Exemplary role of public buildings: What’s new in the new Energy Efficiency Directive (EU)2023/1791

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Summary

A significant and cost-effective potential

Overall, the European Commission (2021) assessed that public buildings would represent about 2% of EU’s total final energy consumption. The share of publicly-owned buildings among non-residential buildings was estimated to vary broadly among EU Member States, from about 10% (in Greece) up to about 90% (in Estonia) (BPIE 2011).

Energy efficiency improvements in public buildings have been shown to be cost-effective: based on data from 1543 projects done in public buildings and entered in the DEEP database¹ as of March 2025, the median payback time of energy efficiency investments in public buildings would be about 7 years. The median payback time per type of investment goes from less than 4 years for improvements in lighting, up to about 10 years for improvements in the building envelope. The median avoidance costs (average cost in Eurocent for each kWh energy saved over the lifetime of the measure) of energy efficiency projects is about 1.9 c/kWh, which is also the same rate as assessed for integrated renovation. The highest median avoidance cost was found about investments in HVAC (Heating, Ventilation and Air Conditioning) systems: 4.2 c/kWh.

An exemplary role enforced with a specific renovation obligation strengthened in the new Energy Efficiency Directive

The first Energy Efficiency Directive (2012/27/EU) introduced, in its Article 5, an obligation for Member States to renovate 3% per year of the total floor area of central government buildings larger than 250 m² and not yet meeting minimum energy performance requirements. Member States could choose to implement an alternative approach delivering an equivalent amount of energy savings in buildings (e.g. with energy management and behavioural measures). Central government buildings would represent about 10% of all public buildings. The 2012 EED then required Member States to encourage the other public bodies, especially at regional and local level as well as social housing bodies, to adopt an energy efficiency plan, implement an energy management system, and where appropriate use energy services for energy efficiency improvements.

The new Energy Efficiency Directive (EU)2023/1791 has strengthened these provisions, now in Article 6: (1) the scope of the 3%/year renovation obligation is extended to all buildings larger than 250 m² and owned by a public body; and (2) the required depth of renovation is clarified and should achieve at least nearly zero-energy buildings or zero-emission buildings. The related energy savings potential was assessed by the European Commission (2021) to be about 2.6 Mtoe/year by 2030.

Member States may still use an alternative approach to deliver an equivalent amount of energy savings. In addition to monitoring the energy savings achieved, the use of an alternative approach now also requires introducing a renovation passport for buildings representing at least 3 % of the total floor area of buildings owned by public bodies, with the aim to renovate them to nearly-zero energy buildings by 2040.

Renovating public buildings contribute to broader energy efficiency objectives

The obligation for renovating public buildings is expected to be one of the key measures to achieve the umbrella energy efficiency target for the public sector set in Article 5 of the new Energy Efficiency Directive (EED): reducing total final energy consumption of all public bodies by at least 1,9 % each year (vs. 2021 level).

Renovating public buildings can also contribute to the achievement of Member States’ energy savings obligation (now Article 8 in the new EED).

It is also related to provisions of the new Energy Performance of Buildings Directive (EPBD, (EU)2024/1275). The new EPBD (Article 3) has replaced the former long-term renovation strategies (LTRS) with national building renovation plans (NPRB), with the objective to transform existing buildings into zero-emission buildings by 2050. These plans shall address public buildings, as a specific segment of the building stock. Moreover, Article 9 of the new EPBD requires Member States to establish minimum energy performance standards for non-residential buildings (which includes public buildings). 

The new EPBD includes provisions stressing the exemplary role of public buildings:

• New buildings shall be zero-emission buildings from January 2028 (vs. January 2030 for all new buildings) (Article 7)
• Buildings owned or occupied by public bodies must issue an Energy Performance Certificate (displayed in a prominent place clearly visible to the public) (Articles 20 and 21)
• Existing public buildings to install solar energy, with a progressive approach that starts in December 2027 for the largest public buildings (2.000 m²) and progressively reduces the threshold until December 2030 (250 m²), while for other buildings this is required in case of major renovation or works on the roof (Article 10).

