
Minimum energy performance standards and progressive renovation trajectories: from the Energy Performance of Buildings Directive to national enforcement

Minimum energy performance standards and progressive renovation trajectories: from the Energy Performance of Buildings Directive to national enforcement
How are Minimum Energy Performance Standards (MEPS) and renovation trajectories being translated from EU policy into national action? Discover the instruments, data, timelines, and rules reshaping building upgrades across Europe.
(Note: Opinions in the articles are of the authors only and do not necessarily reflect the opinion of the European Union)
Introduction
The recast Energy Performance of Buildings Directive (EPBD) has a new operational engine: Minimum Energy Performance Standards (MEPS) and progressive renovation trajectories. They are central to achieving the EU’s 2050 objective of a decarbonised building stock. Member States are now defining and planning the enforcement of MEPS to renovate the worst-performing 16% of non-residential buildings by 2030 and 26% by 2033. They must also adopt national trajectories to cut average energy use in homes — for example, 16% reduction by 2030 and 20–22% by 2035, compared with 2020 levels. At least 55% of reductions must come from the worst-performing dwellings. Implementation is supported by complementary tools and data-driven measures, such as Energy Performance Certificates (EPCs), Renovation Passports (RPs), the Smart Readiness Indicator (SRI), and Indoor Environmental Quality (IEQ) standards. Together, MEPS and renovation trajectories form a pathway to healthier, smarter, and more energy-efficient indoor environments.
This overview article explains how these requirements are set at EU level through the EPBD, and how they are expected to be translated into action across building types, outlining practical timelines, national examples, enabling measures, and EU-level support driving implementation. The upcoming BUILD UP Technical Article 'Smart compliance, staged upgrades, and quality indoor spaces: EPBD tools delivering renovation results' will complement this overview by exploring in more detail how EPCs, RPs, the SRI, and IEQ provisions turn policy ambitions into practical, data-driven renovation actions across Europe.
Figure 1. MEPS and renovation trajectories don't stand alone: they are reinforced by a whole ecosystem of instruments and support.
Minimum energy performance standards (MEPS) and renovation trajectories in the EPBD
The 2024 recast of the Energy Performance of Buildings Directive (EPBD) introduces a legally binding, data-driven framework to scale up renovations and drive the transformation of the EU’s building stock towards zero emissions by 2050. Minimum Energy Performance Standards (MEPS) and national renovation trajectories, defined respectively in Article 9(1) and Article 9(2) of the directive, are the two key instruments. These provisions require Member States to set time-bound targets for building upgrades.
Figure 2. EPBD milestones for the building stock.
MEPS for non-residential buildings
For non-residential buildings, Article 9(1) sets MEPS targeting the worst-performing segment. Rather than a one-size-fits-all EU standard, thresholds are defined at national level — for example, maximum kWh/m² per year — corresponding to the bottom tiers of the 2020 building stock. The directive requires that thresholds ensure at least the worst-performing 16% of the floor area complies by 2030, and at least 26% by 2033. Each Member State must rank non-residential buildings by 2020 energy use and set a cut-off. After 2033, further thresholds will drive upgrades towards 2040 and 2050 targets in line with climate neutrality.
The EPBD gives Member States flexibility. MEPS can be enforced via broad programmes or at natural trigger points. For example, a Member State might require compliance when a building is sold, rented, or undergoes major renovation. Alternatively, all buildings above the threshold must be improved by 2030 or 2033, regardless of ownership changes. MEPS create a clear legal obligation for owners of inefficient buildings to invest within set deadlines.
Member States can express a threshold in primary or final energy use, as Article 9(1) allows. Many will use EPC rating scales. For instance, a Member State could require all offices to achieve EPC band D by 2030, and tighten to band C by 2033. Owners of lower-rated buildings would need to renovate. Enforcement is mandated. If an owner fails to comply, authorities must impose penalties or other measures to ensure upgrades.
Progressive renovation trajectories for the residential building stock
For residential buildings, the EPBD takes a different approach. Rather than prescribing specific performance levels for each dwelling, Article 9(2) mandates a national trajectory to progressively reduce the average energy use of housing. This is expressed as percentage reductions in average primary energy consumption compared with 2020: 16% by 2030, 20%–22% by 2035, with further cuts by 2040 and 2050. These targets account for differences in national building stocks, allowing flexibility in the choice of buildings to renovate and measures to deploy, provided the overall average consumption is reduced by the stated amount.
A key provision is that the worst-performing homes must be a priority. At least 55% of the total reduction must come from the bottom 43% of the stock, that is, the most inefficient dwellings. This ensures that countries must tackle energy band G and F dwellings at scale. Governments gather data (EPC databases, energy use statistics, surveys, and other sources) to estimate the 2020 baseline, then map milestones — for example, improving the average from X kWh/m² in 2020 to 0.84·X by 2030 (16% reduction), and to 0.78-0.80·X by 2035 (20–22% reduction). This translates into renovating a certain number of homes per year, especially those rated EPC F or G.
