EPBD Recast Renovation Requirements: Who Buys First

The EPBD recast, Directive (EU) 2024/1275, makes every EU country renovate its worst buildings on a timetable. For offices, schools, hotels and other non-residential buildings, the European Commission's EPBD overview says minimum energy performance standards will trigger renovation of the worst-performing 16% by 2030. By 2033, that rises to the worst-performing 26%.

For homes, each country sets a trajectory to cut average primary energy use (energy counted at the source, including losses before it reaches the building) by 16% by 2030 and by 20 to 22% by 2035.

On top of that, every country writes a National Building Renovation Plan with its own thresholds, measures and money. The national law and that plan decide where a contractor's work lands first.

I read this directive as a sales document. Which building owners now have a reason to act, and by when? Treat what follows as market reading for business development. For a ruling on a specific building, ask a lawyer or the national energy agency.

What the EPBD recast requires, and what each country decides

The recast entered into force on 28 May 2024, and member states had until 29 May 2026 to transpose it into national law (Directive (EU) 2024/1275 on EUR-Lex). A directive binds governments. The building owner you want to sell to is bound only once their own country writes the rules into its law.

Before that, the owner of a drafty 1970s office block has a news story. After it, that owner has a threshold to meet and a date to meet it by.

The deadline has passed. Whether a given country finished its law on time is a separate question, and the answer can change after this article is published. Before you size a market, check the national measures listed against the directive on EUR-Lex, or call the national energy agency and ask what is in force.

The national plans are not final yet either. On 14 July 2026, the European Commission published its first assessment of the draft National Building Renovation Plans. The assessment is meant to help countries refine their drafts. Final versions are due by 31 December 2026.

The split between the two levels is simple. EU law fixes the shape: two renovation tracks, the target years, the percentages and the duty to write a national plan. National law fills in what a real project depends on. It sets the energy line that marks a building as worst-performing, the measures, the funding and the buildings left out.

The revised EPBD requires each member state to identify the worst-performing slices of its own non-residential stock, measured against the start of 2020, according to the World Green Building Council's 2024 factsheet. An office in the bottom slice of one country's stock can clear the line in another country, because each line is measured against a different stock.

Here is what a national line can look like. The Dutch rule below predates the recast, but it shows the kind of hard number to expect. The Dutch government states that every office building in the Netherlands larger than 100 m2 must have at least energy label C. Under that label, an office may use at most 225 kWh per m2 of primary fossil energy per year. That is a hard number a prospect can check against their own building.

A cross-border pitch built on the EU percentages alone will miss.

Which buildings face renovation first?

Offices, schools, hotels and warehouses get a dated standard

The non-residential track covers offices, shops, hotels, warehouses, schools, hospitals and the rest of the non-domestic stock.

This is the most predictable demand in the whole text. An owner whose building sits below the national line is the one buyer here with a real deadline. That date does not stay on paper. In the years before that date, I expect it to show up as a budget line first, then a survey, then a tender.

Homes follow a national average

The residential track works differently. Each country sets a trajectory for its housing stock, with milestones in 2030, 2035, 2040, 2045 and 2050 (the directive on EUR-Lex). The targets are averages across the stock, so no single house gets an EU date.

Countries choose the homes and the measures, with one limit: at least 55% of the drop in average primary energy use has to come from renovating the worst-performing buildings (Commission EPBD overview). Residential work will reach contractors through national programs: grants, loans or rules for certain types of housing. Two countries with the same target can produce very different work.

The order in which demand arrives

So the dated track comes first, and home work follows whatever speed each national program funds.

If your firm can do both, my advice is to spend sales effort on the dated track now. Keep the home track on a watch list until your country's program has a budget behind it. A comparable date-driven list exists outside the EU too: US cities set building performance standards, and the owners who miss them form a similar target list.

What do national building renovation plans decide?

The National Building Renovation Plan is where the directive turns into a national program. Every member state has to produce one under Article 3. The plans replace the long-term renovation strategies that countries wrote under the old rules. The Commission's page on national building renovation plans calls the new plan a fully operational planning tool.

