Energy Performance Certificates Around the World in 2026: The Document That Now Decides Whether a Foreign-Owned Property Can Even Be Rented

Published on: May 17, 2026

Quick answer: By 2026 the Energy Performance Certificate, DPE in France, EPC in the UK, CEE in Spain, APE in Italy, Energieausweis in Germany, has become a regulatory gatekeeper that can determine whether a property can be legally rented at all. France already imposes a rental ban on G-rated homes (since 1 January 2025), with F-rated banned from 2028 and E-rated from 2034, while the UK's Warm Homes Plan requires EPC Band C for all privately rented homes in England and Wales by 1 October 2030, backed by fines up to £30,000 per breach. The practical effect is that two physically identical apartments can now carry radically different rental yields and values based on a single letter, so EPC tier has joined location, building age, and tenancy regulation as a primary screen for cross-border buyers.

For most of the 2010s, the Energy Performance Certificate was a piece of paper that European notaries asked for, foreign buyers glanced at, and almost nobody priced. By 2026 that has inverted. The EPC, DPE in France, EPC in the UK and Ireland, CEE in Spain, APE in Italy, Energieausweis in Germany, has become the single most consequential regulatory document attached to a residential property, often determining whether the unit can be legally rented at all.

The shift is concrete and dated. France's Diagnostic de Performance Énergétique now imposes an outright rental ban on G-rated properties (since 1 January 2025), with F-rated properties banned from 1 January 2028 and E-rated properties banned from 1 January 2034. The UK's January 2026 Warm Homes Plan requires every privately rented property in England and Wales to achieve EPC Band C by 1 October 2030, backed by fines up to £30,000 per breach per property. The EU's EPBD recast (Directive 2024/1275) sets binding building-renovation trajectories that every member state is now transposing. Italy's Decreto CER, Spain's Real Decreto 390/2021, Germany's Gebäudeenergiegesetz (GEG) are all in active implementation, each tightening what an EPC means for what a building can legally be.

For foreign property owners, the practical effect is that two physically identical apartments, same square metres, same location, same view, can now have radically different rental yields and market values based on a single letter on a certificate. A B-rated Paris apartment is fully rentable, fully mortgageable, and trading at premium. A G-rated Paris apartment is technically un-rentable from 2025, hard to mortgage, and trading at a discount that the original foreign buyer almost certainly did not factor when buying in 2019.

This is the 2026 country-by-country framework for EPCs from a cross-border investor's perspective.

How EPCs Work and Why 2026 Is the Year They Bite

Every EU and many non-EU energy performance certificates share the same basic architecture. A qualified assessor inspects the building, measures or models its annual energy consumption per square metre (typically expressed as kWh/m²/year), and assigns a letter rating from A to G (with some national variants extending to A+ or below G).

The certificate is valid for a defined period, typically 10 years in most EU regimes, and must be presented at the moment of sale or rental of the property. Failure to provide a valid EPC carries administrative fines that have escalated steeply in recent years: up to €15,000 in France, up to £30,000 in the UK (under the new MEES regime), up to €3,000 in Spain, up to €5,000 in Italy, and similar figures elsewhere.

For a long time the certificate was a disclosure obligation only. What changed in 2025–2026 is the addition of rental and sale restrictions that turn the certificate into a regulatory gatekeeper. The progression is happening at different speeds across jurisdictions but the direction is uniform: F and G classes are progressively being removed from the legal rental market; E will follow in many jurisdictions by 2034; the longer-term EU trajectory under EPBD recast is for residential buildings to reach Class E by 2030 and Class D by 2033.

France: The DPE Reform That Reshaped the Rental Market

France's Diagnostic de Performance Énergétique is the most aggressive EPC enforcement regime in Europe and the model many other EU member states are studying. The 2026 reality is shaped by three legislative moments.

The Climate and Resilience Law of 22 August 2021 (Loi n° 2021-1104) established the progressive rental ban on energy-inefficient housing. The schedule, slightly modified by subsequent legislation:

• 1 January 2025: G-class properties cannot be rented under new leases, renewals, or tacit renewals.
• 1 January 2028: F-class extension.
• 1 January 2034: E-class extension.

In April 2025 the French Senate adopted a softening bill allowing G-rated landlords to continue renting subject to a commitment to undertake energy renovation works, in response to landlord lobbying and a tight rental market. This created a partial relief valve but did not remove the underlying trajectory.

