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Current Status of the Legislative Process

EU Energy Performance of Buildings Directive – What is changing?

Objectives and key proposals of the Directive


The aim of the Energy Performance of Buildings Directive is to improve the energy efficiency of buildings, reduce energy consumption and dependence on imported energy, and drive Member States towards a zero-emission building stock by 2050. The national renovation plan will show how the existing building stock will be brought into compliance by 2050.

For non-residential buildings, minimum energy performance requirements are being introduced for the 2030s, which may lead to a wave of demolition or renovation of these buildings.

The Directive must be transposed by 29 May 2026. However, the new energy performance requirements will apply to buildings owned by public authorities from the beginning of 2028, and to all buildings from the beginning of 2030. Under current legislation, “nearly zero-energy buildings” and the new “zero-emission buildings” (ZEB) will therefore coexist for several years. Energy performance assessment will continue to be largely based on calculation exercises.

A “zero-emission building” is defined in Annex I of the Directive as a building with very high energy performance, very low or zero energy demand, no on-site carbon emissions from fossil fuels, and overall very low or zero greenhouse gas emissions from building operation. Zero-emission buildings consume at least 10% less energy than current nearly zero-energy buildings.

Implementation in Finland in 2026

Although the Government Programme states that the Directive will be implemented with minimal changes to existing legislation, significant changes will still be introduced.

The Building Act will receive a second amendment package (“fine-tuning package”), which will incorporate new energy performance requirements at statutory level (updating the definition of nearly zero-energy buildings, defining zero-emission buildings, etc.) and provide necessary authorisations for secondary legislation. In summer 2025, the Ministry of the Environment circulated three draft regulations for consultation:

  • Ministry of the Environment Decree on the energy performance of zero-emission buildings
  • Ministry of the Environment Decree on improving the energy performance of buildings in renovation and alteration works
  • Government Decree on energy performance factors for buildings

The regulations can be issued once the amendments to the Building Act have been approved. The content described here is based on draft versions.

A completely new Act on the Energy Performance of Buildings will also be required. In addition, amendments are underway to regulations on energy certificates and on charging infrastructure and technical building systems. Changes will also be made to the Building Act’s carbon-related provisions and the climate report decree. The preparation of the national renovation plan required by the Directive is also ongoing at the Ministry of the Environment, aiming for a highly energy-efficient and carbon-free building stock by 2050.

Zero-emission new buildings

New buildings (and extensions) must be zero-emission after the transition period. The requirements will not apply to buildings with a useful floor area under 50 m², industrial and workshop buildings, defence buildings, or unheated buildings. There are also limitations regarding holiday homes, temporary buildings, agricultural buildings, and protected buildings.

A regulation will require calculation of annual greenhouse gas emissions from building operation, annual consumption of renewable and non-renewable energy (purchased energy and on-site consumption), and on-site renewable energy production and waste heat recovery. Calculation rules will be defined for all of these. Renewable energy may also be produced off-site, for example through energy communities.

Compared to previous regulation, some tightening is introduced: ventilation will be included in purchased energy calculations, airtightness requirements will be tightened, and airtightness testing will become mandatory in most projects.

Zero-emission renovation

The regulation is largely similar to the existing decree on improving the energy performance of buildings in renovation and alteration works, but some performance requirements (e.g. window U-values and heat recovery efficiency) are tightened to meet the Energy Performance of Buildings Directive requirements. Flexibility will still be allowed based on technical, functional, or economic feasibility.

Energy performance factors

The new regulation replaces the current decree on energy performance factors for buildings (788/2017). The factors for nearly zero-energy buildings remain unchanged, while new factors for zero-emission buildings are introduced in line with the Directive. Separate calculations will also be introduced for renewable and non-renewable primary energy.

A key change is that, due to the increasing greenness of Finnish electricity production, electricity weighting factors will be reduced. Otherwise, the relative structure of the factors remains similar, favouring district heating and renewable energy. In residential design and energy performance calculations (E-number), air-source heat pumps can be better utilised alongside electric heating.

Energy performance of existing buildings and solar energy requirements

The Directive introduces energy efficiency obligations for existing buildings, implemented through a new Energy Performance Act.

From 31 December 2030, energy certificate E-values for office, commercial, accommodation, educational, sports, and hospital buildings must not exceed reference values for each building category. Requirements will tighten further by 31 December 2033. Authorities may grant exemptions based on energy performance requirements, but cost-effective measures should still be implemented.

