Introduction
As Europe’s buildings undergo their most ambitious transformation in decades, the 2024 recast of the Energy Performance of Buildings Directive (EPBD) provides not only strategic direction but also operational tools. National Building Renovation Plans (NBRPs) are now the backbone of this transformation, defining clear milestones towards a zero-emission building stock. Central to these plans are Minimum Energy Performance Standards (MEPS) for non-residential buildings and progressive renovation trajectories for the residential sector—policy instruments designed to phase out the worst-performing buildings and steer the entire stock towards mid-century climate goals. However, success will ultimately depend on more than strategies: it hinges on implementation through robust compliance instruments and decision-support tools.
To support implementation, the Commission has issued guidance and templates on every aspect of the recast EPBD—from solar energy in buildings to databases and digital tools. The overall timeline is tight: Member States must transpose the directive by May 2026, submit draft NBRPs by the end of 2025 and final NBRPs by the end of 2026. Some measures take effect earlier—for example, from January 2025, Member States will no longer be able to provide financial incentives for installing fossil-fuel boilers.
Energy Performance Certificates (EPCs), Renovation Passports (RPs) and the Smart Readiness Indicator (SRI) have evolved under the EPBD to guide, measure, and incentivise renovation actions. EPCs remain the cornerstone of compliance and data reporting, while RPs are emerging as personalised roadmaps that enable staged renovations aligned with national goals. The SRI, meanwhile, brings a new dimension by encouraging smart technologies to optimise building performance and support dynamic energy systems. Together, these instruments not only reinforce the implementation of NBRPs but also empower building owners and public authorities to act with confidence. At the same time, data-driven insights—enabled by national building databases and feeding into the EU Building Stock Observatory—are now central to tracking progress and targeting policies. Equally important is the emphasis on Indoor Environmental Quality (IEQ), which is no longer merely a co-benefit but a key driver of renovation uptake—linking climate targets with healthier, more comfortable and more productive indoor environments.
This article explores how EPCs, RPs, the SRI and IEQ provisions are being leveraged to move from strategy to action, ensuring that Europe’s Renovation Wave is not only planned on paper but also delivered in practice.
EPCs as compliance anchors for MEPS and renovation trajectories
EPCs have long been a cornerstone of EU building policy, and the recast EPBD reinforces their central role as both a compliance and a monitoring tool. The 2024 EPBD recast upgrades and digitalises EPC schemes to support the Renovation Wave. This involves harmonising EPC classes across the EU—Class A reserved for zero-emission buildings by 2030, and Class G denoting the worst-performing 15% of the stock—phasing out the lowest classes over time and ensuring that recommendations are more actionable. EPC data must be stored in national databases and made accessible to building owners, tenants, financial institutions and public authorities in digital format.
Crucially, EPCs are the mechanism through which MEPS compliance will be verified. Since many MEPS are defined by the achievement of a specific EPC rating by a given deadline, the EPC becomes the ‘checkpoint’ to demonstrate compliance. For example, if non-residential buildings must reach at least an E rating by 2030, an updated EPC showing grade E or better serves as the required proof. Without an improved EPC, an owner cannot legally continue to use or transact a building that falls below the standard. This marks a significant shift from earlier years, when EPCs were viewed mainly as informational tools. Under the recast EPBD, they have become a compliance anchor for renovation obligations and a metric for tracking progress in NBRPs.
To perform this role, the quality and credibility of EPCs must be high. The directive therefore strengthens independent control systems and quality-assurance procedures for the issuance of EPCs. Member States must establish procedures to randomly verify a proportion of EPCs each year. This helps prevent inconsistencies and overly optimistic ratings. High-quality EPC assessments are vital because the success of NBRPs and MEPS will be measured partly by aggregate improvements in EPC classes across the building stock. Many countries face a challenge in this regard: today, only an estimated 30 – 40% of buildings have an EPC, and data on actual energy consumption are often not linked to EPC databases. The EPBD’s push for comprehensive building databases (Article 22) and for digital building logbooks aims to address these gaps by capturing all relevant building data in one place. Each building could eventually have a digital logbook containing its EPCs, renovation plans, technical-system records, Smart-Readiness scores and even measured energy use—enabling better analysis of whether EPC-based improvements translate into real performance.
