Over the last decade, Europe has faced unprecedented legislation changes principally related to climate change. This has redefined the way the economy and society are and will be operating in the years to come. CBRE’s mapping tool provides a general overview of the risks and opportunities that are related to European Regulation through the lens of energy and carbon, as well as potential impact on real estate decision-making.
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Ludovic Chambe Head of ESG & Sustainability – Continental Europe M: +33 (0)6 77 42 35 26 E: ludovic.chambe@cbre.fr
Impact on RE decision
The European Climate Law entered in force in July 2021 and writes into law the goal set out in the European Green Deal for Europe’s economy and society to become climate-neutral by 2050. As part of the European Climate Law, the 2030 Climate Target Plan sets out to reduce greenhouse gas emissions to at least 55% (‘Fit for 55’) below 1990 levels by 2030, upwards from the previous target of at least 40%.
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A set of European Directives are directly applicable to the build sector and come in support to the ‘Renovation Wave’. They are to be considered in specific parts of the property lifecycle (new construction, renovation, operation & maintenance, etc). • Energy Efficiency Directive (ED) • Energy Performance of Buildings Directive (EPBD) • Renewable Energy Directive (RED) The EED and EPBD are the backbone of the European Union policy for energy efficiency in buildings and will help accelerate the rate of change, as about 95% of the existing building stock in Europe will still be in use in 2050 and % of it is currently rated energy inefficient.
In March 2018, the European Commission released the EU Action Plan for Sustainable Finance. This plan includes two key European Regulations that are binding laws and are immediately applicable in its entirety in all Member States: • The Taxonomy • The Sustainable Finance Disclosure Regulation (SFDR) In the UK, the Task Force on Climate-Related Financial Disclosures (TCFD)’s approach is very likely to become mandatory.
For comparisons between countries
The purpose of this sustainability legislation mapping is to provide a general overview of the risks and opportunities that are related to European and local legislation. Looking at the effects of energy and carbon and how it will impact real estate decisions making.
Click on the countries below to read each profile
United Kingdom
15
Portugal
12
Poland
11
Norway
10
Netherlands
09
Sweden
14
Ireland
07
Germany
06
France
05
Finland
04
Czech Republic
03
Belgium
02
Austria
01
08
Spain
13
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The purpose of this sustainability legislation mapping is to provide a general overview of the risks and opportunities that are related to European Regulation through the lens of energy and carbon and how it will impact real estate decisions making.
Cédric Nicard Head of Sustainability France M: +33 (0)7 62 24 14 35 E: cedric.nicard@cbre.fr
Content available soon.
Michael Csiszar Head of ESG & Sustainability – Austria M: +43 676 501 75 60 E: Michael.Csiszar@cbre.com
Giovanni Litti Head of ESG & Sustainability - BELUX M: +32 488 94 74 61 E: Giovanni.litti@cbre.com
In Belgium, especially in the Flanders and Brussels regions, there is strong commitment to ESG- implementation. As defined by the Article 4/1 of the Belgian Company Code (BCC), companies are requested to disclose the sustainability impact of their activities. This is applicable primarily to the financial sector, but also other sectors will follow. In all the three regions of Belgium, have been introduced energy targets by 2050. This for both residential and nonresidential buildings. In Flanders, the 2050- objective for nonresidential buildings is carbon neutrality, where the totality of operating energy is covered by renewable sources (no embodied carbon included). Residential units, should be by 2050 either conform to the minimum energy performance requirements of the building envelope or have an energy use of max 100kWh/m2 y. With regard to energy production, in Brussels Capital-Region fro instance, the installation of coal fired appliances is forbidden from 2021, oil-fired heating systems installation will be forbidden as from 2025 and gas-fired installations will be forbidden as from 2030.
New construction projects should respect the in force EPB- regulation in the three different regions of Belgium. The differences between the regions are not substantial. Below is given an example for the Region of Brussels-Capital. The following rules need to be respected: • Primary energy consumption (for heating, SWW, cooling and ancillary energy) should be below the maximum threshold (**); • U- value for envelope- components should be below the maximum thresholds; • Ventilation- rates should meet the minimum threshold; • Thermal bridges should be limited (to encode within the EPB-modelling); • Installed renewable energy should be ≥ 20 kWh/m2 year
• The EPB- regulation in Belgium differentiates simple renovations and major renovations. The requirements are different according to the renovation-typology. Non-residential renovation- projects should respect the in force EPB- regulation in the three different regions of Belgium. The difference between major renovation and renovation refers to the percentage of envelope- surface undergoing renovation.
In the Flemish region, for example, • From 01/01/2022, in case of transactions, minimum renovation works are required within 5-years from the transaction for non-residential buildings (a difference is made between small and large buildings). • From 01/01/2030, obligations regarding minimum energy-labels will enter into force.
The EPC do have different performance -scale through the three regions in the country. In many cases, EPC are mandatory : In Brussels : • New (non- residential) buildings construction; • Sale/rent of nonresidential buildings > 500 m2 ; In Flanders : • In transaction of nonresidential small buildings (less than 500m2). The EPC- certification should be >2019 ; • From 01/01/2023, in case of renting or selling of large nonresidential buildings, an EPC- certificate is mandatory. • New construction In Wallonia : • Sell/ Rent of buildings with surface > 50m2
The installation of solar panels is promoted as also of other RES. Minimum renewable energy production-requirements are listed below for the case of Brussels. • ≥ 20 kWh/m2 year for non-residential buildings (new construction) • ≥ 15 kWh/m2 year for non-residential buildings (under major renovation) In Flanders, by 2050, the totality of operating energy should be covered by onsite renewable sources.
In Belgium monitoring of energy produced by renewable sources will be phased in. • In Flanders, It will be requested to measure onsite total energy use as well as onsite produced renewable energy. From 2023 these figures will be considered in EPC of nonresidential buildings.
