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Regulation

Energy Performance of Buildings Directive (EPBD IV)

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.

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Which EPBD IV duties apply to building owners in the Netherlands, and from when?

EPBD IV is Directive (EU) 2024/1275, the recast Energy Performance of Buildings Directive. Member States had to transpose most of it by 29 May 2026. The Netherlands brought its first tranche into force that day through Staatsblad 2026, 103, an amendment of the Besluit bouwwerken leefomgeving (Bbl) whose parts take effect in stages up to 1 January 2033. For existing commercial buildings the first new duty falls on 1 January 2027: a car park with more than 20 spaces needs one recharging point for every ten spaces, or ducting for half of them.

Energy label D by 2030 for the worst-performing non-residential buildings is not law yet. RVO describes it as an obligation from 1 January 2030, but as at 14 October 2026 it sits in the third Dutch tranche, which the government plans to adopt in 2027. This page labels it Proposed wherever it appears.

Last updated: 14 October 2026. Checked against the Official Journal text of Directive (EU) 2024/1275, the text of Staatsblad 2026, 103, the second-tranche consultation page and the RVO, IPLO and European Commission pages listed under sources.

At a glance

Official title

Directive (EU) 2024/1275 of the European Parliament and of the Council of 24 April 2024 on the energy performance of buildings (recast)

CELEX

32024L1275 · Annex III replaced by Delegated Regulation (EU) 2026/52 on the calculation of life-cycle global warming potential

OJ

OJ L, 2024/1275, 8.5.2024

In force

28 May 2024, the twentieth day after publication (Article 37)

Transposition

By 29 May 2026 for Articles 1 to 3, 5 to 29 and 32 and most annexes (Article 35(1)) · Article 17(15), the end of subsidies for stand-alone fossil fuel boilers, by 1 January 2025

Repeals

Directive 2010/31/EU, with effect from 30 May 2026 (Article 36)

Scope

Addressed to Member States, which place the duties on owners of new and existing buildings · the heaviest duties fall on non-residential buildings and on buildings owned by public bodies

Dutch implementing act

Besluit van 21 april 2026, Stb. 2026, 103, published 7 May 2026 · in force 29 May 2026, with parts from 1 January 2027, 2028, 2029, 2030, 2031 and 2033 (Article IV)

Supervisor (NL)

Municipality or omgevingsdienst for the Bbl building rules · ILT for the energy label at sale, rental and delivery

Further Dutch tranches

Second tranche consulted 29 April to 26 May 2026 · third tranche (minimum standards) planned for adoption in 2027 · fourth planned for 2029 (IPLO, 4 September 2026)

What changes for building owners under the Dutch rules?

The first tranche changes five things an owner of a non-residential building will notice. The before column is the rule as RVO describes it; the after column comes from Stb. 2026, 103 and RVO.

TopicBefore EPBD IVUnder the Dutch EPBD IV rules

Building automation (GACS)

Required from 1 January 2026 for non-residential buildings with heating or cooling above 290 kW

Automatic lighting control added from 1 January 2028 · threshold falls to 70 kW from 1 January 2030

Recharging points in existing car parks

n/a

More than 20 spaces: one recharging point per ten spaces, or ducting for 50% of spaces, from 1 January 2027

Solar energy on existing buildings

No specific duty

Buildings of public bodies above 2,000 m² from 1 January 2028 · non-residential buildings above 500 m² at permit-requiring roof or installation works from 1 January 2028

Energy label for monuments

Exempt

Required in the same situations as other buildings since 29 May 2026

Inspection reports for heating and air conditioning

Stored in the RVO inspection portal

No longer stored there from 1 July 2026; the GACS duty takes over

Who is in scope?

The Directive binds Member States. Its duties reach a business through national law, and in the Netherlands that law is the Bbl. Three groups carry most of the new Dutch duties.

Owners of non-residential buildings (utiliteitsgebouwen): offices, shops, schools, healthcare buildings, hotels and other buildings not used for housing. They carry the car park, building automation, solar-at-renovation and energy label duties, and from 2030 the proposed minimum standard. A bank, insurer or pension fund meets these rules as the owner or user of its offices and as the owner of the buildings it holds as investments.

