The Energy Performance of Buildings Directive recast sets a pathway to climate‑neutral buildings by 2050. This overview examines the EU framework and early national approaches, highlighting implementation patterns and the challenge of translating zero‑emission goals into workable national policies.
(Note: Opinions in the articles are of the authors only and do not necessarily reflect the opinion of the European Union).
The European Union’s commitment to achieving climate neutrality by 2050 has profound implications for the built environment. The revised Energy Performance of Buildings Directive (EPBD), adopted in 2024, establishes a comprehensive regulatory framework for zero-emission buildings (ZEBs) across several articles. Article 2(2) defines a zero-emission building as a building with a very high energy performance, requiring no or a negligible amount of energy from fossil fuels, and generating no on-site carbon emissions from fossil fuels. Articles 7 and 11 set the implementation timelines and technical requirements, while Annex III defines the boundary conditions for energy performance calculations. Article 11 also specifies the performance logic of zero‑emission buildings, setting the dual compliance framework based on very high energy performance and maximum operational GHG emission limits, with numerical thresholds defined at national level.
To meet the energy requirements of a zero-emission building and achieve the necessary standards, the EPBD preamble outlines four possible pathways: renewable energy sources either on-site or nearby; renewable energy communities; efficient district heating and cooling systems; or carbon-free energy sources. This flexibility supports the diversity of national energy systems.
The EPBD does not specify exact numerical values for the energy demand thresholds, delegating this responsibility to Member States. They are to base these thresholds on their national climate zones, building typologies, and local cost-optimal conditions. This situation creates significant timing pressure for Member States. The first cost-optimal reports following the revised methodology must be submitted to the Commission by 30 June 2028, which is six months after ZEB requirements enter into force for public buildings on 1 January 2028. As a result, Member States must establish initial ZEB thresholds based on pre-existing cost-optimal methodologies, with the likelihood that these will need to be revised once updated reports become available. This temporal misalignment represents one of the key early implementation challenges introduced by the EPBD.
The ZEB definition established under Articles 2 and 7 focuses exclusively on operational performance (energy demand and GHG emissions during building use). However, the EPBD recognises that a comprehensive decarbonisation framework cannot overlook the carbon embedded in construction itself. Article 7 therefore introduces a mandatory requirement to calculate and disclose the life cycle Global Warming Potential (GWP) of new buildings with a usable floor area exceeding 1,000 m² from 1 January 2028, extending to all new buildings by 2030. This assessment covers the full building life cycle from production and transport of construction materials to end-of-life management.
Figure 1: Representation of the full building life cycle.
Source: Global warming potential of buildings - Energy - European Commission
However, that embodied carbon is not yet integrated into the ZEB compliance definition. Life cycle GWP remains a disclosure obligation rather than a compliance threshold, meaning a building can legally qualify as zero-emission while having a substantial embodied carbon footprint. This gap creates a risk of misaligned or sub-optimal incentives. Similarly, current frameworks do not explicitly address the trade-off between renovating existing buildings, which typically carry lower total life-cycle emissions, and demolition and new construction. The Commission expects to address this through delegated acts establishing life cycle GWP limit values and integrating embodied carbon more explicitly into the ZEB compliance framework, while Member States that wish to go beyond the minimum requirements of the EPBD should anticipate this trajectory in their national ZEB frameworks.
European initiatives are designed to support the transition towards zero-emission building standards, providing the technical methodologies, data infrastructure, and practical tools that the EPBD framework requires but does not itself supply.
The 2024 EPBD recast places its most technically demanding expectations on Member States in two areas where methodological gaps remain particularly acute: the standardisation of ZEB requirements and the operationalisation of NBRPs. Within this context, the LIFE project EPBD.wise acts as a technical accelerator, working precisely on these implementation dimensions where the distance between EU-level ambition and national enforcement is most evident. Its activities include developing concrete ZEB benchmarks for primary energy demand and GHG emission limits across diverse climatic conditions, providing analytical toolkits and data templates to support NBRP frameworks, advancing harmonised methodologies, and facilitating cross-border policy replication A concrete output of this work is the report 'NBRP and ZEB Policy Needs and Best Practices', which maps national policy gaps, identifies good practices across participating countries, and provides structured analytical templates to support Member States in operationalising zero-emission building definitions and National Building Renovation Plans.
Beyond the challenges associated with the standardisation of zero-emission buildings and the operationalisation of NBRPs, Member States also face significant timing and capacity constraints in implementing other elements of the EPBD recast. A notable example is the revision of cost‑optimal methodology required under Article 6, where many national authorities currently lack sufficiently advanced calculation tools to update minimum performance thresholds in a consistent and timely manner. Article 6 plays a pivotal role in supporting the transition towards zero-emission buildings by ensuring that new regulatory requirements remain economically viable. To this end, the Commission will adopt a delegated act to further refine the cost-optimal methodology in line with updated zero-emission building targets. Member States will be required to apply the common calculation framework to set minimum performance requirements at levels that deliver the most favourable cost-benefit outcome over the building’s estimated economic life cycle. Within this context, the LIFE Clean Energy Transition project BREEZE supports national administrations in Poland, Italy, and France by making advanced calculation tools available as open‑source software, helping to reduce disparities in methodological capacity and enabling more coherent threshold‑setting across the EU.
