Comparing implementation strategies for minimum energy performance standards across Southern European member states.
The revised Energy Performance of Buildings Directive (EPBD 2024/1275/EU), which entered into force in May 2024, introduces mandatory minimum energy performance standards (MEPS) for the worst-performing residential buildings. Member states must ensure that 16% of residential floor area improves by at least one EPC class by 2030, rising to 26% by 2033. These binding thresholds represent the most significant shift in EU building policy since the original EPBD of 2002.
Southern European member states — characterised by large stocks of uninsulated masonry construction and high cooling demand — face particular implementation challenges. This paper analyses national transposition strategies across Italy, Spain, Greece and Portugal, drawing on the 2024 EPBD implementation roadmaps submitted to the European Commission. The International Energy Agency’s assessment of European renovation trajectories provides the comparative benchmark for this analysis; full methodology is available via the IEA Energy Efficiency 2023 report.
National Approaches
Italy’s proposed Piano Casa Efficiente would create a dedicated financing vehicle combining state guarantees with green bond proceeds to fund renovations in the worst-performing quintile. The scheme builds on lessons from Superbonus 110%, which drove a surge in renovation activity in 2021-2022 but proved fiscally unsustainable at full subsidy rates and has since been restructured.
Spain’s draft transposition relies primarily on extending IDAE (Instituto para la Diversificacion y Ahorro de la Energia) grant programmes, with MEPS enforcement delegated to autonomous communities. The devolved enforcement model creates significant inter-regional variation: Catalonia and the Basque Country have drafted compliance frameworks, while several southern communities lack regulatory capacity for systematic monitoring.
Greece and Portugal have opted for tax incentive frameworks, allowing property owners to deduct renovation costs from income tax over ten years — an approach that reduces upfront cost barriers but may disproportionately benefit higher-income households with greater taxable income against which to offset expenditure.
Measurement and Verification Challenges
The MEPS framework requires credible measurement of starting and post-renovation EPC class to verify compliance. Across the four countries analysed, EPC registry coverage ranges from 62% (Greece) to 91% (Portugal) of total residential stock, with systematic underrepresentation of pre-1960 dwellings — precisely the segment most likely to require MEPS-triggered renovation.
EPC quality heterogeneity is a further concern. Spot audits conducted by national energy agencies in Italy and Spain found that 31-38% of assessed EPCs showed material errors in U-value estimation for opaque building elements, suggesting that MEPS compliance reporting will require enhanced quality assurance protocols beyond the current self-certification regime.
Compliance Timeline Assessment
Projecting current renovation rates against MEPS thresholds, Italy and Greece face the most significant compliance gaps: at 2023 renovation velocities, both countries would reach only 8-10% of the required 16% residential floor area improvement by 2030. Spain is better positioned at approximately 13%, while Portugal — with its active EPC market and established green finance infrastructure — may approach compliance with modest programme acceleration.
Practitioners can verify whether proposed renovation works achieve NZEB thresholds under their national framework using the observatory’s NZEB compliance assessment instrument, which incorporates primary energy limit values for all 27 member states.
Outlook
The credibility of the MEPS framework across Southern Europe will ultimately rest on enforcement capacity rather than on the ambition of the headline targets. Member states that pair clear renovation obligations with reliable EPC registries, adequate financing and trained assessors are best placed to convert the directive into measurable improvements in building stock performance. Where registry coverage is incomplete or enforcement is devolved without matching resources, compliance reporting risks diverging from the physical reality of the building stock. Closing that gap will require sustained investment in data quality and assessor training alongside the financial instruments that dominate current national plans.