Certain building categories (including new buildings, covered parking areas, public buildings over 250 m² ground-floor useful area, and other buildings over 500 m² undergoing major renovation) will be required to install solar energy systems where technically, functionally, and economically feasible. Obligations will be phased in between 2026 and 2030. Exemptions are possible, but justification must be provided upon request.

Automation and charging infrastructure amendments

Building automation systems must in future continuously monitor indoor environmental quality. The obligation for non-residential buildings remains largely unchanged, but lowering the threshold for heating and cooling system nominal power to 70 kW will bring many additional buildings into scope from 1 January 2029.

These buildings must also be equipped with zone-based automatic lighting controls with occupancy detection.

Charging point obligations will expand, including requirements for pre-installation (cabling and conduits) for future electrification. Minimum bicycle parking requirements will also be introduced.

Energy performance certificate reform

The energy certificate content will be expanded and the E-number calculation will change. New energy classes A0 and A+ will be introduced. A voluntary renovation passport will be added.

The certification obligation will extend to protected buildings and holiday homes used for more than four months per year. Energy certificates will also be required in permitting for major renovations and significant extensions.

Remote assessments (e.g. via video) will become possible in some cases. A simplified update procedure will be introduced for targeted building modifications. However, this will not extend the validity period of the certificate.

Changes to low-carbon construction regulation

The obligation to prepare a climate report will be extended. From 1 January 2030, it will apply to detached houses and other buildings up to 1,000 m²; for larger buildings, it will apply from 2028. The obligation does not apply if an energy certificate is not required.

The climate report decree will be updated to include emissions from building maintenance, upkeep, and renovation. Carbon handprint calculations will also include energy recovery from building materials.

In addition, data obtained under EU regulations (Construction Products Regulation, Ecodesign Directive and Regulation, and Energy Labelling Regulation) will take precedence over national emission databases or other general methodologies in low-carbon assessments.

Other Amendments to the Building Act

Amendments to the Building Act’s penalty provisions are proposed due to developments in EU legislation. The proposal would introduce sanctions for intentional or grossly negligent breaches of the EU Construction Products Regulation, including fines for construction offences and the possibility of confiscation of criminal proceeds. In addition, failure to comply with obligations under Section 37 of the Building Act (energy efficiency requirements) would also be made punishable in connection with the implementation of the Energy Performance of Buildings Directive (EPBD).

To implement the RED III Directive, the minimum share of renewable energy in buildings would be increased from 38% to 52% of consumed energy.

Certain technical provisions from the Land Use and Building Decree (895/1999) would be elevated into law. These include regulations on building distances, determination of building height, maximum roof pitch, minor deviations, fences, and provisions on exemption permits, as well as selected procedural rules for construction control.

The proposal also includes two corrections to the Building Act:

  • The wording of one sentence in the provision on building permits would be amended (…repair measures may endanger the health or safety of the building…), lowering the threshold for requiring a permit to the level intended by the Parliamentary Environment Committee.
  • The transitional provision on qualification requirements for design tasks would be amended so that also civil engineers and engineers with suitable qualifications would be eligible for exceptionally demanding design tasks.

Additionally, to implement RED III, the minimum share of renewable energy would again be increased from 38% to 52% of the energy consumed in buildings.

Short-term Rentals

The amendment proposal to the Building Act was circulated for consultation in early 2025 and has since been revised based on feedback. According to the updated proposal, a residential investment property located in a zoned area could be rented for periods of less than 28 days for a maximum of 90 days per calendar year without a permit.

A municipality could, for reasons such as tourism needs or other considerations, decide that a maximum rental limit of 180 days per year applies in certain or all zoned areas.

A permanently occupied home could be rented without restriction, as could holiday homes and properties in rural areas. However, the proposal would not change provisions on building use classification or change of use, meaning that a substantial change of use (e.g. to accommodation use) would still require a building permit.

Monitoring of rental days would primarily rely on self-monitoring: short-term rental operators would be required to keep a log of rental days, which must be presented to building supervision authorities upon request.

A reform of the Housing Companies Act is also underway at the Ministry of Justice, aiming to improve mechanisms for addressing disturbance situations in housing companies.

Permitting Pathway for Defence-Related Production Facilities

A fast-track permitting process, similar to that used for clean transition projects, is being developed for production facilities important to national defence. In practice, a statement from the Defence Forces would determine whether a project qualifies for the fast-track procedure and whether public access to information is restricted for security reasons.

In addition to explosives factories, this may include facilities such as drone manufacturing plants, border security-related projects, or factories producing construction products needed for fortification works.

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