---
title: "Public bodies"
description: "Public bodies (EPBD IV): authorities and the entities they directly finance and run, without an industrial or commercial character."
canonical: "https://gencompl.ai/glossary/public-bodies-epbd"
language: "en-US"
type: "Glossary term"
published: "2026-10-14T18:26:32.958Z"
modified: "2026-10-14T19:05:31.164Z"
---

# Public bodies

National, regional or local authorities and entities directly financed and administered by those authorities but not having an industrial or commercial character (Article 2, point (12), of Directive (EU) 2023/1791).

Also known as: overheidsinstantie

**What does "Public bodies" mean under EPBD IV?**

Defined in: [EPBD IV](https://gencompl.ai/regulations/epbd) (32024L1275)

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Public bodies as defined in Article 2, point (12), of Directive (EU) 2023/1791:

> ‘public bodies’ means national, regional or local authorities and entities directly financed and administered by those authorities but not having an industrial or commercial character

## Defined in / by

- [EPBD IV (32024L1275)](https://gencompl.ai/regulations/epbd), Article 2, point (5)

Last updated: 14 October 2026.

## 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.

> **What we could not establish**
>
> Whether an entity has an "industrial or commercial character" is a question of fact the definition does not settle, and the line between a public body and a public company can be close. This entry fixes the term. It does not decide whether the term catches your institution; counsel decides that.

## Questions and answers

### Is a publicly owned company a public body under EPBD IV?

Not if it has an industrial or commercial character. The definition, taken from Article 2, point (12), of Directive (EU) 2023/1791, covers authorities and entities they directly finance and administer, but excludes those with an industrial or commercial character.

### Which EPBD IV duties apply earlier to public bodies?

Zero-emission new buildings from 1 January 2028 (Article 7(1)), solar on existing public buildings from 31 December 2027 (Article 10(3)(b)) and pre-cabling for half their parking spaces by 1 January 2033 (Article 14(2)).

## Sources

- [Directive (EU) 2024/1275 on the energy performance of buildings (recast)](https://eur-lex.europa.eu/eli/dir/2024/1275/oj/eng) (EUR-Lex · 8 May 2024)
- [Directive (EU) 2023/1791 on energy efficiency (recast)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023L1791) (EUR-Lex)
- [Besluit van 21 april 2026 tot wijziging van het Besluit bouwwerken leefomgeving (eerste tranche EPBD IV), Stb. 2026, 103](https://zoek.officielebekendmakingen.nl/stb-2026-103.html) (Officiële bekendmakingen · 7 May 2026)

## Related content

### Regulation

- [Energy Performance of Buildings Directive (EPBD IV)](https://gencompl.ai/regulations/epbd): EPBD IV is Directive (EU) 2024/1275, the recast Energy Performance of Buildings Directive. The Netherlands put its first tranche into force on 29 May 2026 (Stb. 2026, 103), with duties staged to 2033: recharging points in existing car parks from 1 January 2027, solar and lighting control from 1 January 2028. Energy label D by 2030 is still a proposal.