

2018 

Minimum Energy Efficiency 
Standard 

Scotland 

Residential 

Minimum standard for all 
office buildings 

Renewable heating and 
efficiency obligation 

Netherlands 

Germany, 
Baden 
Württemberg 

Non-
residential 

Residential 
and most 
non-
residential 

Asset 
rating 

Asset 
rating 

Asset 
rating 

2020 

2023 

2008 (with 
updates 
2015) 

Trigger point 
(heating 
system) 

Table 13. Overview of MMR cases analysed in Europe 

The following section presents five of the most interesting and representative MMR cases 
in Europe. A selection criterion was that the cases should go beyond the requirements 
set in the EPBD. 

123 All non-residential and non-industrial buildings. 

101 

Change of 
owner 

Change of 
owner 

Complaints 
by tenants  

Implementati
on of other 
works 

Enforcement 
calendar/ 
change in 
tenancy 

Enforcement 
calendar 

Change in 
tenancy/Enfor
cement 
calendar 

Change in 
tenancy/Enfor
cement 
calendar 

Change in 
tenancy/Enfor
cement 
calendar 

Enforcement 
calendar 

 
 
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Mandatory progressive implementation of a building renovation passport 

Brussels, Belgium 

The scheme is being developed to improve the energy efficiency of the capital’s non-
residential buildings and meet international climate goals, especially the 2030 climate 
objectives of the EU. The vision has been translated into concrete objectives in a 
strategy document, which was adopted by the Brussels government in 2016 and aims 
to reduce GHG emissions by 30% by 2025.124 The Brussels LTRS also includes 
references to renovation requirements from 2030 onwards based on specified time 
intervals linked to a building renovation passport (BRP).125 

Status: Planned.  

Legal provision  

The scheme aims to reduce the primary energy consumption (kWh/m²/year) of the non-
residential building stock. Targeted building owners must propose a three-year action 
plan to reduce primary energy consumption. The mandated renovations are based on 
cost-effective measures defined by the local administration, which the building owner 
refers to in the action plan. The energy reduction in the plan is mandatory and applies 
to the total building stock owned. The owners decide which measures to apply.  

The scheme operates in five-year cycles. The first year is used to formulate the  plan, 
while  the  subsequent  four  years  are  used  to  execute  the  plan.  The  plan  is  based  on 
‘Energy  Performance  Certificates  3.0’.  These  are  based  on,  amongst  other  factors, 
thermal insulation, airtightness and heating installations, and thus an asset rating.  

Building typology  

The programme applies to:  

Owner-occupiers and landlords (residential and service sector) 

Compliance mechanisms  

At the end of every five-year cycle, the execution of the plans is verified by the Brussels 
Environment  Office.  If  the  procedures  are  deemed  non-compliant,  sanctions  are 
applicable including administrative fines.  

Key success factors  

•  Proper training for inspectors. 
•  Cost-effective measures are mandatory and will quickly be implemented. This is 
good for efficiency but discourages the uptake of less cost-effective measures in 
investment packages. 

•  A regulation or scheme fostering the re-investment of the cost-savings from 

lower primary energy consumption in other energy efficiency measures would 
enhance the effectiveness but is currently absent.  

124 Second National Energy Efficiency Action Plan Belgium (2011). Belgium.  
125 Strategy to reduce environmental impact of buildings Brussels (2020). Mandatory renovations at 5-year 
intervals to achieve decarbonisation in 2050. LTRS, p42. 

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Minimum energy performance standard for all tertiary buildings 

Flanders, Belgium 

The 2019 Flemish coalition agreement set specific energy efficiency targets as part of 
Flanders’ 2050 goals for the building stock. Within the Draft Flemish Energy plan 2021-
2030, the Flemish authorities specify policies to achieve these targets, including energy 
efficiency  measures  for  the  tertiary  sector  (all  non-residential  and  non-industrial 
buildings).126 The rationale behind energy efficiency and more responsible energy usage 
is to reach European climate targets and reduce energy costs. To achieve this vision, 
inefficient large non-residential buildings are required to get energy labels and need to 
be renovated after they are sold.  

Status: Planned.  

Legal provision  

As  of  2021,  all  non-residential  buildings  are  required  to  undergo  a  thorough  energy 
renovation  within  five  years  after  purchase  to  reduce  their  climate  footprint.14  From 
2025 onwards, all Flemish large non-residential buildings are obliged to have an energy 
label. After 2030, they also need to reach a minimum energy label (yet to be defined). 
Public buildings (owned by the government) will need to comply with these measures 
two years in advance of private building owners.  

Building typology  

Non-residential buildings (tertiary sector) 

Compliance mechanisms  

The penalty will probably be monetary fines, but it is yet to be defined.  

Key success factors  

•  The Flanders Energy Agency indicates that this policy is aligned with the long-

term goals of carbon neutrality for non-residential buildings.  

•  The buildings are assessed on actual energy consumption rather than theoretical 

consumption.  

•  Transition measures could be considered in the form of no-regret or renewable 
energy production. Additionally, a requirement for energy audits including 
obliged implementation of cost-effective measures (like in Brussels) or the 
adoption of energy management systems could contribute to realising the 
potential of this policy.  

126 Draft Flemish Energy Plan. (2018). Flemish Government.  

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Minimum Energy Efficiency Standard in 

England and Wales 

The Minimum Energy Efficiency Standard (MEES)127 was introduced in March 2015 by 
the Energy Efficiency Regulations.128 The MEES originates from the Energy Act of 2011, 
which  was  a  package  of  energy  efficiency  policies  including  the  now  defunded  Green 
Deal. The MEES has been designed to contribute to the legislative targets of reducing 
CO2 emissions for all buildings to around zero by 2050. 

The MEES is linked to the EPC framework and stipulates that a dwelling cannot be let if 
it  does  not  comply  with  EPC  rating  E.  The  EPC  rating  (‘SAP  rating‘),  which  is  the 
infrastructure  used  to  check  compliance,  gives  a  score  from  1-100  based  on  the 
estimated cost to heat and light the building compared to other buildings of the same 
size.  One  of  the  main  reasons  for  its  implementation  was  to  circumvent  the  split-
incentive dilemma, where the landlords are responsible for the building, yet the tenants 
pay the utility bills.  

Status: Ongoing.  

Legal provision  

From 1 April 2018, the MEES requires private landlords of homes rated at EPC ratings F 
or G to improve their property to E before issuing a new tenancy, unless they obtain an 
exemption. From April 2020 the MEES was extended to include existing tenancies (as 
long  as  the  property  has  an  EPC).  Landlords  are  never  required  to  spend  more  than 
£3,500 on energy efficiency improvements (cost cap on investment). 

Building typology  

Privately rented properties. Around 7% of the targeted building stock has an EPC rating 
worse than label E.  

Compliance mechanisms  

If a landlord does not provide the requested information or lets a substandard property, 
they  get  a  monetary  fine.  The  fine  ranges  between  £2000  and  £5000  (≈  €2035  and 
€5585).  

Key success factors  

•  A mature and reliable EPC framework. In the UK and several other countries, 

there is a lack of confidence in the quality and reliability of EPCs.  

•  An EPC database which enables the implementing public authorities to check 

compliance.  

•  The implementing body must-have resources to uphold and enforce the 

legislation.  

•  Avoid too many exemptions to the regulations. In the UK, ‘the high-cost 

exemption criteria are a major reason for not putting in much effort to enforce 
the MEES to date’.129 

127 Domestic Minimum Energy Efficiency Standard Guidance Site (2017). United Kingdom 
128 The Energy Efficiency (Private Rented Property)(England and Wales) Regulations (2015). 
129 RSM. (2019). “Enforcing the Enhancement of Energy Efficiency Regulations in the English Private Rented 
Sector”. RSM Consulting. 

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Minimum standard for all office buildings 

The Netherlands 

The  parties  to  the  Energy  Agreement,  including  the  government,  aim  for  an  energy-
neutral built environment in 2050, with as an intermediate step at least an average level 
of  the  (current)  label  A  for  all  buildings  in  2030.  The  2018  amendment  of  the  Dutch 
Building  Decree  to  require  that  office  buildings  have  an  Energy  Efficiency  Index  of  at 
least 1.3 (equivalent to a ‘C’ EPC rating) by 1 January 2023 is part of a set of measures 
to achieve these targets130. 

The Dutch coalition agreement of 2017 also set forward a target of a 49% reduction in 
CO2 emissions by 2030 compared to 1990 levels, which for non-residential construction 
(including office buildings) amounts to 3 MT CO2 reduction. This target has also been 
incorporated in the Climate Agreement, which includes the ongoing commitments of the 
Energy Agreement as well. The label C obligation for offices is therefore also the first 
step to meet this CO2 target. A tighter target of an ‘A’ label by 2030 was considered but 
not introduced. However, the ‘C’ requirement by 2023 is expected to be tightened to a 
higher level in future. In response, commercial financial institutions (ING, ABN) have 
indicated they will stop financing office buildings that do not meet the standard. This 
illustrates the effectiveness of MMR as policy instruments.  

Legal provision  

From 1 January 2023, all office buildings are required to have an Energy Efficiency Index 
of at least 1.3 (equivalent to a ‘C’ EPC rating)131. As the minimum standard applies to 
the use of the office building, the duty to comply can be with either the tenant or the 
building owner. 

Building typology  

Existing office buildings, with a few exceptions132, such as office buildings with a total 
surface area of 100m2 or less, buildings in which less than 50% of floor area is used for 
offices,  and  national,  municipal  or  provincial  historic  buildings  (except  protected 
townscapes and villages). Out of 62,000 offices falling within the scope of this obligation, 
56% do not yet have an EPC (no label registered). Of those that do have an EPC, around 
one-quarter (7,000) has a label of D–G, and about 20,000 have an A-C label. Since the 
beginning of 2016, the proportion of offices subject to the obligation with a green label 
(A-C) has increased by an average of 8 percentage points each year.  

Compliance mechanisms  

Failure to comply will be addressed through administrative enforcement measures, such 
as periodic penalty payments, a fine and, ultimately, the closure of the office building. 
The standard is generally enforced by the municipality in which the building is located, 
but it can also be delegated to another nominated ‘competent authority.’ 

Key success factors  

•  Enabling framework: (1) online tool providing information on investment costs, 

energy cost savings and payback time; (2) government-approved energy 
advisors; (3) grant for the cost of the advice if measures are taken following 
that advice (in addition to existing financing schemes). 

130 Climate Agreement. (2019). The Netherlands 
131 Bouwbesluit (Building Code) (2012). The Netherlands 
132 Explanatory note Bouwbesluit. (2012). The Netherlands  
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Tertiary Renovation Decree 

France 

The ELAN law (Evolution of Housing, Planning and the Digital Environment) was created 
to  improve  the  building  stock  in  France,  including  its  carbon  footprint  and  energy 
efficiency  level.  The  ‘Décret  Tertiaire’  (article  175  of  the  ELAN  law)  defined  and 
mandates an energy consumption reduction of tertiary buildings.133  

This is one part of the French government's plan to achieve its long-term objectives, i.e. 
zero net GHG emissions by 2050. 

Status: Planned. 

Legal provision  

The  targeted  buildings  (i.e.  tertiary  sector)  must  reduce  their  energy  consumption 
(kWh/m²/year)  compared  to  the  reference  year  (which  is  a  year  between  2010  and 
2020, chosen by the building manager), achieving at least134 40% reduction in 2030, 
50% reduction in 2040 and 60% reduction in 2050. 

The building managers need to provide, via a digital platform, yearly information on the 
tertiary activity for which the building is used and its area in m². This information must 
then be published by the building owner and made available to the general public. 