Public bodies that own buildings. They meet the earliest solar duty (existing buildings above 2,000 m² from 1 January 2028), pre-cabling for half their parking spaces from 1 January 2033 and, under Article 7 of the Directive, zero-emission new buildings from 1 January 2028.

Developers of new buildings. Every new building must be zero-emission from 1 January 2030. New buildings above 1,000 m² need a life-cycle global warming potential figure in their energy performance certificate from 1 January 2028.

Size thresholds decide most cases: more than 20 parking spaces, more than 500 m² for solar at renovation, 290 or 70 kW of heating or cooling capacity for automation. Offices have needed label C since 1 January 2023, unless office use is under 100 m² or under half the floor area (RVO).

Homes are treated differently. Article 9(2) asks each Member State for a national trajectory that lowers the average primary energy use of residential buildings by at least 16% against 2020 by 2030 and by 20 to 22% by 2035. That is a target for the state, not a duty on each home.

What does EPBD IV require?

Six duty sets matter to building owners. Each card names the Directive article and, where one exists, the Bbl article that carries it into Dutch law.

  • Article 10 · Bbl 3.86a

    Solar energy

    Existing buildings of public bodies above 2,000 m² must generate solar energy on the building from 1 January 2028; the threshold falls to 750 m² in 2029 and 250 m² in 2031. Non-residential buildings above 500 m² meet a solar requirement from 1 January 2028 when roof or installation works need a permit. New non-residential buildings meet Article 10(3)(a) through the existing BENG renewable share.

  • Article 14 · Bbl 3.87b, 4.160a

    Recharging points and bicycle parking

    Since 29 May 2026, new or majorly renovated non-residential buildings with more than five spaces need one recharging point per five spaces (per two at offices), pre-cabling for half the spaces and ducting for the rest. Existing buildings with more than 20 spaces follow from 1 January 2027. Bicycle parking for new buildings runs through the municipal omgevingsplan (Bkl 5.131b).

  • Article 13 · Bbl 3.145

    Building automation and lighting control

    Non-residential buildings heated or cooled for people need a building automation and control system above 290 kW of capacity. Automatic lighting control is added from 1 January 2028, and the threshold for both falls to 70 kW from 1 January 2030.

  • Article 19

    Energy performance certificate

    Since 29 May 2026 the Dutch label has a new design, monuments are no longer exempt, a label is required after a major renovation, and every building of a public body and every office needs a valid one. RVO expects a new A to G scale in 2030; Article 19(2) lets states that rescaled between 2019 and May 2024 wait until 31 December 2029.

  • Article 9

    Minimum energy performance standards

    The Directive requires non-residential buildings to be below a 16% threshold from 2030 and a 26% threshold from 2033, measured against the national stock on 1 January 2020. The Dutch proposal sets label D by 1 January 2030 for the worst performers. The 2033 Dutch level has not been set.

  • Article 7

    Zero-emission and life-cycle emissions

    New buildings owned by public bodies must be zero-emission from 1 January 2028 and all new buildings from 1 January 2030. The life-cycle global warming potential goes on the certificate from 1 January 2028 for new buildings above 1,000 m², and for all new buildings from 2030. The Dutch rules sit in the draft second tranche.

The dates

2024

  1. 8 May 2024 · Set by law

    Directive (EU) 2024/1275 published in the Official Journal

  2. 28 May 2024 · Calculated

    Directive (EU) 2024/1275 enters into force

    Article 37: the twentieth day after publication.

  3. 31 December 2024 · Set by law

    Building automation for non-residential buildings above 290 kW (Article 13)

    The Dutch rule applies from 1 January 2026; see that entry.

2025

  1. 1 January 2025 · Set by law

    No more financial incentives for stand-alone fossil fuel boilers (Article 17(15))

    Article 35(1) required this provision to be transposed by the same date.

2026

  1. 1 January 2026 · Set by law (Bbl, as stated by RVO)

    Building automation required in the Netherlands for non-residential buildings above 290 kW

  2. 7 May 2026 · Set by law

    First Dutch tranche published as Staatsblad 2026, 103

    The decree is dated 21 April 2026.

