What Article 9 of the recast EPBD requires: binding standards for the worst-performing non-residential buildings, a national trajectory for homes, and the exemptions member states can use.
Minimum energy performance standards, usually shortened to MEPS, are the part of the recast Energy Performance of Buildings Directive that reaches furthest into the existing building stock. Article 9 of Directive (EU) 2024/1275 sets them out, and its final text differs in important ways from the proposal that was debated in 2022 and 2023. This article explains what was adopted.
Two different approaches
The directive treats non-residential buildings and homes differently. For non-residential buildings, member states must set binding minimum standards that individual buildings have to meet. For residential buildings, there is no EU-wide obligation on individual homes. Instead, each member state must reduce the average energy use of its whole housing stock along a national trajectory, and choose the measures that get it there.
Non-residential buildings: the 16% and 26% thresholds
Each member state must take its non-residential building stock as it stood on 1 January 2020 and set two maximum energy performance thresholds, expressed in kWh per square metre per year:
- the 16% threshold, above which the worst-performing 16% of the stock sits;
- the 26% threshold, above which the worst-performing 26% sits.
The standards must ensure that all non-residential buildings are below the 16% threshold from 2030 and below the 26% threshold from 2033. In practice, that means the worst-performing sixth of offices, shops, schools, hospitals and other non-residential buildings must be renovated by 2030, and roughly the worst quarter by 2033. Member states can set thresholds for the stock as a whole or per building type, and can express them as an energy performance class. Compliance is checked mainly through energy performance certificates.
The national renovation roadmaps must also set timelines for stricter thresholds by 2040 and 2050, in line with the goal of a zero-emission building stock by 2050.
Homes: a national trajectory
For residential buildings, each member state had to establish a national trajectory by 29 May 2026. It is expressed as a reduction in the average primary energy use of the entire residential stock, compared with 2020:
- at least 16% by 2030;
- at least 20–22% by 2035;
- from 2040, and every five years after that, a nationally determined value on the path to a zero-emission stock in 2050.
At least 55% of the reduction must come from renovating the 43% worst-performing residential buildings. That rule stops a country from meeting the average only through new construction or light upgrades to already efficient homes. Member states must use measures such as minimum standards, technical assistance and financial support, but the directive leaves the mix to them. A country may introduce MEPS for homes, for example linked to sale or rental, but it is not required to.
This is the main change from the original proposal, which would have required individual homes to reach set energy classes by fixed dates. That approach was dropped during the negotiations.
Exemptions
Member states may decide not to apply the standards to several categories of building, including:
- officially protected and other heritage buildings, where compliance would unacceptably alter their character or appearance, or where renovation is not technically or economically feasible;
- buildings used as places of worship;
- temporary buildings used for two years or less, industrial sites, workshops and certain agricultural buildings with low energy demand;
- holiday and other homes used for less than four months a year, and stand-alone buildings under 50 m²;
- buildings owned by the armed forces or central government that serve national defence purposes.
They can also publish criteria for exempting individual non-residential buildings because of their expected future use, serious hardship or an unfavourable cost-benefit assessment. The criteria must be clear and stringent, and exempted buildings are excluded from the 2020 baseline.
Support and safeguards
The directive links the standards to support. Member states must provide financing, technical assistance and information, including through one-stop shops for building renovation. Financial incentives must target vulnerable households, people affected by energy poverty and people living in social housing as a priority. Member states must also address the eviction of vulnerable households caused by disproportionate rent increases after an energy renovation. See energy poverty and the building renovation gap for more on this.
What it means in Southern Europe
For Mediterranean member states such as Italy, Spain, Greece and Portugal, the standards raise specific questions. A large share of their stock is older masonry housing with little insulation, and cooling demand matters more than in northern Europe. The energy performance calculations behind the thresholds include cooling, so shading, ventilation and efficient cooling can count alongside insulation.
These countries have also relied heavily on national renovation subsidies, often funded through the EU Recovery and Resilience Facility: Italy’s Superbonus, Spain’s PREE programme for building energy renovation, Greece’s Exoikonomo grants and Portugal’s Edifícios Mais Sustentáveis programme. Much of that funding was temporary. The residential trajectory will require them to keep renovation going at scale once it runs out, with the 43% worst-performing homes as the priority.
Timeline summary
- 29 May 2026: transposition deadline and national residential trajectory in place.
- 2030: all non-residential buildings below the 16% threshold; residential average down at least 16%.
- 2033: all non-residential buildings below the 26% threshold.
- 2035: residential average down 20–22%.
For the other deadlines in the directive, see the EPBD Policy Tracker. The official text is available on EUR-Lex, and the European Commission’s EPBD page summarises its main elements.