Implementing Energy Performance of Buildings Directive in Spain

Keywords: EPBD, ZEB, Decarbonisation, IEQ, Atecyr, Spain

Spain is currently in the process of gradually implementing the Energy Performance of Buildings Directive (EPBD), which involves updating three national regulations: the Technical Building Code (CTE), the Regulation on Thermal Installations in Buildings (RITE) and the Energy Performance Certification of Buildings (CEE). In addition, the publication of specific regulations concerning the energy refurbishment of existing buildings is planned.

Regulatory framework and recent developments

The most significant step taken by Spain has been the publication of the new draft Technical Building Code (CTE). The document has been open for public consultation since December 2025 and represents a major overhaul of the previous version. The following requirements are particularly noteworthy:

1.    Total decarbonisation in new construction: The shift is from EECN (nearly zero-energy) buildings to zero-emission buildings (ZEB). The regulatory definition of a “zero-emission building” is introduced. It is stipulated that by 2028, public buildings will be ZEBs and by 2030, all new buildings will be ZEBs.

2.    New Basic Document: DB-HSA (Environmental Sustainability), which introduces Global Warming Potential, in kg CO₂ equivalent/m² over 50 years. It quantifies GWP in accordance with standard UNE-EN 15978:2012 and by applying a correction factor depending on the data source. This methodology will enable mandatory maximum limits to be set in the future.

3.    The new Technical Building Code (CTE) sets stricter requirements regarding both energy demand and energy consumption. The indicator used is now total primary energy, rather than non-renewable primary energy. The limit values remain unchanged, as the previous thresholds were already very strict. However, a second phase of the CTE review may introduce different or tighter values, depending on the results of the optimal cost study now in progress. This issue is not covered in the draft currently open for consultation.

4.    The new document increases the requirements for renewable energy generation, stipulating that the majority of new buildings, as well as those undergoing complete refurbishment, must have on-site solar generation.

5.    The new document improves the efficiency of building use by providing infrastructure for sustainable mobility, consisting of smart electric vehicle charging points and bicycle parking.

Furthermore, Atecyr is aware that the Ministry is working on the new Energy Performance Certificate for Buildings. At present, there are seven different certification schemes, which are being adapted to verify compliance with the new Technical Building Code and to provide energy ratings based on the new certification scale.

In this regard, it has been announced that new conversion factors will soon be published; in the case of electricity, a much lower value is expected for both CO₂ emissions and total primary energy. The conversion factors currently in use were calculated using data from the electricity grid between 2007 and 2013, and electricity generation is now much more renewable than it was then.

Pathways to decarbonisation

Decarbonisation of the building sector in Spain is proving straightforward in new-build properties. New buildings are now constructed with heat pumps for both heating and domestic hot water (furthermore, the demand for cooling is growing).

Problems arise in existing buildings, where many boilers are installed and, in many cases, boilers are still being replaced one by one, without considering heat pumps as an alternative. The price of gas in Spain is around three times lower than that of electricity, resulting in a similar annual energy cost (this is offset by the heat pump’s COP of 3). Users do not perceive a return on investment, and, furthermore, installing a heat pump can be three times more expensive. There are grants available for the purchase of heat pumps (Energy Saving Certificates), but these are insufficient to accelerate their widespread adoption.

Indoor Environmental Quality (IEQ)

Indoor environmental quality in Spain is regulated by the Regulation on Thermal Installations in Buildings. This regulation sets high ventilation flow rates and significant requirements for outdoor air filtration. Its amendment is pending, following which UNE EN 16.798 will be applied.

The role of ATECYR

ATECYR plays a key role as a technical intermediary between regulators, industry, and professionals. Its contribution can be summarised in three main areas:

·         Development of technical guidelines and best practices for HVAC systems and energy efficiency.

·         Development of documentation and training for engineers and professionals

·         Participation in the regulatory debate process, providing technical information to policy-makers.

ATECYR also helps to bridge the gap between theoretical compliance and actual operational performance, particularly by disseminating practical solutions and case studies.