Commission Delegated Regulation (EU) 2025/2273 of 30 June 2025 supplementing Directive (EU) 2024/1275 of the European Parliament and of the Council as regards the establishment of a comparative methodology framework for calculating cost-optimal levels of minimum energy performance requirements for buildings and building elements

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Directive (EU) 2024/1275 of the European Parliament and of the Council of 24 April 2024 on the energy performance of buildings (1), and in particular Article 6(1) thereof,

Whereas:

(1) Directive (EU) 2024/1275 empowers the Commission to adopt delegated acts to establish a comparative methodology framework for calculating cost-optimal levels of minimum energy performance requirements for buildings and building elements, and for the revision of cost-optimal levels.

(2) Directive (EU) 2024/1275 requires Member States to set minimum energy performance requirements for buildings and building elements, with a view to achieving at least cost-optimal levels. Member States are also to ensure that the requirements they set for technical building systems reach at least the latest cost-optimal levels. It is up to Member States to decide whether the national benchmark used as the final outcome of the cost-optimal calculations is calculated from a macro-economic perspective (looking at the costs and benefits of energy efficiency investments for society as a whole) or from a strictly financial viewpoint (looking only at the investment itself). National minimum energy performance requirements are not to be more than 15 % more lenient than the outcome of the cost-optimal results of the calculation taken as the national benchmark. The cost-optimal level is to lie within the range of performance levels where the cost-benefit analysis over the life cycle is positive.

(3) Directive (EU) 2024/1275 promotes the reduction of energy use in the built environment but also emphasises that the building sector is a leading source of greenhouse gas emissions and responsible for about half of primary fine particulate matter (PM2,5) emissions in the Union, which cause premature death and illness.

(4) The performance of standalone components falls under the scope of product-specific regulations. Regulation (EU) 2024/1781 of the European Parliament and of the Council (2) establishes minimum energy performance requirements for almost all categories of physical goods, including energy-related products. When setting national requirements for technical building systems, Member States must take into account the implementing measures established under that Regulation and the existing measures adopted pursuant to Directive 2009/125/EC of the European Parliament and of the Council (3). The performance of construction products to be used for the calculations under this Regulation should be determined in accordance with the provisions of Regulation (EU) 2024/3110 of the European Parliament and of the Council (4), as well as with the existing measures adopted pursuant to Regulation (EU) No 305/2011 of the European Parliament and of the Council (5).

(5) The objective of cost-optimal energy performance levels could, in certain circumstances, justify Member States in setting cost-optimal requirements for building elements that, in practice, raise obstacles for some building design or technical options as well as stimulate the use of energy-related products with better energy performance and, where relevant, emission performance. Pursuant to Article 2, point 32 of Directive (EU) 2024/1275, in order to determine the cost-optimal levels, the environmental and health externalities of energy use are to be taken into account, as well as the cost of greenhouse gas allowances as part of the energy costs.

(6) The steps that comprise the comparative methodology framework are set out in Annex VII to Directive (EU) 2024/1275 and include the establishment of reference buildings, the definition of energy efficiency measures and measures based on renewables to be applied to these reference buildings, the assessment of the total primary energy use and resulting emissions following these measures, and the calculation of the costs, that is to say the net present value, of those measures.

(7) The common framework for the calculation of the energy performance as established in Annex I to Directive (EU) 2024/1275 applies also to all steps of the cost-optimal framework methodology, in particular the calculation of the energy and emission performance of buildings and building elements. On-site energy production using locally available renewable energy sources (e.g. ambient heat, geothermal heat, solar thermal, photovoltaic, etc.) displaces delivered energy from the grid and reduces the impact of the building on the energy grid. To represent these benefits, the impact of self-use of renewable energy produced on site is not to be accounted in total primary energy use. Member States have flexibility regarding how they account renewable energy produced on site that is used for non-EPB uses or exported to the grid in the calculation of a building’s primary energy.

(8) For the purpose of this Regulation, the emission performance refers both to the operational emissions produced on-site (direct) and those from off-site generation of energy used by the building (indirect). When calculating the cost-optimal levels of minimum energy performance requirements, Member States could also take into account the life-cycle global warming potential (GWP).

(9) For the purpose of adapting the comparative methodology framework to national circumstances, Member States should determine the estimated economic life cycle of a building and/or building element; the appropriate cost for energy carriers, products, systems, maintenance, operational and labour costs; the renewable and non-renewable primary energy conversion factors or weighting factors per energy carrier; the greenhouse gas emission conversion factors; the energy price developments to be assumed for fuels used in their national context for energy used in buildings, taking into account the cost of greenhouse gas allowances, where appropriate; and the carbon price developments. As regards energy and carbon price developments, Member States should take into account the information provided by the Commission, as well as the new emission trading system for emissions from fuel combustion in buildings, road transport, and additional sectors (6). Member States can also include the monetisation of multiple benefits of energy efficiency measures in their cost-optimal calculations, including, for example, for private and public health and the gross domestic product (GDP).

