Directive EU 2024/1275 refers to the fourth iteration and latest major revision of the Energy Performance of Buildings Directive. Formally adopted in spring 2024, it establishes the legal framework to decarbonise the European Union's building stock by 2050. Under Article 3 of the recast EPBD, each EU Member State is required to establish an NBRP. The NBRP serves as the primary strategic planning and operational framework to guide the transition of national building stocks—both residential and non-residential, public and private—toward zero emissions by 2050. It replaces the former Long-Term Renovation Strategies (LTRS) established under previous directives. 

Member states outline national strategies replacing former long-term renovation strategies. EU Member States must transpose the Directive into national law. December 31, 2026 is the final deadline for the submission of the final and definitive version of all 27 National Building Renovation Plans.

NBRP  macro-sections

Every NBRP submitted by Member States must strictly articulate 4 key macro-sections:

1. Overview of the national building stock:

• Mapping of buildings by type (residential, public, commercial) and construction era.
• Analysis of energy performance levels (EPC classes), current consumption, and primary/final energy consumption.
• Estimated share of households living in energy poverty.

2. Roadmap with national targets to 2030, 2040, and 2050:

• Residential: Trajectory to reduce average primary energy consumption (minimum -16% by 2030 and -20/22% by 2035).
• Non-Residential (MEPS): Renovation plan for 16% of the worst-performing buildings by 2030 and 26% by 2033.
• Heating: Trajectory and deadlines for the gradual phase-out of fossil fuels in heating (full phase-out of gas boilers by 2040).
• Whole Life Carbon (WLC): Strategies to monitor the embodied carbon footprint of materials.

3. Implementation policies and measures:

• Legislative reforms for energy classes and minimum performance standards.
• Specific measures to eliminate market and administrative barriers (One-Stop Shops).
• Integration of solar infrastructure in buildings and sustainable mobility (charging stations).

4. Financial requirements and capital mobilisation:

• Estimation of the overall investment needed to reach the targets.
• Public funding sources: European (RRF/NRRP, Social Climate Fund, Cohesion funds) and national.
• Tools to stimulate the mobilisation of private capital (green mortgages, public guarantees).

The gap between EPBD and the national intention

From the official assessment published by the European Commission on 14 July 2026 (and the supporting report by the Joint Research Centre – JRC) on the first 16 drafts received, a significant gap emerges between the national intentions set out in the various NBRPs and the stringent regulatory constraints imposed by the EPBD (EU 2024/1275). The main discrepancies identified by Brussels concern quantitative, methodological, and financial aspects alike.

1. Detail on residential trajectories (-16% by 2030)
   - EPBD requirement: Reduce average primary energy consumption by 16% by 2030 (compared to 2020), with at least 55% of the savings targeted at the worst-performing buildings (the 43% least efficient building stock). 
   - Reality in the plans: Many countries outlined aggregated targets without specifying the exact breakdown or intermediate milestones on how to identify and renovate the worst-performing buildings.
    
2. Definition of MEPS for non-residential buildings
   - EPBD requirement: Mandatory renovation of the bottom 16% worst-performing non-residential buildings by 2030 and the bottom 26% by 2033. 
   - Reality in the plans: Several plans lack precise inventories of public and private non-residential properties; many Member States have not yet translated these percentages into binding Minimum Energy Performance Standards (MEPS).
    
3. Gas boiler phase-out plan (by 2040)
   - EPBD requirement: Gradual elimination of fossil fuel heating systems by 2040, starting with the termination of subsidies for standalone boilers as of 1 January 2025. 
   - Reality in the plans: This is one of the weakest areas. Many countries (including Germany and the Netherlands) provide incentives for heat pumps but hesitate to establish a strict legal prohibition on installing gas boilers in existing buildings, fearing social and economic fallout.
    