Draft plans were due by 31 December 2025 under Article 3 of the directive. The Commission gives feedback within 6 months of a draft, and the final plan is due by 31 December 2026 (European Commission, National Building Renovation Plans).

Submitted plans are published on that Commission page. I am not listing here which countries have filed, because that list goes stale quickly. The Commission page is the live record. If your target country's draft is missing, do not build a sales plan around it yet.

A plan has four parts, and each tells a contractor something different.

Building stock overview. Where the worst buildings sit, what types they are and roughly how many there are. This is your market map.

Roadmap with targets for 2030, 2040 and 2050. The pace. A country with a steep 2030 step creates work sooner than one that loads its effort into later decades.

Policies and measures. The mechanism. A mandate creates owners who must act. A grant creates owners who can act. You run a different sales conversation with each.

Investment needs and financing sources. Who pays. Public money usually ends in a tender, while private money often waits for a bank to approve the spend.

The EPBD timeline at a glance

Read the table one country at a time. Starting buildings differ by country, a draft can change before the final version, and budgets, tenders and owner decisions all come after the law.

Who buys renovation work under the EPBD?

The buyer is the building owner, and the owner type decides the whole sales motion. For the non-residential stock, I would sort owners into groups like these:

1. Regional and local government estates, from town halls to administrative offices
2. School and university estates
3. Hospital and health estates
4. Office landlords and property funds
5. Logistics and warehouse owners
6. Hotel groups and retail landlords

The directive does not tell you how big each group is in your country, and I have no reliable cross-country figure to give you. Before you commit, size the pool of owners for your building type and country yourself. For one building type in one country the number is often smaller than founders expect.

Then pick one group. A pitch written for "anyone affected by the EPBD" reaches nobody in particular. The rule I give every B2B founder is one offer for one audience, kept for 12 months. For a retrofit firm, that means one building type with one owner group, such as school estates or private office portfolios, until you are the obvious specialist.

Pick that group from your own records. Go back through finished projects and check who made the final call. Start with the owner group whose people signed your last contract.

If homes are your work, the buyer is often a social landlord. How suppliers win housing association work covers how those landlords buy and what they check before awarding a contract.

The person who signs is rarely a generic "manager". On a renovation program I expect at least two roles: the one who owns the building problem (head of estates, director of property services, asset manager, facilities director) and the one who owns the budget. A sustainability lead may shape the brief, but rarely signs it.

Owners check you before they answer. Identical wording has drawn 2% replies for one company and 7.5% for another in our campaigns. The difference sat in who was sending, and what the buyer found when they checked. So I check the sender before I touch the wording.

The estates team opens your website, then your case studies, then the LinkedIn profiles of the people they would meet. Your project director and estimator get checked as well, so their profiles should read like references, with building types, sizes and dates. A plain message from someone with a solid profile will beat a polished one from a name with an empty page.

Speed differs by owner. Public owners plan through budgets and procurement, so their intentions show up early in public documents and then move slowly to tender.

Price shocks act as triggers too. A 2023 fi-compass factsheet found that the jump in energy prices from 2021 pushed Polish public bodies toward energy performance contracting (a contract where the provider guarantees the energy savings and is paid out of them), to get outside financing and guaranteed savings. But the same factsheet points to regulatory uncertainty over how to procure these contracts and how to treat them on public balance sheets. Interest came fast. Tenders did not.

Private owners act when something forces the decision: the threshold date, a sale, a refinancing or a tenant who asks. Some move early to protect a building's value. Others wait until the last season.

Where do renovation opportunities show up first?

Most of the early signal sits in documents, long before a tender exists. The draft plan's stock overview tells you which building types each country considers worst. The transposing law gives you the threshold and the date. Public owners' budgets and capital programs show which estates have money set aside for upgrades.

The directive names no project types, but it points at a very old stock. BUILD UP, the European Commission's buildings portal, reports that on average 75.4% of the building stock in EU member states was built before 1990.