  3. 24 May 2026 · Calculated

    Delegated Regulation (EU) 2026/52 enters into force, replacing Annex III on life-cycle global warming potential

    Published 4 May 2026; in force on the twentieth day after publication (Article 2).

  4. 26 May 2026 · Set by the Ministry of BZK

    Consultation on the second Dutch tranche closes

    It opened on 29 April 2026.

  5. 29 May 2026 · Set by law

    Transposition deadline for Articles 1 to 3, 5 to 29 and 32 (Article 35(1)); new certificate template with a closed A to G scale (Article 19(2))

  6. 29 May 2026 · Set by law

    First Dutch tranche enters into force (Stb. 2026, 103, Article IV(1))

    Recharging points and pre-cabling for new and majorly renovated non-residential buildings, the bicycle parking rule in the Bkl and the energy label changes.

  7. 30 May 2026 · Set by law

    Directive 2010/31/EU repealed; Articles 30, 31, 33 and 34 apply (Articles 36 and 37)

  8. 1 July 2026 · Set by RVO

    Heating and air conditioning inspection reports no longer stored in the RVO inspection portal

  9. 15 July 2026 · Set by the European Commission

    Letters of formal notice to all 27 Member States for incomplete transposition

    Member States had two months to reply.

  10. 31 December 2026 · Set by law

    Solar installations on new public and non-residential buildings above 250 m² (Article 10(3)(a))

    The Netherlands relies on the existing BENG renewable share requirement for these buildings.

  11. 31 December 2026 · Set by law

    Member States submit their first national building renovation plan (Article 3(7))

2027

  1. 1 January 2027 · Indicative: RVO, 23 September 2026

    Second Dutch tranche enters into force

  2. 1 January 2027 · Set by law

    Existing non-residential buildings with more than 20 parking spaces: one recharging point per ten spaces or ducting for 50% (Article 14(2); Stb. 2026, 103, Article IV(2))

    Buildings renovated between May 2024 and May 2026 have until 1 January 2029.

  3. 1 July 2027 · Proposed (draft second tranche)

    Stricter energy performance requirements for healthcare buildings with beds, sports buildings and other lodging functions

  4. 1 July 2027 · Indicative: RVO, 23 September 2026

    Third Dutch tranche enters into force: minimum standards for non-residential buildings

2028

  1. 1 January 2028 · Set by law

    Solar on existing buildings of public bodies above 2,000 m² and on non-residential buildings above 500 m² at permit-requiring works; automatic lighting control above 290 kW (Stb. 2026, 103, Article IV(3))

  2. 1 January 2028 · Set by law

    New buildings owned by public bodies must be zero-emission (Article 7(1))

    The Dutch rule is in the draft second tranche.

  3. 1 January 2028 · Set by law

    Life-cycle global warming potential disclosed in the certificate for new buildings above 1,000 m² (Article 7(2))

  4. 31 December 2028 · Set by law

    Commission reviews the Directive (Article 28)

2029

  1. 1 January 2029 · Set by law

    Solar on existing buildings of public bodies above 750 m² (Stb. 2026, 103, Article IV(4))

  2. 31 December 2029 · Set by law

    Latest date for the new energy label scale in Member States that rescaled between 1 January 2019 and 28 May 2024 (Article 19(2))

2030

  1. 1 January 2030 · Set by law

    Building automation and lighting control above 70 kW (Stb. 2026, 103, Article IV(5))

  2. 1 January 2030 · Set by law

    All new buildings zero-emission; life-cycle global warming potential for all new buildings (Article 7)

  3. 2030 · Set by law

    Non-residential buildings below the 16% threshold (Article 9(1))

  4. 1 January 2030 · Proposed (third Dutch tranche, not adopted)

    Worst-performing non-residential buildings at least energy label D

  5. 1 January 2030 · Indicative: RVO, 23 September 2026

    New Dutch energy label scale from A to G

2031

  1. 1 January 2031 · Set by law

    Solar on existing buildings of public bodies above 250 m² (Stb. 2026, 103, Article IV(6))

2033

  1. 1 January 2033 · Set by law

    Buildings of public bodies: pre-cabling for at least 50% of parking spaces (Article 14(2); Stb. 2026, 103, Article IV(7))

  2. 2033 · Set by law

    Non-residential buildings below the 26% threshold (Article 9(1))

Without an official date

  1. No official date · Indicative: RVO, 23 September 2026

    Dutch minimum standard for non-residential buildings in 2033

    RVO states the national government still has to set it.

