EPBD ‘green homes’ directive: what changes for commercial and non-residential buildings

The European Energy Performance of Buildings Directive, EPBD (EU) 2024/1275, is known in Italy as the ‘green homes directive’. The name is misleading, because the part likely to have the most immediate impact is not about homes: it concerns offices, shops, hotels, healthcare facilities, schools and industrial buildings.

For those managing commercial properties, there is one practical takeaway. The directive does not require every building to be renovated: it requires building energy consumption to be understood, the worst-performing buildings to be brought out of the lowest-performing segment, and buildings to be equipped with systems that control their technical installations.

In brief:

• It also covers non-residential buildings, with deadlines starting in 2026.
• The two nearest requirements for non-residential buildings are solar installations on new buildings larger than 250 square metres and building-system automation above 70 kW by the end of 2029.
• Minimum energy performance standards target the worst-performing buildings, not every building.
• Italy has not yet transposed the directive: the operational rules will be introduced through national decrees.

What is the EPBD and why does it concern commercial properties?

The EPBD is the directive that sets European energy-performance targets for the building stock, with a view to decarbonisation by 2050. It does not apply directly to property owners: it binds Member States, which must transpose it into national law.
This explains why much of the alarmist coverage has been inaccurate. The directive does not require an owner to start construction work by a specific date: it requires states to achieve measurable results across their building stock, while national legislation determines how.
For non-residential buildings, however, the practical implications are much the same. European targets translate into requirements for new buildings, major renovations, technical systems and equipment, and the relevant deadlines have already been set.

Where does Italy stand?

This is the uncertainty to keep in mind when reading any content on the subject, including this article.
The transposition deadline was 29 May 2026, and Italy reached that deadline without transposing the directive. The national building renovation plan was also still outstanding, even though it had to be submitted by 31 December 2025, leading to the opening of an infringement procedure.
In practice, this means two things. First, the thresholds, exemptions and implementation procedures in Italy will be those established by the transposition decrees, which must be reviewed when they are published. Second, the European deadlines remain the reference point for planning: anyone who waits for the decree before assessing their buildings will end up playing catch-up.

The deadlines that matter for non-residential buildings

The dates are those set out in the directive: national transposition may clarify them, introduce exemptions and define verification procedures.

What does ‘the worst-performing 16%’ actually mean?

This is the most misunderstood point. MEPS do not establish one energy class for every building: they set a relative threshold, calculated against the national building stock existing on 1 January 2020 and measured in kWh per square metre per year.
By 2030, non-residential buildings must move out of the segment containing the worst-performing 16% of the building stock; by 2033, they must move out of the worst-performing 26%. In practice, the requirement affects the least energy-efficient properties first. To know whether a building is at risk, its actual specific energy consumption must be known, not just the class stated on its energy performance certificate (APE).
The energy performance certificate is also changing: the directive provides for a harmonised scale from A to G, with class A reserved for zero-emission buildings and class G corresponding to the least efficient buildings.

What is worth doing now?

While waiting for the decrees, the useful work is not legal work but fact-finding:

• Find out how much energy buildings actually consume. Specific consumption per square metre is the unit used for MEPS and must be calculated from actual consumption. It is also the starting point for an energy audit.
• Record the capacity of technical systems. The 70 kW BACS threshold due by the end of 2029 affects far more buildings than many people realise: it is worth identifying properties above the threshold before the deadline approaches.
• Assess the roofs. Surface area, orientation and load-bearing capacity determine whether a solar requirement will be straightforward or costly, and the assessment takes time.
• Prioritise work by payback period. Deadlines are constraints, not a plan. Measures should still be selected based on their returns, as explained in our guide to energy efficiency improvements.
• Keep the evidence. Historical consumption, completed work and performance before and after interventions will be needed to demonstrate compliance and access incentives.

Sector by sector: where requirements will arrive first

The same requirement has different implications depending on the type of property:

• Offices and headquarters: centralised systems often exceed the capacity thresholds for automation, and company car parks can trigger requirements for charging points. Further reading: how to reduce office energy consumption.
• Retail and shopping centres: many individual outlets are small and often leased. The key issue is understanding who—owner or tenant—carries out and pays for the work, and who maintains the data. Further reading: energy management in retail and in shopping centres.
• Hotels: large floor areas, substantial technical systems and continuous comfort requirements make automation the most practical first step before work on the building envelope. Further reading: energy management in hotels.
• Hospitals and nursing homes: high installed capacity and systems that run continuously. BACS thresholds are easily exceeded, but requirements must be managed without compromising operational continuity or comfort. Further reading: energy management in hospitals and nursing homes.
• Schools and public buildings: often older building stock, making them more exposed to minimum performance standards, although dedicated funding and existing public-sector obligations can help. Further reading: energy efficiency in schools and in public buildings.