This decree applies to both landlords and tenants (the responsibility of each is decided 
in the rental contract).  

Building typology  

Non-residential buildings (with a tertiary use area ≥ 1,000 m²)  

Exemptions:  

•  Buildings with temporary construction permits  
•  Buildings used for religious activity 
•  Certain public buildings, including buildings of defence, civil security, or national 

security 

Compliance mechanisms  

Non-compliance with this decree will be punished by: 

•  The publication, on a public website, of the non-compliance of the company 
•  Fine of €1,500 for a physical person 
•  Fine of €7,500 for legal entities.  

Key success factors 

•  Public communication on (non)compliance. 
•  Obligation can be transferred to the tenant. 
•  Platform: needs to be clear and easy to use for building managers. 
•  Monitoring of the building managers’ compliance with the decree (there is a 

need for a strong incentive and controls so that they all put their real 
consumption on the platform every year). 

133 Decree 2019-771. (2019) Decree on the reduction of energy consumption of tertiary buildings. 
134 Information website about the Décret Tertiare. (2019) Citron. 

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The Energy and Climate Law (Loi 2019-1147) 

France 

In  the  French  Energy  and  Climate  Law  of  2019135,  a  ban  on  the  worst-performing 
buildings (EPC G and F) is included to reduce the emissions of the built environment in 
France. 

Legal provision 

Article  22  of  the  Law  prescribes  that  the  primary  energy  consumption  of  residential 
buildings (kWh/m2/year), defined by an EPC, may not exceed 330 kWh. When a building 
is  rented  out  or  sold  after  1  January  2022  it  is  obliged  to  include  the  obligations 
mentioned in the law in the advertisement.  

If the building does not meet the requirements mentioned in article 22 at the point of 
sale or rent from 2028 onwards, this should also be mentioned in the advertisement. If 
a building does not meet the requirement in 2028 (primary energy consumption exceeds 
330  kWh/m2/year),  an  energy  audit  must  be  performed  which  includes  suitable 
renovation measures to meet the targets and the costs. 

Building typology 

The obligation applies to all residential buildings. 

Compliance mechanism 

Compliance  dates  are  set  in  2022  for  advertisements  to  include  the  obligation  to 
renovate  bad  performing  buildings  described  in  article  22.  From  1  January  2028,  the 
energy performance may not exceed 331 kWh. The energy performance and compliance 
with the Climate Law should be included in the advertisement. Non-compliance with the 
inclusion of correct information in these advertisements can result in financial penalties 
ranging from a maximum of €3000 (private person) to €15,000 for legal entities. 

Key success factors 

•  Phasing out the worst-performing buildings based on energy performance.  
•  Building owners get sufficient time to prepare the renovation. 
•  The ‘Troisième ligne de quittance’136 allows landlords to (partially) share the 

financial burden of energy-saving measures with tenants. 

•  The energy performance in the EPC of the building must be included in rental 

advertisements after 2022. 

135 Law 2019-1147. (2019). Law 2019-1147 related to Energy and Climate. France 
136 Decree 2009-1438. (2009). Decree related to tenant contribution to energy saving work. France 

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9.2.  United States of America  

In  the  USA  policymakers  recognise  the  need  for  more  ambitious  policies  to  stimulate 
energy efficiency in the built environment.137 MMR is seen as an effective approach to 
achieve climate targets. The development and implementation of MMR in the USA is just 
beginning. Different types of MMR in terms of metrics, building segments targeted and 
compliance are implemented and tested in various jurisdictions of the USA. An overview 
of different types of compliance is presented in Figure 42.  

Recurring  metrics  for  MMR  are  energy  use  intensity  (EUI),  sometimes  related  to  the 
Energy Star Score, and carbon intensity. The first generation of MMR implemented in 
the USA suggests that operational rating is more suited for large (commercial) buildings 
whereas asset rating is more suited for smaller or single-family residential buildings. In 
certain  jurisdictions,  only  audit  obligations  and  requirements  for  cost-effective 
renovation  measures  exist,  rather  than  whole-building  MMR.  The  building  segments 
most often targeted by MMR in the USA are commercial and multi-family buildings. In 
contrast to Europe and Canada, single-family houses are often not targeted in the USA, 
except  in  Boulder,  Colorado.26  Compliance  with  MMR  is  mostly  based  on  compliance 
cycles and in some cases pegged to trigger points like sale or major renovation.  

Figure 42. Overview of type of compliance in cases analysed in USA 

Some in-depth examples are presented below in table 14.  

Name/description of 
requirement 

New York Building 
Emissions Law (Local 
Law 97 of 2019) 

Location 

Building type 

Metric 

Effectiv
e 

Compliance 
category 

New York 
City  

Larger buildings 
(>2300 m2) 

Carbon intensity 
(tCO2 eq/m2) 

2024 

Enforcement 
calendar 

137 Nadel, S & Hinge A (2020) Mandatory Building Performance Standards: A Key Policy for Achieving Climate 
Goals. ACEEE (Available: Online) 

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Building performance 
goals 

Reno, 
Nevada 

Residential and 
non-residential 
buildings 
(>2700 m2) 

Minimum 
ENERGY STAR 
score /EUI 

Building Energy 
Performance 
Standards 

Washingto
n DC 

Larger buildings 
(> 4600 m2) 

Minimum 
ENERGY STAR 
score above the 
median score of 
district 

(compliance cycle 
of 5 years) 

2026*   Enforcement 

calendar 

(compliance cycle 
of 7 years) 

2026 

Enforcement 
calendar 

(compliance cycle 
of 5 years) 

Clean Buildings for 
Washington Act 

Washingto
n state  

Larger buildings 
(> 4600 m2) 

EUI** 
(kBtus/m2)  

2026 

Enforcement 
calendar 

Boulder SmartRegs 
program (2010) 

City of 
Boulder 

Building Energy 
Performance Standard 
bill 

St Louis, 
Missouri 

The minimum 
score on HERS 
rating system / 
local carbon and 
energy checklist 

 EUI (kBtus/m2) 

Residential 
buildings in the 
rental market 

Residential and 
non-residential 
large buildings 
(>4600 m2) 

Building Tune-up 
Ordinance 

Municipalit
y of Seattle 

Non-residential 
buildings 

Audit obligation 
+ cost-effective 
renovation 

(compliance cycle 
of 5 years) 

2019 

Enforcement 
calendar 

(compliance cycle 
of 4 years) 

2019-
2025* 

Enforcement 
calendar 

(compliance cycle 
of 4-6 years) 

2018-
2021* 

Enforcement 
calendar 

(compliance cycle 
of 5 years) 

Mandatory seismic 
retrofit program 

Building Energy 
Saving Ordinance 

Los 
Angeles 
City 

Municipalit
y of 
Berkeley 

Existing Commercial 
Buildings Energy 
Performance 
Ordinance 

Municipalit
y of San 
Francisco 

Seismically 
vulnerable 
buildings (soft-
story buildings) 

Small buildings 
at trigger point 
(<2300 m2) 
Large buildings 
(>2300 m2) 
compliance 
cycle 

Non-residential 
buildings (>900 
m2) 
All buildings 
(>4600m2) 

N/a 

2016-
2017* 

N/a 

Audit obligation  

2019-
2022* 

Enforcement 
calendar 

Audit obligation 

2020 

(compliance cycle 
of 5-10 years) + 
trigger point 
(sale) 

Enforcement 
calendar 

(Compliance cycle 
of 5 years) + 
trigger point 
(sale) 

Existing Buildings 
Energy and Water 
Efficiency Program 

Municipalit
y of Los 
Angeles 

Larger buildings 
(>1850 m2) 

Audit obligation 
+ cost-effective 
renovation 

2019 

Enforcement 
calendar 

Energy Conservation 
Audit and Disclosure 
(ECAD) Ordinance 

City of 
Austin 

All buildings 

Audit obligation 

2008 

109 

(compliance cycle 
of 5 years) 

A trigger point 
(sale) 

 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

ECAD for residential 
Homes: Information 
for Home Sellers, 
Buyers and Real 
Estate Professionals. 

Austin 

Multi-family 
buildings 

EUI reduction of 
20%  

2008 

If EUI is more 
than 150% of the 
average 

New York Sustainable 
Roof Laws (Local Law 
94 of 2019) 

New York 
City  

Residential and 
non-residential 
large buildings 
(>2300m2) 

Boulder Building 
Performance 
Ordinance  

City of 
Boulder 

Non-residential 
buildings 

Percentage 
available roof 
covered with PV, 
green roofing or 
both 

Audit obligation 
+ cost-effective 
renovation 

2019 

A trigger point 
(major 
renovation)  

2020-
2027* 

Enforcement 
calendar 

(compliance cycle 
of 10 years) 

Table 14. Overview of MMR analysed in the USA 

 *Depending on the building segment/size, starting with public and large buildings 

**Energy use intensity 

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New York Building Emissions Law (Local Law 97 of 2019) 

New York City, USA 

The law was developed to reduce the adverse impact of climate change and limit GHG 
emissions. The New York City Council has proposed the Climate Mobilization Act, which 
aims to reduce the GHG emissions of buildings by 40% in 2030 compared to 2005 
levels, and by 80% in 2050.  

Legal provision  

Local Law No. 97138 provides a straightforward limit on the amount of GHG a building 
can emit. It mandates that covered buildings 25,000 square feet (2322m2) and larger 
cannot emit GHGs at levels higher than the limits set by the law. It defines mandatory 
emission intensity limits (metric tons of CO2/m2) for different Building Code occupancy 
groups, based on use and type of the building.  

Building typology  

It targets large buildings (larger than 2322m2), both residential and non-residential. 
The law incrementally expands the share of buildings that are covered by the 
requirement: 20% of buildings in 2024-2029 and 75% of buildings in 2030-2034.  

Compliance mechanisms  

Large-building  owners  must  annually  report  energy  and  water  consumption  in 
compliance with the NYC Benchmarking law (Local Law 84). In the Energy Start Portfolio 
Management  System,  where  this  data  is  uploaded,  the  energy  use  is  transposed  in 
kilograms of carbon equivalents (kgCO2eq). The building emission law specifies carbon 
intensity limits per building segments in these terms. These reports will be checked by 
the office for energy performance and emissions performance. When buildings exceed 
the annual buildings emission limit, the owner is liable for a civil penalty equal to the 
difference between the emission limit for that year and the reported emissions in tonnes 
of CO2 multiplied by $268. 

A  separate  office  of  building  energy  and  emissions  performance  within  the  New  York 
City  department  of  buildings  has  been  created  to  oversee  the  implementation  of  the 
new  energy  performance-related  policies.  This  office  is  charged  with  monitoring 
buildings  energy  use  and  emissions,  reviewing  building  emissions  assessment 
methodologies,  building  emission  limits,  goals,  and  timeframes  to  further  the  goal  of 
achieving the emission targets.  

Key success factors  

•  Low-interest loans available through a new Property Assessed Clean Energy 
programme to finance energy efficiency and green energy through a special 
assessment on a building’s property tax bill.  

•  Available financial subsidies to support the various measures, including ‘green 

roof tax abatement’.  

•  The  GPRO training programme, a national training and certificate program, 

trains professionals in sustainable techniques and high-performance construction 
and maintenance practices. 

•  City-owned buildings will lead by example and follow stricter rules, with a target 

of 50% reduction in 2030.  