New construction projects should respect the in force EPB- regulation in the three different regions of Belgium. The differences between the regions are not substantial. Below is given an example for the Region of Brussels- Capital. The following rules need to be respected: • Primary energy consumption (for heating, SWW, cooling and ancillary energy) should be below the maximum threshold; • U- value for envelope- components should be below the maximum thresholds; • S-value should be below a maximum threshold; • Ventilation- rates should meet the minimum threshold; • Thermal bridges should be limited (to encode within the EPB-modelling); • Installed renewable energy should be ≥ 15 kWh/m2 year; • Risk of overheating (> 25°C) should be limited to max. 5% of the occupied time in one year.
The EPB- regulation in Belgium differentiates simple renovations and major renovations. The requirements are different according to the renovation-typology. Residential renovation- projects should respect the in force EPB- regulation in the three different regions of Belgium. The difference between major renovation and renovation refers to the percentage of envelope- surface undergoing renovation.
In Flanders, • From 01/01/2023, in case of transactions, minimum renovation works are required within 5-years from the transaction for residential buildings. • EPB- requirements are applicable to residential buildings in case of renovation, refurbishment (or works with submission of building permit).
The EPC do have different performance - scale through the three regions in the country. • Mandatory for residential buildings construction • Mandatory for apartments upon sale/ let with the following surface: • Brussels > 50m2 • Wallonia > 18m2 • Flanders NA • From 2022 in Flanders it should be issued a EPC for the common areas of residential-buildings
The installation of solar panels is promoted as also of other RES. Minimum renewable energy production-requirements (among the others from solar panels but not only) are listed below for the case of Brussels. Minimum renewable energy production from RES in case of residential buildings: • ≥ 15 kWh/m2 year for residences (both new or under major- renovation) • No requirements for simple renovations
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Jiří Stránský Head of ESG & Sustainability - Czech Republic M: +420 702 098 189 E: jiri.stransky@cbre.com
ESG commitments in the Czech Republic are mainly driven by policies and requirements coming from the European Union level. Most of the national regulations are transitions of EU policies and regulations into the state legislation. This meant in the past decade mainly EU 20/20/20 targets and European Green Deal in the decades to come. Other internal Czech commitments are not very strong. Greenhouse gas emissions (GHG) of the Czech Republic decreased between 1990 and 2018 by 35,2 %. Nevertheless, Czech GHG emissions per capita of 12,2 t CO2e are still above EU average (8,7 t CO2e) . In the 2021, Czech Republic has prepared the National Recovery Plan, a document which presents the reforms and investments that will be implemented with the European funds of the Next Generation EU. Among its objectives is to decrease GHG emissions by 44 MtCO2e till 2030, which represents the decrease of 30 % between 2005 and 2030.
New construction in the Czech Republic must meet two main sets of regulatory requirements: planning law and building regulations. Planning law controls the general design and layout of buildings, and will often have requirements relating to building density, green spaces, water management etc. Building regulations are more technical and relate to matters such as insulation, water consumption, fire safety and energy efficiency.
Policy and regulation in the Czech Republic tends not to make significant distinctions between renovation and new build construction in commercial property: the legal basis is the same, though regulations for renovation are less stringent compared to new construction. Renovation of an existing building will often require building regulations approval, even for matters as small as replacing lighting or wiring.
Energy efficiency of the commercial stock in the Czech Republic is regulated under the Act No. 406/2000 Coll. on Energy Management. This already requires that commercial property in the Czech Republic must not be leased unless it holds a valid EU Energy Performance Certificate rating. There are proposals to tighten this requirement to a certain level of energy performance.
Where residential property is let, it need to have a valid Energy Performance Certificate. Furthermore, it is expected that a certain level of EPC will have to be achieved for letting the property.
No specific policy or regulation regarding solar photovoltaics exists. Nevertheless main metrics in Energy Performance Certificate required to be met for new construction projects in non-renewable primary energy demand. This can sometimes result in the need of installation of on-site renewable energy sources including photovoltaics.
There is no specific legal requirement regarding smart metering.
There are almost no regulations relating to the sustainability of the existing residential stock in the Czech Republic. Where residential property is let, however, there are similar requirements as for commercial property, deriving from the requirement of having a valid Energy Performance Certificate. Furthermore it is expected that a certain level of EPC will have to be achieved for letting the property.
The French EPC is called Diagnostic de Performance Energetique (DPE). It covers all existing commercial and residential real estate that have an area of >50 sqm and all new construction or extension of existing real estate for over 150 sqm. Progressive interdiction of the renting out of energy slums, according to the following schedule : 2025 for class G, 2028 for class F, 2034 for class E
Niklas Wiik Head of ESG & Sustainability – Finland M: +358 (0)50 345 4146 E: niklas.wiik@cbre.com
Finland aims to be carbon neutral by 2035. The key pillar of Finland’s national climate policy is the Climate Change Act that entered into force on 1 June 2015. According to the Act, Finland must reduce its greenhouse gas emissions by at least 80% by 2050 from the levels in 1990. The current Climate Change Act is being reformed and strengthened to achieve this target. The Government’s proposal for the amended Climate Change Act have been handed over to the Parliament in the beginning of 2022. The current Land Use and Building Act is also being reformed and it is planned the reformed law would enter into force on 1 January 2024.
National Decree 1010/2017 regulates the minimum requirements for building energy performance. Strict requirement levels for the calculated energy performance reference value for each intended use category. The regulations for new construction and renovations will be revised in 2023. In the case of a new building with more than 10 parking spaces, one high-capacity charging point shall be installed or, alternatively: 1) at least one charging station with normal capacity, if there are 11–50 parking spaces; 2) at least two charging stations with normal capacity, if there are 51–100 parking spaces; 3) at least three normal-capacity charging points if there are more than 100 parking spaces.
The party engaging in the renovation or alteration project must, in connection with the planning required for the appropriate permit, present the measures intended to improve the energy performance of the building by buildingelement, system or for the entire building in accordance with the extent of the project and the selected option. In the case of a major renovation with more than 10 parking spaces, one high-capacity charging point shall be installed or, alternatively: 1) at least one charging station with normal capacity, if there are 11–50 parking spaces; 2) at least two charging stations with normal capacity, if there are 51–100 parking spaces; 3) at least three normal-capacity charging points if there are more than 100 parking spaces.