Incentives help, but they have their own deadlines

European requirements and national incentives follow separate timelines, and it is worth accounting for both in planning.
The Conto Termico scheme is also open to businesses for work on non-residential buildings, including insulation, efficient lighting and building automation systems, while the new Transition 5.0 Plan also covers interconnected intangible assets such as monitoring software. These measures have their own eligibility windows: anyone planning work only around the directive’s deadlines risks missing the incentive window.

How it fits with certifications and ISO 50001

Three different pathways that largely require the same data.
The EPBD is legislation and concerns building performance. LEED, BREEAM and WELL certifications are voluntary and serve market needs. ISO 50001 is a management system that structures internal processes.
Those who approach them separately end up collecting the same information three times. Those who establish energy-consumption and environmental-condition monitoring once can meet the information needs of all three and will also be prepared when the transposition decrees arrive.

The BACS requirement is the first to affect building systems

Of all the deadlines, the automation requirement is the most tangible for those managing existing buildings, because it does not require changes to the building envelope.
The directive requires non-residential buildings with heating systems above a certain capacity to be equipped with building automation and control systems, where technically and economically feasible: the 290 kW threshold is already предусмотрed, while the 70 kW threshold applies by the end of 2029.
Such a system must be able to monitor and analyse energy consumption, detect losses in system efficiency and allow controls to be adjusted. These are the functions of a BMS, which can now also be provided for medium-sized and small buildings through lighter cloud-based solutions, as explained in our article on BMS and building automation.

The tools: compliance and savings rely on the same data

Everything the directive requires organisations to demonstrate relies on the same foundation: knowing how much energy each building consumes, how consumption changes over time and under what comfort conditions.
UTwin’s energy management software covers this area: the supply of smart meters and IoT sensors for energy, water, gas and environmental parameters; cloud-based data collection; visualisation on the building model; AI algorithms that detect anomalies; and remote system control based on outdoor weather and occupancy.
For buildings where a traditional BMS does not offer a sufficient return on investment, such as retail outlets, supermarkets, hotels, nursing homes and small premises, the platform works as a light BMS, with CAPEX up to 70% lower. Where a BMS already exists, it integrates with it and enhances its automation capabilities.
The integrated maintenance software (CMMS) tracks maintenance work, providing the documentation needed to demonstrate compliance.

Frequently asked questions

• Does the EPBD require companies to renovate their buildings?

  No, not directly. The directive requires Member States to achieve targets for their national building stock, while transposition legislation determines the obligations and procedures. For non-residential buildings, minimum energy performance standards apply to the worst-performing segment of the building stock, not to every building.

• What are the nearest deadlines for non-residential buildings?

  The nearest deadlines are the requirement for solar installations on new non-residential buildings larger than 250 square metres by 31 December 2026 and, for buildings larger than 500 square metres undergoing major renovation, by 31 December 2027. This is followed by the requirement for automation and control systems above 70 kW by the end of 2029.

• Has Italy transposed the EPBD?

  By the 29 May 2026 deadline, transposition had not been completed, and the national building renovation plan was also delayed. The Italian implementation rules, including any exemptions, will be those established by the transposition decrees.

• What changes for the energy performance certificate?

  The directive provides for a harmonised scale from A to G, with class A reserved for zero-emission buildings and class G for the least efficient buildings, as well as a certificate containing more information that can be compared across Europe.

• What is the relationship between the EPBD and the requirement for automation systems?

  The BACS requirement is set out in the directive itself for non-residential buildings whose technical systems exceed specified capacity thresholds, where technically and economically feasible. It is the measure with the greatest impact on existing buildings because it concerns technical systems rather than the building envelope.

Where to start

The first step costs almost nothing: list the buildings in your portfolio along with their floor area, annual specific energy consumption, heating-system capacity, presence of an automation system and number of parking spaces.
That table already shows which properties will be affected first and which requirements will arrive soonest, turning a directive perceived as threatening into a structured, prioritised action plan.