138 Local Law 97. (2019). New York City Council. 

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Building Performance Ordinance 

Boulder, Colorado, USA 

The Building Performance Ordinance (Ordinance No. 8071)139 is important in the 
context of the Boulder Building Performance Program.140 To reduce GHG emissions 
and increase the energy efficiency of the building stock, the ordinance requires owners 
of commercial, city and industrial buildings to: 

•  Annually report the energy usage of their buildings,  
•  Perform periodic energy assessments  
•  Perform periodic retro-commissioning and implement cost-effective energy 

efficiency measures 
Implement one-time lighting upgrades.  

• 

Legal provision  

The legal provisions part of the Building Performance Program can be divided into two 
categories: the annual rating and reporting of building energy usage and the 
implementation of energy efficiency requirements.  

The implementation of energy efficiency requirements consists of three parts141:  

1.  Implement one-time lighting upgrade in line with City of Boulder Energy 

Conversation Code.  

2.  Perform a quality energy assessment every 10 years, tuning up buildings and 

calibrating existing functional systems to run as efficiently as possible.  

3.  Implement cost-effective retro-commissioning measures. The ordinance obliges 
building owners to implement cost-effective measures within two years after 
the audit. Cost-effective is defined as each measure with a payback period of 
two years or less with rebates.  

Building typology  

•  All municipal buildings larger than 460m2 floor area 
•  New buildings with a floor surface larger than 930m2 
•  All commercial and industrial properties larger than 1850m2.  

Compliance mechanisms  

Failure to report on energy data of buildings before the building typology related 
deadlines results in fines of $0.027/m2, up to a maximum of $1000 per building per 
day of non-compliance. 

Key success factors  

•  A wide set of support resources, including training programmes for portfolio 

management, municipal training programmes, assistance for dealing with the 
split-incentive dilemma and green leases.  

•  Rebates and other financial instruments to support the implementation, like the 

• 

level II Energy Assessment Rebates, Excel Energy Retro-commissioning 
Incentives, C-PACE Financing, Boulder County PACE Rebates, solar rebates and 
grants, clean energy loans and Xcel Energy Prescriptive Rebates. 

139 Boulder Building Performance Ordinance. (2015). City of Boulder. 
140 Boulder Building Performance Program. (2020) City of Boulder. 
141 Boulder Building Performance Ordinance no. 8071. (2020). Buildingrating.org 

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9.3.  Oceania  

In Australia and New Zealand different types of MMR are being implemented (see table 
14). Where some focus on public buildings, e.g. the Green Lease Schedules in Australia, 
the  recent  adoption  of  new  MMR  legislation  focuses  mostly  on  the  rental  sector  to 
improve the health and well-being of tenants, e.g. the Residential Tenancies Regulations 
(AUS) and the Healthy Homes Guarantee Act (NZ). Metrics relate to minimum insulation 
values (R-values) and the efficiency and capacity of installations. Compliance is based 
on specific dates by which building owners must comply, as presented in Figure 43.  

An in-depth analysis of two cases is provided below Table 15. 

Figure 43. Overview of type of compliance in cases analysed in USA 

category 

Enforcement 
calendar 

Name/description of 
requirement 

Location 

Building 
type 

Metric 

Effective  Compliance 

Green Lease Schedules 
/ National Green 
Leasing Policy 

Australia 

Non-
residential  

NABERS energy rating  2010 

Residential Tenancies 
Regulations 2020 

Victoria, 
Australia  

Residential   To be confirmed 

2021 

TBC*  

Healthy Homes 
Guarantee Act 

New Zealand  Residential   Minimum  

2021 

-temperature (°C) 
-insulation thickness 
(mm) 
-ventilation (openable 
windows/mechanic 
ventilation) 
-moisture (effective 
drainage)  

Table 15. Overview of MMR analysed in Oceania 

Enforcement 
calendar 

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Green Lease Schedules, 

Australia 

To improve energy efficiency and environmental impacts of government operations, the 
Australian government enacted the Energy Efficiency in Government Operations (EEGO) 
policy. The policy aims to overcome traditional barriers to improve the energy efficiency 
of buildings like the  split-incentive dilemma by enabling parties with influence  on the 
building to benefit from implementing improvements. The aim of the policy is to:  

1.  Reduce energy intensity in operations by 25% in offices 
2.  Achieve  a  20%  reduction  of  energy  consumption  in  office  central  services  by 

2021. 

Legal provision  

The introduced ‘Green Leases’142 contain mutual obligations for tenants and owners of 
office  buildings  to  achieve  efficiency  targets.  The  scheme  aims  to  improve  energy 
efficiency by setting a minimum operational building energy performance standard (i.e 
the Australian Building Greenhouse Rating – ABGR).143  

Minimum energy performance requirements for premises above 2000m2 are a minimum 
of 4.5 stars within ABGR, which is equivalent to ‘excellent’ energy performance. 

Building typology  

All leased government properties and other government buildings. 

Compliance mechanisms  

Yearly reports on the energy usage of operations made by agencies every financial year, 
by fuel type and end-use category. 

Key success factors 

•  Public buildings are leading by example. 
•  Templates for green lease schedules. 

142 Green Lease Schedules. (2010). Forms and templates 

143 Australian Government (2017). Factsheet - Green Lease Schedule 

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Healthy Homes Guarantee Act, 

New Zealand 

The  aim  of  the  Healthy  Homes  Guarantee  Act144  is  to  ensure  healthy,  dry  and  warm 
rental buildings in New Zealand. The Act includes requirements for rental buildings to 
have a fixed heating device with a specified capacity, minimum underfloor and ceiling 
insulation, and ventilation requirements. 

Legal provision 

These objectives of the act are to be achieved through the ‘Healthy Home Standards’145, 
in  which  MMR  for  heating,  insulation  and  ventilation  is  specified.  This  ‘Residential 
Tenancies (Healthy Homes Standards) Regulation’ became law in July 2019. 

The  standards  prescribe  that  the  heating  system  must  be  fixed  and  able  to  heat  the 
living  space,  have  a  minimum  capacity  of  1.5  kW,  have  a  thermostat  and  meet  a 
prescribed  minimum  heating  capacity  based  on  living  space  building  characteristics 
(Schedule 2)16. The insulation must have a minimum R-value (ranging between 2.9 – 
3.3  for  ceiling  insulation  and  1.3  for  underfloor)  depending  on  the  climatic  zone. 
Ventilation  requirements  relate  to  the  presence  of  windows  and  doors  that  can  be 
opened  next  to  requirements  for  mechanical  ventilation  in  kitchens  (>50L/s)  and 
bathrooms (>25L/s). Additional requirements exist for draught stopping and drainage. 

Building typology 

Rental buildings in the residential sector 

Compliance mechanisms 

Compliance  dates  are  formulated  for  heating,  insulation  and  ventilation  and  specified 
for  building  typologies  (e.g.  social  rent,  private  rent,  etc.).  Information  about 
compliance is available on the webpage of the government of New Zealand.146 

Key success factors 

•  Addresses the whole rental market. 

144 Healthy Homes Guarantee Act. (2017). Government of New Zealand. 

145 Residential Tenacies (Healthy Homes Standards) Regulations. (2019). Government of New Zealand. 
146 Healthy Homes Standards Webpage. (2020). Ministry of Housing and Urban Development New Zealand. 

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10.  APPENDIX 2: STAKEHOLDER VIEWS 

10.1.  Stakeholders support MMR  as  a central instrument to decarbonise 

the building stock 

Around 80% of stakeholders consulted think that MMR is a necessary policy for the EU 
to decarbonise the  building stock by  2050. The same share of respondents also argues 
that the EU should actively support and encourage MMR.  

Stakeholders  have  been  involved  in  two  ways  in  this  study:  (1)  113  stakeholders 
answered  an  online  survey  and  (2)  over  100  stakeholders  participated  in  an  online 
workshop147.  The  stakeholders  represent  different  sectors  and  professions,  including 
building  owner  representatives,  tenant  organisations,  installation  manufacturers, 
construction sector, financial sector, public administration, (energy) service providers, 
civil society, and research institutes. This section highlights some of the most relevant 
findings and feedback concerning the impact and feasibility of various EU policy tools. 
The stakeholder views are presented in three sections:  

1)  What MMR should be supported?  

2)  How should MMR be designed?  

3)  What actions should the EU take?  

10.1.1. 

What MMR should be supported?  

The main objective of any MMR should be to achieve deep renovation and a link to clear 
long-term climate and energy targets. Figure 44 displays stakeholders’ preferences for 
different MMR types (one choice possible or multiple?); most respondents think more 
than one type of MMR could be successful. The large majority of stakeholders consulted 
via the  survey - three-quarters (74%,  or  84 out  of 113  survey  respondents)  - 
think the MMR should focus on the overall energy performance of the building. 
Over half (53%) think MMR could be linked to certain building components, while almost 
50% say it should be linked to the building’s overall climate performance. Only a quarter 
(24%)  say  the  MMR  should  be  linked  to  the  occupants’  energy  behaviour,  while  less 
than 3% think the MMR should not encompass energy or climate requirements.  

During  the  stakeholder  workshop,  support  was  expressed  for  carbon  efficiency  (i.e. 
maximum  GHG/m2/year)  as  an  MMR  parameter  because  this  provides  most  certainty 
for  the  long  term  and  gives  the  building  owner  more  freedom  to  decide  how  the 
requirement will be met.  

Some stakeholders stressed that incorporating indoor environmental quality, embodied 
carbon and/or accessibility for disabled people in MMR should be considered. In contrast, 
other stakeholders argued that MMR only focus on energy performance parameters, to 
be kept simple and effective. The debate around how much to include, or not include, 
in the MMR resembles the discussion around EPCs.  

147 The survey was divided into three broad parts. The first part assessed the stakeholder views regarding 
opportunities  and  risks,  as  well  as  success  factors  and  barriers  for  MMR.  The  second  part  explored  their 
preferences for different policy designs. In the third part participants expressed their views about how the EU 
could  best  implement,  support  or  introduce  MMRs.  During  the  webinar  the  participants  were  divided  in 
breakout groups with moderators that discussed these three aspects in more depth. See more details about 
the survey and workshop in Appendix 2, including additional survey results.  

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What should MMR encompass, in terms of energy/climate 
requirements?

0

10

20

30

40

50

60

70

80

90

Overall energy performance of the building (e.g.
kWh/m2/year, EPC label)

Performance of building components (e.g. replace
inefficient heating system)

Overall climate performance of the building (e.g.
CO2 tonne limit)

Whole life carbon (i.e. carbon emissions throughout
the full life cycle of buildings, including embodied
and operational carbon)

Other

Energy consumption behaviour of the occupants

It should not include any energy/climate
requirements

Figure 44: Survey question – stakeholders’ preferences for different types of MMR (several 
votes were possible) 

10.1.2. 

How should the MMR be designed?  

The  views  among  stakeholders  are  diverse  when  it  comes  to  central  design  options, 
such as target groups,  trigger points and when the requirement should apply. It was 
reiterated that these aspects ought to be defined at the national and/or regional level, 
which explains some of the divergent views. 

The stakeholders generally think that MMR can best be applied to the worst-performing 
buildings, excluding heritage buildings. This will achieve the highest impact in the short 
term. Additionally, the building owners’ ability to comply with the requirement should 
be  considered.  The  most  widespread  view  (57%  of  respondents)  is  that  MMR  should 
encompass all building typologies. This view was followed by a focus on larger and more 
polluting  buildings,  such  as  public  buildings  (41%),  multi-family  buildings  (31%), 
commercial  buildings  (30%),  all  non-residential  buildings  (28%)  and  larger  buildings 
and portfolios of building assets (27%). Less popular are low-income households (10%) 
and social housing (20%). See all answers in Figure 45.  

