The EPBD on the horizon #9. New energy performance classes for buildings.
By 29 May 2026, all European Union member states, including Poland, must adapt their regulations on energy performance certificates for buildings. The new regulations introduce a unified energy classification from A to G. Poland is already working on legislation to implement these changes.
What will the new requirements look like and what do they mean for the real estate market in Poland?
According to the EPBD, energy performance certificates will have to use a classification from letter A to G, where:
- class A corresponds to zero-emission buildings,
- class G covers buildings with the worst energy performance.
However, there is an exception: if a Member State has previously labelled zero-emission buildings as “A0”, it may continue to use this label instead of class A. In addition, Member States may grant buildings the class A+ if their energy demand is at least 20% lower than the maximum level for zero-emission buildings and they generate more renewable energy on site per year than their total annual primary energy demand.
The EU legislator also provided for the possibility of postponing the change of the energy performance classes scale until the end of 2029 for Member States that changed the energy performance classes class scale between 1 January 2019 and 28 May 2024, adapting national legislation to the previous EU rules in this regard.
How will Poland implement the new regulations?
Legislative work is currently underway on a new act on the energy performance of buildings and a new regulation on the methodology of determining the energy performance of a building or part of a building and energy performance certificates. These are the legal acts that will define the new classification and requirements for individual energy classes.
According to the draft regulation, published last month, energy classes ranging from A+ (best) to G (worst) would apply in Poland. The division would be based on two indicators, expressed in kWh/(m2·year), i.e:
- the non-renewable primary energy demand indicator EP,
- the net delivered energy demand indicator ED, i.e. the difference between delivered and exported final energy.
The projected limit values of both indicators, which enable energy classification, vary considerably depending on the type of buildings, which include:
- single-family residential
- multi-family residential
- collective residential
- public buildings – healthcare, and
- public buildings – other (e.g. office buildings),
- commercial, storage and production buildings.
For example, for an office building to achieve the energy class A will require EP and ED indicators to be met at levels of no less than respectively: 108 and 45. In the case of multi-family housing, class A will be at levels no lower than: 63 (EP) and 53 (ED). In addition, A+ and A classes will be reserved for buildings that do not emit CO₂ on-site as a result of burning fossil fuels.
However, it should be borne in mind that both the new act on energy performance and the regulation are at the draft stage of legislative work, and we will only know their exact wording in a few months or so.
Impact of new legislation on the real estate market
New requirements for the energy performance of buildings may significantly affect the Polish real estate market. First of all, they may indirectly lead to the necessity of modernising older buildings to bring them up to the new standards. In addition, it is likely that investors will try to achieve the highest possible energy classes for new developments, which may increase construction costs.
On the other hand, buildings that meet the new standards are likely to gain in value, attracting more interest from potential buyers and tenants. Despite the need for more money at the initial investment stage to improve energy efficiency, this is likely to result in significant savings in running costs in the long term.
The introduction of the A+ grade has the potential to increase the use of renewable energy sources, which will accelerate the energy transition in the real estate sector.
In conclusion, in the long term, the new regulations can contribute to reducing energy consumption and greenhouse gas emissions, benefiting both the environment and the residents and users of the facilities.
If you have any questions, please feel free to contact our experts:
Katarzyna Koszel-Zawadka
Partner | Attorney-at-law
Piotr Nowak
Junior Associate
