What has changed for the energy performance certificate since 2026?

What is behind the new rules from 2026?

The legal basis is the revised EU Buildings Directive (EPBD), which requires all Member States to transpose new standards for energy performance certificates and building efficiency into national law. Germany is implementing these requirements via the Buildings Modernisation Act (GModG), which fully replaces the previous Buildings Energy Act (GEG).

The law was adopted by the Bundestag and Bundesrat on 10 July 2026. The provisions that affect energy performance certificates (Article 2 of the GModG) are expected to enter into force in early 2027 – six months after publication in the Federal Law Gazette. For a general overview, please see our guide to energy performance certificates.

The new energy efficiency scale: What changes from 2026?

One of the central innovations concerns the efficiency classes used in energy performance certificates. However, the new scale does not apply equally to all buildings – the distinction here is crucial.

Residential buildings: Scale from A+ to H remains

If you own or let out a flat or a house, nothing changes for now in terms of the efficiency scale. For residential buildings, the familiar scale from A+ to H continues to apply. Aligning residential buildings with the EU‑wide A‑to‑G scale is planned for a future legislative amendment, but is not yet included in the current GModG.

Non‑residential buildings: New EU scale from A to G

For non‑residential buildings – such as offices, retail space, medical practices, warehouses and similar properties – the GModG introduces a new, EU‑harmonised efficiency scale from A to G. Up to now, Germany did not have a standardised classification of efficiency classes for non‑residential buildings.

The new scale makes it possible to compare commercial properties in different EU countries directly – a clear advantage for investors and businesses operating internationally.

The new efficiency scale for non‑residential buildings at a glance

When do you have to present the energy performance certificate?

The obligation to present the energy performance certificate is being expanded under the GModG. The existing duty to present it proactively when selling or newly letting a property remains in place. Two additional situations are added.

Lease renewals: If an existing lease is renewed, owners will, in future, also have to present the energy performance certificate proactively.

Major refurbishments: For larger renovation or refurbishment projects, presenting the energy performance certificate will be mandatory where the works affect more than 25 per cent of the building envelope or costs exceed 25 per cent of the building’s value.

Public buildings – exemption removed: Previously, buildings owned or used by public institutions were exempt from the obligation to present an energy performance certificate. This exemption will be removed in full under the new rules.

What does this mean for owners?

Two aspects are particularly relevant for you as an owner:

Extended obligation to present the certificate: In future, you will need to present the energy performance certificate not only when newly letting or selling a property, but also for lease renewals and major refurbishments. Failure to comply can result in an administrative fine of up to EUR 10,000.

New efficiency classes for non‑residential buildings: If you own commercial property, these assets will be assigned an efficiency class for the first time under the new A‑to‑G scale. This can influence the asset’s value – especially if you are planning a sale or new letting.

What does this mean for buyers and tenants?

For buyers of commercial property, the new efficiency scale increases transparency: properties in different EU countries can be compared directly – a real advantage when acquiring an investment property abroad.

Tenants also benefit: Following major refurbishments, an updated energy performance certificate gives them a clear indication of how the works have affected the building’s energy efficiency.

When do you need a new energy performance certificate? 

Existing energy performance certificates remain valid – the new rules only apply in specific situations. As an owner, you do not need to commission a new certificate as long as none of the following events occur:

• The property is newly let.

• An existing lease is renewed.

• The property is to be sold.

• Major refurbishment or renovation works are carried out.

What stays the same for the energy performance certificate?

Despite the changes, several key rules remain unchanged:

• Validity: An energy performance certificate is still valid for ten years from the date of issue.

• Type of certificate for residential buildings: Owners continue to have a choice between a consumption‑based certificate and a demand‑based certificate.

• Scale for residential buildings: The familiar scale from A+ to H remains in place for residential property for the time being.

• Fines: The level of fines for failure to comply with energy performance certificate obligations has not been adjusted.