Renovation Passports (RPs): roadmaps for staged deep renovation
The recast EPBD introduces building RPs as a voluntary yet strategic instrument to facilitate staged deep renovation (Article 12). A renovation passport is essentially a customised renovation roadmap for a specific building, tailored to the owner’s circumstances and the building’s condition. It typically sets out a series of recommended renovation steps—with estimated benefits and costs—that can be implemented over a long-term horizon (for example 10 to 15 years), eventually bringing the building to a high-performance level (such as zero-emission). RPs encourage holistic upgrades—addressing the building envelope, systems, renewables and indoor conditions together—rather than separate actions. The aim is to enable owners—especially those who cannot renovate everything at once—to plan a stepwise journey that avoids the lock-in of sub-optimal improvements. Each step in the passport builds on the previous one, ensuring compatibility and long-term efficiency gains.
Member States are required to establish schemes for RPs so that building owners have the option of obtaining one. Although not mandatory for all buildings, RPs are regarded as an important tool for driving deeper renovation. By making renovation planning more consumer-friendly and tailored, they can boost the uptake of multi-stage retrofits that go beyond superficial fixes. Several countries have already pioneered similar concepts; for instance, Belgium (Flanders) offers the Woningpas (housing passport) and France has tested Passeport Efficacité Énergétique. These experiences show that when homeowners receive a clear plan—for example, insulate the attic in 2024, replace windows by 2026 and install a heat pump by 2028—together with indicative costs and energy-savings estimates, they are more likely to invest gradually. The EPBD builds on this by allowing the recommendations normally included in an EPC can be replaced by a RP if one has been issued for the building. In other words, if an owner holds a certified RP, it can serve as the official list of renovation measures, streamlining the guidance provided. This integration ensures that EPCs and RPs complement rather than duplicate each other: the EPC provides the current performance rating and the final target, while the RP maps the course to get from one to the other.
RPs are expected to play a particularly important role in the residential sector. The EPBD’s progressive renovation trajectories for homes can be underpinned by RPs. For example, the owner of a Class G dwelling could be given an RP that breaks down how to reach Class C in several stages—perhaps improving insulation first, then the heating system, and finally adding solar panels. This staged approach is crucial for making deep renovation achievable in practice, given constraints such as disruption, cost and the preference to align works with life events (for example, a new purchase).
The Smart Readiness Indicator (SRI) and the drive for digitalisation
The SRI is the newest instrument in the EPBD toolbox, first introduced as an optional scheme in the 2018 amendment to the EPBD and strengthened in the 2024 recast. The SRI measures a building’s capability to use smart-building technologies to adjust operations, improve energy efficiency, adapt to occupants’ needs and enable demand-response and flexibility services. In simpler terms, it assesses how smart a building is—for example, does it have automation controls for heating and cooling? Can it be monitored and managed remotely? Does it inform users of their energy use? Can it interact with the grid—for instance, by shifting energy consumption in response to peak pricing or by using on-site batteries?
Member States are encouraged to apply the SRI, and the scheme is expected to become partly mandatory. Specifically, Article 15 provides for the mandatory application of the SRI to large non-residential buildings with high-energy demand, while keeping it voluntary for smaller buildings and homes. The final directive text states that, for non-residential buildings above a certain size or HVAC capacity—the political agreement mentions buildings with HVAC systems over 290 kW effective rated output—the SRI framework will be implemented through future delegated acts, potentially making SRI assessments obligatory for those buildings. For other buildings, the SRI remains an optional scheme that Member States may choose to roll out. Even as an optional measure, the EPBD clearly aims to integrate the SRI into the broader building-performance framework. It explicitly clarifies the complementary relationship between the SRI and EPCs: the two assessments address different aspects—the EPC covers inherent energy performance and efficiency of the building envelope and technical systems, while the SRI focuses on operational smart capabilities—but together they provide a more complete picture of a building’s performance potential.
One practical step towards integration is that national building databases (Article 22) should accommodate SRI data, just as they do EPCs and RPs. If a building has an SRI score, that information should be stored in the same central repository. This allows policymakers and researchers, for example, to correlate smart-readiness with energy-performance improvements over time. It also makes it easier for building owners and tenants to access all information in one place—for instance, through a building-logbook interface.