EPCs mandatory before transactions. From 2025, commercial heated buildings will be required to have at least one EV charge point when more than 20 parking spaces.
An EPC is required when: • Prior to a sale • Issued in connection with renting • For larger buildings frequently visited by the public • For new buildings.
No requirements.
Since 2011, it has been required to install individual meters for cold and warm domestic water in new buildings. It is not (yet) mandatory to use the readings as a basis for billing. Intelligent metering enables the collection of useful data that can be shown in EPCs. The same applies to the renovation of buildings. All main electrical metering points for all commercial and non-commercial buildings that measure electricity must be smart meters.
National Decree 1010/2017 regulates the minimum requirements for building energy performance. Strict requirement levels for the calculated energy performance reference value for each intended use category. The regulations for new construction and renovations will be revised in 2023. In the case of a new residential building with more than four parking spaces, a charging point capability must be installed so that a charging point can be installed in each parking space at a later date.
The party engaging in the renovation or alteration project must, in connection with the planning required for the appropriate permit, present the measures intended to improve the energy performance of the building by buildingelement, system or for the entire building in accordance with the extent of the project and the selected option. In the case of a major renovation for a building with more than four parking spaces, charging point capability must be installed so that a charging point can be installed in each parking space at a later date.
EPCs mandatory before transactions.
An EPC is required when: prior to a sale issued in connection with renting for larger buildings frequently visited by the public for new buildings.
France has developed a specific roadmap called SNBC (Stratégie Nationale Bas-Carbone) giving pluriannual “carbon budgets” that every economic sector had to reach with specific regulations. This roadmap provides two key objectives: 1) Emissions reduction by 49% by 2030 compared to 2015 2) Full decarbonization and achieve carbon neutrality by 2050 French Government released recently two main laws to translate EU Directives into country level: • Ecological Transition and Green Growth (LTECV, Loi Transition Ecologique pour la Croissance Verte). The purpose is to further contribute to the fight against global warming, to the preservation of the environment, and to increase energy independence. • Climate Resilience Law (Loi Climat et Resilience), whose purpose is to accelerate the ecological transition of the French society and economy, and targeting six areas of actions: consumption, housing, commute and travel, industrial production, food, and ecological harm.
Environmental regulation (Réglementation Environnementale RE2020) will come into French law in January 2022 and is an upgrade of the RT2012 regulation. This law will look at two key areas for new construction, both commercial and residential assets: environmental and energy criteria & environmental and energy performance.
The “RT Existant” regulation covers renovation projects. It aims to ensure every renovation project contribute to significantly improve energy performance.
Published during summer 2019, the Tertiary Decree (Décret tertiaire or Eco Energie Tertiaire) refers to the obligation for commercial assets of over 1,000 m² to cut their energy consumption by 40% before 2030, 50% before 2040 and 60% before 2050
The French EPC is called Diagnostic de Performance Energetique (DPE). It covers all existing commercial and residential real estate that have an area of >50 sqm and all new construction or extension of existing real estate for over 150 sqm. EPC are being conducted by third-party, certified professionals and disclose four key information: • Description of its thermal and geometric building characteristics • List of data that was used to calculate the EPC rating • Two categories of rating: Energy and Climate (GHG emissions) • Recommendations for improvements
The Urbanism Code sets out requirements for the installation of solar photovoltaic panels and vegetated roofs under Article L111-18-1 released into law in February 2020. This applies to all new construction of commercial real estate that is above >500 sqm of footprint.
The Decree for Building Automation and Control System (BACS) requires all buildings with HVAC systems of >290 kW to have a building automation and control system in place by January, 1st 2025.
Progressive interdiction of the renting out of energy slums, according to the following schedule : 2025 for class G, 2028 for class F, 2034 for class E
No requirements Not required by law. However, solar photovoltaic panels could be required to meet the primary energy requirements for building regulation standards in France.
For new construction, mandatory to have sub meters for the monitoring of the 5 main energy uses. For existing building (condominiums), mandatory to have sub-meters (heating, cooling, hot water) for each flat.
FRANCE has developed a specific roadmap called SNBC (Stratégie Nationale Bas-Carbone) giving pluriannual “carbon budgets” that every economic sector had to reach with specific regulations. This roadmap provides two key objectives: 1) Emissions reduction by 49% by 2030 compared to 2015 2) Full decarbonization and achieve carbon neutrality by 2050 French Government released recently two main laws to translate EU Directives into country level: • Ecological Transition and Green Growth (LTECV, Loi Transition Ecologique pour la Croissance Verte). The purpose is to further contribute to the fight against global warming, to the preservation of the environment, and to increase energy independence. • Climate Resilience Law (Loi Climat et Resilience), whose purpose is to accelerate the ecological transition of the French society and economy, and targeting six areas of actions: consumption, housing, commute and travel, industrial production, food, and ecological harm.
Published during summer 2019, the Tertiary Decree (Décret tertiaire or Eco Energie Tertiaire) refers to the obligation for commercial assets of over 1,000 m² to cut their energy consumption by 40% before 2030, 50% before 2040 and 60% before 2050.
The Decree for Building Automation and Control System (BACS) requires all buildings with HVAC systems of >290 kW to have a building automation and control system in place by January, 1t 2025.
The French EPC is called Diagnostic de Performance Energetique (DPE). It covers all existing commercial and residential real estate that have an area of >50 sqm and all new construction or extension of existing real estate for over 150 sqm. Progressive interdiction of the renting out of energy slums, according to the following schedule : 2025 for class G, 2028 for class F, 2034 for class E.
No requirements
Thorsten Huff Head of ESG & Sustainability – Germany M: +49 (0)172 7221549 E: thorsten.huff@cbre.com
The Federal Government has stepped up the climate protection targets by amending the Climate Change Act (Klimaschutzgesetz). Compared to 1990, emissions are to be reduced by 65% by 2030. Greenhouse gas neutrality is to be achieved in 2045. In the “Easter Package” certain targets and actions regarding renewables are published by the Government. Electricity is to be renewable by 80% in 2030 and 100% renewable in 2035.