A 2022 guidebook from IMT and BPIE put the energy-renovation rate at about 1% a year, with deep renovation at 0.2%. Both figures are dated, but the Commission's EPBD overview still puts the annual energy renovation rate at 1%. That gap between an old stock and a slow renovation pace is what the new standards are meant to close.

A typical sequence looks like this. An owner first needs condition and energy surveys across the portfolio to learn which buildings sit below the line. Design and phasing plans follow, spreading a retrofit across several budget years. Then come phased retrofits of occupied buildings, from envelope and heating systems to controls.

A public owner with many old buildings may bundle them into one procurement. If you sell surveys, you get in first, and you will already know the portfolio when the retrofit gets scoped. That is a cheap place to start a relationship with an estates team.

How do you reach the owners who have to act?

When one national threshold defines the market, that threshold is the trigger for every owner below the line. I do not go hunting for extra signals.

Intent data (signals that a company is researching a topic right now) earns its place only when the addressable market is large. Say a segment has 1,200 target companies and intent signals appear on only about 8 of them. I skip intent data there and write one offer for the whole list. Outbound for a small market covers that approach in more depth.

The math keeps expectations honest. Reply rates usually sit around 1%, and closer to 0.5% at very high volume. Of the people who reply, 10% to 50% book a meeting. Those are ranges, and the bigger the volume, the lower the averages.

When a campaign is tightly targeted and heavily personalized, our reply rates have reached 15% to 17%, with about 75% of repliers interested. For a contractor, personalized means three things in the message: the owner's building type, the national threshold that applies to it, and one finished project that looks like theirs.

Channel choice depends on the country. LinkedIn is where we find the real titles and reach them. In Germany, Austria and Czechia, cold email to owners needs a compliant basis, which is why those conversations start on LinkedIn.

Estates directors are busy. Plan 5 or 6 touches across channels, with real gaps between them. Do not stop after the second touch. The follow-up that usually works best for us is the third one, once real time has passed since the last.

Then plan for the wait. A renovation program is a large purchase. Sales cycles of 6, 9 or even 12 months are normal. A meeting can land in the first 30 days of a campaign, while the contract that grows from it may take 4 months or longer. Booking a meeting and winning the contract are separate jobs, so judge the first quarter on the conversations you started.

What should the first message say?

Here is an illustration with invented names, written for a contractor that retrofits occupied offices.

Subject: Your older offices and the new threshold

Hi Petra,

Once the national renovation threshold for offices is set, someone on your team will have to decide which buildings in your portfolio go first, and in what order.

We survey and phase retrofits of occupied office buildings: envelope, heating and controls, floor by floor, with tenants in place. Our last one: [building type, size, months on site].

Would a 20-minute call help, to look at which of your older buildings are most exposed and what a phased plan could look like?

Tomas

The message has one job: to sell the meeting. Swap in your own building type and add one real project with its size and timing. Keep the directive to a single line. The owner cares far more about why you than about what Brussels decided.

Should you track a country now or wait?

Work through these in order:

1. Sort your finished projects by building type and country. Past and current clients come first, then owners that look like them.
2. Pick one or two countries where you already have references, crews and permit experience. Treat this step as part of how you pick a market before any outreach.
3. Read the draft renovation plan there, using the four parts above.
4. Read the transposing law for the threshold, the dates and who enforces them.
5. Map the owner group with the oldest stock in your building type, plus the titles that sign.
6. Write one case study for that owner group with building type, size, timeframe and outcome.

Then apply a simple rule. Track the country now if all of these are true:

1. Its draft plan or national law names thresholds or building types you already work on
2. You have at least one finished project of that type in that country
3. You can name the owner group and the job titles that sign

If any one is missing, put the country on a watch list and come back when its final plan is published.

The law gives every owner below the line a date. Your job is to be the firm they already know when that date starts to bite. Start with the owners whose date comes first.

If you retrofit buildings and want a second opinion on which country to track first, book a call and bring your list of finished projects. I will tell you where I would start.