Implementing Energy Performance of Buildings Directive in Denmark

Keywords: Energy Performance of Buildings Directive (EPBD), National Building Renovation Plan (NBRP), Minimum Energy Performance Standards (MEPS)

Denmark is facing a comprehensive transformation of its building stock. With the recast Energy Performance of Buildings Directive, stricter requirements are introduced for new construction, energy renovation, and the phase-out of fossil fuels in buildings in Denmark. The goal is a zero-emission building stock by 2050.

Process for Implementation

On 24 April 2024, the EU adopted the recast Energy Performance of Buildings Directive (EPBD) [1], which sets an ambitious course towards a zero-emission building stock by 2050. The implementation deadline is 29 May 2026, and in Denmark the process of converting the Directive's requirements into national legislation is well underway.

Responsibility is shared between two ministries. The Ministry of Social Affairs and Housing handles the technical building requirements in the Building Regulations, including requirements for new buildings, solar energy, and charging infrastructure. The Ministry of Climate, Energy and Utilities is responsible for the broader framework, such as the national building renovation plan, minimum energy performance standards for existing buildings, energy performance certificates, financing, and one-stop-shops [2].

Before Christmas 2025, a draft legislative proposal anchoring the new obligations [3], along with a draft National Building Renovation Plan (NBRP) [4], was sent out for public consultation. According to the plan, the legislative proposal will be introduced in the Danish Parliament (Folketinget) in the spring of 2026, so that it can enter into force precisely on the implementation deadline of 29 May 2026. The final national plan is expected to be submitted to the European Commission by the end of 2026.

Key Changes in Denmark

The EPBD gives national degrees of freedom to adapt and implement the provisions into Danish legislation. The most important changes are as follows.

Minimum Energy Performance Standards (MEPS): For non-residential buildings, individual obligations are introduced requiring the worst-performing buildings to be renovated first. From 2030, all covered buildings must have an energy consumption below approximately 190 kWh/m² per year corresponding to the worst-performing 16 percent stated in EPBD, and from 2033 the requirement is tightened to approximately 168 kWh/m² per year (the worst-performing 26 percent as stated in EPBD). Compliance is to be documented by the building owner through a valid energy performance certificate. A number of building types, such as heritage-protected buildings, places of worship, and industrial facilities, are exempted. Exemptions from the requirements may be granted if a renovation is not cost-effective, or if the building owner is affected by hardship such as bankruptcy or serious illness, or the future use of the building will change.

For residential buildings, no individual requirements are introduced; instead, a national trajectory is established. The average primary energy use of the entire housing stock must be reduced by at least 16 percent by 2030 and by 20–22 percent by 2035 compared to 2020. At least 55 percent of this reduction must be achieved by renovating the worst-performing 43 percent of dwellings. Denmark is expected to be well on track to meet these targets, primarily driven by the green transition of district heating and conversions to heat pumps.

According to Statistics Denmark [5], district heating and heat pumps are already supplying about 65 percent of the total heated building area in 2024 (Table 1).

Table 1. Distribution of heating systems in Denmark. [5]

Zero-Emission Buildings (ZEB): From 1 January 2028, new public buildings must be zero-emission buildings, and from 1 January 2030, the requirement applies to all new buildings. A ZEB has a very high energy performance and zero on-site CO₂ emissions from fossil fuels. In Denmark, this will be implemented through a ban on on-site use of fossil fuels and a 10 percent reduction of the energy framework compared to the current Danish requirement for nearly zero-energy buildings (NZEB).

Life-Cycle Global Warming Potential (GWP) of New Buildings: Denmark already fulfils the requirement to calculate the life cycle GWP for new buildings. The requirements were introduced as of 1 July 2025 and apply to both residential and non-residential buildings, with specific GWP limits for different building categories.

Renovation Passports: By 29 May 2026, a voluntary renovation passport scheme will be introduced. It is an individually tailored roadmap showing a building owner the path towards a staged, deep renovation to achieve ZEB status. The passport, which is drawn up by a certified expert, is expected to be administratively a part of the energy performance certificate scheme.

Energy Performance Certificates and Advertising: The energy performance certificate scale is harmonised so that class A corresponds to zero-emission buildings. A requirement for an energy performance certificate is introduced for major renovation works, defined as renovation of more than 25 percent of the building envelope. The requirement to display the energy performance certificate in advertisements is extended to cover all forms of advertising, not just commercial media. Conversely, the obligation to submit the energy performance certificate to the municipality upon completion notification for new construction is removed.

Solar Energy: New buildings must be designed to optimise the potential for solar energy. Staged requirements for the installation of solar energy systems are also introduced, where technically and economically feasible.

Building Automation and Control Systems (BACS): For larger non-residential buildings (with a heating/cooling demand exceeding 290 kW), a requirement for a building automation and control system that includes monitoring of indoor climate quality is introduced. From 1 January 2030, this will also apply to non-residential buildings with a heating/cooling demand exceeding 70 kW. For zero-emission buildings, there will additionally be a requirement that they be equipped with measurement and control devices for monitoring and regulating indoor air quality [6].

Smart Readiness Indicator (SRI): Concerning Danish activities on the Smart Readiness Indicator (SRI), a non-binding national testing phase was carried out in 2022. The Danish testing phase was led by the Danish Energy Agency in cooperation with the Danish Technological Institute (DTI). A report has been prepared that can contribute to the European Commission's work on presenting further measures [7].

Outlook Towards 2050

With the EPBD and the national implementation, the course is set towards a fully decarbonised building stock by 2050. The national building renovation plan serves as the central roadmap, which must be revised every five years to ensure that Denmark stays on track.

The national targets for 2030, 2040, and 2050 encompass reductions in both primary and final energy consumption, as well as in operational greenhouse gas emissions. For non-residential buildings, provisional milestones have been set, aiming for an energy consumption of approximately 139 kWh/m²/year by 2040 and approximately 97 kWh/m²/year by 2050, corresponding to the current cost-optimal level for renovation.

To reach these goals, a broad range of policy instruments will continue to be deployed: requirements in the Building Regulations, subsidy schemes, continued rollout of green district heating, information campaigns, and technical advisory services. The new legislation grants the Ministers extended powers to establish rules on financial incentives and to target efforts towards vulnerable groups to ensure a socially fair green transition.

Denmark has a strong starting point, but the task is substantial. It requires persistence, investment, and a construction sector with the capacity to deliver the many energy renovations necessary to meet the climate targets.

References

[1]     Directive (EU) 2024/1275 of the European Parliament and of the Council of 24 April 2024 on the energy performance of buildings (recast).

[2]     Presentation of proposals for the implementation of the EPBD. (Præsentation af forslag til implementering af EPBD). (December 11, 2025).

[3]     Draft Act amending the Act on the Promotion of Energy Savings in Buildings. (Udkast til Lov om ændring af lov om fremme af energibesparelser i bygninger). (December 8, 2025).

[4]     Draft National Building Renovation Plan. (Udkast til National Bygningsrenoveringsplan)(December 8, 2025).

[5]     Building survey, January 1, 2024. Statistics Denmark. (March 27, 2024).

[6]     Draft amendments to the Building Regulations (BR18) in connection with the implementation of the Building Directive (February 16, 2026).

[7]     Test af Smart Readiness Indicator (SRI) i dansk kontekst (September 2022), Teknologisk Institut.