The Building Energy Act (GEG) combines previous regulations on the energy efficiency of buildings and the use of renewable energies, thereby implementing European requirements into national law. According to the GEG, the final energy demand of a new building depends on the usage and is calculated for each project. There must be a proportionate use of renewable energy to cover the demand for heating/cooling.
As soon as more than 10 percent of the total area of the respective building component group is to be renovated, corresponding minimum standards (in terms of the thermal coefficient) apply to the respective building components must comply with regulation requirements.
Currently nearly no regulations in terms of existing buildings. The Building Energy Act (GEG) requires certain energy efficiency measures when a building has been sold, like replacement of old boilers or insulation of inefficient roof. Certain restrictions are expected due to a tightened Energy Efficiency regulation.
GEG: Mandatory energy performance certificate - Since 2009, all buildings require an energy performance certificate when they are newly rented or sold.
In some federal states there will be an obligation to install photovoltaic systems from 2022 at the earliest, which is intended to ensure that more renewable energy is produced and consumed at the same location. There are also nationwide regulations apply to new buildings, existing buildings (in case of roof repair/replacement) and parking lots.
The “Messstellenbetriebsgesetz” (MsbG) regulates when analogue or digital meters must be exchanged for smart meters (with a communication unit (gateway) with internet connection). All metering points (i.e. also sub-meters) for all commercial and non-commercial buildings that measure an annual electricity consumption of more than 6,000 kWh are affected by this replacement obligation.
Currently nearly no regulations in terms of existing buildings. The Building Energy Act (GEG) requires certain energy efficiency measures when a building has been sold, like replacement of old boilers or insulation of inefficient roof. Excemptions are possible for self-used small homes or when measures are not economical feasible.
GEG: Mandatory energy performance certificate - Since 2009, all buildings require an energy performance certificate when they are newly rented or sold. Residential buildings have energy efficiency classes.
Rachael Mcginley Head of ESG & Sustainability – Ireland M: +353 87 3724 617 E: rachael.mcginley@cbre.com
Ireland is legally committed to become climate-neutral by 2050, and with a reduction in national carbon emissions of 51% by 2030. Details on how Ireland will meet these commitments are detailed in the Government's Climate Action Plan 2021, an ambitious plan to put Ireland on a more sustainable path, cutting emissions, creating a cleaner, greener economy and society and protecting us from the devastating consequences of climate change. Specific actions for the real estate sector are detailed in teh Climate Action Plan's Annex of Actions, which was published in late 2021. The Annex sets out goals for further research and planning, as well as specific targets that the real estate and property sector must meet. The targets include: • Delivery of the National Retrofit Plan • Delivering a District Heating System in Central Dublin and Tallaght • Ban the installation of fossil fuel boilers in new homes from 2023 • Develop a road map for low carbon construction materials and Develop an embodied carbon building rating calculation methodology • Develop specific climate maps and data for use in building design to enhance resilience in support of climate change adaptation
The revised Building Regulations Part L – “Building Regulations 2021: Technical Guidance Document - Buildings other than Dwellings, requires building to be designed to nZEB standards. The regulations are due for review in 2025, as stated in the Climate Action Plan Annex.
Directive requires that where major renovations (defined as a renovation where more than 25% of the surface envelope of the building undergoes renovation) are carried out on a building, the building should achieve a cost optimal energy performance at building level insofar as is technically, functionally and economically feasible. The cost optimal energy performance level is equivalent to a B2 BER.
To ensure building stock is meeting current standards, the Irish Government has issued the revised Building Regulations Part L – “Building Regulations 2021: Technical Guidance Document L - Buildings other than Dwellings”, which requires buildings to make a 60% improvement in energy efficiency and also includes a requirement for up to 20% of any remaining demand to be met with renewable energies
Known as Building Energy Rating (BER) in Ireland, a commercial BER Cert is required whenever a commercial property or unit therein is offered for sale or letting. Similar to EPC schemes in other countries, BER rate buildings from A – G depending on their energy and carbon performance, with A1 being the best and G being the worst. Heating fuel, energy use intensity and carbon intensity are also listed on the BER certificate.
The Climate Action Plan 2021 includes a commitment to introduce a Microgeneration Support Scheme (MSS) which supports deployment of an expected 260 MW of new micro-generation by 2030. The final design of the MSS received government approval on 21 December 2021
By the end of 2024, every home and business in Ireland will have a smart meter.
Known as Building Energy Rating (BER) in Ireland, a residential BER Certificate is legally required whenever a home is offered for sale or letting. Similar to EPC schemes in other countries, BER rate buildings from A – G depending on their energy and carbon performance, with A1 being the best and G being the worst. Heating fuel, energy use intensity and carbon intensity are also listed on the BER certificate.
The Climate Action Plan 2021 includes a commitment to introduce a Microgeneration Support Scheme (MSS) which supports deployment of an expected 260 MW of new micro-generation by 2030. The final design of the MSS received government approval on 21 December 2022.
Under the previous 2011 regulations, a typical new dwelling is built to an A3 Building Energy Rating (BER). The NZEB requirements will equate to an A2 BER.
The Climate Action Bill 2021 plan aims to retrofit 500,000 homes through the National Retrofit Plan, to help meet targets set in the National Development Plan 2021-2030. A new National Home Energy Upgrade Scheme providing increased grant levels of up to 50% of the cost of a typical deep retrofit to a B2 BER standard.
To ensure building stock is meeting current standards, the Irish Government has issued the revised Building Regulations Part L – “Building Regulations 2021: Technical Guidance Document L - Buildings other than Dwellings”, which requires buildings to make a 60% improvement in energy efficiency and also includes a requirement for up to 20% of any remaining demand to be met with renewable energies.