The DPE methodology overhaul of 1 July 2021 unified what had been two separate certificates (one for the property's energy consumption, one for its CO₂ emissions) into a single rating combining both. This was the moment when many older Parisian apartments, particularly small electric-heated units, saw their ratings collapse, with hundreds of thousands moving from D or E to F or G overnight.

The January 2026 reform addressed the most criticised aspect of the 2021 methodology: the electricity conversion coefficient. From 1 January 2026, the coefficient drops from 2.3 to 1.9, meaning that homes heated by electricity now look approximately 17% better on paper. An estimated 850,000 French properties rated F or G are expected to move up at least one class on recalculation, without any physical renovation. The recalculation is available free through ADEME's website.

Also from 1 January 2026, DPE collectif (a building-level energy diagnosis) became mandatory for buildings with 50 units or fewer; it was already required for larger buildings. This means every smaller Parisian copropriété now has a building-level energy diagnostic, accelerating the planning of common-parts renovations.

For foreign owners in 2026, three practical implications:

• Recalculate before renovating. A G-rated apartment may become an F under the January 2026 coefficient revision, automatically buying three additional years of rental life. Many owners are renovating without first running the recalculation.
• DPE C or better is now the safe rental threshold. Even E and F currently allowed (or soon to be banned) face declining tenant demand, gel des loyers (rent freezes already applied to F and G), and lower market values.
• Renovation costs are partially subsidised through MaPrimeRénov' (state grant), CEE certificates (energy supplier bonuses), and the doubled déficit foncier cap of €21,400 per year (for landlords doing energy works on rented property). These reduce the net cost of renovation by 30–50% for many foreign landlords who file French tax returns.

United Kingdom: The Warm Homes Plan and the October 2030 EPC-C Deadline

The UK's Minimum Energy Efficiency Standards (MEES) regime has been in place since 2018, originally requiring EPC E minimum for new tenancies. The 2026 update represents the largest tightening since inception.

On 21 January 2026, the UK government published the Warm Homes Plan, a 152-page document setting out:

• EPC Band C minimum for all privately rented properties in England and Wales by 1 October 2030.
• A single compliance date (the earlier two-stage 2028 / 2030 proposal was abandoned).
• A per-property cost cap of £15,000 for required improvements (raised from the previous £3,500).
• Fines of up to £30,000 per property per breach.
• A new EPC methodology (the Home Energy Model) coming into force for new EPCs from 1 October 2029, assessing four metrics: energy cost, fabric performance, heating system, and smart readiness.

Properties that hold a valid EPC of C or above against the current metrics before 1 October 2029 will be "grandparented", recognised as compliant with the new regime until the existing certificate expires. This creates a powerful incentive to obtain an EPC-C rating under current methodology before October 2029, locking in compliance for up to 10 years.

The new metrics, when they apply, will impose additional requirements that may go beyond simple thermal insulation. Practical compliance under the new system requires either a heat pump (Heating System Metric) or solar panels / micro-generation (Smart Readiness Metric), combined with adequate fabric performance. An efficient gas boiler will not pass the Heating System Metric.

For foreign owners with UK buy-to-let portfolios, the strategic decision points in 2026 are:

• Pre-October-2029 renovation to current EPC-C locks in compliance through grandparenting and avoids the more demanding new-metric requirements.
• Properties below EPC-C with high renovation costs may face the £15,000 cost cap as a partial cap on liability but will need new-format EPCs if works occur after October 2029.
• Boiler Upgrade Scheme grants of up to £7,500 for heat pump installation do not count against the personal cost cap, materially reducing the effective net cost of compliance.
• Properties under £30,000 EPC-improvement-cost-to-C can be improved within the cap; properties above this threshold may register for the high-cost exemption (subject to evidence).

The buy-to-let market response has been substantial. Hamptons research estimates 340,000 rental properties per year need EPC improvement to hit the 2030 target. Many landlords are selling rather than renovating, which has accelerated the foreign-buyer exit from UK buy-to-let that began with the Section 24 mortgage-interest restriction (2017–2020).

Spain: CEE Mandatory, Rental Restrictions Coming Under EPBD Transposition

Spain's Certificado de Eficiencia Energética (CEE) is mandatory for any sale or rental of a residential property and is governed by Real Decreto 390/2021. Penalties for failure to provide a valid CEE range from €300 to €6,000.