One popular opinion is that MMR could initially best be targeted at public and/or larger 
commercial  buildings.  This  might,  according  to  the  stakeholders,  kickstart  local 
renovation markets and improve renovation skills amongst construction workers. 

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What type of building and ownership types should it 
address?

0

10

20

30

40

50

60

70

All buildings

Public buildings

Multifamily buildings

Commercial buildings

All non-residential buildings

Large buildings/ portfolio of large housing owner

Private landlords

Single-family buildings

Social housing

Buildings built before a certain year (e.g. 1980)

Others

Low-income households

Figure 45: Survey question – building and ownership types to be targeted by MMR (several 
votes were possible) 

Figure  46  shows  that  many  stakeholders  want  the  MMR  to  include  both  progressive 
enforcement  of  milestones  and  various  trigger  points,  something  reaffirmed  in  the 
workshop  discussion.  In  the  multiple-choice  question  on  when  the  MMR  should  come 
into  effect,  most  participants  say  MMR  enforcement  based  on  progressive  milestones 
(66%) and trigger points (55%) are the best solutions.  

Most  stakeholders  argue  that  MMR  should  support  long-term  objectives  and  that  the 
deadlines for the requirements should be planned and communicated well in advance. 
This  gives  landlords  and  the  market  time  to  adapt  and  take  actions.  The  enabling 
framework  could  also  be  coupled  to  long-term  targets  and  stimulate  quick  action. 
Financial measures could be designed to reward early action with high support and be 
reduced closer to the deadline.  

The argument for linking MMR to a building renovation passport (which is supported by 
42%  of  the  respondents)  is  to  avoid  technical  and  economic  lock-in  effects.  Building 
renovation  passports  could  support  building  owners  to  take  adequate  renovation 
measures, which makes sense in the short term as well as in the long term. A couple of 
stakeholders  argue  that  MMR  supported  by  the  EU  should  only  allow  one-stage  deep 
renovations. Other participants perceived the choice between staged and one-step deep 
renovation as too simplistic and called for an open mindset to find a balanced solution.  

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When should the minimum requirement apply?

0

10

20

30

40

50

60

70

80

Progressive enforcement of milestones (2025, 
2030, …)

Trigger points (property transfers, change of 
occupation, …)

According to building renovation passports
(setting out a renovation roadmap for individual
buildings)

Other

Figure 46: Survey question – When should the requirement apply? (several votes were possible) 

Stakeholders view the EPC framework as a natural way of implementing and enforcing 
MMR by the EU. It was, however, also stressed that the reliability of EPCs and their (lack 
of)  comparability  across  the  EU  remains  a  barrier.  Concerning  EPCs,  it  was  also 
concluded  that  they  could  be  expanded  to  include  other  non-energy  parameters  like 
indoor environmental quality, which could then be taken into account by future MMR.  

Error! Reference source not found.7 displays what the stakeholders view as the most s
uitable trigger points for MMR. Some 86% (97 out of 113 respondents) say that major 
renovation or building-related construction work is the most suitable trigger point, which 
partially links to what Article 7 of the EPBD declares148. Most respondents think ‘property 
transfer’ (62%) and ‘change of use’ (50%) are good trigger points for MMR.  

148 Article 7 of the EPBD states that "Member States shall take the necessary measures to ensure that when 
buildings undergo major renovation, the energy performance of the building or the renovated part thereof is 
upgraded in order to meet minimum energy performance requirements set in accordance with Article 4 in so 
far as this is technically, functionally and economically feasible." 

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What are the most suitable trigger points for MMR?
0

60

10

20

50

30

40

70

80

90

100

Major renovation or building-related construction
work

Property transfer

Change of use

Extension

Lease and rent

Repair and maintenance work

Issuance of a certificate

Others

Fire safety checks

Figure 47: Survey question – Most adequate trigger points (several votes were possible) 

10.1.3. 

What should the EU do?  

There is almost a consensus among stakeholders on the view that MMR cannot function 
without  a  supportive  policy  framework.  Participants  mentioned  financial  support 
schemes  (green  loans  and  grants),  awareness  and  communication  campaigns,  long-
term  planning  tools,  training  of  experts  as  well  as  a  compliance  and  enforcement 
strategy, as essential enabling measures. The survey shows (see Figure 48) that most 
stakeholders view all enabling measures to be, at least, moderately important. Financial 
support  is  seen  as  the  most  important  measure  (85%  say  it  is  ‘very  important’  or 
‘important’),  followed  by  information  measures  (73%)  and  long-term  planning  tools 
(80%).  

It was also stressed that the EU must take further actions to improve the trustworthiness 
of EPCs and make sure data supporting MMR is reliable and comparable. Stakeholders 
suggested  that  the  EU  can  play  an  important  role  in  harmonising  data  collection  and 
facilitating the comparison of EPCs within the EU. Concerning the supply of construction 
materials and building installations, MMR could play a role in ensuring that, even if MMR 
is defined on a local scale, it is still part of a wider and comparable European framework.  

In  addition,  continuing  the  work  on  raising  awareness  on  building  performance,  for 
example through one-stop shops, was frequently referred to as part of the solution.  

Some stakeholders warn of the additional financial burden MMR can impose for some 
building owners and tenants. This is in general seen as the most important aspect that 
should be addressed and solved. Financial support is seen as the most suitable solution 
to this barrier.  

On the role of the EU, the general view was that Member States must have the flexibility 
to define the ambition level, enforcement mechanisms and certain design features. A 
few  stakeholders  highlighted  that  the  EU  should  provide  guidance  in  the  form  of 
overviews  of  possible  measures  and  allow  local  and  national  authorities  to  determine 
what is most suitable.  

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If MMR were implemented at national or subnational level, 
what would be the most important supporting measures? 

100

80

60

40

20

0

Not important

Slightly important

Moderately important

Important

Very important

Figure 48: Importance of measures in the enabling framework 

Several stakeholders consider embodied carbon to be relevant in the context of MMR. 
In particular, the technical installations and materials in energy-efficient buildings can 
have  a  considerable  impact  over  the  lifetime  of  a  building.  If  MMR  is  not  suitable  to 
address the issue, this issue should be addressed through another support framework.  

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11.  APPENDIX 3: IMPACT AND FEASIBILITY OF THE MMR MODELS  

11.1.  MMR  model  1:  Progressive  enforcement  of  MMR  for  existing 

buildings 

Impact consideration  

Indicator 

Strengths 

Weaknesses 

Techno-economic aspects 

Renovation rate  By  triggering  the  renovation  of 
the  worst-performing  buildings 
(i.e. over 50% of buildings with 
an EPC have a rating worse than 
D149) by 2030, the model has the 
potential to bring the renovation 
rate to 3-5%/year in the period 
to  2030  (i.e.  triggering  the 
renovation  of  30%  to  50%  of 
buildings  within  10  years).  The 
impact  on  the  renovation  rate 
will  depend  on  how  the  MMR  is 
designed, 
and 
enforced.  

regulated 

Renovation 
depth 

Visibility of the long-term targets 
steering  all 
contributes 
renovation  measures  towards 
the long-term objective.  

to 

Renovation 
quality 

The  EPC  can  be  used  to  prove 
post-measure  compliance  (as 
done  with  financial  subsidies  in 
several  of  the  Member  States), 
which  fosters  higher  quality  of 
works.  

No weakness.  

Progressive  enforcement  might  trigger 
step-by-step renovations before one-stage 
deep  renovations.  If  the  progressive 
enforcement  calendar  is  defined  right 
away (i.e. what performance is required by 
it  would 
2050, 
reduce  this  risk,  as  building  owners  and 
investors  would  also  renovate  to  make 
their building asset “future proof” (i.e. not 
just 
pending 
requirement  but  the  ones  that  will  come 
into force in 10-20 years time).   

including  milestones) 

complying  with 

the 

Without a BRP, there is a risk of technical 
and  economic  lock-in  effects,  if  shallow 
renovations  and 
incentivised,  without 
considering the long-term objective.   

The 

rating). 

Operational  (actual)  energy  use  often 
differs  from  the  theoretical  energy  use 
(asset 
EPC 
frameworks are predominantly focused on 
theoretical  energy  use,  which  might  lead 
to that the full scope of estimated energy 
savings  might  not  materialise  in  actual 
energy savings.  

current 

149 Calculation based on data from BPIE (2018); 97% of buildings in the EU need to be upgraded. 
(Available: Online) 

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Cost-optimality 

The EPBD says EPC ought to 
indicate as to where the user 
can  receive  more  detailed 
including 
information, 
the  cost-
information  on 
effectiveness 
the 
of 
recommendations  made  in 
the EPC.  

To  reach  equal  final  performances,  one-
stage  deep  renovations  are,  in  general, 
cheaper than  staged  deep renovations.  If 
the  MMR  model 
staged 
renovations,   the overall cost will increase.  

triggers 

The  most  cost-optimal  decarbonisation 
pathway  might  not  be 
if 
renewable energy consumption and whole-
life carbon considerations are excluded in 
the  calculations.150  These  aspects  can  be 
tackled in parallel to the MMR.   

reached 

While  this  model  focuses  on  individual 
buildings, building managers might have a 
more  cost-optimal  pathway  to  the  final 
target  (e.g.  deep  renovation  of  20%  of 
their buildings every five years). 

Socio-economic aspects 

Split incentives 

The  progressive  MMR  reduces 
the barrier of the split-incentive 
dilemma  since  the  decision  to 
invest  in  energy  renovations  is 
mandatory. 

The actor bearing the cost to comply with 
the MMR might not be the same as the one 
getting  the  benefits.  At  worst,  this  could 
lead to a higher demolition rate or vacant 
apartments.  

Energy Poverty 

Improving the worst-performing 
buildings, in which a larger share 
live, 
of  energy-poor  persons 
would  reduce  energy  bills  and 
improve health and wellbeing.  

Without clear regulation, there is a risk the 
cost of the renovation  measures will fully 
be  put  on  the  tenants  (through  rent 
increases),  which  then  could  have  an 
adverse effect.  

EU long-term targets 

2030 
milestone 

GHG 

The  model  alleviates  the  worst-
performing 
first, 
contributing to the 2030 targets 
implemented  and 
if  being 
enforced before this date.   

buildings 

focus  on 

The 
the  worst-performing 
buildings does not foster improvements in 
the  rest  of  the  building  stock.  Energy 
savings  will  be  more  difficult  (more 
expensive)  to  achieve  after  the  initial 
round of renovations.  

Carbon 
neutrality 
2050 

by 

Renewables 

The model ensures that targeted 
in 
segments  do  their  share 
energy efficiency improvements. 
If  the  progressive  calendar  is 
defined  to  be  aligned  with  the 
2050 target, it could ensure the 
building stock is decarbonised by 
2050.  

Local  renewable  production  can 
be  integrated  into  certain  types 
of  EPC  (e.g.  in  France  and 
Wallonia with solar PV).  

Additional 
to 
decarbonise the remaining heat demand.  

needed 

actions 

are 

carbon 

Whole-life 
impacts  are  not 
considered  and  need  to  be  tackled  in 
parallel.  