Gianluca Padula Head of ESG & Sustainability - Italy M: +39 340 1164 959 E: gianluca.padula@cbre.com
In Italy, the new National Energy Strategy (SEN) was adopted on 10 November 2017, which constituted a point of departure for the preparation of the Integrated Plan for the Environment (PNIEC), in implementation of Regulation (EU) 2018/1999. Italy plans to pursue the target of obtaining 30% of gross final consumption of energy from renewable sources in 2030 by defining a pathway of sustainable growth for renewable sources and the full integration thereof into the system. In the 2021, Italy has prepared the National Recovery and Resilience Plan (PNRR), a document which presents the reforms and investments that will be implemented with the European funds of the Next Generation EU. Among the objectives of the PNRR is to improve the energy efficiency of public and private buildings with the aim of saving at least 0.32 Mtoe and 0.98 MtCO2 by 2026. Italy allocated several resources to new urban regeneration and energy conversion projects and to incentives for the use of renewables. Italy is increasing emission reduction target from 33 to 60% by 2030 from 1990 levels and targets to meet the Paris Agreement net-zero goal by 2050 from same levels.
Decree 19/08/2005, n.192 (and subsequent amendments) transposes the European Energy Performance of Buildings Directive EU 2018/844.1 (EPBD). As defined in the national guidelines D.M. 26/06/2015, from 1 January 2021, all new buildings must be nearly zero-energy buildings (NZEB).
Decree 19/08/2005, n.192 (and subsequent amendments) transposes the European Energy Performance of Buildings Directive EU 2018/844.1 (EPBD). The decree supports the renovation of existing buildings and intervenes on the operation, control, conduction, inspection and maintenance of all air conditioning systems, including those for summer cooling,
D.P.R. 16/04/2013, n.74 (and subsequent amendments) defines new rules on the operation, management, control, maintenance and inspection of heating, cooling and DHW systems. It contains a series of obligations and criteria to be applied to public and private construction.
Energy label requirement (APE). When selling and leasing an asset an energy label is mandatory, but no minimum level is required.
Decree n. 192-19/08/2005 and D.M. 26-06-2015 (Minimum Requirements Decree) impose for new buildings and major renovations the obligations of integration of renewable sources in compliance with the minimum principles of Annex 3, paragraph 1, letter c) of Legislative Decree No 28 of 3 March 2011.
D.lgs. 19/08/2005, n.192 (and subsequent amendments), with its implementing decree D.M. 26-06-2015 (Minimum Requirements Decree), imposes for new buildings and major renovations for non-residential use a minimum level of automation for the control, regulation and management of building technologies and thermal systems that is at least equal to class B of EN 15232 or equivalent standard.
Gianluca Padula Head of ESG & Sustainability – Italy M: +39 340 1164 959 E: gianluca.padula@cbre.com
In ITALY, the new National Energy Strategy (SEN) was adopted on 10 November 2017, which constituted a point of departure for the preparation of the Integrated Plan for the Environment (PNIEC), in implementation of Regulation (EU) 2018/1999. Italy plans to pursue the target of obtaining 30% of gross final consumption of energy from renewable sources in 2030 by defining a pathway of sustainable growth for renewable sources and the full integration thereof into the system. In the 2021, Italy has prepared the National Recovery and Resilience Plan (PNRR), a document which presents the reforms and investments that will be implemented with the European funds of the Next Generation EU. Among the objectives of the PNRR is to improve the energy efficiency of public and private buildings with the aim of saving at least 0.32 Mtoe and 0.98 MtCO2 by 2026. Italy allocated several resources to new urban regeneration and energy conversion projects and to incentives for the use of renewables. Italy is increasing emission reduction target from 33 to 60% by 2030 from 1990 levels and targets to meet the Paris Agreement net-zero goal by 2050 from same levels.
Tim Habraken Head of ESG & Sustainability – Netherlands M: +31 6 25640769 E: tim.habraken@cbre.com
In the Netherlands, the Dutch government has signed the ‘Climate Agreement’ out of which sector-wide agreements are set to reduce greenhouse gas emissions, being 49% by 2030, compared to 1990 levels, and a 95% reduction by 2050. The ‘Climate Agreement’ aligns with EU Legislation and is further incorporated into other Dutch standards. The Dutch Climate Agreement include a specific target for the built environment, with the target for the sector to reduce 3.4 MTon of CO2.
Each new building requires a BENG calculation and certificate (new version of the EPC calculation), which translates to “Almost Energy Neutral Buildings”. The label sets limits for the maximum energy demand, the primary fossil fuel usage and the share of renewable energy.
The regulations for major renovations are similar to new construction. A major renovation defined as when more than 25% of the building envelope and/ or 25% of the technical installations is renovated, changed or enlarged. Bouwbesluit (Building Decree) contains performance requirements for the building envelope and EPBD III contains performance requirements for technical installations.
The Dutch office building stock will have to improve is energy efficiency. For all utility buildings transactions, being sold, leased or delivered, an energy label C will be mandatory for the office portion of a building after 2023 and an energy label A will be mandatory for offices after 2030.
When selling and leasing an asset an energy label is mandatory to be obtained by building owner. Energy labels are valid for 10 years. Since January 1, 2021, there is a new calculation method (NTA 8800 / BENG), old labels remain valid.
The Dutch Building Decree BENG 3 (for new construction and major renovation) requires a share of on-site produced (or produced within a limited radius from the building) renewable energy with a minimum of between 30% and 50% depending on the asset function.
The Dutch law indicate that Building automation and control systems is mandatory for heating- and air conditioning systems of >290 kW before 2026.
The residential stock owned by housing corporations (“woningcorporaties”) need to have an energy label B on average since 2021.
No obligation to have smart metering, nevertheless, for residential units (on a unit level), the “netbeheerder” (grid company) installs a smart meter for free (at renovations or at timing as per their disclosure).
Tim Habraken Head of ESG & Sustainability – Netherlands M: +31 6 2564 0769 E: tim.habraken@cbre.com
Emma Otervik Head of ESG & Sustainability – Norway M: +47 489 96 728 E: emma.otervik@cbre.com
Norway's strengthened climate target is to reduce emissions by at least 50 per cent and up to 55 per cent by 2030 compared with the 1990 level. Norway wants to cut its greenhouse gas emissions in cooperation with the EU. Through the climate agreement with the EU, Norway has already committed itself to cooperating with the EU to reduce emissions by at least 40 percent by 2030 compared to 1990 levels. The Climate Act confirms Norway's strengthened climate goals for 2030 and the climate goal for 2050. The law constitutes the framework for Norwegian climate policy and shall promote the implementation of the transition to a low-emission society, with the goal that emissions by 2050 will be reduced by 90-95 percent.