Who supervises EPBD IV in the Netherlands?

No single authority supervises the whole Directive. Enforcement follows the instrument that carries each duty.

DutyWho enforcesSource

Building automation (GACS)

Municipality or omgevingsdienst

RVO, GACS

Label C for offices

Municipality or omgevingsdienst, since 1 January 2023

RVO, label C offices

Energy label at sale, rental and delivery

ILT; the owner risks a fine when a valid label is missing

RVO, energy label

Recharging points, solar and lighting control

Not stated per duty; RVO names the municipality or omgevingsdienst as competent authority for the GACS rules in the same Bbl chapter

Our reading

Transposition by the Netherlands

European Commission

Commission, 15 July 2026

What has changed?

15 July 2026. The European Commission sent letters of formal notice to all 27 Member States for not fully transposing the Directive.

1 July 2026. Inspection reports for heating and air conditioning no longer go into the RVO inspection portal.

29 May 2026. The first Dutch tranche entered into force on the Directive's transposition deadline.

26 May 2026. The consultation on the second Dutch tranche closed. It covers zero-emission new buildings for public bodies, the life-cycle calculation for new buildings above 1,000 m² and stricter insulation requirements.

24 May 2026. Delegated Regulation (EU) 2026/52 entered into force and replaced Annex III, the Union framework for calculating life-cycle global warming potential.

7 May 2026. Staatsblad 2026, 103 was published, three weeks before the transposition deadline.

Check your buildings against the Dutch thresholds

Book a working session and we will test your buildings against the Bbl thresholds and dates, naming the article and the source for each conclusion.

Book a working session

Questions and answers

Does EPBD IV apply directly to my company?

No. EPBD IV is Directive (EU) 2024/1275 and binds Member States, not companies. In the Netherlands its duties reach building owners through the Besluit bouwwerken leefomgeving, amended for the first tranche by Staatsblad 2026, 103, which entered into force on 29 May 2026.

Does my office need energy label D by 2030?

Not under current Dutch law. RVO describes label D by 1 January 2030 for the worst-performing non-residential buildings, but as at 14 October 2026 that rule sits in the third Dutch tranche, planned for adoption in 2027. Offices already need at least label C, which municipalities have enforced since 1 January 2023.

Do I have to install recharging points in an existing car park?

Yes, if the car park belongs to a non-residential building and has more than 20 spaces. From 1 January 2027 the Bbl requires one recharging point for every ten spaces, or ducting for at least half of them. Buildings renovated between May 2024 and May 2026 have until 1 January 2029.

When does a non-residential building need building automation?

In the Netherlands, non-residential buildings with heating or cooling above 290 kW have needed a building automation and control system since 1 January 2026, according to RVO. Automatic lighting control is added from 1 January 2028, and the threshold falls to 70 kW from 1 January 2030 under Staatsblad 2026, 103.

Are solar panels mandatory on existing commercial buildings?

Not in general. From 1 January 2028 a non-residential building above 500 m² must meet a solar requirement when it undergoes roof or installation works that need a permit. Existing buildings of public bodies face a direct duty from 1 January 2028 above 2,000 m², 2029 above 750 m² and 2031 above 250 m².

Who enforces the EPBD IV rules in the Netherlands?

The municipality or the omgevingsdienst enforces the building rules in the Bbl, such as building automation and the label C office duty. The ILT checks that a valid energy label is present at sale, rental and delivery of a building, and the owner risks a fine when it is missing.

Did the Netherlands transpose EPBD IV on time?

Partly. The transposition deadline was 29 May 2026, and the first Dutch tranche entered into force that day, but the second, third and fourth tranches follow between 2027 and 2030. On 15 July 2026 the European Commission sent letters of formal notice to all 27 Member States for incomplete transposition.

What happens to my current energy label?

It stays valid for its term. The Directive requires a closed A to G scale, but lets Member States that rescaled between 1 January 2019 and 28 May 2024 postpone until 31 December 2029. RVO expects the new Dutch scale, without the A+ to A++++ classes, in 2030.