Energy Performance Certificates 2027: What Commercial Property Owners Need to Know Now

From 1 January 2027: Four key changes for commercial property owners

From 1 January 2027, significant changes to the requirements for non-residential buildings are expected to take effect. Commercial property owners should review these developments carefully. Violations of energy performance certificate requirements may result in fines of up to €10,000, while failure to comply with mandatory energy-related upgrades may lead to fines of up to €50,000.

Four key areas are particularly relevant:

• Energy performance certificates: From 1 January 2027, current plans предусматриen that non-residential buildings will require energy demand certificates using the new A–G rating scale. Even a single relevant commercial unit may determine which requirements apply. Existing certificates remain valid for ten years. Energy performance certificates are also expected to become mandatory when contracts are renewed, while the current exemption for listed buildings will be removed.

• Energy performance standards: From 2030, a maximum threshold of 3.5 times the primary energy demand of the reference building is expected to apply. Buildings rated in energy efficiency class G may therefore require additional energy-related improvements and modernisation by 2030.

• Roof renovations: From 2028, roof renovations on existing privately owned commercial properties may trigger an obligation to install photovoltaic systems.

• Building automation: The threshold for mandatory building automation is set to decrease from 290 kW to 70 kW of heating or air-conditioning capacity. Affected existing buildings must comply by 31 December 2029.

Energy demand certificates for non-residential buildings: A focus on building characteristics

An energy demand certificate assesses a building's energy requirements based on its structural and technical characteristics. These include insulation, windows, heating systems, ventilation and air-conditioning technology.

By contrast, an energy consumption certificate is based on actual recorded energy consumption. Its performance indicators are therefore also influenced by how the building is used.

Under the proposed changes, energy demand certificates are expected to become the only permitted certificate type for non-residential buildings. The net room area, as defined by DIN 277, is also expected to become the relevant reference area.

What this means for property owners: Complete documentation of the building envelope and technical systems will become particularly important. Gathering these documents early can simplify the preparation of an energy demand certificate, saving both time and costs.

Energy efficiency classes A to G: Greater transparency for prospective buyers and tenants

A new energy efficiency rating system ranging from A to G is planned for non-residential buildings. The scale is intended to make the energy performance of commercial properties easier to understand at a glance.

For prospective buyers and tenants, this will provide an additional point of reference. However, an energy efficiency rating alone does not provide a complete assessment. The property's intended use, building systems and individual energy performance indicators remain important factors.

When marketing a commercial property, it is therefore advisable to present its energy-related characteristics clearly and ensure that all relevant documentation is readily available.

Energy performance information in property listings: Current and planned requirements

If an energy performance certificate is available when a property listing is published, certain energy-related information must already be included. For non-residential buildings, this primarily covers:

• The type of energy performance certificate

• The final energy demand or actual energy consumption, stated separately for heating and electricity

• The main energy sources used for heating

Additional mandatory disclosures are planned, including the property's energy efficiency class and the date on which the energy performance certificate was issued.

Before publishing a property listing, the energy performance information should be checked for consistency across the certificate, property brochure and advertisement. In principle, responsibility for the accuracy of the published energy information lies with the party commissioning or publishing the advertisement. This is, however, subject to the required data having been correctly provided by the property owner or the issuer of the energy performance certificate. Careful coordination between the owner, property consultant and marketing agent is therefore recommended.

It is also important to establish when any additional requirements take effect and whether transitional provisions apply.

Energy performance certificates when selling or leasing commercial property

An energy performance certificate is generally required when selling, renting or leasing a commercial property, unless a statutory exemption applies. If a valid certificate already exists, a new one does not automatically need to be issued solely because the property is being marketed. Energy performance certificates are generally valid for ten years, provided there are no circumstances requiring an earlier replacement.

Prospective buyers or tenants must be provided with the energy performance certificate, or a copy, no later than the property viewing. Disclosure obligations also apply if no viewing takes place. Following the conclusion of the contract, the certificate or a copy must be handed over.

Reviewing the energy performance documentation should therefore be one of the first steps in preparing a property for sale or lease. This allows sufficient time to obtain missing documents or arrange for a new certificate if necessary.

Checklist: What commercial property owners should review now

Property owners planning to sell or lease their commercial properties can already take steps to prepare their documentation:

• Check validity: When does the existing energy performance certificate expire?

• Compile building data: Is the documentation relating to the building envelope and technical systems complete?

• Document modernisation measures: Have changes to heating systems, windows, insulation or other relevant building components been recorded?

• Verify energy performance information: Are the details in the energy performance certificate, property brochure and advertisement consistent?

• Consider upcoming requirements: Which regulations will apply when the property is scheduled to be marketed?

Keeping documentation accurate, complete and up to date helps streamline preparations and reduces avoidable enquiries during the marketing process.

Sell or lease your commercial property in Hamburg

Are you planning to sell or lease a commercial property in Hamburg? Engel & Völkers Commercial Hamburg supports you throughout the preparation and marketing process.

Contact our team to discuss your property plans.

Sources

• Expert presentation by Jennifer C. Kreibich, ETC Energie- und Thermografie Centrum Hamburg GmbH: “GModG für Gewerbeimmobilien – Nachrüstpflichten und Neuerungen für Nichtwohngebäude” (GModG for Commercial Properties – Mandatory Upgrades and New Requirements for Non-Residential Buildings), dated 22 September 2026.

• Section 80: Issuing and Use of Energy Performance Certificates

• Section 87: Mandatory Information in Property Advertisements

Disclaimer

This article is intended for general information purposes only and does not constitute legal advice. The proposed regulatory changes outlined above are based on the expert presentation dated 22 September 2026 and reflect the information available at that time. The applicable statutory provisions, including their effective dates and any transitional arrangements, shall take precedence.