2.III.iii. Progress and current status of EPCs on public and large buildings visited by the public – OVERVIEW

Displaying the front page (including the labelling) of EPCs in buildings frequently visited by the public is mandatory in all federal provinces. EPCs are displayed in all public buildings owned by public authorities and visited by the public (including the buildings managed by the Federal Real Estate Company (BIG).

The format and content of the EPC for public buildings is also defined in the OIB Guideline 6 and follows the same methodology as the EPC for non-residential buildings.

Buildings occupied by public authorities must display an EPC; this must be updated yearly on the basis of real consumption if more than 250 m² of the building is occupied by public authorities.

In the Flemish Region, the certification of public buildings has been gradually introduced. Initially (since January 2009), only large (> 1,000 m²) public buildings needed to have an EPC on display. Since January 2013, all public buildings larger than 500 m² need to display an EPC. As of January 2015, small public buildings (> 250 m²) are also included.

Since September 2016, it is possible to rely on the EPC for new buildings to meet the above requirement. In the future, it will also be possible to rely on the EPC for non-residential buildings in order to meet the above requirement.

In case of rental or sale, an EPC for non‐residential buildings will be necessary. The EPC for existing non-residential buildings is still under development.

From 2009 until the end of December 2019, more than 10,000 certificates for public buildings were issued. These certificates are issued on the basis of an operational rating (measured energy consumption).

Public buildings are defined as buildings used by the federal, regional and local governments, schools and health, as well as welfare institutions. Private buildings visited by the public are not yet included.

For public buildings visited by the public, a web software called ECUS¹³ was created to input the collected building data.

The certificate indicates the energy class of the building according to its type. This is based on the operational rating being converted into primary energy per m². The certificate also contains a graph showing the real consumption of electricity and combustible fuel for the last three (3) years and other specific indicators.

The deadlines are as follows:

• Buildings occupied by European and international institutions, federal, regional, community, provincial and municipal authorities: 1 January 2021.
• Buildings occupied by organisations created, approved or controlled by the above institutions: 1 January 2022.
• Buildings intended for early childhood education or care: 1 January 2022.

There is not yet an energy register of public buildings.

It was estimated that +/- 11,000 public buildings had to be certified:

• +/- 4,500 buildings by the deadline of 1 January 2021.
• +/- 6,500 buildings by the deadline of 1 January 2022.

By the end of 2019, there were no public buildings certified as yet. Public authorities took a long time to launch public procurements to do so. The first certificates were established in 2020.

All existing buildings, including public and large buildings visited by the public, shall be subject to mandatory audits and certification - with the exception of some buildings of cultural merit, places of worship, and residential buildings with a limited annual time of use, to name a few.

Public buildings with a total useful floor area of over 250 m² must display the EPC. This includes public buildings used by public authorities for performing their activities, and buildings used to house specific population groups (e.g., elderly persons, children, etc.) as well as non-residential buildings in which a high number of people are present or are provided with a service.

Municipal service officers control whether these EPCs are adequately displayed by visiting the buildings and making a report. In the case of non-compliance with the regulation, they shall ask the owner to display the EPC.

EPCs for public buildings are in the same format as those of non-residential buildings and follow the same procedures (audit followed by issue of EPC).

Fines for public building owners who fail to display the EPC are established by law and amount from 15,000 to 30,000 kuna (approximately 2,000 – 4,000 €) for legal entities, and from 5,000 to 10,000 kuna (approximately 700 – 1,300 €) for natural persons. The obligation for public display of the EPC is commonly followed and no fines have yet been issued.

Figure 4. Display of the EPC in public buildings for the period of 2010 – 2019.

The public sector is housed in 1,087 buildings, while public schools are approximately an additional 900 buildings. It is required that public buildings over 250m² and frequently visited by the public issue and display an EPC. The Department of Electrical and Mechanical Services has the overall responsibility for issuing EPCs for the buildings owned by the central government, while the issuing of an EPC for buildings that the government rents is the sole responsibility of the owner. For the rest of the public sector the responsibility lies on each public authority. In order to check compliance with the display of EPCs, 19 inspections have been carried out in buildings used by the central government, the local authorities and other public bodies. In 10 cases the EPC was not displayed and the relevant public authorities were notified.

