On 7 May 2026, REHVA participated in the 2nd stakeholder workshop on the revision of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action, convened jointly by DG ENER and DG CLIMA at the Charlemagne Building in Brussels. The event gathered representatives from EU institutions, Member States, financial institutions, industry, investors, NGOs, trade unions, academia, and energy experts.
The Policy Dossier: Revising the Energy Union Governance Regulation
Regulation (EU) 2018/1999 is the legislative backbone of the Energy Union. It governs how Member States plan, report, and monitor their progress towards EU energy and climate objectives, primarily through National Energy and Climate Plans (NECPs). The European Commission is now preparing a legislative proposal — expected in Q4 2026 — to simplify, strengthen, and modernise this framework. The revision aims to assist the EU and its Member States in building a conducive policy framework for energy and climate for the coming decade, to strengthen the European Energy Union, to support the attainment of the Paris Agreement's long-term objectives, and to more effectively mobilise the investments required for the transition.
The revision process has been structured around a public consultation phase (18 December 2025 – 19 March 2026), followed by two stakeholder workshops. The 2nd workshop on 7 May builds on the first, held on 3 March 2026, and on the outcome of the Open Public Consultation and Call for Evidence.
REHVA's Engagement
REHVA has been an active participant throughout this revision process, contributing at each stage.
REHVA submitted a formal written contribution to the public consultation, setting out its core principles for the revision: technology-neutral and performance-based targets rather than prescribed solutions; the evolution of NECPs into genuine investment plans covering both supply-side and demand-side measures; enhanced quality assurance in construction and renovation, including commissioning and monitoring of technical building systems; decentralisation and a diversity of solutions as prerequisites for resilience; and the need to balance all three energy policy dimensions — security, competitiveness, and decarbonisation — without creating new systemic fragilities by focusing exclusively on one pathway. This contribution is summarised on the REHVA website.
On 3 March 2026, REHVA participated in the 1st stakeholder workshop at the Berlaymont building, reaffirming these positions in dialogue with EU institutions, Member States, and other stakeholders.
Key Discussions at the 2nd Workshop
Consultation results and the target structure debate
Ramboll, the Commission's contractor for the impact assessment, presented the results of the consultation process. Responses were numerous and reflected a wide diversity of views: broad support emerged for a binding EU target, but industry stakeholders favoured greater flexibility while NGOs called for stricter measures. The Commission presented five options for the post-2030 target architecture, ranging from the current structure of binding EU targets with national contributions, through options introducing a single clean energy or electrification target, to complementing any structure with a monitoring KPI framework.
KPIs: a central and contested debate
The role of KPIs in the revised Governance Regulation was among the most discussed topics. Several industry voices argued strongly for embedding electrification KPIs in the regulation and rejected flexibility for certain energy vectors. Transport & Environment outlined three principles: KPIs should complement rather than replace binding targets, be harmonised across Member States, and rely on existing data sources. Other voices questioned whether KPIs make sense for all actors, pointing to market mechanisms such as the ETS as a more appropriate guiding tool in certain contexts.
A significant signal from DG CLIMA
Particularly noteworthy for REHVA was the intervention of the Director of DG CLIMA, who stated clearly that more electrification does not necessarily mean less fossil fuel use. This is a significant acknowledgement: it cautions against treating electrification as a self-sufficient decarbonisation strategy and underlines the need to address the full energy mix.
REHVA's Position
The discussions at this workshop confirm the continued relevance of REHVA's core principles. The DG CLIMA intervention resonates directly with REHVA's long-standing view that European policies should not create new systemic fragilities by focusing on a single solution. As REHVA has consistently argued, the complementarity of energy carriers — electrons and molecules — is precisely the kind of approach that addresses security, competitiveness, and decarbonisation simultaneously.
On KPIs, REHVA supports well-designed indicators that measure real outcomes and draw on existing reporting infrastructure. However, indicators should define objectives, not means: if a KPI effectively mandates a specific technology, it ceases to be a neutral monitoring tool and becomes a policy prescription — one that may exclude efficient alternatives relevant to the building sector, such as thermal solar or hybrid systems.
On the governance reform more broadly, REHVA welcomes simplification efforts, provided they do not reduce the rigour with which building sector performance is monitored and reported. The gap between expected and actual energy savings in buildings is often not a technology problem but an implementation one — linked to quality of installation, commissioning, and operational monitoring. A revised Governance Regulation that keeps this dimension visible will be more effective, not less.
Next Steps
The Commission's legislative proposal for the revised Governance Regulation is expected in Q4 2026. REHVA will continue to follow this process closely and contribute to further discussions, ensuring that the practical expertise of HVAC engineers and building professionals informs EU energy governance decisions.
