COMMISSION DELEGATED REGULATION supplementing Directive 2024/1275/EU of the European Parliament and of the Council on the energy performance of buildings concerning the establishment of a comprehensive portfolio framework for voluntary use by financial institutions to encourage them to increase lending volumes provided for energy performance renovations.
Date: 2026-01-13
Institutions: Directorate-General for Energy, European Commission
Subjects: energy policy

Public consultation on a portfolio framework to increase lending volumes to-
wards energy performance renovations  

Summary report of the public consultation 

Disclaimer: the views presented in this factual summary report are not the views of the European Commission 
but of the stakeholders that participated in this open public consultation. It cannot under any circumstances 
be regarded as the official position of the Commission or its services.  

Summary report 
Factual summary report of the public consultation 
From 26 June until 18 November 2025 an open public consultation (OPC)1 was held on the delegated act estab-
lishing a portfolio framework to encourage financial institutions to increase lending volumes for energy perfor-
mance renovations of buildings.  

The consultation followed an earlier call for evidence on “Energy efficient  buildings  – portfolio framework to 
increase lending for renovations (delegated act)” from November 2024. Its objective was to gather more detailed 
feedback from credit institutions and other stakeholders on how a portfolio framework could support energy 
renovation lending in practice, including the most appropriate EU level action and data requirements. 

This factual report summarises the contributions submitted through the online questionnaire. It presents the 
views of respondents in a factual and neutral way and does not draw policy conclusions or provide recommen-
dations. 

 Methodology 
The analysis is based on 45 contributions submitted via the online questionnaire. The dataset used for this report 
consists of the structured export from the consultation platform. The questionnaire contained 25 questions, split 
into 17 questions primarily addressed to financial institutions and financial intermediaries (Q1–Q17) and 8 ques-
tions addressed to all respondents (Q18–Q25).  

The questionnaire was structured in two parts: 

1.  Questions for financial institutions and financial intermediaries, covering products offered, refinancing 

and public support, disclosure and reporting obligations, and data availability and quality. 

2.  Questions for all respondents, focusing on enabling conditions for renovation finance, including the role 
of public authorities, non-financial measures, effective programmes and policies, EU initiatives, and ac-
cess to finance for worst performing buildings and vulnerable building owners. 

For each question, responses were analysed as follows: 

• 

Closed questions (yes / no)  were  summarised in terms of absolute numbers and percentages of re-
spondents answering each option. Non-responses (including where questions did not apply) were ex-
cluded from the baseline when calculating percentages and are indicated in tables where relevant. 
•  Open questions were analysed qualitatively to identify recurring themes, areas of broad convergence 
and notable minority views. Quotations are paraphrased to avoid identifying individual respondents. 

1 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13688-Cooking-appliances-
ecodesign-requirements/public-consultation_en 

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Profile of respondents 
Geographical distribution 
Respondents were predominantly based in Belgium, which accounted for 12 contributions, or 26.7% of all re-
plies, many of which were EU level organisations located there. A further group of responses came from larger 
Member  States  with  substantial  building  stocks  and  financing  activities,  in  particular  Italy  (6  contributions, 
13.3%), France (5 contributions, 11.1%), Spain (5 contributions, 11.1%) and Germany (4 contributions, 8.9%). 
Additional inputs were received from the Netherlands and Sweden (3 contributions each, 6.7% each) and from 
Finland and Austria (2 contributions each, 4.4% each). Finally, Romania, Hungary and Greece each provided 1 
contribution, corresponding to 2.2 % of replies per country. In total, the consultation collected contributions 
from 11 countries. 

