EPBD 2024/1275: Germany missed 29 May 2026; stricter Energieausweis and 2028/2030 zero‑emission new‑builds

What changed in EU law—and Germany’s missed deadline

Directive (EU) 2024/1275 on the energy performance of buildings (EPBD, recast) entered into force on 28 May 2024. Member States had to transpose it by 29 May 2026, except Article 17(15) on ending subsidies for stand‑alone fossil boilers, which had to be transposed by 1 January 2025. On 15 July 2026 the European Commission sent letters of formal notice to all 27 Member States, including Germany, for failing to fully transpose by the deadline. These proceedings can escalate to the Court of Justice if delays persist.

The recast sets the direction to a zero‑emission building stock by 2050 and introduces: zero‑emission building (ZEB) standards for new buildings; a tighter, harmonised A–G scale for energy performance certificates (EPCs, Energieausweis) with A corresponding to ZEB; disclosure of life‑cycle global warming potential (GWP) for new buildings; national building‑performance databases linked to the EU Building Stock Observatory; and minimum energy performance standards (MEPS) for non‑residential buildings plus renovation trajectories for residential stock. These changes will alter how German homes are designed, sold and advertised over the rest of the decade.

Zero‑emission new‑builds: 2028 and 2030 milestones

Under Article 7, new buildings owned by public bodies must meet the zero‑emission building (ZEB) standard from 1 January 2028; all new buildings must meet ZEB from 1 January 2030. A ZEB has very high energy performance and no on‑site carbon emissions from fossil fuels; remaining energy needs are covered by renewables on‑site or nearby, efficient district heating/cooling, energy communities, or clean electricity from the grid. The directive also pushes solar readiness: new residential buildings must be designed to optimise solar generation and, where suitable and feasible, solar installations are required for permit applications from 1 January 2030.

Germany has now legislated these dates. The Gebäudemodernisierungsgesetz (GModG), published in the Federal Law Gazette on 28 July 2026, introduces §10 (ZEB for all new buildings from 1 January 2030) and §10a (ZEB for new public‑sector non‑residential buildings from 1 January 2028 to 31 December 2029). For buyers of off‑plan units completing after 1 January 2030, this means fossil‑fuel heating in new buildings will not be permitted and developers must evidence compliance with ZEB limits when applying for permits and commissioning.

Energieausweis will tighten: A–G scale, content, databases, controls

By 29 May 2026, EPCs must follow the Annex V template and show the class on a closed A–G scale with A for ZEB and G for the worst performers; the EPC must display the primary energy indicator in kWh/(m²·y). Countries that rescaled between 1 January 2019 and 28 May 2024 may postpone rescaling to A–G until 31 December 2029. The directive mandates national databases for building energy performance with annual data feeds to the EU Building Stock Observatory and an independent control system with sampling checks; EPCs are generally valid for 10 years.

Germany’s law already operates an EPC registry and random checks via DIBt. With the GModG (published 28 July 2026), Germany keeps existing EPC templates through 31 December 2026 and applies updated templates and calculations from 1 January 2027. For non‑residential buildings, Germany introduces an A–G scale from 1 January 2027, with class A reserved for ZEBs. For residential buildings, German EPCs currently still show A+ to H under Annex 10 GModG; a switch to the EU’s A–G may come by 31 December 2029 if Germany relies on the rescaling derogation. EPCs remain mandatory in marketing: German §87 GModG requires the class (and other data) in property advertisements when an EPC exists, with fines up to €10,000 for missing handover or ad‑content obligations.

From 1 January 2028, EPCs must disclose life‑cycle global warming potential (GWP) for new buildings above 1,000 m²; from 1 January 2030 for all new buildings. Expect banks and valuers to request EPC identifiers and GWP disclosures as standard attachments in due diligence.

Renovation rules that will bite: MEPS and trajectories

Article 9 requires Member States to set minimum energy performance standards for non‑residential buildings based on national thresholds that correspond to the worst 16% and 26% of the stock in 2020. All non‑residential buildings must be brought above the 16% threshold by 2030 and above the 26% threshold by 2033, subject to exemptions. For residential buildings, each country must set a national trajectory that reduces average primary energy use by 16% by 2030 and by 20–22% by 2035 versus 2020, with at least 55% of the reduction delivered by renovating the worst‑performing 43% of homes. Countries may set trigger points such as sale or rent to enforce upgrades.

Germany must transpose these MEPS/trajectory rules. Foreign buyers of German offices, retail or logistics should assume additional capex before 2030/2033 if assets sit in the lowest‑performing segments. Landlords should plan for tighter checks on ad compliance and EPC data uploads.

What buyers should do now

- For new‑builds completing after 1 January 2030, require the developer’s ZEB design package (energy demand calculations, on‑site/no on‑site fossil fuel assurance, RES or district‑energy strategy) before signing. Check for solar‑ready design and, where suitable, rooftop PV. - For existing assets, obtain the current EPC and plan for the new A–G scale transition. In Germany, residential EPCs still show A+ to H today; monitor whether Germany uses the EU’s rescaling derogation through 31 December 2029. - Expect EPC identifiers and GWP disclosures to become standard in data rooms from 2028/2030. Banks may condition financing on these. - Advertising a property for sale or rent without the required EPC data is risky. In Germany, breaches can attract fines up to €10,000. Ensure agents include the class and indicator in all ads and hand over the EPC at viewings. - This article is not legal advice. For transactions, instruct a German notary and ask a Gebäudeenergie‑berater or architect to review EPC, ZEB compliance and planned renovations.