4. Whole Life Carbon (WLC) assessment
   - EPBD requirement: Mandatory calculation of Whole Life Carbon emissions for all large new buildings from 2028 and for all new buildings from 2030.
   - Reality in the plans: Only countries such as Finland and France have integrated structured methodologies and construction material databases. Most other Member States address the topic in a purely qualitative manner.
    
5. Funding gap and cost coverage
   - EPBD requirement: Credible financial plans combining public funds (RRF/NRRP, Social Climate Fund, Cohesion funds) and private capital to address energy poverty.
   - Reality in the plans: The Commission highlighted that public resources allocated by governments cover, on average, only between 20% and 35% of the actual estimated investment needed up to 2030. Clear mechanisms to leverage private banking capital (e.g., green mortgages and state guarantees) are lacking.

Delays by country

There are nine Member States that have not yet submitted the official draft of their NBRP, or whose draft has not yet been validated and published in the formal registers of the European Commission. These non-compliant or delayed countries are Italy, Poland, Ireland, Cyprus, Hungary, Malta, Slovakia, the Czech Republic, and Luxembourg, alongside the federal government of Belgium, which submitted only the regional plan for Wallonia rather than a consolidated national plan. 

Regarding the status and consequences for these non-compliant countries, the European Commission has issued formal letters of notice to all defaulting governments for violating Article 3 of the EPBD. The main reasons for these delays vary by country: Italy faces difficulties in defining post-superbonus incentive mechanisms, estimating financial coverage, and prescriptively mapping low-efficiency condominiums, while Poland and the Czech Republic face complexities linked to the social impact of the transition and a heavy reliance on coal and gas for residential heating. Regardless of these delays in the initial draft, all 27 Member States remain under a non-negotiable legal obligation to submit their final definitive Plan by December 31, 2026.

An effective Italian National Building Renovation Plan (NBRP)

An effective and credible Italian NBRP cannot ignore the unique and complex features of the country's real estate stock: a building fleet with an extremely high rate of fragmented ownership (over 80% of households own the home they live in), a major presence of historical buildings subject to heritage/landscape constraints, marked condominium fragmentation, and the recent memory of the distortions caused by the Superbonus. To comply with the provisions of EPBD and earn approval from the European Commission, the Italian NBRP should be built upon 5 targeted strategic pillars:

1. Real mapping and targeting of the 'Worst 43%'.

Italy has approximately 12 million residential buildings, more than half of which were built before 1970 (in EPC classes F and G).

• Database interconnection: Creation of a single national digital platform merging the Land Registry (Catasto), the SIAPE database (Information System for Energy Performance Certificates), and ARERA's actual energy consumption data.
• Objective criteria for worst-performing buildings: Prioritised identification of 1960s–1980s condominiums in suburban peripheries and single-family houses in non-gasified inland regions.
• Plans for historic centres and villages: Definition of specific exemptions or Heritage Authority (Soprintendenza) guidelines for 'invisible' efficiency solutions (e.g., specialised thermal renders, air-source heat pumps without visually intrusive outdoor units, renewable energy communities with remote PV).

2. Sustainable financial architecture (beyond the Superbonus)

The main mistake of the past was the indiscriminate 110% subsidy. The Italian NBRP must propose a progressive, fair, and bankable financial model:

• New Selective Credit Assignment (Cessione del Credito): Reintroduction of invoice discounts or credit transfers exclusively for low-income (ISEE) brackets and for multi-family condominiums undertaking deep renovations.

3. Heating decarbonisation roadmap (gas phase-out)

In Italy, over 60% of homes are heated by standalone or centralised gas boilers.

• Curbing subsidies: Immediate elimination of all tax deductions for standalone gas condensation boiler replacements, retaining subsidies solely for factory-built hybrid systems or electric heat pumps.
• Municipal heating plans: Requirement for municipalities with over 20,000 inhabitants to map gas grids and designate priority areas for efficient district heating deployment or electrification.
• Progressive deadlines: Enacting legal bans on installing standalone fossil-fuel generators in new buildings from 2030 and in replacement systems in existing buildings from 2035.