A similar alignment with EPBD implementation can be seen in the Horizon Europe EIC project ZERAF, which develops adaptive façade technologies aimed at reducing operational energy demand and associated GHG emissions. Although primarily focused on technological innovation, its objectives mirror the performance requirements embedded in ZEB compliance—particularly the need to address energy performance and environmental impact across diverse climatic conditions. These technological advances contribute to the broader ecosystem of solutions that can support Member States in meeting the EPBD operational performance expectations. A deeper understanding of this project’s approach is available in this BUILD UP technical article.
The Horizon Europe project ZEBAI takes this alignment a step further by placing ZEB performance at the core of its methodology. Rather than treating ZEB outcomes as indirect benefits, the project explicitly targets the design and optimisation of buildings that meet the regulatory objectives set out in Articles 7 and 11 of the recast directive. This makes ZEBAI one of the initiatives most directly connected to the EPBD technical and regulatory ambitions, particularly regarding the integration of energy performance, emissions limits, and life-cycle considerations.
The EPBD provides a certain degree of flexibility to Member States. Article 11(6) allows exemptions from on-site renewable requirements if they are ‘technically and economically not feasible’, yet no EU-wide criteria define feasibility. Member States must develop their own definitions, potentially creating inconsistencies. Additionally, Member States can set ZEB thresholds anywhere from cost-optimal levels to the ‘nZEB minus 10%’ cap, creating competitive distortions in construction markets and complicating efforts to assess collective EU progress towards the 2050 goals.
The timing mismatch between ZEB implementation dates and cost-optimal report availability means that many Member States may implement provisional thresholds, creating uncertainty for construction industry stakeholders and potentially necessitating disruptive mid-course corrections.
The most recent EU Impact Assessment Report highlights the broader challenge of balancing decarbonisation ambitions in the construction sector with economic feasibility. For example, the report underscores the need for predictable demand and financial support to accelerate investments in low-carbon technologies, where public procurement and incentives are critical to driving market transformation. With well‑designed policies and accessible funding mechanisms, the transition to ZEB can accelerate, lowering costs, strengthening climate ambition, and ensuring the benefits of decarbonisation are shared equitably across society. In line with the Energy Performance of Buildings Directive (EU) 2024/1275, the Commission will also help Member States draw up their national building renovation plans by the end of 2026 to identify the worst performing buildings, where the most vulnerable citizens reside, and design tailor-made policies that help them reduce their energy bills and live more comfortably in their homes, in winter and in summer. The plans also aim to mainstream accessibility for older persons and persons with disabilities in the context of renovations.
As electricity grids progressively incorporate higher shares of renewable energy, primary energy conversion factors change, directly affecting ZEB threshold calculations and potentially shifting which buildings remain compliant over time. The EPBD requires forward-looking primary energy factors aligned with projected grid trajectories, but long-term grid composition involves substantial uncertainty that makes static threshold-setting problematic.
Similarly, rapid technological development may render feasibility assessments made in 2026 obsolete by 2030: declining solar costs, improvements in battery storage, and advances in heat pump technology may make on-site renewable integration technically and economically viable in contexts where it was initially deemed infeasible. Member States that have granted broad exemptions from on-site renewable requirements should build in mechanisms to revisit those decisions as the technology landscape evolves.
Finally, climate change itself introduces a design challenge that current standards do not fully address. Buildings designed to meet today's performance requirements may be inadequate for the climatic conditions they will face over their operational lifetimes.
These considerations collectively point to the need for iterative, evidence-based policy learning.
The revised EPBD makes zero-emission building (ZEB) standards central to the EU’s 2050 climate-neutral building goal, setting binding milestones for design, construction, and renovation. However, flexibility for Member States could lead to fragmented implementation, while incomplete EPC databases continue to limit effective monitoring of progress.
Deep ZEB renovations also pose affordability challenges, especially for vulnerable households. The revised EPBD introduces social safeguards, which are complemented in the European Affordable Housing Plan and are meant to be integrated in specific and national measures in the NBRPs. Eventually, their success will depend on adequate funding and balanced national policies ensuring inclusiveness.
At present, the regulatory framework primarily addresses operational emissions, but the forthcoming disclosure of life-cycle global warming potential (GWP) will gradually integrate embodied carbon into compliance. As implementation advances, adapting policies to evolving energy systems, technological innovation, and climate objectives will be essential. With coordinated action and sustained investment, the EPBD can play a decisive role in accelerating the transition toward a more efficient, resilient, and climate-neutral European building sector.
March’s Topic of the Month in BUILD UP is ‘Towards climate-neutral buildings: implementing zero-emission standards under the EPBD’. We welcome contributions from professionals, researchers, local authorities and organisations working to advance energy efficiency in the built environment. Readers are invited to share articles, technical insights, project results, case studies, news, events or training materials that can support the platform’s knowledge base and strengthen collaboration across Europe’s renovation community.
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