Table 1 – Number of contributions per country 

Country 
Belgium 

Italy 
France 

Spain 
Germany 

Number of contributions 
12 

6 
5 

5 
4 

Netherlands  3 
3 
Sweden 

Finland 
Austria 

Romania 
Hungary 

Greece 

2 
2 

1 
1 

1 

Types of respondents 

Business associations and companies together accounted for more than half of all contributions, reflecting the 
strong interest of market actors involved in financing, supplying, or enabling energy renovations. The group of 
business associations (17 respondents) included EU level and national level representative bodies active in bank-
ing and mortgage lending, energy efficiency services and construction, real estate and manufacturers of renova-
tion-related technologies. These organisations typically responded on behalf of broader memberships and often 
provided consolidated sectoral perspectives on lending conditions, regulatory frameworks, market barriers and 
the expected role of public support programmes. 

The company or business respondents (8 contributions) were a heterogeneous group comprising commercial 
banks and specialised lenders and firms involved in building technologies or advisory services. Compared with 
associations, these contributions more frequently drew on operational experience, for example regarding prod-
uct  design,  risk  assessment,  data  management  practices  and  practical  obstacles  when  serving  households  or 
building owners. 

The consultation also attracted six contributions from NGOs, including environmental organisations, consumer 
advocacy bodies and groups active in just transition, housing and real estate policy. These organisations generally 
emphasised consumer protection, affordability, data transparency and equitable access to renovation finance. 
Their submissions often placed renovation finance in the wider context of energy poverty, the transition of the 
building stock and the need for inclusive policy design. 

Consumer organisations submitted two contributions, adding more detailed reflections on households’ ability 
to navigate renovation options and financial products. These stakeholders highlighted administrative complexity, 
information asymmetries and the importance of accompanying measures such as advisory services. 

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Public authorities (three contributions) participated primarily from the perspective of regulatory implementa-
tion and delivery programmes. These included national or sub national authorities involved in building renova-
tion schemes, energy efficiency programmes or public financial instruments. Their input typically focused on the 
interaction between EU level requirements and national implementation, as well as the design features that can 
improve access to finance for specific target groups. 

Two contributions were submitted by EU citizens, reflecting individual views on topics such as renovation needs, 
availability of financing options and the role of public authorities.  

One submission came from a trade union, highlighting worker related aspects of the renovation wave, including 
skills needs, job quality and the social dimension of large-scale renovation programmes. 

Taken together, the diversity of respondents provided insights from across the renovation finance ecosystem, 
including representative bodies, market actors, civil society organisations, public administrations and individual 
citizens. The distribution, and the list  of responding organisations by category and country, is  summarised in 
Table 2 and in the respondent annex. 

The distribution is summarised in Table 2. 

Table 2 – Contributions by type of respondent2 

2 Source: Energy efficient buildings – portfolio framework to increase lending for renovations (delegated act) 

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Organisation size 
Where reported, organisation size was distributed as shown in Table 3. 

Respondents therefore covered a mix of smaller organisations, including specialist associations and service pro-
viders, and larger institutions such as commercial banks, national promotional banks and large utilities. Two or-
ganisations did not report their size. 

Table 3 – Organisation size of respondents 

Organisation size 
Micro (< 10 employees) 

Number of contributions 
16 

Small (< 50 employees) 
Medium (< 250 employees)  6 

11 

Large (250 or more) 
Not reported 

10 
2 

Questions for financial institutions (Q1-Q17) 

Across Q1–Q17,  25 out  of the 45 respondents provided at  least  one reply. These questions were mainly ad-
dressed to financial institutions and similar actors, and the response pattern reflected this. Most answers came 
from business associations speaking on behalf of member banks, from companies and businesses active in fi-
nance or energy services, and from entities classified as “Other”, which included national promotional institu-
tions and specialised intermediaries. Three public authorities and one consumer organisation also replied to 
several of these questions, often bringing in a public finance or supervisory perspective. NGOs, trade unions and 
EU citizens generally did not respond to this more technical, institution focused section. 

Taken together, the replies suggested that a significant number of participating institutions already integrated 
energy renovation in their product offering and, to a lesser extent, in their risk assessment practices, although 
the scale of this activity remained modest relative to total real estate business. Many of the respondents who 
did offer renovation-related products said they relied mainly on standard credit risk processes, supplemented 
in some cases using energy performance information. There was also broad interest in co-investment, blended 
instruments and green refinancing tools, including green and sustainability bonds and covered bonds, although 
use remained uneven and often concentrated in larger or more specialised entities. 

