A Guide to the Energy Performance of Buildings Directive (EPBD)

Buildings account for around 40% of energy consumption and 36% of energy-related CO₂ emissions in the EU. Despite decades of energy efficiency policy, a large proportion of the EU's building stock remains poorly insulated, fossil fuel dependent, and far from the performance standards the bloc needs to meet its 2050 climate goals.

The Energy Performance of Buildings Directive (EPBD) is the EU's primary legislative tool for addressing this. First introduced in 2002 and significantly revised in 2010 and 2018, it has historically focused on operational energy: how much energy a building consumes to heat, cool, and power. The 2024 recast changes that. For the first time, the EPBD extends its scope to whole-life carbon, covering the full carbon impact of a building across its entire lifecycle, not just the energy used to run it. That shift makes it directly relevant to corporate sustainability teams, not just built environment professionals.

What is the EPBD?

The EPBD sets minimum energy performance requirements for buildings across the EU. It covers both new buildings and existing ones undergoing significant renovation, and applies to residential and non-residential property alike.

Its core mechanism is the Energy Performance Certificate (EPC): a rating document that assesses a building's energy performance and is required when a building is constructed, sold, or rented. EPCs currently vary in methodology and rating scale between member states, but the 2024 recast requires them to be harmonised across the EU by May 2026. From 2028, EPCs will also be required to disclose a building's Global Warming Potential (GWP), which is a measure of its total greenhouse gas emissions over its lifecycle.

The directive sets the framework and minimum requirements; member states decide the specific thresholds, timelines, and renovation pathways within their own building stock.

What changed in the 2024 recast?

The 2024 recast, which entered into force on 28 May 2024, is the most substantive revision to the directive since 2010. Several changes are significant for businesses with property exposure in the EU.

Zero-emission buildings

From 1 January 2028, all new public buildings must meet the Zero-Emission Building (ZEB) standard. From 1 January 2030, this applies to all new buildings. A ZEB is defined as a building with very high energy performance, no on-site fossil fuel emissions, and zero or very low operational greenhouse gas emissions. This replaces the previous nearly zero-energy buildings (NZEB) standard, which focused on energy efficiency but did not require the elimination of fossil fuel use.

Minimum Energy Performance Standards

Member states must introduce Minimum Energy Performance Standards (MEPS) for existing buildings. For non-residential buildings, at least 16% of the worst-performing stock must be renovated by 2030, rising to 26% by 2033. For residential buildings, energy use must fall by 16% by 2030 and by 20 to 22% by 2035. These are national targets: each member state sets the specific thresholds and decides which buildings are classified as worst performers within its own building stock.

Solar installations

Mandatory solar installations are required on new non-residential buildings from 31 December 2026, and on new residential buildings in subsequent years. Member states may also extend requirements to existing buildings being renovated.

National Building Renovation Plans

Each member state must submit a National Building Renovation Plan covering its full building stock, with roadmaps to 2030, 2040, and 2050. The plans must also set out how fossil fuel boilers will be phased out by 2040.

The biggest change: Whole-Life Carbon

Every previous version of the EPBD focused on how much energy a building uses to operate. The 2024 recast extends this to whole-life carbon (WLC): the total greenhouse gas emissions associated with a building across its entire lifecycle, from the raw materials used in construction through operation to eventual demolition.

What whole-life carbon means in practice

Whole-life carbon has two components. Operational carbon covers the emissions produced by running a building: heating, cooling, lighting, and power. Embodied carbon covers everything else: the emissions locked into the materials used to construct, renovate, and ultimately demolish the building. Concrete, steel, insulation, glass, and other construction materials all carry a carbon cost from extraction and manufacturing before a building is ever occupied. That embodied carbon cannot be reduced once the building is built, which is why what materials are chosen at the design stage matters so much.

What the EPBD requires on whole-life carbon

From January 2028, life-cycle GWP calculations will be mandatory for all new buildings above 1,000 square metres. From 2030, this extends to all new buildings regardless of size. GWP results must be disclosed on EPCs from those dates.

The required methodology is EN 15978, the European standard for assessing the environmental performance of buildings. In practice, this means conducting a building-level lifecycle assessment (LCA): a standardised calculation of a building's total carbon impact across all lifecycle stages, from material extraction through construction, operation, and demolition.

Member states must publish national roadmaps setting GWP limit values by January 2027. Those thresholds are expected to tighten progressively over time.

How EPDs feed into whole-life carbon compliance

A building LCA requires carbon data for each individual material used in construction. Environmental Product Declarations (EPDs) are the standardised documents that provide this for individual construction products. An EPD is a verified, third-party document setting out the environmental impact of a specific product, based on a lifecycle assessment of that product.

Two terms worth keeping distinct: an EPD is a document for a material or product. An EPC is a rating certificate for a building. They are easily confused and serve entirely different purposes.

EPDs are not explicitly named in the EPBD text, but they are the primary data input for any compliant whole-life carbon calculation. The updated Construction Products Regulation (CPR), revised in November 2024, is pushing EPD standardisation across the EU to support this, making EPD provision an increasingly standard expectation for construction materials suppliers.