(10) The discount rate reflects to a certain extent not only policy priorities (for macroeconomic calculations), but also different financing environments and mortgage conditions. The choice of a discount rate could have a significant impact on the result of the calculations of the comparative methodology framework and Member States have to determine the most appropriate discount rate for each calculation once the sensitivity assessment is performed. Therefore, Member States should also establish the discount rate to be used in both macroeconomic and financial calculations after having carried out a sensitivity analysis of at least two discount rates for each calculation.

(11) In line with the national emission reduction commitments set for main air pollutants pursuant to Directive (EU) 2016/2284 of the European Parliament and of the Council (7) and with the more stringent air quality standards set by Directive (EU) 2024/2881 of the European Parliament and of the Council (8), air pollutants emissions are introduced in the macroeconomic calculation. The broader perspective provided by the macroeconomic calculation required in this Regulation, including the monetisation of the health and environmental impacts linked to PM2,5 and NOx emissions as well as the costs of greenhouse gas (GHG) emissions, provides information that could be useful, also outside of the cost-optimal calculation, for example for establishing additional requirements, including in terms of emission performance, and wider climate, environmental, and public health policy objectives.

(12) To ensure a common approach to the application of the comparative methodology framework by the Member States, the Commission should establish the key framework conditions needed for net present value calculations, such as the starting year for calculations, the cost categories to be considered and the calculation period to be used. This Regulation should replace the existing comparative methodology framework set out in Commission Delegated Regulation (EU) No 244/2012 (9).

(13) Establishing a common calculation period does not conflict with the Member States’ right to fix the estimated economic life cycle of buildings or building elements, since the latter could be either longer or shorter than the calculation period fixed. The estimated economic life cycle of a building or building element has only limited influence on the calculation period, since the latter is determined instead by the refurbishment cycle of a building, which is the period of time after which a building undergoes a major refurbishment.

(14) Cost calculations and projections with many assumptions and uncertainties, including, for example, energy price developments over time, are generally accompanied by a sensitivity analysis to evaluate the robustness of the key input parameters. For the purpose of the cost-optimal calculations, the sensitivity analysis should address at least the energy price developments and the discount rate.

(15) Forward-looking primary energy factors or weighting factors and greenhouse gas emission factors, appropriately accounted for over the calculation period, allow the progressive decarbonisation of the electricity grid and efficient district heating networks to be taken into consideration in the calculation, in accordance with the 2030 emission reduction and climate neutrality goals set out in the national energy and climate plans submitted to the Commission pursuant to Article 14 of Regulation (EU) 2018/1999 of the European Parliament and of the Council (10). Such factors should be appropriately specified, for example, by taking into account the situation in the initial year of the calculation and the expected progress throughout the lifetime of the building. Those factors should be reviewed and, where necessary, updated every time a new cost-optimal calculation is performed. They can coincide with the factors set for the calculation of the energy performance of buildings, set in line with Annex I to Directive (EU) 2024/1275. Forward-looking primary energy or weighting factors should be used in the calculation, whereas forward-looking greenhouse gas emissions are recommended.

(16) The comparative methodology framework should enable Member States to compare the results of the cost-optimal calculations with the minimum energy performance requirements in force and to use the result of the comparison to ensure that minimum energy performance requirements are set with a view to achieving at least cost-optimal levels and, where relevant, more stringent reference values, such as nearly zero-energy building requirements and zero-emission building requirements. Those levels should be aligned to the national pathways set out in the national energy and climate plans (NECP) submitted to the Commission pursuant to Article 14 of Regulation (EU) 2018/1999. It should also be possible for Member States to consider setting minimum energy performance requirements at cost-optimal level for those building categories where no minimum energy performance requirements have existed to date.

(17) The cost-optimal methodology is technologically neutral and does not favour one technological solution over another. It ensures a competition of measures, packages, or variants over the estimated lifetime of a building or building element.

(18) In order to minimise the administrative burden of Member States, it should be possible for Member States to reduce the number of calculations by establishing reference buildings that are representative of more than one building category, without affecting their obligations pursuant to Directive (EU) 2024/1275 to set minimum energy performance requirements for certain building categories.

