Public bodies

The earliest deadlines fall on public bodies

EPBD IV does not write its own definition. It takes the one from the Energy Efficiency Directive, Directive (EU) 2023/1791, so the same set of bodies is caught by both. The test has two branches: authorities at national, regional or local level, and entities that those authorities directly finance and administer. The second branch excludes entities with an industrial or commercial character, so a publicly owned company that trades on the market is not a public body in this sense.

The term matters because public bodies meet the Directive's duties first. New buildings they own must be zero-emission from 1 January 2028, two years before all other new buildings (Article 7(1)). Existing public buildings carry their own solar schedule under Article 10(3)(b), from 2,000 m² by 31 December 2027 down to 250 m² by 31 December 2030. Buildings owned or occupied by public bodies need pre-cabling for at least 50 % of their car parking spaces by 1 January 2033 (Article 14(2)). And where a public body occupies a building that is frequently visited by the public, the energy performance certificate must be on display (Article 21(1)).

The Dutch Bbl uses the term overheidsinstantie. Staatsblad 2026, 103 applies the solar duty to existing buildings owned by an overheidsinstantie above 2,000 m² from 1 January 2028, above 750 m² from 1 January 2029 and above 250 m² from 1 January 2031.