Implementation timeline

• 28 May 2024: Recast EPBD entered into force
• 31 December 2025: European Commission to established standard GWP calculation method; member states to submit draft National Building Renovation Plans
• 29 May 2026: Deadline for all member states to transpose the directive into national law
• 31 December 2026: Mandatory solar installations on new non-residential buildings
• 1 January 2027: Member states must publish national roadmaps for GWP limit values
• 1 January 2028: Life-cycle GWP calculations mandatory for new buildings above 1,000m²; public buildings must be ZEB; GWP disclosed on EPCs
• 1 January 2030: All new buildings must be ZEB; life-cycle GWP calculations mandatory for all new buildings
• 2033: Non-residential buildings must reach minimum EPC class E (worst 26% renovated)
• 2040: Fossil fuel boilers phased out
• 2050: Full decarbonisation of the EU building stock

Who does the EPBD affect?

The EPBD's direct obligations fall primarily on building owners, developers, and member states. But its effects reach companies that lease property, procure construction materials, or hold real estate as an investment.

Companies that own commercial property in the EU are directly exposed. MEPS thresholds will require renovation of the worst-performing assets, and new developments from 2028 onwards must meet ZEB standards and include whole-life carbon calculations from the design stage.

Companies that lease will feel the effects indirectly. Landlords facing renovation costs will pass them through leases, and green lease clauses are becoming increasingly standard. Buildings with low EPC ratings face declining valuations and restricted financing options over time.

Investors face the risk that properties unable to meet incoming standards become difficult to sell or finance, commonly referred to as stranded assets. EPC ratings are already affecting valuations and access to green finance.

Developers must integrate whole-life carbon assessment into the design process from feasibility stage. A building LCA conducted at the start of a project costs a fraction of what it costs to add later.

Materials suppliers and manufacturers are increasingly expected to provide EPDs for their products to support the WLC calculations their customers need for compliance.

UK companies: the UK is no longer subject to the EPBD following its departure from the EU. However, the UK has its own parallel trajectory on building performance, including EPC reform and the Future Homes Standard, which is currently in development. UK businesses with EU property exposure remain in scope of the EPBD for those assets.

What does the EPBD mean for corporate carbon reporting?

The EPBD sits at the intersection of buildings compliance and corporate carbon accounting in a way that is worth making explicit.

Building energy use flows into Scope 1 emissions (direct gas and fuel combustion on site) and Scope 2 emissions (purchased electricity). Improving EPC ratings reduces both. The embodied carbon in construction materials is typically a Scope 3 exposure: Category 1 (purchased goods and services) for companies procuring materials, or Category 11 (use of sold products) for companies involved in developing or selling buildings.

For companies subject to CSRD, the whole-life carbon data the EPBD requires feeds directly into sustainability disclosures. The building LCA data produced for EPBD compliance and the Scope 3 emissions data required for CSRD draw on much of the same underlying information: energy consumption, material quantities, and supplier-level carbon data in the form of EPDs.

Companies that integrate building performance into their carbon strategy rather than treating EPBD compliance as a separate exercise will find the same data serves both EPBD and CSRD requirements.

What the EPBD means in practice

With the EPBD's deadlines confirmed, here is where to focus before the first obligations arrive.

• Audit your building portfolio. Know your current EPC ratings across EU assets and identify where they sit relative to the MEPS thresholds being set in each relevant member state.
• Integrate whole-life carbon into new development briefs. For any new build above 1,000m², a life-cycle GWP calculation will be mandatory from 2028. Starting this process at feasibility is far more cost-effective than adding it later.
• Require EPD data from materials suppliers. EPD provision is becoming a procurement expectation for construction products. Building this into supplier requirements now avoids delays when WLC calculations are needed.
• Connect building data to your Scope 1, 2, and 3 reporting. Building energy and embodied carbon data feed the same disclosures CSRD requires.
• Monitor national implementation. The EPBD sets the framework but national law determines the specific thresholds and timelines. Stay close to the relevant national regulations for each EU market where you hold property.

How Zevero can help

The EPBD sets a clear and confirmed direction: from operational energy to whole-life carbon, with mandatory disclosure requirements and tightening performance thresholds through to 2050. Companies that integrate building performance into their sustainability strategy now will be better placed for compliance, cost efficiency, and investor scrutiny as those thresholds take effect.

Zevero helps companies bring all of their climate data together, including the building energy and embodied carbon data the EPBD will require:

• Track Scope 1 and 2 emissions from building energy use, so operational performance data feeds directly into corporate carbon disclosures
• Connect embodied carbon and supply chain data to Scope 3 inventory, so the material procurement data the EPBD requires serves CSRD reporting at the same time
• Manage CSRD and EPBD data requirements from a single foundation, to avoid duplicating effort across overlapping regulatory obligations

For companies navigating whole-life carbon compliance, Zevero's EPD tool helps create compliant, third-party verified Environmental Product Declarations in a fraction of the time.