(19) Cost-optimal levels are also relevant to the new ‘zero-emission building’ (ZEB) standard, defined in Article 2(2) of Directive (EU) 2024/1275, as the maximum primary energy use thresholds are to be set with a view to achieving at least the cost-optimal levels and are to be reviewed every time that the cost-optimal levels are revised. In line with the ZEB definition, measures producing on site carbon emissions from fossil fuels cannot be considered in the cost-optimal calculations for ZEBs.

(20) Delegated Regulation (EU) No 244/2012 should therefore be repealed.

(21) The experts designated by each Member State were consulted in accordance with Article 32(4) of Directive (EU) 2024/1275,

HAS ADOPTED THIS REGULATION:

Article 1

Subject matter and scope

This Regulation establishes the comparative methodology framework to be used by Member States for calculating the cost-optimal levels of minimum energy performance requirements for new and existing buildings and building elements. It also sets out rules for the application of the comparative methodology framework to selected reference buildings.

Article 2

Definitions

In addition to the definitions set out in Article 2 of Directive (EU) 2024/1275, the following definitions shall apply for the purposes of this Regulation:

(1) ‘global cost’ means the sum of the present values of the initial investment costs, running costs, replacement costs (referred to the starting year), waste management costs, if applicable and, for the purposes of the calculation at macroeconomic level, it includes costs of greenhouse gas emissions as well as health and environmental externalities of energy use;

(2) ‘initial investment cost’ means all costs incurred up to the point when the building or building element is delivered to the customer, ready to use. Those costs include design, purchase of building elements, connection to suppliers, installation and commissioning processes;

(3) ‘energy cost’ means the annual energy costs, including energy price, capacity tariffs and grid tariffs, and national taxes, taking into account the cost of greenhouse gas allowances.

(4) ‘operational cost’ means all costs linked to the operation of the building, including annual costs for insurance, utility charges and other standing charges and taxes;

(5) ‘maintenance cost’ means the annual costs for measures to preserve and restore the desired quality of the building or building element including annual costs for inspection, cleaning, adjustments, repair and consumable items;

(6) ‘running cost’ means the annual maintenance, operational and energy costs;

(7) ‘waste management cost’ means the cost of a building or building element at the end of its life, including dismantling, removal of building elements that have not yet come to the end of their lifetime, transport, disposal and recycling;

(8) ‘replacement cost’ means a substitute investment for a building element, in accordance with the estimated economic life cycle during the calculation period;

(9) ‘annual cost’ means the sum of running costs and replacement costs paid per year;

(10) ‘cost of greenhouse gas emissions’ means the monetary value of environmental damage caused by CO2 emissions, related to the energy consumption in buildings;

(11) ‘environmental and health externalities of energy use’ means, but is not limited to, the monetary value of the health and environmental damage caused by emissions of PM2,5 and NOx, related to the energy consumption in buildings;

(12) ‘reference building’ means a hypothetical or real building that represents the typical building geometry and systems, the typical energy performance for both building envelope and systems, the typical functionality and typical cost structure in the Member State, and that is representative of climatic conditions and geographic location;

(13) ‘discount rate’ means a specific value to compare the value of money at different times expressed in real terms;

(14) ‘discount factor’ means a multiplicative number used to convert a cash flow occurring at a given point in time to its equivalent value at the starting point, which is derived from the discount rate;

(15) ‘starting year’ means the year from which the calculation period is determined;

(16) ‘calculation period’ means the time period considered for the calculation, usually expressed in years;

(17) ‘residual value of a building’ means the sum of the residual values of building elements at the end of the calculation period;

(18) ‘price development’ means the development over time of prices for energy, products, building systems, services, labour, maintenance and other costs which can be different from the inflation rate;

(19) ‘energy efficiency measure’ means a change to a building or building element resulting in a reduction of the building’s final energy use;

(20) ‘package’ means a set of energy efficiency measures or measures based on renewable energy sources applied to a reference building, or both;

(21) ‘variant’ means the global result and description of a full set of measures or packages applied to a building that can be made up of a combination of measures on the building envelope, passive techniques, measures on building systems or measures based on renewable energy sources, or a combination of those measures;

(22) ‘subcategories of buildings’ means categories of building types that are more disaggregated according to size, age, construction material, use pattern, climatic zone or according to criteria other than those established by point 6 of Annex I to Directive (EU) 2024/1275, for which reference buildings are generally established;

Article 3

Comparative methodology framework

(a) energy efficiency measures;

(b) measures incorporating renewable energy sources;

(c) packages and variants of such measures.

(a) shall establish the year in which the calculation is being performed as the starting year for the calculation;

(b) shall use the calculation period set out in Annex I;

(c) shall use the cost categories set out in Annex I;

(d) are recommended to use the projected carbon price trajectories, set out in Annex II, for carbon costing.