The deadline for EU member states to write the recast Energy Performance of Buildings Directive into national law was 29 May 2026. None of them fully made it. On 15 July 2026 the European Commission opened infringement procedures against all 27 member states, giving each two months to respond. For design offices, that creates an awkward but practical question: if the national rules are still moving, what do you actually check a project against today?
What happened on 15 July 2026?
The Commission sent letters of formal notice to all 27 member states for failing to fully transpose Directive (EU) 2024/1275, the recast EPBD. Per the Commission's announcement, the provisions specifically called out include minimum energy performance standards for non-residential buildings, the trajectory for renovating residential stock, sustainable mobility infrastructure such as EV charging and bicycle parking, solar energy requirements, one-stop shops for renovation advice, and financing mechanisms.
Two points of accuracy matter here. The action is for failure to fully transpose or to notify complete transposition, not a finding that nothing has been done: several states have partial transposition in place. And member states now have two months to respond and complete the job, after which the Commission may issue a reasoned opinion. The direction of travel is not in doubt, only the timing.
Does the delay mean the deadlines have moved?
No. The substantive dates in the directive are unchanged, and they arrive quickly. If you are designing a building that completes toward the end of this decade, it is the 2028 and 2030 requirements that govern it, not the transposition timetable.
| When | What applies |
|---|---|
| End of 2026 | Solar energy installations required on new public and non-residential buildings above 250 m² of useful floor area |
| From 2028 | All new buildings owned by public bodies must be zero-emission buildings |
| From 1 Jan 2028 | Life-cycle global warming potential must be calculated and disclosed on energy performance certificates for new buildings over 1,000 m² |
| End of 2029 | Solar energy installations required on new residential buildings |
| From 2030 | All new buildings must be zero-emission buildings |
| From 1 Jan 2030 | Life-cycle GWP disclosure extends to all new buildings |
| 2030 | Non-residential stock must perform better than the worst-performing 16 percent; residential average primary energy use down 16 percent on the 2020 baseline |
| 2033 | Non-residential threshold tightens to better than the worst-performing 26 percent |
The solar requirements for existing public and non-residential buildings phase in separately, by building type and size, so check the directive text and your national rules rather than assuming a single date.
The thing most EPBD coverage misses: there is no EPBD to comply with
This is the part that matters most for a design office. The EPBD is a directive, not a regulation. It binds member states to a result, and each one writes its own law to get there. You do not submit a project for approval against the EPBD. You submit it against your country's transposition of the EPBD, which may differ in thresholds, definitions, exemptions, and timing, and which will be published in your national language.
That is why the current moment is genuinely difficult rather than merely newsworthy. In mid-2026 the operative rules are 27 different, partially complete national instruments that are actively being amended. A practice working across borders is not tracking one code. It is tracking a different moving document per market.
What about zero-emission buildings? Is there a number to hit?
Not at EU level, and this is a common misconception. A zero-emission building is defined by very high energy performance, no or negligible fossil energy use, and zero on-site carbon emissions from fossil fuels, assessed against both a maximum energy demand and a maximum operational greenhouse gas figure. But the actual numerical thresholds are set nationally, based on national climate zones, building types, and cost-optimal analysis. The one EU-level constraint is that the maximum energy demand for a zero-emission building must be at least 10 percent below the national nearly-zero-energy threshold that applied when the directive entered into force in May 2024.
So if you see a table of EU-wide zero-emission thresholds in kWh per square metre, treat it with suspicion. There is not one. There are national ones.
Which EPBD requirements actually show up on a drawing set?
Plenty of EPBD commentary is written for investors and asset managers. On a drawing set and in a model, the requirements that surface are more concrete:
- Solar readiness and installed solar: roof zones, available area, structural provision, and plant space.
- Sustainable mobility: EV charging points and cable routing provision, and bicycle parking counts and locations.
- Envelope performance: insulation, glazing, and thermal bridging as documented in the drawings and schedules.
- Building automation and control provision, and the plant space it needs.
- Documentation trails: the data feeding energy performance certificates, and from 2028, the life-cycle GWP disclosure for larger new buildings.
These are checkable, and they are exactly the sort of requirement that gets missed once the design is committed and expensive to change.
How do you check a project when the national rules are moving?
Check against the document that actually governs your project, and re-run the check when that document changes. That is the practical answer, and it is what UptoCode is built for. Because you upload the code you want to be measured against, you can point a project at your own country's current transposition, in its own language, alongside your drawings and IFC model, and get findings cited to the clause and the sheet they came from. When your national rules are amended, you upload the amended text and check again, rather than waiting for a tool vendor to update a hard-coded rule set.
For the mechanics, see our guide on checking drawings against a code before submission, or how UptoCode reads BIM and IFC models. Create a free account and run a cited check on your next European project, with 65 free credits and no card.
Last reviewed 27 July 2026 against European Commission sources. This article is general information, not legal or compliance advice. The EPBD takes effect through national law, so always confirm the current requirements with the relevant national authority for your project.