The  focus  on  energy  efficiency  does  not 
the  development  of 
explicitly 
renewable production.  

foster 

Table 16. Table impact assessment MMR Model 1 

150 Cost-optimal decarbonisation pathways include a mix of approaches, all of which mandate a high level of 
energy efficiency/energy performance of the building and the remaining energy demand being covered by 
renewable heat (see e.g. ifeu, Fraunhofer IEE and Consentec (2018). Building sector Efficiency: A crucial 
Component of the Energy Transition. A study commissioned by Agora Energiewende). (Available: Online) 

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Illustrative impact consideration 

MMR model 1 is modelled below (Figure 49 and 50) as a progressive ban on the worst-
performing buildings,  meaning that all EPC F buildings should be  renovated by 2035, 
then all EPC E buildings by 2040, etc. It is assumed that by 2050 all buildings have an 
EPC rating of B or better. It is also assumed that a “decarbonised building stock” implies 
a  long-term  primary  energy  consumption  target  of  100kWh/m²/year  for  existing 
buildings. The ‘theoretical’ primary energy consumption is corrected to account for the 
lower actual energy consumption in highly efficient buildings. This leads to a reduction 
of the final energy consumption by 2050, with reference to 2020, of 39% for France and 
57%  for  Germany  (which  are  used  to  illustrate  the  potential  impact).  The  expected 
adverse impact of the performance gap is illustrated and shows that these results could 
be  reduced  by  16  percentage  points  if  this  issue  is  not  solved.  The  performance  gap 
could  be  tackled  in  parallel  to  the  MMR  model  and  be  reduced,  through  systemic 
research and quality assurance measures. 

While  MMR  model  1  translates  into  reductions  of  the  final  energy  consumption,  the 
related impact of GHG emissions is more uncertain. Reaching the minimum performance 
level will be achieved by a combination of energy efficiency of the building envelope and 
retrofits to more efficient heating systems with lower carbon intensities (e.g. from liquid-
fuel boilers to condensing gas boilers and from gas and liquid boilers to heat pumps and 
biomass-based  technologies).  For  the  sake  of  the  illustration,  it  is  considered  that  all 
liquid-fuelled boilers will be replaced by heat pumps. This reduces the GHG intensity of 
heating by 29% for France and 37% for Germany. Combined with the reduction of the 
final energy consumption, this reduces GHG emissions by 56% and 73% respectively. 

Figure 49 – Illustrative impact assessment of MMR model 1 on the French residential buildings 
stock 

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Figure 50 – Illustrative impact assessment of MMR model 1 on the German residential buildings 
stock 

Feasibility assessment  

Indicator 

Strength 

Weaknesses 

Maturity  of 
“infrastructure” 

existing 

The  EPC  infrastructure  already 
exists in all Member States, with 
energy experts and databases in 
place.  

Most  Member  States  have  less 
than 10% of their building stock 
covered  by  EPCs.  The  EPCs 
diverge  in  quality  and  reliability 
and  control  mechanisms.  The 
EPC frameworks must improve in 
all  jurisdictions,  in  terms  of 
availability and reliability.   

Public databases are not in place 
in all countries, so the quality of 
the 
differs 
between the Member States.  

gathered 

data 

Simplicity 

Ease of compliance 

Several  Member  States  have 
robust  EPC  databases  that  can 
be used to check compliance.  

Excluding  renewables  makes 
the  calculations  simpler  and 
easier  for  building  owners  to 
understand.  Many 
building 
owners  are  familiar  with  the 
EPC.  

The  existing  EPC  infrastructure 
can  easily  be  adapted  to  check 
for compliance.  

Table 17. Feasibility assessment MMR Model 1 

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11.2.  MMR  model  2:  Progressive  enforcement  of  minimum  carbon 

performance requirements for all existing buildings 

Impact assessment  

Indicator 

Strengths 

Weaknesses 

Renovation 
rate 

Renovation 
depth 

Socio-economic 

By  triggering  the  renovation  of  the 
worst-performing  buildings  (i.e.  over 
50% of buildings with an EPC have a 
rating worse than D151) by 2030, the 
model  has  the  potential  to  bring  the 
renovation  rate  to  3-5%/year  in  the 
period  to  2030  (i.e.  triggering  the 
renovation of 30% to 50% of buildings 
within  10  years).  The  impact  on  the 
renovation  rate  will  depend  on  how 
the  MMR  is  designed,  regulated  and 
enforced.  

Visibility  of  the  long-term  targets 
contributes  to  steering  all  renovation 
measures 
long-term 
objective.  

towards 

the 

the 

integrate 

Opening 
(on-site) 
renewables  in  the  minimum  standard 
brings  new 
lock-ins  as 
risks  of 
production units could be oversized for 
buildings  where  the  energy  efficiency 
potential has not been captured yet. For 
renovation  occurring  up  to  2030,  this 
might,,  however,  be  alleviated  by  the 
shorter  lifetime  of  heating  systems 
compared to building envelopes. 

If 

right 

away 

renovations. 

Progressive  enforcement  might  trigger 
step-by-step  renovations  before  one-
stage  deep 
the 
progressive  enforcement  calendar  is 
defined 
(i.e.  what 
is  required  by  2050, 
performance 
including  milestones)  it  would  reduce 
this  risk,  as  building  owners  and 
investors  would  also  renovate  to  make 
their  building  asset  “future  proof”  (i.e. 
not  just  complying  with  the  pending 
requirement but the ones that will come 
into force in 10-20 years).   

Renovation 
quality 

The  EPC  can  be  used  to  prove  post-
measure  compliance  (as  done  with 
financial subsidies in  several  Member 

Without  a  BRP,  there  is  a  risk  of 
technical  and  economic  lock-in  effects, 
if shallow renovations and incentivised, 
without  considering 
long-term 
objective.   

the 

Operational  (actual)  energy  use  often 
differs  from  the  theoretical  energy  use 
(asset 
current  EPC 
frameworks  are  predominantly  focused 

rating).  The 

151 Calculation based on data from BPIE (2018); 97% of buildings in the EU need to be upgraded. 
(Available: Online) 

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States),  which  fosters  higher  quality 
of works. 

on theoretical energy use, which might 
lead to that the full scope of estimated 
energy savings might not materialise in 
actual energy savings. 

Cost-
optimality 

Expressed in terms of GHG emissions, 
the  requirements  facilitate  the  cost-
optimal combination of investment in 
building  performance  or  renewable 
energy sources. 

To reach equal final performances, one-
stage deep renovations are, in general, 
cheaper than staged deep renovations. 
If  the  MMR  model  triggers  staged 
renovations,      the  overall  cost  will 
increase.  

Optimising  the  combination  of  energy 
efficiency  and 
renewables  on  an 
individual building level, risk leading to 
of  macro-
the  non-consideration 
additional 
economic 
investments 
power 
infrastructure),  which  are  not  reflected 
in  the  microeconomic  model  for  the 
individual building.  

costs 

(e.g. 

the 

in 

Socio-economic 

Split 
incentives 

The  progressive  MMR  reduces  the 
barrier of the  split-incentive dilemma 
since the decision to invest in energy 
renovations is mandatory. 

Energy 
Poverty 

Improving 
the  worst-performing 
buildings,  in  which  a  larger  share  of 
live,  would 
energy-poor  persons 
improve 
reduce  energy  bills  and 
health and wellbeing.  

The  actor  bearing  the  cost  to  comply 
with the MMR might not be the same as 
the  one  getting  the  benefits.  At  worst, 
this  could  lead  to  a  higher  demolition 
rate or vacant apartments. 

In  contrast  to  MMR  model  1,  more 
investment will go to renewable energy 
in  model  2,  which  have no  real impact 
on energy poverty. Therefore, ensuring 
a  minimum  energy  performance  level 
should  be  ensured,  while  the  final 
stages to a decarbonised building can be 
investments  in  renewable  energy  if 
these investments are considered more 
cost-optimal for the individual building.  

EU long-term targets 

2030 
milestone 

GHG 

the  worst-
The  model  alleviates 
performing 
first, 
contributing  to  the  2030  targets  if 
being 
implemented  and  enforced 
before this date.  

buildings 

The  focus  on  the  worst-performing 
buildings does not foster improvements 
in the rest of the building stock. Energy 
savings  will  be  more  difficult  (more 
expensive)  to  achieve  after  the  initial 
round of renovations. 

2050  carbon 
neutrality 

The  model  focusses  on  mitigation  of 
carbon  emissions  and  is  thus  more 
aligned  with  EU’s  2050  climate 
targets. Which are expressed in CO2.  

The  MMR  model  states  that  whole-life 
carbon  considerations  can  be  included 
when  standards  and  infrastructure  for 
doing  this  are  mature  enough.  If  not 
included, all related emissions would not 
be included nor considered.  

Renewables 

The  model  fosters  investments  in 
renewables,  which  contributes  to  the 
renewable targets.  

Table 18. Impact assessment MMR Model 2 

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Illustrative impact consideration 

MMR model 2 formalises targets on GHG emission intensities (i.e. kgCO2/m²/year). It is 
considered that the EU carbon neutrality 2050 target is transposed as a long-term target 
for the performance of all residential buildings (an average target for the buildings stock 
would  lead  to  similar  results).  Therefore,  the  estimated  GHG  emissions  are  reduced 
down to zero, which is reflected in the impact consideration figure.   

The evolution of the final energy consumption is expected to differ from MMR model 1. 
MMR model 2 might result in a higher share of renewable energy investments, instead 
of energy efficiency investments, which could lead to lower reductions of the final energy 
consumption. This is not captured in this simplified model. Instead, it is considered that 
renewable heat investments are added to investments in energy efficiency, i.e. on top 
of the energy savings obtained with MMR model 1, so the deployment of low-carbon and 
higher-efficiency  heating  technologies  slightly  increases  the  final  energy  consumption 
reductions. The possible impact of a performance gap is illustrated with the light orange 
range, as in MMR model 1.  

Figure 51 – Illustrative impact assessment of MMR model 2 on the French residential buildings 
stock 

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Figure 52 – Illustrative impact assessment of MMR model 2 on the German residential buildings 
stock 

Feasibility assessment 

Indicator 

Strength 

Weaknesses 

If whole-life carbon is included, there 
is  a  data  gap  to  properly  evaluate 
embodied  emissions  of  construction 
materials and products. No common 
database of these emissions exist.  

of 

Maturity 
existing 
“infrastructure” 

factors 

Emission 
for  all  energy 
vectors are available and used by the 
Member  States  for  their  national 
inventories of GHG emissions. 
The EPC infrastructure already exists, 
to  different  extents,  in  all  Member 
States. The EPBD allows the Member 
States  to  include  an  indication  of 
carbon emissions in their EPC, which 
is  done  by  several  Member  States 
(e.g. France, Portugal and Poland).  

The  reliability  of  EPCs  is  improving 
(though 
from  being  perfect) 
offering  a  head  start  over  any  new 
instrument. 

far 

Several  Member  States  have  robust 
EPC  databases  that  can  be  used  to 
check compliance.  

Public databases, of current EPC, are 
not  in  place  in  all  countries  so  the 
quality  of  the  gathered  data  differs 
between the Member States.  

CO2  emissions  depend  on  energy 
supply contracts.  

Simplicity 

in 

GHG  emissions  of  the  building  are 
already the main indicator for nearly 
zero-energy  buildings 
some 
countries (NO, ES) or provided as an 
extra  indicator  (AT,  EI,  LU,  RO). 
Translating 
the  primary  energy 
consumption  (kWh/m2),  as  given  in 
the  EPC,  to  GHG/carbon  emissions 
 is not a complicated process.  
CO2

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The  calculation  and  message  to  the 
building 
become  more 
complex, which can hamper effective 
communication. 

owner 

Ease 
compliance 

of 

The  existing  EPC  infrastructure  can 
easily  be  adapted  to  check 
for 
compliance. 

Table 19. Feasibility assessment MMR Model 2 

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11.3.  MMR model 3: Progressive real carbon emissions budget 

No  impact  consideration  modelling  was  conducted  for  model  3,  as  most  of  the 
assumptions are mirroring model 2.  