Norway have TEK 17, and energy Requirements for energy efficiency. TEK 17 is a regulation that describes different standards a building must contain. The regulations apply to both commercial and residential buildings and have some common requirements and some special requirements based on what the building is to be used for. This applies, among other things, to requirements for roof or wall. It further sets minimum requirements for: technical subjects, such as how the ventilation should be, and correspondingly for electricity, water and drainage, etc. patio, when it comes to parking, playgrounds, etc.
Norway have TEK 17, and energy Requirements for energy efficiency Building technical regulations (TEK17) stipulate minimum requirements for properties that a building must have. Today's requirements also apply if you are to take measures on existing buildings, which are often built at a time when there were other requirements.
EPCs mandatory before transactions. Norway also have TEK 17, and energy Requirements for energy efficiency. TEK17 regulations on technical requirements for buildings raise the limit for the minimum standard a building must have in order to be erected legally in Norway, this also include energy efficiency. The total net energy requirement for the building shall not exceed the energy limits frame.
An EPC is required when: • Prior to a sale • Issued in connection with renting • For new buildings.
In Norway according to regulation TEK17, is not permitted to install heating installations for fossil fuels Building with more than 1,000 m2 of heated BRA shall have energy-flexible heating systems; and adapted for the use of low-temperature heating solutions.
All electricity consumers will receive smart meters by 1 January 2019. And all energy demanding technical equipment are required to have metering.
Norway have TEK 17, and energy Requirements for energy efficiency. TEK 17 is a regulation that describes different standards a building must contain. This applies, among other things, to requirements for room distribution in housing, how much insulation there should be in walls and roof, etc. It further sets minimum requirements for: technical subjects, such as how the ventilation should be, and correspondingly for electricity, water and drainage, etc. patio, when it comes to parking, playgrounds, etc.
An EPC is required when: • Prior to a sale • Issued in connection with renting/commissioning • For new buildings.
Norway has a broad set of instruments that ensure a sustainable and secure energy system. A sustainable energy system is environmentally and climate-friendly, efficient, secure and facilitates value creation on the way to the low-emission society.
All electricity consumers in Norway have a smart meter installed.
Norway have TEK 17, and energy Requirements for energy efficiency . TEK 17 is a regulation that describes different standards a building must contain. This applies, among other things, to requirements for room distribution in housing, how much insulation there should be in walls and roof, etc. It further sets minimum requirements for: technical subjects, such as how the ventilation should be, and correspondingly for electricity, water and drainage, etc. patio, when it comes to parking, playgrounds, etc.
Norway have TEK 17, and energy Requirements for energy efficiency. Building technical regulations (TEK17) stipulate minimum requirements for properties that a building must have. Today's requirements also apply if you are to take measures on existing buildings, which are often built at a time when there were other requirements.
In Norway according to regulation TEK17, is not permitted to install heating installations for fossil fuels. Building with more than 1,000 m2 of heated BRA shall have energy-flexible heating systems; and adapted for the use of low-temperature heating solutions.
Poland sets a national target to improve energy efficiency of primary energy consumption by 23% by 2030, as compared to 2020 and reduction of GHG emissions by 30% by 2030 (compared to 1990 levels). Moreover, Poland declares reaching at least 23% share of RES (Renewable Energy Sources) in gross final energy consumption in 2030.
Paweł Kotlarski Head of ESG & Sustainability – Poland M: +48 608 662 569 E: Pawel.kotlarski@cbre.com
Owners must obtain EPC in the following instances: • New construction buildings • Buildings or parts of buildings to be sold or rented to a new lessee • Public buildings with a total useful floor area greater than 250 m2
Not required by law. However, solar photovoltaic panels could be required to meet the primary energy requirements for building regulation standards in Poland.
Although not implemented, it is expected that, by 2025, it will be required to ensure that commercial buildings with an effective rated output for heating systems or systems for combined space heating and ventilation of over 290 kW are equipped with building automation and control systems.
Paweł Kotlarski Head of ESG & Sustainability – Poland M: +48 608 662 569 E: pawel.kotlarski@cbre.com
Bernardo Rebelo de Freitas Head of ESG & Sustainability – Portugal M: +351 91 192 29 00 E: bernardo.freitas@cbre.com
By 2030, Portugal has set the following national goals: • 45% to 55% reduction in global CO2 emissions • 35% increase in energy efficiency • 47% increase in renewable energy Specifically for buildings, the following goals were established in terms of C02 emissions reduction: • Commercial – 70% by 2030 • Residential – 35% by 2030
New commercial buildings must achieve an EPC rating of at least B.
All buildings to be transformed into NZEB (Near Zero Energy Building) by 2050.
An EPC is required when performing a transaction of a commercial building. A minimum energy performance is targeted (energy label C or D, depending on the age of the building). If the building doesn’t achieve this minimum efficiency target, an Energy Efficiency Plan will have to be designed and implemented along the years. In addition, if the building uses more than 2,5GWh/year of final energy, the building is also obliged to implement an Energy Efficiency Plan.
Since 2020, an EPC is required when performing perform a transaction of a commercial building and are valid during 10 years.
By 2050, all large commercial buildings with heating, cooling or mixed systems and with thermal power higher or equal to 290 kW are required to the installation of automation and control systems of buildings (SACE).
New residential buildings must achieve a minimum label of A.
EPCs for residential buildings are valid for 10 years.
Linda Kjällén Head of ESG & Sustainability – Sweden M: +46 (0) 70 204 51 78 E: linda.kjallen@cbre.com
Sweden’s overarching climate target is to achieve zero net emissions of greenhouse gases by 2045 and hereafter negative emissions. Emissions from Swedish territory are to be at least 85 percent lower 2045 than they were 1990. Below are the intermediary milestone targets, for emissions not covered by the EU Emission Trading System, (EU ETS): • By 2020 emissions are to be 40 percent lower than 1990 • By 2030 emissions are to be 63 percent lower than 1990 • By 2040 emissions are to be 75 percent lower than 1990 Similarly, to the 2045 target, parts of the 2030 and 2040 targets can be reached by carbon sinks or by mitigation outside of Swedish territory.