The Renewable Energy Directive (Article 15a(4)) also refers to the exemplary role of public buildings, related to the share of renewable energy they use.

National, regional and local level fulfil an exemplary role as regards the share of renewable energy used. Member States may allow that the renovation obligation set in the EED be fulfilled by, inter alia, providing for the roofs of public or mixed private-public buildings to be used by third parties for installations that produce energy from renewable sources.

Stronger action needed to meet the higher ambition

During the period 2014-2020, Member States had to report annually to their achievements related to the EED, including about the renovation obligation for central government buildings. Most Member States that chose the alternative approach met their obligation, vs. only half of these that chose the main approach (European Commission, 2022).

For the period 2021-2030, the reporting is now included in the National Energy and Climate Progress Reports, due every two years. 

The assessment of the 2023 reporting stressed that “Member States will have to step up their efforts as early as possible in the next years of the obligation period to be able to meet the savings requirement for the whole obligation period ending in 2030” (European Commission, 2023). 

The 2023 reporting included few data on energy use in public buildings. When reported, data showed an increase in public buildings’ final energy consumption in 2021 vs. 2020 in three countries (Denmark, Greece and Hungary), and a decrease in two countries (Croatia and Ireland).

The 2023 reporting and assessment were still about the provisions as set in the EED2012. The challenge is now even bigger, when aiming at improving all public buildings to achieve zero-emission buildings.

Overview of energy efficiency measures for public buildings

A review of the measures in the MURE database as of February 2024 found that out of the 383 on-going measures in the services sector, 226 were dealing with public buildings², including 94 measures specific to public buildings. Four main categories of measures could be identified and are further discussed below.

1) Monitoring and energy management

This is often a first step to improve energy efficiency in buildings. Examples of measures include the deployment or network of energy managers (implemented in Belgium, Croatia, Greece, Malta and Portugal), or requiring public bodies to implement energy management (see table below).

Table 1: Examples of measures specifically about energy management in public buildings

Good practices include:

• Croatia’s energy management information system³, started in 2014, that includes an automation of data collection, an integration with other databases, training of energy managers, the verification of actual energy savings, and the possibility to expand its use beyond the public sector.
• Ireland’s monitoring & reporting⁴, started in 2013, requiring public bodies and schools to report energy performance annually to an information system operated by SEAI, tracking national target achievement, providing public bodies with feedback and benchmarking, and showcasing results to the general public.

Monitoring and energy management is also often a key component in voluntary agreements.

2) Agreements or obligations

Agreements or obligations can take various forms, and cover different scope (from specific segments to the whole non-residential buildings).

Table 2: Examples of agreements or voluntary commitments

Table 3: Examples of obligations or mandatory targets for all tertiary buildings

Table 4: Examples of obligations or mandatory targets for public buildings

Good practices include:

• Finland’s Energy Efficiency Agreement for Municipalities⁵, started in 2008, providing municipalities with technical support when they commit to voluntary energy savings targets, implementing an energy audit, defining an action plan and monitoring their actions and achievements.
• Netherlands’s Minimum Energy Performance Standards for offices⁶, adopted in 2018, and requiring office buildings to be C-class or better by 2023, and a compliance of 77% of the office areas by January 2024.

3) Dedicated body or national roadmap

A more structural measure can be to establish a body in charge of coordinating the improvement of public buildings, or to set a roadmap for public buildings.

Slovenia established in 2015 the Project Office for Energy Renovation of Public Buildings⁷. Developed as part of an Operational Programme, it provides technical support in the selection and implementation of energy renovation projects for State and municipal buildings. It acts as a one-stop-shop for public building renovations, facilitating experience sharing and replication and dissemination through ‘demonstration effects’.