What does the revised EPBD mean for property owners and investors?

The revised Energy Performance of Buildings Directive (EPBD) is more than a regulatory update. It signals a wider shift in the European real estate market changing how buildings are assessed and valued. For owners of poorly performing buildings, waiting for national regulations to be finalised could mean missing an opportunity to plan ahead.

Ultimately, less energy-efficient buildings could face increasing regulatory and market pressure, alongside higher operating costs and growing expectations from occupiers and investors. While Spain has yet to finalise its approach, investment, acquisition and asset management decisions made today will influence how buildings retain their value over the coming decade. Understanding where assets are most exposed, and where improvements should be prioritised, can help owners prepare for the transition rather than react to it.

Zero-emission buildings: a new benchmark for building performance

One of the most significant changes is the introduction of the zero-emission building (ZEB) as the new benchmark for building performance. A ZEB combines very low energy demand with the elimination of on-site fossil fuel emissions and a greater reliance on renewable energy sources. Unlike the previous concept of nearly zero-energy buildings (nZEB) the new standard supports the long-term decarbonisation of buildings and will influence how they are designed and valued.

In a previous article, I reviewed the role of nZEB as a turning point in the evolution of building energy regulations. The new EPBD takes this a step further, putting the focus on eliminating direct emissions rather than reducing energy consumption.

The change will affect new build projects first. New public buildings will need to meet the zero-emission standard from 2028, followed by all other new buildings from 2030, subject to specific exceptions. However, the regulations extend beyond new developments and provides the wider property market indications of how existing buildings will need to evolve over time.

For owners and investors, the ZEB is more than a technical definition. It’s an indicator that will shape design, refurbishment and decarbonisation strategies.

The bigger challenge: improving existing buildings

The EPBD is based on a well-known fact. 80% of the buildings that will still be in use in 2050 have already been built. For owners and investors, the refurbishment of existing buildings will be where the greatest challenges and opportunities are. Improving the performance of these buildings will be critical to achieving Europe’s long-term decarbonisation plans with Member States required to establish national building renovation plans and progressive targets by 2050.

For non-residential buildings, the EPBD has introduced minimum energy efficiency thresholds, targeting the buildings with the poorest energy performance, with targets in 2030 and 2033. For residential buildings, the focus is on reducing average primary energy consumption, with particular attention given to improving the least efficient homes.

Improving existing buildings is more than meeting energy targets. The directive encourages owners to consider the inclusion of solar energy, electric vehicle infrastructure, the electrification of heating and whole-life carbon. 

Rather than addressing these measures individually, they should be part of a coordinated long-term strategy for every building. This can help prioritise investment and avoid problems that would make future improvements more difficult or costly. Overall, ensuring that the decisions made today will support the transition towards better energy and carbon performance.

How Building Renovation Passports can help owners plan ahead

Another new development introduced through the EPBD is the Building Renovation Passport (BRP), designed to provide a roadmap for improving the energy performance of an individual building. Member States are required to establish a scheme for renovation passports in 2026 however, these will be voluntary for property owners unless made compulsory in national law.

Even if the BRP remains voluntary, for property owners the value goes beyond meeting future regulatory requirements and can become a key management tool. It helps understand a building’s current performance, identifies the improvements needed and prioritises how these can be amended over time. This can help owners prioritise investment and plan improvements, avoiding isolated interventions that could restrict future options or increase the cost of major refurbishment later.

When integrated with tools such as the Carbon Risk Real Estate Monitor (CRREM) a BRP becomes particularly relevant for investors and large portfolios. While the BRP can define a technical renovation roadmap for a building, CRREM can help assess whether an asset is aligned with decarbonisation pathways and identify potential exposure to future obsolescence or loss of value.

What does the EPBD mean for buildings in Spain?

The EPBD sets out the European framework, but its impact will depend on how it is implemented nationally. In Spain, this is expected to affect existing regulations such as: 

• Technical Building Code
• Regulation of Thermal Installations in Buildings
• Energy certification system
• Building registers
• Inspection, monitoring, financing and enforcement mechanisms

While the direction is clear, there are still some unresolved details that need to be defined. These include how minimum energy performance thresholds will be set, which buildings will be affected at each stage, how compliance will be verified and what exemptions may apply. There is also further information to come on how the BRP will be integrated with energy performance certificates and what the standards of the inspection regime will be.

For property owners and investors, this uncertainty makes early preparation particularly relevant. Understanding the current energy and carbon performance of assets will provide a stronger basis for the future as the Spanish requirements become clearer.

What property owners and investors should do now

Although the implementation in Spain is still to be confirmed, property owners and investors should prioritise understanding current building performance and identify where intervention may be needed. Key areas to consider include: 

• Assess current energy and carbon performance and understand improvement potential
• Identify assets with poor performance, fossil-fuel dependency or greater exposure to future requirements
• Develop building improvement roadmaps that consider how interventions can be coordinated and planned
• Integrate energy, carbon and renewable energy measures into long-term asset strategies.

The revised EPBD creates a clearer direction for Europe’s buildings. For owners and investors in Spain, the exact regulatory pathway is still developing, but the value of understanding asset performance now is already clear. Establishing a baseline, identifying the buildings most exposed and developing coordinated improvement roadmaps can help owners make better-informed investment decisions and prepare their portfolios for the transition ahead.

Get in touch with our sustainability team to discuss how the EPBD could affect your buildings and the steps you can take to prepare.