The trajectory approach gives more flexibility than building-specific MEPS. Governments might combine programmes to achieve the overall reduction. However, progress is binding and monitored. If average consumption is not reduced as required, additional measures must follow.
Integrating MEPS and renovation trajectories into national building renovation plans (NBRPs)
EPBD Article 9 sets minimum performance targets for existing non-residential and residential buildings.
Building stock segment | Requirement under the 2024 EPBD | Deadline |
Worst-performing non-residential buildings (for example, commercial and public buildings) | Renovate at least 16% of floor area (the most energy-consuming segment) to comply with the national MEPS threshold | By 2030 |
| Renovate at least 26% of floor area (the next segment of worst performers) to comply with the MEPS threshold | By 2033 |
Residential building stock (houses and apartments) | 16% reduction in average primary energy use compared with the 2020 baseline | By 2030 |
| 20–22% reduction in average primary energy use compared with 2020 | By 2035 |
Table 1. EPBD Article 9 minimum performance targets for existing non-residential and residential buildings. Further targets for 2040 and 2050 will ensure a fully zero-emission building stock by 2050. Source: Directive (EU) 2024/1275 of the European Parliament and of the Council of 24 April 2024 on the energy performance of buildings (recast).
These obligations sit within the broader planning framework of the EPBD. Article 3 requires every Member State to submit a National Building Renovation Plan (NBRP) by 2025 or 2026. Each plan must provide a detailed roadmap for decarbonising the building stock. Further details on how NBRPs are structured and how they support the transition to zero-emission buildings are available in the BUILD UP Overview Article 'National Building Renovation Plans under the EPBD: towards a zero-emission building stock'. Related content is also available in the June 2025 Topic of the Month, 'National Building Renovation Plans (NBRPs): practical implementation through EPCs, the SRI, renovation passports (including Indoor Environmental Quality aspects)'.
The NBRPs must include the necessary policies and actions to enforce MEPS for non-residential buildings and achieve the residential trajectory. In other words, the high-level targets of Article 9 become national strategies specifying numbers of buildings, financing, workforce, and monitoring.
Other EPBD provisions complement Article 9. Article 5 requires periodic updates of minimum energy performance requirements for buildings and building elements. Article 8 strengthens rules for buildings undergoing major renovation, for example, by mandating a certain EPC class. These provisions push more buildings towards compliance at natural intervention points, in combination with MEPS and trajectories.
Critically, Article 17 obliges Member States to put in place robust financial incentives and to remove market barriers for renovation, particularly for vulnerable households and worst-performing buildings. Article 18 requires one-stop shops to provide advice and coordination for building renovations. Together, these measures ensure that as obligations tighten, citizens and businesses have support to meet them.
Early implementation in Member States
While this overview article focuses on the EU framework, practical national implementation is already underway. Early examples, including pioneering MEPS-like approaches and renovation trajectories, are being documented and analysed on an ongoing basis.
Ongoing national implementation of MEPS and renovation trajectories
Implementation challenges and success factors
The European Commission issued a comprehensive communication in June 2025, accompanied by 13 thematic annexes explaining how to implement in national legislation the amended or new provisions of the recast EPBD. Annex 1 offers detailed guidance on establishing MEPS for non‑residential buildings and designing residential renovation trajectories under Article 9, while other annexes provide operational guidance on EPCs, RPs, financial incentives, one‑stop shops, building databases, and energy performance calculation methods. These are publicly available on the Commission’s EPBD webpage, offering practical tools for authorities responsible for transposing the directive by May 2026.
Translating MEPS and renovation trajectories from paper into reality is a complex task. Experience so far highlights several key challenges and success factors that determine whether these policies deliver on their promise.
Data and building stock knowledge
A robust data foundation is essential. Member States must identify which buildings are worst-performing and set appropriate performance thresholds. This requires up-to-date inventories of building energy data. Many countries are using existing EPC databases, building registries, and novel data sources such as satellite images and digital logbooks to characterise their stock. The Commission’s guidance emphasises starting with 1 January 2020 as the baseline and ranking all buildings by energy use. Statistical sampling can fill gaps where EPC coverage is poor. In short, knowing where you stand in terms of energy performance is the first step. Countries with detailed building data, such as the Netherlands, have had a head start in designing effective MEPS. The EU Building Stock Observatory also plays a role in tracking this data and progress across Europe.