Buildings shall be designed in such a way that energy use is limited by low heat losses, low cooling demands, efficient use of heat and cooling and efficient use of electricity. At least one EV charge point when more than 10 parking spaces and charging infrastructure for minimum 20% of the spaces. From 2022, most new built projects need to present a climate declaration (for construction phase) before commissioning and limit values are expected by 2027.
The extent of the renovation will decide the current regulations and needs to be considered during construction and design phases. Providing infrastructure for charging electric vehicles might apply as for New Construction.
EPC is mandatory for sales and sometimes always required. The Minimum Energy Performance Standards (MEPS) is assumed to be implemented in a few years within the adaptation of the revised EPBD. From 2025, commercial heated buildings will be required to have at least one EV charge point when more than 20 parking spaces.
An EPC is required when: • Prior to a sale; • Issued in connection with renting; • For larger buildings frequently visited by the public; • For new buildings.
No laws currently require Solar PV to be installed.
From 2025, commercial heated buildings with an HVAC of >290 kW will be required to have a system for property automation and management.
Buildings shall be designed in such a way that energy use is limited by low heat losses, low cooling demands, efficient use of heat and cooling and efficient use of electricity. Charging infrastructure to all the parking spaces if more than 10. From 2022, most new built projects need to present a climate declaration (for construction phase) before commissioning and limit values are expected by 2027.
EPC is mandatory for sales.
An EPC is required when: • Prior to a sale • Issued in connection with renting/commissioning; • For new buildings.
Requirement applies for some residential buildings as part of EDD. Includes individual meters and billing for heating and hot water for household use.
An EPC is required when: • Prior to a sale; • Issued in connection with renting/commissioning; • For new buildings.
Patricia García de Ponga Head of ESG & Sustainability – Spain M: +34 677 500 823 E: patricia.garciadeponga@cbre.com
In Spain a new law has been approved in July 2021 (Ley 7/2021, de 20 de mayo, de cambio climático y transición energética) which set the following goals to 2030: • Cut greenhouse gas emissions by 23% (compared with 1990 levels); • An improvement in primary energy efficiency of 39,5%; • Increase the share of renewables to 42% of final energy consumption and to 74% of electricity production; • Spain's electricity system will have to be 100% renewable before 2050; • To achieve climate neutrality ‘no later than’ 2050; • Two tools have been created to materialize the objectives set in the Spanish Climate Change law (above) for action against climate change: • Short-medium term: Plan Nacional Integrado de Energía y Clima (PNIEC) 2021-2030 • Long term: Estrategia de Descarbonización a 2050
Technical Building Code, obligation from 2020 to build buildings Near Zero Energy Buildings consumption (EPC-A). Modification of the DBHE4, which eliminates the obligation of solar thermal installations and facilitates the substitution by photovoltaic and aerothermal equipment. Improvement in the passive behavior of buildings.
Every major renovation of a building must comply with current NZEB regulations, with the need to incorporate higher energy efficiency thermal systems, photovoltaic installations and improvements in the passive behavior of buildings.
Certificado de Eficiencia Energética (CEE) Real Decreto 390/2021 , that abolish RD 235/2013. In this certificate, and by means of an energy efficiency label, an Energy Efficiency Class is assigned to each building, which will vary from class A, for the most energy efficient, to class G, for the least efficient. The validity of the CEE is 10 years, although when the class assigned to the building is G, then the validity is 5 years. The person responsible for its renovation is the owner of the property, although it must comply with the specific regulations of each Region regarding procedures and deadlines.
Royal Decree on Self-consumption has greatly facilitated the development of PV. • Installations < 100kWp are plug&play. • Installations > 100 kWp have reduced installation procedures.
The Spanish Regulation of Thermal Installations in Buildings (RITE) has been updated on March 2021 and entered into force in July 2021. Itiincludes the following developments regarding smart metering in buildings: • large non-residential buildings with heating, cooling and ventilation systems with a nominal heat outpout>290 kW must include automation and control systems (BMS) • Buildings of more than 1,000 sqm must display the information of energy consumption during the last 5 years in a visible way for users. This can be achieved with the installation of an EMS system.
Smart submetering is mandatory in residential in case of central HVAC system
In SPAIN a new law has been approved in July 2021 (Ley 7/2021, de 20 de mayo, de cambio climático y transición energética) which set the following goals to 2030: • Cut greenhouse gas emissions by 23% (compared with 1990 levels); • An improvement in primary energy efficiency of 39,5%; • Increase the share of renewables to 42% of final energy consumption and to 74% of electricity production; • Spain's electricity system will have to be 100% renewable before 2050; • To achieve climate neutrality ‘no later than’ 2050; • Two tools have been created to materialize the objectives set in the Spanish Climate Change law (above) for action against climate change: • Short-medium term: Plan Nacional Integrado de Energía y Clima (PNIEC) 2021 2030 • Long term: Estrategia de Descarbonización a 2050
Kaela Fenn-Smith Head of ESG & Sustainability – UK M: 07793 709 247 E: kaela.fennsmith@cbre.com
Following Brexit, the UK is still exposed to almost all of the regulatory requirements that applied to it when the UK was a member of the EU. This is because all EU law relating to environmental matters was adopted into UK law at the point of exit. An example is the ‘UK Green Taxonomy’ which is the UK equivalent of the EU Taxonomy. Although the UK Taxonomy will be different in its details from the EU Taxonomy, the underlying legislation is the same. The UK targets to bring all greenhouse gas emissions to net zero by 2050, compared with the previous target of at least 80% reduction from 1990 levels. The UK established ambitious 2030 and 2035 emission reduction targets of 68% and 78%, respectively, from 1990 levels. UK Commitments are summarized in the “Ten-point plan for a Green Industrial Revolution”: Building back better, supporting green jobs and accelerating path to Net Zero. Main points to consider: • Minimum Energy Efficiency Standards (MEES) • Performance based ratings (NABERS)
New construction in the UK must meet two main sets of regulatory requirements: planning law and building regulations. Planning law controls the general design and layout of buildings, and will often have requirements relating to energy consumption, building density, materials etc. Building regulations are more technical and relate to matters such as insulation, water consumption, fire safety and energy efficiency. These regulations exercise very tight control over what can be built in the UK.
