EPBD – The French Implementation Process

Keywords: EPBD, ZEB, Decarbonisation, IEQ, AICVF, France

France is often a frontrunner regarding the objectives of the EPBD. Therefor the existing French laws and EPBD are often in line in terms of objectives, but they differ in the operational means. The problem to tackle is that the French real estate sector structured itself already according to the existing French schemes.

The French EPBD implementation – a step-by-step implementation

France adopted a step-by-step process to make the necessary changes in existing laws and regulations to transpose the EPBD. The “Conseil d’Etat”, which represents a form of French Supreme Court for public matters, stressed that even if current French law and EPBD are often in line in terms of objectives, they differ by the technical, operational means and exemption that the EPBD imposes substantial changes to the national law.

As a matter of fact, France has already implemented national dispositions that went further than the previous versions of EPBD. The essential and most structural subject to tackle is to manage the compatibility of the existing schemes, around which the real estate sectors structured itself, with EPBD recast 2024, s.

This is why the government is choosing a step-by-step process with a distinction between:

·         Regulations that can be modified by the government itself,

·         Laws that need to go through Parliament in a longer and heavier process which may need supplementary regulations for full implementation

Regulatory framework and recent developments

As all European Countries, France has to report to the Commission the implementation of the European Energy and Climate policies via:

·         the National Energy and Climate plans (NECPs) related to the Regulation on the Governance of the Energy Union and Climate Action (under revision),

·         the Comprehensive Assessment (CA), dealing with the evaluation of the heating and cooling strategy, related to the Energy Efficiency Directive (EED),

·         the national building renovation plan (NBRP) related to the Energy Performance of Building Directive (EPBD.

France declared that it will not be able to keep the EPBD transposition deadline of the 29^th of May 2026, and is not in a position to provide a deadline (EPBD expert group 24^th February 2026).

At the time being, France has also not submitted yet its national building renovation plan. Some of it can already be inferred since it is meant to be consistent with the National Decarbonization strategy (still at draft stage) and the National Pluriannual Energy Plan PPE3 (in force).

To move away from fossil fuels, France is focusing on:

·         decarbonization through nuclear power. This requires the construction of 27 additional nuclear units,

·         an increase in the production of heat from renewable sources,

·         the development of geothermal energy (heat pump),

·         the development of biomass and especially biogas. Biomass and biogas will account for around half of renewable energies in 2050, followed by heat pumps,

·         an accelerated development of district heating and cooling networks, their share in the heating and cooling sector will be doubled (from 4% to 10%).

PPE3 contains an electrification and “heat pump plan” with an objective of producing at least 1 million heat pumps a year and maximize their installations which are booming following the war in Iran (300,000 sold in first trimester; +21%). The residential sector is meant to be a priority target.

On the one hand, it already exists in the existing French regulation, a basis of regulatory framework issued from the transposition of the previous EPBD, which needs to be strengthened (the existing thermal regulation on existing buildings) or adapted (the existing environmental regulation on new buildings Re2020).

On the second hand, there is also a political will not to go beyond European requirements, for instance on Bacs.

Some aspects of the new EPBD recast have already been transposed, such as the suppression of funding for fossil fuel boilers. Parliamentary work on solar energy is also underway.

However, most of the transposition work has still to be done particularly on energy performance requirements (cost optimal levels, revised NZEB, ZEB definition, …), and the new requirements in terms of IEQ and IAQ.

The following table gives an overall status of the French transposition procedure.

The role of AICVF in the French EPBD implementation

AICVF faces a persistent difficulty in exchanging information with the French administration in charge of the EPBD transposition. Several invitations, for example to the AICVF national congress in 2025, did not received any response,

Despites these difficulties, in 2025, AICVF decided to create a task force to analyse both, the articles of the EPBD including the annexes of the guidelines, and their adequacy to the French regulatory framework.

The target of this task force is to provide visibility to our professionals and to avoid possible instability in future regulations.

AICVF shares its comments and observations with its partners and publicly through the publication of analyses such as "Comments on Article 13 of the EPBD relating to the phasing out of fossil fuel boilers." An analysis of the guideline documents, and more recently a publication on solar (article 10) with comments on a proposed legislation have been already published.

AICVF is still working on:

·         Energy performance requirements: Comparison between existing national schemes and EPBD

·         Technical building systems

·         Renovation passports

·         IAQ indicators.

AICVF aicvf.org positions and proposals will be published soon.