Setting realistic yet ambitious standards
Deciding the level of MEPS (or the slope of the trajectory) is a balancing act. If thresholds are too lenient, energy savings will be minimal. If they are too stringent, compliance may prove impossible or face public backlash. Successful examples like the Dutch office MEPS involved consultation with stakeholders (building owners, businesses, and public entities) well in advance, ensuring the targets were ambitious but achievable with available technology and finance. The EPBD gives flexibility, for example, in allowing the use of final or primary energy metrics and possible exemptions, which can be used to tailor the standard. However, transparency is key. Building owners need clarity on what exactly they must do — for example, reach label C or cut 30% consumption — and by when.
Financial support and incentives
MEPS will not succeed without making renovation affordable. Many of the worst-performing buildings are occupied by low-income families or small businesses that cannot shoulder the upfront costs. Therefore, public financing, incentives, and innovative funding models are critical success factors. The EPBD obliges Member States to establish a comprehensive financing framework (Article 17) and specifically to address upfront cost barriers and support vulnerable groups. Leading countries have deployed grants (for example, France’s MaPrimeRénov’ for home renovations), tax credits, zero-interest loans, and grant–loan blends to stimulate MEPS compliance. The EU is significantly boosting support as well. From 2026, the new Social Climate Fund will provide dedicated funding to help vulnerable households renovate and cope with energy costs. Likewise, the Recovery and Resilience Facility (RRF) has channelled billions into building renovation plans in many countries, and programmes such as LIFE Clean Energy Transition and Cohesion Policy funds are financing technical assistance and market development. Moreover, the European Investment Bank (EIB) complements grants with financial engineering solutions that leverage private capital. Instruments like ELENA (European Local Energy Assistance) fund technical assistance to develop large-scale renovation programmes, while the InvestEU framework and dedicated EIB loans de-risk private financing and enable aggregated investments at city or portfolio scale. Incentives must work in tandem with mandates to ensure nobody is left behind and private capital is leveraged, through schemes such as on-bill financing, energy service companies, and similar approaches.
Further details on how financing aspects are evolving at EU and national levels are available in the BUILD UP Overview Article 'Financial instruments for an energy-efficient building stock: from EU support to local action', and in the September 2025 Topic of the Month, ‘Financial instruments and initiatives in place at the local level’.
Capacity and supply chain
Rapidly scaling up renovations to meet MEPS deadlines will test the capacity of the construction industry. A shortage of skilled workers or materials can slow progress and inflate costs. Success, therefore, hinges on training programmes, certification of installers, and supply chain readiness. Some national plans, and EU initiatives such as BUILD UP Skills, focus on expanding the pool of qualified professionals, for example, heat pump installers and energy auditors. Public authorities need the capacity to process and enforce MEPS, for example, by training local building inspectors to issue fines or to declare buildings unfit for use, as in Flanders.
Enforcement and compliance mechanisms
MEPS represent a shift to binding outcomes, which necessitates robust enforcement. Clear legal provisions for penalties, loss of usage rights, or other consequences must be in place. Examples from Flanders and the Netherlands show that the threat of building closure or fines can motivate action. The design of enforcement should be proportionate, such as escalating warnings and fines, with declaring a building uninhabitable or unusable applied only as a last resort. Importantly, enforcement requires monitoring systems. These could be as simple as requiring an updated EPC by the deadline to prove compliance, or as technology-based as remote energy meter readings. Member States that integrate MEPS checks into existing processes, such as requiring an EPC certificate of a certain grade when renewing a rental contract or issuing a business license, will find compliance easier to manage. The EPBD also encourages a degree of flexibility, for example, by allowing temporary exemptions if a building is scheduled for demolition or deep renovation, or if there are serious supply chain delays. However, such exemptions must be well justified to prevent weakening the policy.
Public acceptance and support
Finally, bringing the public and stakeholders on board is a decisive factor. Renovations can be disruptive and costly. Landlords and homeowners may resist mandates. Successful implementation often involves strong communication strategies: informing building owners of their obligations early, highlighting benefits such as energy bill savings, comfort, and property value, and providing accessible support such as hotlines or online renovation simulators. Social safeguards are also vital. France’s phased rental MEPS was paired with protections against tenant evictions and rent increases, and the EPBD explicitly calls for measures to prevent renovictions (evictions due to renovation costs) and to ensure renovations do not worsen energy poverty. Schemes such as one-stop shops can increase acceptance by simplifying the process, since homeowners are more likely to comply if a renovation advisor helps manage the project from start to finish.
Conclusion
Europe’s building sector is entering a new era of quantified and time-bound renovation obligations. The framework now in place, backed by data-driven planning, substantial EU and national funding, knowledge-sharing platforms, and legal mandates, is unprecedented in its scope. As Member States develop and flesh out their NBRPs by 2026, the BUILD UP community will be watching closely to see how MEPS and renovation trajectories accelerate the Renovation Wave. If implemented with care for social fairness and supported by strong enforcement and incentives, these instruments promise to significantly improve Europe’s buildings — cutting energy bills, creating healthier indoor environments, and bringing climate goals within reach, one building at a time.
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