Analysis of the shortfall in primary energy savings under the EU Energy Performance of Buildings Directive (EPBD)
Analysis of Potential Shortfalls in Primary Energy Savings in the Residential Building Sector in Accordance with the Provisions of Article 9 (2) of the EU Energy Performance of Buildings Directive (EPBD) in the Building Modernization Act
Client
Deutsche Umwelthilfe
Duration
April 2026 – May 2026
Background
The Energy Performance of Buildings Directive (EPBD) is a key component in achieving the goals of the Federal Climate Protection Act (KSG) and, consequently, climate neutrality in the building sector. The EPBD requires member states to systematically improve the energy efficiency of their building stock and significantly reduce energy consumption. To measure this progress, the EPBD establishes the average primary energy consumption of the residential building stock as a key indicator. Article 9(2) defines a binding reduction pathway for this: by 2030, a reduction of at least 16% compared to 2020 must be achieved, and by 2035, at least 20–22%.
The EPBD must be transposed into national law by May 29, 2026. In Germany, according to the key points presented in February, this is to be achieved through the planned Building Modernization Act (GMG). However, the currently known key points raise doubts as to whether the planned measures will be sufficient to meet the European requirements. For instance, the plan is to eliminate the previously applicable 65% target for renewable energy when replacing heating systems in both new and existing buildings. Instead, a phased “bioenergy pathway” for newly installed gas and oil heating systems, as well as a green gas quota for gas networks, are to be introduced. This would allow for the continued installation of fossil fuel heating systems. Furthermore, the policy paper does not include any binding, building-specific renovation requirements for residential buildings, which could make it even more difficult to achieve the targets.
Goals and Results
whether the proposed regulations are suitable for achieving the required reductions in average primary energy consumption in the existing residential building stock, and
whether the necessary focus on the buildings with the poorest energy performance is ensured.
On this basis, an assessment will be made as to whether a failure to meet targets—and thus a potential conflict with the European legal framework—is to be expected.