Spain has not yet imposed rental bans on F or G properties, but the 2024 transposition trajectory under the EU EPBD recast (Directive 2024/1275) will require Spain to introduce minimum energy performance standards for residential buildings, with the precise schedule still being finalised in 2026. The implicit direction is convergence with France's model over the late 2020s.

For foreign buyers in 2026, the CEE matters most for three reasons:

• Resale market signal. A C-or-better CEE is increasingly required by mortgage lenders for the best terms; F and G properties trade at discounts of 5–15% in major Spanish cities.
• Tourist rental licensing. Several Spanish regions, Andalucía, Cataluña, Comunitat Valenciana, have tightened tourist licence requirements in 2024–2026, and the CEE rating increasingly factors into licence renewals.
• Forward-looking liability. A G-rated apartment bought in 2026 is likely to face Spanish equivalents of France's rental restrictions by 2028–2030. Buyers should price this risk into purchase decisions.

Italy: APE and the EPBD Transposition

Italy's Attestato di Prestazione Energetica (APE) is governed by Decreto Legislativo 192/2005 as amended, most recently by the 2024 transposition of EPBD recast (Decreto Legislativo 199/2021 and subsequent updates). It is mandatory for sale or rental, and penalties for failure range from €1,000 to €18,000.

Italy's 2020s have been dominated by the Superbonus 110% program, a state subsidy of up to 110% (initially) for whole-building energy renovations including thermal insulation, photovoltaic installation, and heating-system replacement. Although the program has been progressively scaled back (current rates around 65–70% for 2025 and lower for 2026), it produced a multi-year wave of building renovations across Italian condomini that has materially improved national EPC distribution. Many older Italian buildings that were F or G in 2019 are now D or even C after Superbonus-funded works.

The EPBD recast transposition imposes a binding national trajectory: 16% renewable energy share in residential buildings by 2030, with progressive renovation milestones. Italian municipalities are increasingly tying tourist rental licences and short-term rental authorisations to energy ratings.

For foreign owners in 2026, the APE matters for three reasons specific to Italy:

• Building-level renovations are still in flight. Many Italian condomini undertaking Superbonus-funded works in 2023–2025 will be issuing new APEs in 2026–2027 reflecting improved ratings. Foreign owners should obtain updated APEs after works conclude.
• Seismic-retrofit programs (the Sisma Bonus) operate alongside energy programs in earthquake-prone regions. Foreign buyers in Le Marche, Umbria, Abruzzo, and Lazio should expect both energy and seismic considerations.
• Cedolare secca and APE are interlinked for short-term rentals. Lower-class APEs increasingly trigger stricter licensing requirements.

Germany: Energieausweis and the GEG Heating Law

Germany's Energieausweis is governed by the Gebäudeenergiegesetz (GEG), the Building Energy Act, which consolidated three previous laws in 2020 and was substantially amended in 2024 (the controversial "Heating Law" or Heizungsgesetz).

The Energieausweis comes in two forms: the Verbrauchsausweis (based on actual three-year consumption data) and the Bedarfsausweis (based on a building-modelled calculation, mandatory for buildings older than 1977 with limited energy improvements). The latter is typically more demanding and produces lower ratings.

The 2024 Heating Law (effective 1 January 2024) imposes a powerful renovation trigger: new heating installations must use at least 65% renewable energy, with phased application that has been controversial. For foreign owners, the practical effect is that when a building's heating system reaches end-of-life, the replacement must be a heat pump, biomass system, or hybrid, not a conventional gas boiler. This pushes capital expenditure significantly higher than landlords had previously modelled.

Germany has not imposed explicit rental bans on low-class Energieausweise to the extent France has. Instead, the German approach combines:

• Renovation triggers (when work is done, it must meet GEG standards).
• Sale-and-purchase disclosure (Energieausweis must be provided to buyers).
• Subsidies (federal BAFA and KfW grants for energy renovations).

For foreign owners, the German system is structurally more landlord-friendly than France or the UK but financially demanding when major renovation cycles occur. Berlin and Hamburg owners with older buildings should expect heating-system replacements in the 2025–2030 window to cost €15,000–€40,000 per unit through their WEG.

The Other Major Jurisdictions

Netherlands, Energielabel mandatory; office buildings since 2023 require minimum Class C, with residential trajectories under EPBD transposition. Amsterdam tightening short-term rental energy requirements.

