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public buildings lead — the rules for public owners

EU law gives public buildings an exemplary role: zero-emission first, solar first, renovated faster and measured every year. Here is what applies to municipalities, the State and other public bodies, by when, and what building automation contributes.

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At a glance

Rules for buildings owned or occupied by public bodies

RuleWhat it asksWhenWhat the system contributes
EPBD Art. 7New buildings owned by public bodies are zero-emission buildingsFrom 1 Jan 2028Monitoring and control for zero-emission operation; indoor air quality measuring and control in non-residential ZEBs (Art. 13(5))
EPBD Art. 10(3)(a)Solar energy installations on all new public buildings, where technically suitable and economically and functionally feasibleBy 31 Dec 2026PV on the same platform: self-consumption, storage, price-aware heating and charging
EPBD Art. 10(3)(b)Solar on existing public buildings above 2,000 m², 750 m² and 250 m² of useful floor area31 Dec 2027 · 2028 · 2030The same, with measured yield per building for reporting
EED Art. 5Public bodies together cut their total final energy consumption by at least 1.9 % a year, against 2021Every yearMeasured consumption per building and portfolio benchmarks
EED Art. 6Renovate at least 3 % of the total floor area of heated or cooled public buildings above 250 m² each year, to at least nearly zero-energy or zero-emission standardEvery yearRoom-level control installed while in use (wireless), documentation for the renovation file
EED Art. 6A public inventory of heated or cooled public buildings and their energy performanceKept up to dateMeasured data per building, exportable
EED Art. 7Public procurement of products, services, buildings and works with high energy-efficiency performance (Annex IV)When procuringClass B functions as standard, function table and documentation for the tender
EPBD Art. 21(1)Energy performance certificate displayed in buildings occupied by public bodies and frequently visited by the publicWith national transpositionUp-to-date performance data behind the certificate
EPBD Art. 13(9)BACS in non-residential buildings above 290 kW, then above 70 kW31 Dec 2024 · 31 Dec 2029Bisly BACS, EN ISO 52120-1 class B
EPBD Art. 9Minimum energy performance standards: worst 16 % of non-residential buildings renovated by 2030, 26 % by 20332030 · 2033Measured baseline and savings to prioritise the portfolio

Summary of Directive (EU) 2024/1275 and Directive (EU) 2023/1791; the official texts on EUR-Lex prevail.

For a municipality

What this means for a portfolio of schools, halls and offices

01

Know the baseline

The 1.9 % a year and the 3 % renovation rate are measured against real consumption. Metering per building gives the baseline and the proof.

02

Renovate while in use

Wireless room-level control goes into schools and town halls floor by floor, during the school year, without closing the building.

03

Build new as zero-emission

From 2028 every new public building is a zero-emission building: heat pump, solar and the controls that keep it zero-emission in operation.

04

Report from one system

One login for the portfolio: energy, indoor air and alarms ranked per building — ready for the inventory, the council and EU reporting.

Luxembourg

National transposition

The Energy Efficiency Directive had to be transposed by 11 October 2025 and the EPBD recast by 29 May 2026. Luxembourg applies these duties through national law; for every project we confirm the applicable national text, thresholds and dates before quoting.

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What public owners ask

“What do EU rules require from public buildings in Luxembourg?”

New buildings owned by public bodies must be zero-emission from 1 January 2028 (EPBD Art. 7). Solar installations are required on new public buildings by 31 December 2026 and on existing public buildings above 2,000 m², 750 m² and 250 m² by 2027, 2028 and 2030, where feasible (EPBD Art. 10). Public bodies must cut final energy consumption by at least 1.9 % a year against 2021 (EED Art. 5) and renovate at least 3 % of the floor area of their heated or cooled buildings above 250 m² each year (EED Art. 6). Luxembourg applies these through national law.

“How can a municipality prove its 1.9 % yearly energy reduction?”

With measured consumption per building. Bisly meters electricity, heat and water per building and per system, benchmarks the portfolio and exports the data; AMP X SYNC installs it in Luxembourg, in schools and offices while they stay in use.

“Do public buildings need solar panels under the EPBD?”

Yes, where technically suitable and economically and functionally feasible: on all new public buildings by 31 December 2026, and on existing public buildings above 2,000 m² by 31 December 2027, above 750 m² by 31 December 2028 and above 250 m² by 31 December 2030 (EPBD Art. 10(3)).

Sources

  1. 01Directive (EU) 2024/1275 on the energy performance of buildings (recast), Articles 7, 9, 10, 13 and 21 — EUR-Lex
  2. 02Directive (EU) 2023/1791 on energy efficiency (recast), Articles 5, 6 and 7 — EUR-Lex
  3. 03European Commission — Public buildings under the Energy Efficiency Directive
  4. 04European Commission — Solar energy in buildings

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