Impact consideration  

Indicator 

Strengths 

Weaknesses 

Renovation rate 

Techno-economic 

By  triggering  the  renovation  of  the 
worst-performing buildings (i.e. over 
50% of buildings with an EPC have a 
rating worse than D152) by 2030, the 
model has the potential to bring the 
renovation  rate  to  3-5%/year  in  the 
period  to  2030  (i.e.  triggering  the 
to  50%  of 
renovation  of  30% 
buildings  within  10  years).  The 
impact  on  the  renovation  rate  will 
depend on how the MMR is designed, 
regulated and enforced. 

Renovation depth  Visibility  of  the  long-term  targets 
contributes to steering all renovation 
measures  towards  the 
long-term 
objective.  

Avoids  risk  of  the  performance  gap, 
as  the  requirement  is  set  on  actual 
carbon use. 

The  progressive  reduction  of  GHG 
emissions  can  be  aligned  with  EU’s 
long-term  objective  for  the  building 
stock (i.e. the standards can require 
zero emissions by 2050).   

Renovation quality  Ensures  actual  carbon  emission 
savings,  due  to  a  real  decrease  in 
carbon  emissions.  The  performance 
gap is not an issue in this model.  

Cost-optimality 

in 

terms 

of  GHG 
Expressed 
emissions,  the  requirements  leave 
room  to  either  invest  in  building 
performance  or  renewable  energy 
sources. 

in 

terms 

Expressed 
of  GHG 
emissions, the requirements facilitate 
the  cost-optimal  combination  of 
investment  in  building  performance 
or renewable energy sources. 

Depending  on  how 
it's  being 
enforced,  some  building  owner 
would  opt  for  changing  behaviour 
(which  could  have  adverse  health 
effects).  

Progressive  enforcement  might 
trigger  step-by-step  renovations 
before one-stage deep renovations. 
If  the  progressive  enforcement 
calendar is defined right away (i.e. 
what  performance  is  required  by 
2050, including milestones) it would 
reduce this risk, as building owners 
and  investors  would  also  renovate 
to make their building asset “future 
proof” (i.e. not just complying with 
the  pending  requirement  but  the 
ones that will come into force in 10-
20 years).   

To reach equal final  performances, 
one-stage deep renovations are, in 
general, cheaper than staged deep 
renovations.  If  the  MMR  model 
triggers  staged  renovations,      the 
overall cost will increase.  

Optimising 
the  combination  of 
energy  efficiency  and  renewables 
on an individual building level, risk 
leading to the non-consideration of 
macro-economic 
(e.g. 
additional investments in the power 
infrastructure),  which  are  not 

costs 

152 Calculation based on data from BPIE (2018); 97% of buildings in the EU need to be upgraded. 
(Available: Online) 

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reflected 
model for the individual building.  

the  microeconomic 

in 

Socio-economic 

Split incentive 

The  enforcement  calendar  alleviates 
the 
split-incentive  dilemma  by 
mandating  when  to  invest  in  energy 
renovations.  

The  actor  bearing  the  cost  to 
comply with MMR might not be the 
one getting the benefits.  

Energy poverty 

EU long-term targets 

2030 
milestone 

GHG 

The  model  alleviates  the  worst-
performing 
first, 
contributing  to  the  2030  targets  if 
being 
implemented  and  enforced 
before this date.   

buildings 

The  model  raises  awareness  and 
enhances a change of habits towards 
decreased 
beyond 
insulation  and  towards  the  whole 
emission spectrum, including change 
of  comfort  temperature,  numbers  of 
rooms heated, use of appliances, etc. 

emissions, 

A  risk  that  building  owner  forces 
tenants to reduce heating, in order 
to comply with the standard.  

Risk of changing behaviour instead 
of  investments  in  better  buildings. 
The  model  is  less  suitable  for 
residential buildings.  

not 

does 

The focus on  the worst-performing 
buildings 
foster 
improvements  in  the  rest  of  the 
building  stock.  Energy  savings  will 
be  more  difficult  (more  expensive) 
to achieve after the initial round of 
renovations. 

administrative 

People might consider it as leading 
to  a  decreased  quality  of  life. 
Financial, 
and 
counselling  support  to  poor  and 
medium  revenue  households  is  of 
prime 
the 
acceptance of the model.  

importance 

for 

2050 
neutrality 

carbon 

The  actual  carbon  use  is  a  more 
accurate  indicator  and  fully  aligned 
with  the  long-term  target,  which  is 
expressed in CO2.  

The MMR model states that whole-
life  carbon  considerations  can  be 
included  when 
standards  and 
infrastructure  for  doing  this  are 
mature enough. If not included, all 
related  emissions  would  not  be 
included nor considered. 

Renewables 

The  model  fosters  investments  in 
renewables,  which  contributes  to 
renewable energy targets. 

encourages 

The  model 
self-
consumption  for  ‘prosumers’  since 
self-consumption  will  not  be  taken 
into account. 

Table 20. Impact assessment MMR Model 3 

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Feasibility assessment 

Indicator 

Strengths 

Weaknesses 

Maturity of existing 
“infrastructure” 

Simplicity 

and 

declare 

Buildings  across  all  sectors  do 
their 
measure 
consumption,  hence  data  already 
exists. Smart meter data, which is 
prefered  to  monthly  utility  bills, 
in  most  Member  States. 
exist 
Although, 
is  still 
roll-out 
underway.  

the 

Ease of compliance  Expressed in actual carbon use, the 
requirement leaves room to either 
invest  in  energy  performance  or 
renewables,  changing  behaviour 
(awareness-raising) or renewables.  

Data privacy and security ought to 
be  considered.  In  some  countries, 
actual energy consumption data is 
considered sensitive.  

The communication to the building 
owner/person  responsible  for  the 
more 
activity 
complicated,  which  can  hamper 
effective signalling.  

becomes 

A  just  and  fair  definition  of  the 
carbon  budget  must  be  defined 
across all sectors, all activities and 
all  households,  which 
a 
challenging task. 

is 

if  heat  supply 

Full decarbonisation might only be 
achievable 
is 
is  not  the 
decarbonised.  This 
the  building 
responsibility  of 
owner/occupant  but  depends  on 
the  transformation  of  the  supply 
sector. 

Table 21. Feasibility assessment MMR Model 3 

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11.4.  MMR  model  4:  Mandatory 

improvements  trigger  by 

indoor 

environmental quality deficiencies 

Impact analysis 

Indicator 

Strengths 

Weaknesses 

Techno-economic 

Renovation 
rate 

Renovation 
depth  

Renovation 
quality 

Cost-
optimality 

Can  trigger  a  substantial  number  of 
energy  renovations,  in  particular  of 
the  worst-performing  buildings  with 
regards  to  energy  efficiency  and 
energy 
buildings  with 
performance  but  that  do  not  meet 
targeted IEQ levels. 

better 

Not  primarily 
renovations.  

focused  on  energy 

Can  enable  a  more  holistic  view  of 
deep  renovation,  considering  energy 
performance  as well as IEQ  aspects. 
Future technologies, such as sensors 
and smart meters, can enable a more 
accurate evaluation of the buildings. 

Progressive enforcement triggers step-
by-step  renovations  and  does  not 
foster  one-stage  deep 
necessarily 
renovations.  Risk  of 
fragmented 
measures  dealing  with  one  deficiency 
(e.g. ventilation rate).   

Inadequately  designed  deep  energy 
renovation  can  lead  to  reduced  IEQ. 
Explicit  IEQ  requirements  help  to 
raise awareness and ensure that IEQ 
performance  is  part  of  the  design  of 
renovation projects. 

The  energy  or  carbon  efficiency 
improvements will remain  subject to 
regarding 
minimum 
requirements 
IEQ,  which 
foster  quality 
renovations. 

can 

 IEQ investments will improve what is 
described  as  “multiple  benefits”, 
including  better  health,  productivity 
and wellbeing. Research indicates the 
societal 
be 
considerable.  

benefits 

could 

IEQ  is  not  considered  in  the  current 
cost-optimal  calculation.  Most  non-
energy  investments  would,  therefore, 
not be considered “cost-optimal” 

Socio-economic 

Split 
incentives 

The  enforcement  calendar  alleviates 
the  split-incentive  dilemma  when  it  
decides to invest in the overall quality 
of the building.  

The actor  investing to comply with the 
MMR might not be the one benefiting. 
Many  of  the  benefits  are  societal  and 
might  not  be  considered  tangible  for 
the  person  making 
financial  
investment.  

the 

Energy 
poverty 

Inadequate IEQ is a frequent problem 
for 
the  energy-poor  community, 
where it has adverse effect on health 
and wellbeing.  

EU long-term targets 

2030 
milestone 

GHG 

The model, would alone, have a limited 
impact on the 2030 GHG milestone. 

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Carbon 
neutrality  by 
2050 

Renewables 

The model, would alone, have a limited 
impact  on  the  2050  carbon  neutrality 
goal. 

The  focus  on  IEQ  does  not  explicitly 
foster  the  development  of  renewable 
energy. 

Table 22. Impact assessment MMR Model 4 

Illustrative impact assessment: 

MMR model 4 assumes that all unhealthy buildings will be renovated by 2030, in addition 
to what is already triggered by MMR model 2. Given that reasons to renovate go beyond 
energy  efficiency,  it  is  considered  that  deep  renovations  can  be  triggered  (both  two-
stage and one-stage renovations are considered). The impacts of this MMR model derive 
from deeper and earlier renovations. 

Besides buildings where people are unable to keep warm, unhealthy buildings include 
buildings with e.g. leaks, damp and rot that might not be the worst-performing ones in 
terms  of  energy  efficiency.  Based  on  the  question  ‘Do  you  have  any  of  the  following 
problems  with  your  dwelling/accommodation?’,  16%153  of  households  answered  yes, 
qualifying their dwelling as unhealthy – yet only 9%154 (of these155) were unable to keep 
their home warm. In this impact assessment, we consider that unhealthy buildings with 
problems  beyond  minimum  energy  efficiency  requirements  will  undergo  deeper 
renovations,  ranging  from  two-stage  to  one-stage  renovations  toward  the  long-term 
targets. We further assume that dwellings where households are unable to keep warm 
stand within the worst energy-performing EPC class (i.e. class F), and that the ones with 
health issues other than energy efficiency are equally distributed between classes E and 
D. The modelling of MMR model 4 assumes that the renovation of all of these buildings 
is triggered by 2030. 

The  orange  range shows the results for renovation depths  varying from two-stage to 
one-stage renovations toward the long-term target (EPC B with 100kWh/m²/year). As 
discussed above, the broader scope also fosters holistic quality considerations in energy 
renovations,  avoiding  new  unhealthy  situations  resulting  from  wrong  design  or 
implementation. 

153 12% for France and 11% for Germany. See EU’s Energy Poverty Observatory. 
154 6% for France and 4% for Germany. See EU’s Energy Poverty Observatory. 
155 This is an interpretation. 

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Figure 53 – Illustrative impact assessment of MMR model 4 on the French residential buildings 
stock 

Figure 54 – Illustrative impact assessment of MMR model 4 on the German residential buildings 
stock 

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Feasibility analysis 

Indicator 

Strength 

Weaknesses 

of 

Maturity 
existing 
“infrastructure” 

The  policy  option  requires  a 
focus  on  non-energy 
larger 
aspects, 
increasing  people’s 
awareness and expertise in that 
field. 

to 
EPCs  could  be  adapted 
become  effective  instruments  to 
track not only a building’s energy 
performance  but  also  its  overall 
IEQ by providing evidence-based 
information. 