4. Governance and one-stop shop (OSS) networks

One of the biggest hurdles in Italy is administrative complexity within condominiums and local council procedures.

• Territorial one-stop shops (OSS): Establishing a public network of integrated local offices (at the district or municipal union level) managed with technical support from ENEA and GSE.
• 'Turnkey' service: OSS outlets must offer citizens an all-in-one pathway: building energy profiling, feasibility studies, tax compliance verification, access to financing, and pairing with certified contractors.
• Streamlining condominium assemblies: Amending the Italian Civil Code to lower voting quorum thresholds for renovations mandated under the NBRP, as well as for rooftop PV or EV charging installations.

5. Supply chain qualification and local materials

An industrial plan must guarantee adequate skill sets and materials to prevent speculative bubbles and unqualified labor.

• Training-Based Credentialing System (Patente a Crediti): Strict qualification criteria for contractors accessing NBRP funds (certified competencies for thermal insulation installers and heat pump technicians).
• Minimum Environmental Criteria (CAM) Certification: Incentivising sustainable, recycled, or locally sourced building materials (e.g., wood fibre, hemp, wool) to monitor and lower Whole Life Carbon (WLC) emissions.

Derogations under the EPBD for cultural heritage

Officially protected buildings and those of historical or cultural interest represent one of the most complex issues in the application of the EPBD and in the drafting of NBRPs, particularly for countries with an extremely high density of heritage assets, such as Italy.

The Directive balances the need to decarbonise the building stock with the protection of architectural and identity conservation. Article 5 of the EPBD recognises the specificities of historical architecture and grants Member States the faculty to exempt or adapt obligations for certain categories of properties:

1. Exemption from Minimum Energy Performance Standards (MEPS): Buildings officially protected as part of a designated environment or because of their special architectural or historical merit may be exempted from minimum energy performance requirements if compliance would unacceptably alter their character or appearance.
2. Exclusion from Zero-Energy Emission Buildings (ZEB) Obligations: Protected buildings are not required to meet the stringent Zero-Emission Building parameters mandated for new constructions and ordinary deep renovations.
3. Flexible Planning in NBRPs: National Plans must include dedicated strategies for cultural heritage, identifying compatible solutions rather than applying standardised prescriptions.

Retrofitting historical buildings is not based on the application of invasive solutions, such as external thermal insulation cladding or the installation of visible solar panels on protected roofs, but on lightweight, reversible, and breathable interventions. This compatible renovation approach encompasses a passive envelope, advanced systems, and collective sources. The passive envelope includes historical thermal plasters made of hemp and lime, attic insulation, and the restoration and internal double glazing. Advanced systems comprise heat pumps without outdoor units, high-efficiency hydronic generators, and intelligent BEMS regulation. Collective sources involve Renewable Energy Communities and remote photovoltaic systems or invisible integration through photovoltaic roof tiles.

How an NBRP must address cultural heritage

In countries like Italy, with a high concentration of historical centres and landscape restrictions, the National Building Renovation Plan must integrate a dedicated regulatory and operational framework:

• Unified Guidelines with Heritage Authorities (Soprintendenze): Standardised memoranda of understanding between the Ministry of the Environment (MASE) and the Ministry of Culture (MiC) to establish beforehand which interventions are authorised and under what simplified procedures.
• Specifically Adapted Energy Certification: Implementation of modified EPC schemes for historical buildings (e.g., the GBC Historic Building® Protocol) that assess environmental and sustainability performance while accounting for original construction quality (thermal inertia of stone or brick masonry).
• Neighbourhood Solutions and RECs: Shifting the focus from the single building to the urban level. If installing PV on the roof of an 18th-century palace is not feasible, the property can meet its energy consumption needs from renewable sources by joining a Renewable Energy Community (REC) with shared plants located in non-protected external areas.
• Dedicated Financing: Non-repayable funds reserved for high-efficiency, conservative restoration interventions to prevent the high costs of invisible technologies and special materials from falling entirely on the owners.