The value of the SRI lies in highlighting building features that EPCs do not cover but that can greatly impact real-world performance and user experience. For example, an office building might have a mediocre EPC rating (say C or D) but could achieve a high SRI score if it has sophisticated automation that ensures systems operate only when needed, provide demand-response capability and maintain excellent indoor conditions. The SRI would highlight capabilities such as occupancy-based HVAC control, smart lighting and integration with renewables or battery storage. By publishing SRI scores, building owners and occupants become aware of these potential smart improvements. This can spur investment in smart thermostats, IEQ sensors or building-energy-management systems, which not only save energy but also improve IEQ and flexibility. In the long run, as more buildings obtain SRI ratings, this could drive market differentiation similar to that of EPCs: buildings with higher smart-readiness might be seen as more future-proof and as providing optimal performance, thereby commanding higher value. Moreover, the data collected through the SRI could inform policy—for instance, by showing how prevalent certain smart technologies are or how they correlate with energy savings.
Indoor Environmental Quality: putting health and comfort at the core
One of the notable aspects of the recast EPBD is the stronger integration of IEQ considerations, recognising that building renovation and operation should deliver not only energy savings but also healthier, more comfortable spaces. The directive introduces a requirement for optimal IEQ in several provisions. In practice, this means that when Member States set minimum energy-performance requirements for buildings or building elements—for example for insulation, windows or HVAC systems—they must ensure that these do not compromise, and ideally improve, factors such as Indoor Air Quality (IAQ), thermal comfort, lighting and acoustics.
A concrete requirement appears in Article 13 and Annex II, which stipulate that, by a certain date, new buildings must achieve optimal IEQ levels, including good air quality. This effectively pushes national building codes to incorporate modern indoor-climate standards—for instance, some countries may reference Category II conditions of EN 16798 for indoor climate. Furthermore, Article 23 on inspections has been expanded to cover indoor-environmental aspects. Previously, the EPBD required inspections of heating and air-conditioning systems to ensure that they operated efficiently. Now, when such inspections—or their alternatives, like building-automation systems—are implemented, ventilation systems are also included, with attention to maintaining adequate indoor conditions for occupants.
The recast EPBD also calls for the continuous monitoring of IAQ in larger buildings. Specifically, for large non-residential buildings—such as offices, schools and shopping centres—the directive requires the installation of devices that monitor key parameters of indoor-air quality on an ongoing basis. The Commission’s guidance suggests that the minimum set of parameters to be measured are CO₂ concentration, indoor temperature and relative humidity, with additional monitoring of particulate matter (PM2.5) in areas with known outdoor-pollution issues. Some countries might extend such requirements to residential buildings as well. Although the EPBD stops short of mandating IAQ monitors in homes, it does not prevent national initiatives from doing so—particularly for multi-family buildings or social housing where occupant health is a priority.
By formalising IEQ considerations, the recast EPBD embeds the principle that energy-efficiency measures must go hand in hand with health, comfort and productivity outcomes. This is expected to increase public acceptance of renovation, particularly in the residential sector. Homeowners and building users are far more likely to support and invest in upgrades if they experience tangible improvements in indoor conditions—for example, no more draughty rooms, better cooling in summer and fresher air—in addition to lower energy bills. From a policy perspective, it also broadens the benefits of renovation—contributing to public health (fewer respiratory issues linked to damp or poorly ventilated homes), productivity (better IEQ in offices and schools can improve performance and reduce sick days) and overall quality of life.
Conclusions
Europe’s buildings are embarking on a path towards zero emissions, and the recast EPBD provides the map, compass, and tools for the journey. By mandating NRBPs with clear targets and standards, the directive sets the destination—a highly efficient, decarbonised and healthy building stock by mid-century. EPCs, RPs, the SRI and IEQ provisions are the practical instruments ensuring that we stay on course and can measure progress along the way. Critically, these tools do not operate in isolation; they form an integrated ecosystem.
The challenge ahead is considerable: renovating millions of buildings, training hundreds of thousands of workers and investing billions of euros annually for decades. However, the direction is set, and the toolkit is richer than ever. As this article has outlined, the EPBD’s compliance and support instruments are designed to reinforce each other, increasing the likelihood that the sum of Member-State efforts will achieve the EU-wide goals. In short, by aligning policy with data, people and outcomes, the EPBD’s new tools can deliver real renovation results—making Europe’s buildings cleaner, smarter and healthier for all.
