Legal framework after 2030 – EBE’s response to the call for evidence
The current geopolitical context is causing spikes in energy prices (in 44 days, Europe’s bill for fossil fuel imports increased by over EUR 22 billion) and underlines once again Europe’s energy dependence. A structural reduction of energy demand through efficiency – particularly in buildings, which account for 40% of the EU’s energy use and over half of EU gas consumption – is the most effective way to reduce EU dependency on fossil fuel imports. To incentivise industry players and building owners to invest, the European Commission should propose a coherent 2040 energy efficiency framework, backed by adequate financing and synergies with ETS2.
The IEA highlighted the central role of demand-side measures in lowering costs for consumers and businesses. President von der Leyen also acknowledged “energy efficiency levers” like “renovation of buildings” as a key response to the energy crisis. In buildings, energy efficiency is a no-regret option delivering multiple benefits, including lower bills, improved comfort, health and wellbeing, reduced energy poverty, and local job creation.
Yet, the potential of efficient buildings remains largely untapped. Energy efficiency solutions, products, and technologies are available, but the pace and depth of renovation must accelerate. Regulatory uncertainty and inconsistent national renovation programmes create a “stop and go” effect, preventing scale-up.
The 2023 EED has offered predictability and stability for stakeholders and investors, unlocking substantial energy savings.
The Energy Savings Obligation (Article 8) schemes delivered about half of the EU 2020 energy efficiency target and are expected to contribute similarly to the 2030 target. In Hungary, the Energy Efficiency Obligation Scheme, operating since 2021, led to more than 10.000 energy efficiency improvement measures implemented, resulting in 17PJ of additional energy savings. Article 8 could be strengthened by requiring a minimum share of savings in the buildings sector, prioritising the worst-performing buildings, in line with the Energy Performance of Buildings Directive.
Beyond savings, the framework sets the way towards a secure, competitive and resilient energy system, and should be extended to 2040. The post-2030 architecture should include a clear target for energy efficiency and a mechanism to share efforts between Member States. This is paramount to maintain investment certainty, as any changes could also impact measures taken to meet the 2030 energy efficiency target. This will drive action in buildings, energy security and affordability.
The application of the energy efficiency first principle (Article 3) in planning, policy, and major investment decisions helps shield households and businesses from fluctuating energy prices. Some Member States (e.g., France and Romania) effectively applied it in their Recovery and Resilience Plan by earmarking aid to projects focusing on reducing final energy demand before supply-side measures. This should be replicated in future EU funding streams.
Energy management systems and audits give strong data-based incentives for energy efficiency in buildings (Article 11). The new EED could make these more impactful by strengthening the follow-up obligations, such as requiring the implementation of cost-effective recommendations.
The directive also requires the public sector to lead by example (Articles 5 and 6) and provides the right tools to create lead markets through public procurement (Article 7). This has translated into concrete actions, such as dedicated budgets to renovate the public building stock.
The 2023 EED also addresses emerging challenges such as data centres (Article 12) and heating and cooling (Article 25). These elements must be reinforced in the post-2030 framework to limit additional electricity consumption and ensure a timely decarbonisation of district heating and cooling.
The framework must better consider the transformation of the overall energy system, as cost-effective electrification will drive electricity consumption up in buildings. By implementing widespread energy efficiency and flexibility improvements in buildings, the EU could reduce peak demand by up to 49%. While electrification is widely recognised as a driver of energy efficiency, the reverse is equally important: energy efficiency can accelerate and reduce electrification costs. By lowering overall energy demand, energy efficiency solutions make electrification more affordable and easier to implement, making building loads more flexible and grid-responsive, helping to keep energy costs under control. This dimension could be introduced in the directive with new provisions that reflect the benefits of reducing peak electricity demand for heating, and, where relevant, electricity use for space cooling, through efficiency improvements in buildings. This could trigger policy measures and financing programmes consistent with the synergies between heat demand optimisation and electrification.
The post-2030 framework should explicitly recognise digitalisation as an enabler of the transition. Digital tools are a key support to implementation, monitoring, and continuous energy efficiency improvement in buildings.
The assessment process of the EED comes at a very early stage of the implementation phase. The transposition period ended six months ago, and some provisions are still not fully operational. The public sector obligation to reduce energy consumption is indicative until 11 October 2027. Requirements on energy audits or energy management systems’ timelines start respectively on 11 October 2026 and 11 October 2027. Evidence is therefore limited, making it unlikely to draw firm conclusions.
The post-2030 energy efficiency framework must build on the proven success of the current EED by ensuring regulatory stability and investment certainty, strengthening key provisions, and unlocking the full potential of buildings as a cornerstone of a secure, affordable and decarbonised energy system.