Portugal, Certificado Energético mandatory under Decreto-Lei 101-D/2020, governed by ADENE. No rental ban yet but EPBD transposition pending. Lisbon and Porto tightening alojamento local requirements.

Ireland, Building Energy Rating (BER) mandatory; cost rental schemes require minimum B2. The wider EPBD trajectory applies.

Switzerland, Cantonal energy standards (the CECB in French-speaking cantons, GEAK in German-speaking) increasingly required at sale. Lex Koller already restricts foreign buyers; energy compliance adds a layer.

Australia, Some states (particularly the ACT and Victoria) require disclosure of energy ratings at sale; nationwide NatHERS rating system. New South Wales requires disclosure under the Sustainable Building rules.

United States, No federal EPC requirement; some state and city programs (NYC Local Law 97 for large buildings, Boulder's SmartRegs, California's Title 24 disclosure). The patchwork makes US energy compliance idiosyncratic.

What This Means for the Cross-Border Buyer in 2026

Energy rating now functions as a structural pricing input on cross-border residential property, not a footnote. Three practical takeaways shape every foreign-investor decision:

The EPC-driven discount-and-premium has widened materially. A B-rated Paris apartment trades meaningfully above an equivalent E-rated unit. A C-rated UK buy-to-let attracts mortgage finance the F-rated one cannot. A Superbonus-renovated Italian apartment carries an APE-driven premium over the un-renovated unit next door. JanusHermes surfaces these EPC-adjusted valuations explicitly.

Forward regulatory risk is concentrated in F and G stock. Buyers acquiring F or G properties in 2026 should price in the cost of renovation to at least C, plus a margin for methodology changes (such as the UK's new four-metric Home Energy Model). The cost is recoverable in many jurisdictions through subsidies, but the cash-flow timing matters.

Building-level certificates increasingly drive unit-level outcomes. France's DPE collectif (from January 2026 for all buildings), UK whole-building reforms, and Italy's Superbonus dynamics mean that owning a unit in a building with a poor whole-building rating creates renovation pressure even on units that are individually well-rated. Reviewing the building's carnet d'entretien, piano triennale, or equivalent capex plan is now essential.

For investors building cross-border residential portfolios in 2026, EPC tier has joined location, building age, and tenancy regulation as a primary screen. The properties that hold up over the next decade will be those that already meet or can credibly reach the regulatory minimums of their jurisdiction's 2030s trajectory.

Frequently asked questions

Can a low EPC rating stop me renting out my property?
Yes, increasingly. France already bans renting G-rated homes (since 1 January 2025), with F-rated banned from 2028 and E-rated from 2034, and the UK requires EPC Band C for all privately rented homes in England and Wales by 1 October 2030. F and G classes are progressively being removed from the legal rental market.

What does the UK Warm Homes Plan require, and what are the penalties?
Published on 21 January 2026, it requires EPC Band C for all privately rented properties in England and Wales by 1 October 2030, with a per-property improvement cost cap of £15,000 and fines of up to £30,000 per property per breach.

How long is an EPC valid?
Typically 10 years in most EU regimes, and it must be presented at the moment of sale or rental. Failure to provide a valid certificate carries administrative fines that vary by country, for example up to €15,000 in France and up to £30,000 in the UK.

Did France's 2026 reform change any ratings without renovation?
Yes. From 1 January 2026 the electricity conversion coefficient dropped from 2.3 to 1.9, making electrically heated homes look about 17% better on paper, and an estimated 850,000 French properties rated F or G are expected to move up at least one class on recalculation, which is available free through ADEME's website.

JanusHermes surfaces the current EPC rating, expiry date, regulatory exposure under jurisdiction-specific minimum energy standards, estimated cost-to-compliance, and applicable subsidies, so foreign buyers price energy risk explicitly before commitment. From DPE-constrained Paris copropriétés to UK MEES-deadline buy-to-let to Italian Superbonus-renovated condomini, use the JanusHermes platform to make the EPC reality visible at the listing level.

This article is for general informational purposes only and does not constitute legal, tax, or investment advice. EPC regimes and minimum energy efficiency standards change frequently and vary significantly by jurisdiction. Always consult qualified local advisers and verify the current EPC and regulatory status of any specific property before commitment.

A note on the numbers: where no source is named, the market figures in this article (prices, yields, costs) are indicative estimates compiled from publicly available market data and industry reporting at the time of writing. Markets move and rules change, so treat them as a starting point and verify current figures with official sources before acting on them.