Policy and regulation in the UK tends not to make significant distinctions between renovation and new construction in commercial property: the legal basis is the same. Renovation of an existing building will often require building regulations approval, even for matters as small as replacing lighting or wiring.
Energy efficiency of the commercial stock in the UK is regulated under the UK’s Minimum Energy Efficiency Standards (MEES). These already require that commercial property in England & Wales must not be leased unless it achieves an EU Energy Performance Certificate (EPC) rating of at least E or better. There are firm proposals to tighten this requirement so that after 2030, a B or better rating must be achieved, which, currently, only a minority of leased commercial properties in the UK meet.
EPC is a legal requirement when 1) renting out or selling commercial properties, 2) when a building is under construction or is finished, and 3) when there are changes to the number of parts used for separate occupation and these changes involve providing or extending fixed heating, air conditioning or mechanical ventilation systems.
No specific policy or regulation exists.
The UK Government has embarked on a programme of smart meter roll out for commercial. Take-up is voluntary. A multi-tenanted building generating heat at central plant level and distributing heating across tenants can qualify the landlord as “heat supplier”. In this case, The regulations require heat network operators to notify the Secretary of State about their heat networks every four years and, where necessary, to install heat metering devices on those networks.
The specific legal requirements are different for residential properties than for commercial properties, but the legal basis is the same. The most significant regulations for residential property relate to energy efficiency, insulation and water consumption. There is also a relatively new regulation requiring that after 2025 no new home can be built with a gas boiler.
Policy and regulation in the UK tends not to make significant distinctions between renovation and new construction in the residential sector: the legal basis is the same.
Only limited regulations are currently in place for the residential sector. However, where residential property is leased, there are similar requirements as for the commercial sector, deriving from the Minimum Energy Efficiency Standard (MEES). For example, leased properties must not be leased unless they achieve an EPC of E or better. UK Government has said it wishes to raise this requirement so that after 2030, homes cannot be leased unless they achieve an EPC of C or better rating; and by 2035, all homes (whether leased or not) would be required to achieve this standard.
Leased properties must not be leased unless they achieve an EPC of E or better. UK Government has said it wishes to raise this requirement so that after 2030, homes cannot be leased unless they achieve an EPC of C or better rating; and by 2035, all homes (whether leased or not) would be required to achieve this standard.
The UK Government has embarked on a programme of smart meter roll out for residential. Take-up is voluntary. A multi-tenanted building generating heat at central plant level and distributing heating across tenants can qualify the landlord as “heat supplier”. In this case, The regulations require heat network operators to notify the Secretary of State about their heat networks every four years and, where necessary, to install heat metering devices on those networks.
The UK Government has embarked on a programme of smart meter roll out for residential. Take-up is voluntary. A multi-tenanted building generating heat at central plant level and distributing heating across tenants can qualify the landlord as “heat supplier”. In this case, The regulations require heat network operators to notify the Secretary of State about their heat networks every four years and, where necessary, to install heat metering devices on those networks
Policy and regulation in the UK tends not to make significant distinctions between renovation and new construction in the residential sector : the legal basis is the same.
Michael Csiszar Head of ESG & Sustainability – Austria M: +43 676 501 75 60 E: michael.csiszar@cbre.com
Giovanni Litti Head of ESG & Sustainability – BELUX M: +32 488 94 74 61 E: giovanni.litti@cbre.com
Jiří Stránský Head of ESG & Sustainability – Czech Republic M: +420 702 098 189 E: jiri.stransky@cbre.com
Cédric Nicard Head of ESG & Sustainability – France M: +33 (0)7 62 24 14 35 E: cedric.nicard@cbre.fr
Kaela Fenn-Smith Head of ESG & Sustainability – UK M: +44 (0)7793 709 247 E: kaela.fennsmith@cbre.com
FRANCE has developed a specific roadmap called SNBC (Stratégie Nationale Bas-Carbone) giving pluriannual “carbon budgets” that every economic sector had to reach with specific regulations. This roadmap provides two key objectives: 1) Emissions reduction by 49% by 2030 compared to 2015 2) Full decarbonization and achieve carbon neutrality by 2050 French Government released recently two main laws to translate EU Directives into country level: Ecological Transition and Green Growth (LTECV, Loi Transition Ecologique pour la Croissance Verte). The purpose is to further contribute to the fight against global warming, to the preservation of the environment, and to increase energy independence. Climate Resilience Law (Loi Climat et Resilience), whose purpose is to accelerate the ecological transition of the French society and economy, and targeting six areas of actions: consumption, housing, commute and travel, industrial production, food, and ecological harm.
Following Brexit, the UK is still exposed to almost all of the regulatory requirements that applied to it when the UK was a member of the EU. This is because all EU law relating to environmental matters was adopted into UK law at the point of exit. An example is the ‘UK Green Taxonomy’ which is the UK equivalent of the EU Taxonomy. Although the UK Taxonomy will be different in its details from the EU Taxonomy, the underlying legislation is the same. The UK targets to bring all greenhouse gas emissions to net zero by 2050, compared with the previous target of at least 80% reduction from 1990 levels. The UK established ambitious 2030 and 2035 emission reduction targets of 68% and 78%, respectively, from 1990 levels. UK Commitments are summarized in the “Ten-point plan for a Green Industrial Revolution”: Building back better, supporting green jobs and accelerating path to Net Zero. Main points to consider: Minimum Energy Efficiency Standards (MEES) Performance based ratings (NABERS)
The French EPC is called Diagnostic de Performance Energetique (DPE). It covers all existing commercial and residential real estate that have an area of >50 sqm and all new construction or extension of existing real estate for over 150 sqm. EPC are being conducted by third-party, certified professionals and disclose four key information: Description of its thermal and geometric building characteristics List of data that was used to calculate the EPC rating Two categories of rating: Energy and Climate (GHG emissions) Recommendations for improvements
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