Simplicity 

Ease 
compliance 

of 

IEQ  is  not  commonly  addressed 
and  various  approaches  exist  to 
assess it. Having a common and 
uniform 
is 
challenging. 

methodology 

Regular  IEQ  checks  are  not 
carried  out  and  no  simplified 
procedure  (to  check  ventilation, 
noise,  thermal  comfort,  lighting 
etc.) is in place. 

Table 23. Feasibility assessment MMR Model 4 

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11.5.  MMR  model  5:  Progressive 

implementation  of  pre-defined 

renovation steps based on a building renovation passport 

Impact consideration  

Indicator 

Strengths 

Weaknesses 

Techno-economic 

(BRP) 

If  we  assume  that  the  budget  for 
renovation measures is fixed, a fraction 
of  this  will  be  diverted  to  renovation 
advice 
actual 
energy/carbon  saving  measures.  It  is, 
however, likely that the improvement of 
type  of  measures  (saved  kWh  per 
invested  EUR)  would  be  higher  and 
exceed the initial cost.  

instead  of 

Renovation 
rate 

The  model  alleviates  the  worst-
performing 
first, 
contributing  to  the  2030  targets  if 
being  implemented  and  enforced 
before this date.   

buildings 

Renovation 
depth 

The BRP allows every owner to have 
a clear overview of the cost-optimal 
way to reach the 2050 target.  

The  BRP  would  ensure  the  cost-
optimal path to a deep renovation is 
ensured, in one or several steps. The 
existing  EPC  recommendations  are 
too often generic and don’t take into 
account  the  building’s  trajectory 
towards the long-term target.  

Renovation 
quality 

The  EPC  can  be  used  to  prove 
compliance (as is done with financial 
subsidies in several countries), which 
fosters higher quality of works. 

implemented  measures,  as 
The 
suggested by the  BRP,  will  be  more 
accurate  and  of  higher  quality  (e.g. 
higher performance of the insulation 
material)156.   

Cost-
optimality 

The  BRP  can  display  whether 
investing  in  energy  performance  or 
investing 
renewable  energy 
in 
sources is the best option. 

While  this  model  focuses  on  single 
buildings,  buildings  managers  might 
have  a  more  cost-optimal  pathway 
towards the end-goal.  

The audit or passport is written by an 
expert which helps avoid costly lock-
in  effects,  ensuring  that  buildings 
can  reach  optimal  performance  by 
2050  in  a  relatively  cost-effective 
way. 

Optimising  the  combination  of  energy 
renewables  on  an 
efficiency  and 
individual building level, risk leading to 
of  macro-
the  non-consideration 
additional 
economic 
investments 
power 
infrastructure), which are not reflected 
in  the  microeconomic  model  for  the 
individual building. 

costs 

(e.g. 

the 

in 

156  Fabbri,  et  al.  (2020).  “Final  report  –  Technical  study  on  the  possible  introduction  of  optional  building 

renovation passports”. European Commission. (Available: Online) 

138 

 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Socio-economic 

Split 
incentives 

The  progressive  MMR  reduces  the 
barrier of the split-incentive dilemma 
since the decision to invest in energy 
renovations is mandatory. 

The  actor  bearing  the  cost  to  comply 
with the MMR might not be the same as 
the one getting the  benefits.  At  worst, 
this  could  lead  to  a  higher  demolition 
rate or vacant apartments. 

Energy 
poverty 

Improving 
the  worst-performing 
buildings, in which a larger share of 
energy-poor  persons 
live,  would 
reduce  energy  bills  and  improve 
health and wellbeing.  

Without clear regulation, there is a risk 
the cost of the renovation measures will 
fully be put on the tenants (through rent 
increases),  which  then  could  have  an 
adverse effect.  

EU long-term targets 

performance 

The  impact  until  2030  in  terms  of 
energy 
carbon 
emissions  will  be  limited,  as  the  first 
step  will  be  to  acquire  a  building 
renovation passport.  

and 

2030  GHG 
milestone 

can 

This 
force  more  efficient 
buildings  to  also  play  their  role  to 
achieve  the  2030  milestone,  not 
focusing  solely  on  worst-performing 
buildings. 

Carbon 
neutrality 
by 2050 

The  model  enables  the  contribution 
of each building to reach an average 
performance  of  the  overall  building 
stock 

Renewable
s 

The  model  fosters  investments  in 
renewables, which contributes to the 
renewable targets.  

Table 24. Impact assessment MMR Model 5 

Illustrative impact assessment: 

MMR  model  5  consists  of  mandating  the  implementation  of  renovation  packages 
identified in a BRP. BRPs are here assumed to consist of four renovation packages, three 
of which focus on the energy efficiency of the building envelope (assuming distributed 
energy savings across renovation packages) with the fourth one consisting of renovating 
to higher-efficiency and low-carbon heating systems.  

This MMR model is considered to trigger earlier renovations thanks to the provision of 
quality information to households via the deployment of BRPs. However, assuming that 
retrofitting of the heating system is the last step in an ‘energy efficiency first’ renovation 
pathway, large GHG emission reductions are only obtained on the last part of the time 
horizon  (corresponding  to  the  mandatory  implementation  of  the  last  renovation 
packages). This shows that low-carbon heat deployment should be seen in parallel to 
triggering the first renovation packages to reach ambitious 2030 GHG targets. 

139 

 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Figure 55 – Illustrative impact assessment of MMR model 5 on the French residential buildings 
stock 

Figure 56 – Illustrative impact assessment of MMR model 5 on the German residential buildings 
stock 

140 

 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Feasibility analysis 

Indicator 

Strength 

Weaknesses 

of 

Maturity 
existing 
“infrastructure” 

First  experiences  of  BRP  are 
available in several of the Member 
States 
Belgium). 
Further, the instrument is already 
flanked within the EPBD. 

(Germany, 

is  yet 

A  general,  fair  and  adapted  building 
to  be  defined. 
passport 
Inspiration  can  be  found  in  the 
already  existing  cases  but  must  be 
greatly  amended  to  be  applied  EU-
wide.  

Simplicity 

The  BRP  could  simplify  and  tailor 
the  message  to  the  end-user, 
increasing the acceptance.  

Every building must be analysed by an 
expert  which 
requires  a  high 
workforce that is not yet trained. 

The  expert  must  be  trained  and 
unbiased,  having  no  conflict  of 
interests.  Compliance  mechanisms 
and guidelines are required to ensure 
high reliability.  

Ease 
compliance 

of 

Directly relates to the information 
about  the  step  to  implement  and 
how much investment is needed. 

Proof  of  compliance  can  be 
construction 
the 
ensured  by 
workers  or  through  a  purchase 
receipt.  

Table 25. Feasibility assessment MMR Model 5 

141 

 
 
 
 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

11.6.  MMR model 6: Mandatory renovation of all buildings at real estate 

transactions to move towards the long-term target 

Impact consideration  

Indicator 

Strengths 

Weaknesses 

Renovation rate  Real estate transaction rates 

Techno-economic 

Renovation 
depth 

are about ~1.7%/year, 
indicating the potential of this 
model on the renovation rate. 

Real estate transactions are 
the best moment to 
undertake a deep renovation. 
This MMR model captures 
these trigger points. 

Renovation 
quality 

The EPC can be used to prove 
post-measure compliance (as 
done with financial subsidies 
in several Member States), 
which fosters higher quality 
of works. 

Cost-optimality  Many buyers of buildings do 

carry out work in conjunction 
with the purchase. 
Embedding mandatory 
renovations can lead to 
relatively small additional 
costs while bringing savings 
on energy bills capturing 
most of the costs since real-
estate transactions are 
usually long-term (>20 
years) 

Progressive  enforcement  might  trigger 
step-by-step renovations before one-stage 
deep  renovations.  If 
the  progressive 
enforcement calendar is defined right away 
(i.e. what performance is required by 2050, 
including  milestones)  it  would  reduce  this 
risk,  as  building  owners  and  investors 
would also renovate to make their building 
asset “future proof” (i.e. not just complying 
with the pending requirement but the ones 
that will come into force in 10-20 years).   

Operational (actual) energy use often 
differs from the theoretical energy use 
(asset rating). The current EPC 
frameworks are predominantly focused on 
theoretical energy use, which might lead 
to that the full scope of estimated energy 
savings might not materialise in actual 
energy savings. 

To  reach  carbon  neutrality,  one-stage 
approaches  are  cheaper  than  multiple-
staged  ones.  By  default,  MMR  model  6 
triggers staged renovations to comply with 
the  progressively  increasing  requirement. 
total 
then 
This  might 
investment costs.  

increase 

the 

While  this  model  focuses  on  individual 
buildings, building managers might have a 
more  cost-optimal  pathway  to  the  final 
target  (e.g.  deep  renovation  of  20%  of 
their buildings every five years). 

Socio-economic 

Split incentives 

Addresses the split incentive 
by forcing owners at the time 
of their acquisition to 
improve the building.  

Focuses only on single ownership as real 
estate transactions are less of an 
opportunity to structure deep renovation 
projects in multiple-ownership buildings. 

Energy poverty 

If not combined with an MMR 
model targeting the worst-
performing buildings, this 
model would not be effective 
in improving these. 

Risk of higher pressure on access to 
housing; acquiring a property causes 
indebtedness that could be increased 
further with mandatory renovation works. 

142 

 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

EU long-term targets 

2030 
milestone 

GHG 

Mandating all building owners 
to renovate, when purchasing 
a new property. It would 
trigger renovations beyond 
the worst-performing 
buildings.  

If not combined with an MMR model 
targeting the worst-performing buildings, 
this model would not be effective in 
improving these.  

2050 
neutrality 

carbon 

Renewables 

The main focus on single-ownership 
buildings – additional actions are needed 
to decarbonise the remaining buildings. 

The focus on energy efficiency does not 
explicitly foster the development of 
renewable energy sources. 

Table 26. Impact assessment Model 26 

Illustrative impact assessment: 

MMR model 6 is assumed to capture the 1.9%/year sales from 2025 onwards to trigger 
deep  energy  renovations.  Beyond  what  is  already  triggered  by  MMR  model  2,  MMR 
model 6 fosters earlier and deeper energy renovations. It has the potential to increase 
the  results  reached  by  2030,  further  reducing  in  the  case  of  France  the  final  energy 
consumption by between 6% (two-stage renovations) and 9% (one-stage renovations), 
and the GHG emissions by between 8% (two-stage renovations) and 20% (one-stage 
renovations)  compared  to  2020.  Despite  a  similar  annual  rate  of  sales,  additional 
savings by 2030 are higher for Germany as there is a higher share of worst-performing 
buildings. 

Figure 57 – Illustrative impact assessment of MMR model 6 on the French residential buildings 
stock 

143 

 
 
 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

Figure 58 – Illustrative impact assessment of MMR model 6 on the German residential buildings 
stock 

Feasibility analysis 

Indicator 

Strength 

Weaknesses 

Most  Member  States  have  less  than 
10% of their building stock covered by 
EPCs.  The  EPCs  diverge  in  quality 
and  reliability,  depending  on  the 
existing framework in place, including 
control mechanisms.  

Public EPC databases are not in place 
in  all  countries  so  the  quality  of  the 
gathered  data  differs  between  the 
Member States. 

of 

Maturity 
existing 
“infrastructure” 

Simplicity 

Including  EPCs  for  transactions  is 
already mandatory. Hence there is a 
the 
great  opportunity 
necessary investments to reach the 
necessary 
performance 
level. 

to  add 

energy 

infrastructure  already 
The  EPC 
exists,  to  different  extents,  in  all 
Member  States.  The  reliability  of 
EPCs  is  improving  and  has  a  head 
start on any new instrument. 
Several Member States have robust 
EPC  databases  that  can  be  used  to 
check compliance.  