The questions on data and measurement confirmed that institutions faced significant challenges in accessing 
reliable and standardised building-related data, and that approaches to measuring energy savings and co-ben-
efits were still developing. While several respondents described relatively advanced practices, including the use 
of energy performance certificates, audits, modelling tools and internal quality assurance procedures, others 
reported limited or no systematic measurement of energy performance and a heavy reliance on client-provided 
documentation. Across these questions, both private and public actors stressed that fragmented data sources, 
limited digitalisation and the absence of interoperable building databases were major obstacles to fully integrat-
ing renovation considerations into portfolio management and refinancing strategies. 

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Questions for all respondents (Q18-Q25) 

Questions 18–25 covered enabling conditions for scaling up energy renovation lending, the role of public au-
thorities and EU level initiatives, non-financial measures and technical assistance, as well as specific challenges 
in targeting worst performing buildings and vulnerable households. Across these questions, 44 respondents pro-
vided at least one qualitative comment. For each question, between 35 and 42 respondents replied, with busi-
ness  associations  consistently  forming  the  largest  group,  followed  by  companies  and  business  respondents, 
NGOs, and entities categorised as “Other”. Public authorities, consumer organisations, EU citizens and one trade 
union also contributed, often bringing in implementation experiences or citizen-facing perspectives. 

Taken together, the responses pointed to a broad convergence on the  importance of combining risk sharing 
instruments, predictable public support schemes and strong advisory and information structures to make en-
ergy renovation lending attractive for both lenders and households. Business associations and financial sector 
respondents tended to focus on risk mitigation, regulatory coherence and access to data. NGOs and consumer 
organisations more often emphasised social safeguards, protection of vulnerable households and the need for 
science-based criteria. Public authorities and “Other” institutions frequently highlighted practical experiences 
with guarantee funds and national programmes, as well as the need for streamlined procedures and better co-
ordination between public and private actors. 

Several cross-cutting messages emerged across Q18–Q25. Respondents repeatedly underlined the central role 
of public guarantees, guarantee funds and blended finance structures in improving the risk–return profile of 
renovation lending and in enabling banks to offer longer maturities and lower interest rates. There was broad 
agreement that stable, well-designed grant schemes and tax incentives remained critical to stimulate demand, 
particularly  for  deep  renovation  and  among  low-income  households,  and  that  abrupt  changes  in  support 
schemes created uncertainty for both clients and lenders. Many stakeholders saw advisory services, one stop 
shops and technical assistance as indispensable complements to financial products, helping households, small 
businesses and local authorities to understand renovation options, prepare projects and navigate administrative 
requirements. Across several questions, respondents pointed to difficulties in accessing reliable and standard-
ised building performance data, and to the need to improve EPC systems, digital building passports and na-
tional databases so that lenders can identify worst performing buildings and monitor portfolios. 

At EU-level,  several respondents considered that  the legislative  framework, including the EPBD and the EU 
Green Taxonomy, provided an important reference but remained complex and sometimes difficult to opera-
tionalise for portfolio-level lending. Calls for simplification, better alignment between instruments and clearer, 
flexible criteria were recurrent. Stakeholders also drew attention to the importance of EU level financial instru-
ments – such as EU-backed guarantee and refinancing facilities, an EU Renovation Loan concept, green bond 
standards and the Social Climate Fund – to channel long term capital into renovation portfolios and to support 
targeted schemes for vulnerable households and social housing. Finally, questions on worst performing buildings 
and vulnerable households elicited a strong emphasis on fairness: respondents stressed that scaling up renova-
tion finance needed to go hand in hand with measures to avoid over indebtedness, protect tenants and ensure 
that low-income households can benefit from improved comfort and lower energy bills. 

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