The  MMR  applies  to  all  buildings 
(except  the  2050-ready),  which 
makes the provision simple to grasp. 
Easy for municipalities to keep track 
as  property  transfers  generally  are 
reported.    

Ease 
compliance 

of 

Applies  to  real-estate  transactions 
which  allow  easier  and  clear 
ensure 
communication 
understanding and compliance from 
all parties. 

to 

Increases  the  necessary  investment 
when buying new property and works 
may  lead  to  unexpected  additional 
costs or delay which not always viable 
(e.g. new business). 

Table 27. Feasibility assessment MMR Model 6 

144 

 
 
 
 
 
 
 
 
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renovation and modernisation of the built environment  

11.7.  Methodology for the illustrative impact consideration  

The  illustrative  impact  considerations  are  proposed  to  highlight  the  main  features  of 
MMR models, compared to each other. The modelling used CLIMACT tools, developed to 
design and evaluate buildings renovation scenarios in the context of the LTRS. The tool 
was refined to apply to the MMR models proposed in this report. 

The  quantification  was  performed  on  two  Member  States,  Germany  and  France.  The 
illustrative  impact  assessment  focuses  on  residential  buildings  as  data  on  the  energy 
performance of non-residential buildings remain insufficient. This appendix provides the 
data sources considered and the assumptions made for this assessment. 

The goal of this quantification is to provide a first illustration of the relative impacts from 
one MMR model to another. A list of assumptions is provided. The assumptions are a 
simplified version of reality and should be regarded as such. The modelling can certainly 
be refined in the future to better account for additional specific dynamics and variables. 
Also,  only  the  direct  (on-site)  emissions  are  considered,  i.e.  emissions  from  the 
generation of electricity and lifecycle impacts are not accounted for. 

The  results  can  be  very  sensitive  to  some  of  these  assumptions.  Next  steps  to 
strengthen this quantitative assessment beyond the scope of this study should be: 1) 
identify the assumptions to which the results are the most sensitive, 2) collect data to 
strengthen these assumptions, 3) calibrate the modelling data to the reported energy 
consumption (in the absence of calibration the results are provided in relative terms). 

11.7.1. 

General assumptions 

The  impact  is  driven  by  the  distribution  (initial  and  evolving)  of  buildings  across  EPC 
classes and their respective energy intensities. 

Label 

Share of 
residential 
buildings 

F 
E 
D 
C 
B 
A 

11% 
21% 
29% 
17% 
13% 
9% 

Avg primary 
energy 
consumption 
[kWh/m²/y] 
653 
305 
210 
135 
80 
38 

Share of 
residential 
buildings 

56% 
12% 
13% 
10% 
4% 
5% 

Avg primary 
energy 
consumption 
[kWh/m²/y] 
580 
325 
225 
138 
88 
38 

Table 28. Distribution of the residential buildings stock for France and Germany  
and average specific primary energy consumptions by EPC label considered in this assessment 

•  The long-term primary energy consumption target is set to 100kWh/m²/year. 

This seems a realistic target considering the long-term target currently defined 
in LTRS: 100kWh/m²/year in Flanders (Belgium), 85kWh/m²/year in Wallonia 
(Belgium), BBC (low energy building) level corresponding to 80kWh/m²/year in 
France. 

•  Robust calibration of the model to the national energy balances being beyond 

the scope of this project, results are provided in relative terms. The order of 
magnitude of the results is consistent with the one obtained with detailed 
calibration for the building stocks in Flanders and Wallonia. Their renovation 
strategies report that the renovation of their residential buildings stock will 
reduce the final energy consumption for heating (by 2050 in relative to 2020) by 
25% in Flanders targeting 100kWh/m²/year and by 55% in Wallonia targeting 
85kWh/m²/year. 

•  No differentiation of the average floor area is considered across EPC classes. 
Depending on the characteristics of the national buildings stock, proper 

145 

 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

differentiation will modify the weight on the final results of energy renovations of 
the different segments.157 

Label 

F 
E 
D 
C 
B 
A 

Primary energy 
conversion factors 
40% 
55% 
70% 
85% 
100% 
100% 

•  The GHG emissions are derived based on the following fuel mixes: 

Table 29. Primary energy correction factors 

Energy 
carrier 

Coal 
Oil 
Gas 
Electricity 
Sustainable 
energy 
resources 

Fuel mix 
considered by 
2020158 
0% 
15% 
46% 
8% 
31% 

Improved  
fuel mix by 2050 
(MMR model 1) 
0% 
0% 
46% 
8% 
46% 

Low carbon  
fuel mix by 2050 
(MMR model 2) 
0% 
0% 
0% 
10% 
90% 

Table 31. The fuel mix for heating modelled for France 

Energy carrier 

Coal 
Oil 
Gas 
Electricity 
SER 

Fuel mix 
considered by 
2020 
1% 
22% 
50% 
2% 
25% 

Improved  
fuel mix by 2050 
(MMR model 1) 
0% 
0% 
50% 
2% 
49% 

Low carbon  
fuel mix by 2050 
(MMR model 2) 
0% 
0% 
0% 
10% 
90% 

Table 32. The fuel mix for heating modelled for Germany 

•  GHG intensities are further derived for each EPC class considering that each 

improvement of one EPC class increases the share of low-carbon heat (including 
electricity) by 30%. 

•  A performance gap is often observed, resulting from non-optimal performances 

at different steps of the value chain (design, implementation, utilisation, 
maintenance). The possible impact of this performance gap is illustrated by 
considering that for high-efficiency buildings (< 50kWh/m²/year), the real 
energy consumption can be up to 25% higher than the one calculated ex-ante 
(this is a working assumption that can be refined). 

11.7.2. 

Assumptions specific to MMR models 

•  Timing of implementation 

- 

In the modelling of MMR models 1 and 2, it is assumed that the 
announcement of a first mandatory minimum requirement applying 

157 E.g. data from the EPC databases in Belgium show that the floor area of today’s best-performing 
dwellings is 17% (in Wallonia) and 23% (in Flanders) higher than the floor area of the worst-performing 
ones.  
158  Based  on  “Mapping  and  analyses  of  the  current  and  future  (2012,  2020,  2030)  heating/cooling  fuel 
deployment (fossil/renewables) -- Work package 3: Scenarios for heating & cooling demand and supply until 
2020/2030” 

146 

 
 
Task 4 of the study: Lessons learned to inform integrated approaches for the 
renovation and modernisation of the built environment  

by 2035 will progressively accelerate the pace of renovations from 
2025 onward to reach a steady-state activity by 2030.  

-  Given that MMR model 5 requires the deployment of a BRP to 

- 

households and considering that the quality of information helps to 
trigger renovations, MMR model 5 is modelled as leading to steady-
state renovation activity from 2025 onward. 
It is considered that every not-captured key moment is a missed 
opportunity to trigger energy renovations and that key moments 
should be captured as soon as possible to support the realisation of 
the 2030 GHG target. In the modelling of MMR model 6, it is 
assumed that key moments are progressively captured from now on 
to reach their full potential from 2025 onward. 

•  MMR model 2 formalises targets on the GHG emission intensities (i.e. 

kgCO2/m²/year). The modelling tools do not allow to model this as such. Two 
approaches were followed, both considering that carbon neutrality is set as long-
term target: 

-  On top of the final energy consumption reductions resulting from 
MMR model 1, a progressive deployment of low-carbon heating 
technologies is considered towards carbon neutrality. It is assumed 
that low-carbon technologies will be progressively deployed in 
better-performing buildings. The pace of deployment follows the 
evolution of the share of EPC B buildings in the buildings stock. 
-  EPC level upgrades are expressed directly in terms of GHG intensity. 

To this end, the distribution of buildings across GHG intensity 
clusters is structured based on the EPC level distribution and the fuel 
mix as follows: given the buildings-related energy intensities and 
energy carrier-related GHG intensities, solid fuel-based dwellings 
‘lose’ 2 EPC classes and gas-based dwellings ‘lose’ 1 EPC class. This 
increases the amount of worst-performing buildings which then leads 
to triggering the renovation of a higher amount of buildings by the 
first milestone (i.e. 2035 in this assessment). 

-  The initial and targeted levels of GHG intensity provided in the table 
below were considered. While the values based on the theoretical 
energy consumption inform the link between EPC levels and the 
corresponding GHG intensities, those based on corrected energy 
consumption were considered to assess the GHG emission reductions 
resulting from the MMR model. There are slight deviations between 
the initial and targeted GHG intensities which should be read as 
follows e.g. for class E159 buildings: current class E buildings have a 
GHG intensity of 24kgCO2/m²/year, but class F buildings reaching 
class E after renovation has a GHG intensity of 20kgCO2/m²/year. 

159 Class E buildings are – under this modelling approach to MMR model 2 – buildings with the average 
energy efficiency of EPC E buildings heated with gas-fired boilers or lower-carbon technologies. Coal-fired 
and oil-fired boilers are switched to class F. 

147 

 
 
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renovation and modernisation of the built environment  

Class 

F 
E 
D 
C 
B 
A 

Share of EPC 
revisited based 
on GHG 
intensities 
16% 
23% 
26% 
16% 
12% 
7% 

Initial GHG intensity 
[kgCO2/m²], 
based on 

Targeted GHG intensity 
[kgCO2/m²], 
based on 

Theoretical 
energy 
consumption 

Corrected 
energy 
consumption 

Theoretical 
energy 
consumption 

Corrected 
energy 
consumption 

120 
49 
29 
15 
7 
2 

43 
24 
18 
12 
6 
1 

50 
25 
15 
5 
0 

20 
15 
10 
5 
0 

Table 33. GHG intensities considered for the French residential buildings stock 

Class 

F 
E 
D 
C 
B 
A 

Share of EPC 
revisited based 
on GHG 
intensities 
16% 
23% 
26% 
16% 
12% 
7% 

Initial GHG intensity 
[kgCO2/m²], 
based on 

Targeted GHG intensity 
[kgCO2/m²], 
based on 

Theoretical 
energy 
consumption 

Corrected 
energy 
consumption 

Theoretical 
energy 
consumption 

Corrected 
energy 
consumption 

106 
54 
33 
17 
9 
2 

41 
29 
23 
14 
8 
2 

50 
25 
15 
5 
0 

20 
15 
10 
5 
0 

Table 34. GHG intensities considered for the German residential buildings stock 

•  For MMR model 6, the yearly rate of sales of existing dwellings is considered to 

be 1.9%/year based on the following: 

- 

- 

In France, there were 870,000 housing transactions a year on 
average during the last three years with available data160, which 
represents an average yearly rate of 2.9%. Since we focus on 
existing buildings, the 1%161 rate of new residential dwellings must 
be subtracted which leaves a 1.9%/year rate of housing transactions 
of existing units.  
In Germany, there were 1,004,000 housing transactions a year on 
average in the last three years with available data162, which 
represents an average yearly rate of 2.5%. Subtracting the 0.6%163 
rate of new residential dwellings leaves a 1.9%/year rate of housing 
transactions of existing units. 

160 European Central Bank – Statistical Data Warehouse (2017, 2016, 2015) (Available: Website) 
161 Zebra 2020 Porject. European Commission – Horizon 2020 (Available: Website) 
162 Arbeitskreis der Oberen Gutachterausschüsse, Zentralen Geschäftsstellen und Gutachterausschüsse in 
der 
Bundesrepublik Deutschland (AK OGA) (2019)  Figure 4-1 (Available: Online) 
163 Zebra 2020 Porject. European Commission – Horizon 2020 (Available: Website) 

148 

 
 
 
 
 
 
 
 
 
 
 
 
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