Since 2012, all buildings over 500m² and frequently visited by the public have to display an EPC, if it has been issued.

The Czech Republic runs a database called the Central Register of Administrative Buildings¹. This register keeps records of 5,000 buildings that are properties of the state. The Energy Management Act §7a sets the obligation for public authorities and owners of buildings occupied by public authorities to have the EPC issued by 1 July 2013 for buildings with a total floor area of over 500 m², and by 1 July 2015 for buildings with a total floor area of over 250 m². The same paragraph requires that the EPC be displayed in the building in accordance with Decree no. 264/2020 Coll., which obliges owners to obtain it for a new building construction or a major renovation of a building in which the energy reference floor area is equal to or greater than 500 m². It also requires that the EPC be displayed in the building in accordance with the Decree No. 264/2020 Coll., for buildings having an energy reference floor area equal to or greater than 250 m² and being intended for public use. The EPC has the same format as the one for non‐public buildings and must be displayed in a prominent place where it is clearly visible to the public. The EPC must be issued again as soon as it expires (within 10 years), in case of major building renovations, or if a change is made to the heating, cooling or hot water preparation system in the building.

An EPC for a public building or a large building often visited by the public has the same format, content and validity as an EPC for any other building type. In addition, it is required that the EPC is placed somewhere visible to the public. Key information about the certificate is available on www.boligejer.dk, where it is possible to find the calculated consumption as well as the name of the energy expert and the certified company who issued the certificate.

In 2019, the Danish Energy Agency carried out an analysis to identify the extent to which data from the energy labelling scheme is included in existing commercial digital products, addressed to building owners with the aim of supporting maintenance and energy efficiency. The analysis concluded that a number of actors work systematically to use energy labelling data and that such data is of great value to building owners.

Current legislation requires an EPC for every public building used by the government that has a floor area larger than 250 m². The EPC must be placed in a location visible to visitors.

In 2015, the CPTRA focused on central government buildings, so that by the end of 2015, 90% of the relevant buildings had an EPC. Exceptions are in place for certain building types, e.g., historical buildings, etc.

In the 2016-2021 period, the CPTRA focus was on local municipality buildings. By the end of January 2022, 90% of local municipality buildings for which an EPC is mandatory have an EPC. A full report¹⁴ on the local municipality building stock was published in April 2022.

According to the report, 98% of the buildings that are required by law to have an EPC, meet this requirement. A 2% of the missing EPCs can be justified with local municipalities’ plans to renovate those buildings within the coming years after which these buildings will be certified and given higher energy class (vs. if they would get the EPC today).

Of the existing buildings owned by the local municipalities, class C and class D buildings have the largest share, respectively 23% and 22% (Figure 3).

Figure 3: Energy profile of local government buildings’

According to legislation from 1 July 2015, the EPC must be displayed so as to be visible to the public in buildings where over 250 m² of total useful floor area is occupied by public authorities and visited by the public. In addition, the EPC must be displayed so as to be visible to the public in all buildings that already have an energy certificate and that have over 500 m² of total useful floor area visited by the public. The display regulation is controlled by the ARA.

Information on EPCs displayed in public buildings owned and occupied by public authorities, such as municipalities, is also received through the Finnish energy efficiency agreement scheme. The latest information is from 2018. The energy efficiency agreement scheme coverage in the public sector is high, as the communities involved represent close to 80% of the population of Finland and, respectively, nearly 80% of the overall volume of service buildings in the sector.

Since 2007, all buildings over 1,000 m² occupied by public authorities and frequently visited by the public must have a valid EPC. The threshold was successively lowered to 500 m² in 2013 and to 250 m² in 2015. Once issued, the EPC must be displayed near the entrance point of the building, clearly visible by the public.

As for the general activity level, the exact number of EPCs issued for each type of building since April 2013 is determinable (Table 4). Since August 2015, a 1,500 € fine can be imposed to non-compliant building administrators.

Concerning the format and content of EPCs, German legislation does not distinguish between public and large private buildings visited by the public, and other non-residential buildings. The display form (Figure 3) is provided by the printing tool as an integrated part of every EPC for a non-residential building. Thus, a display form is at hand in case that the display becomes compulsory for the building in question in the future, or in case that the owner wants to put out a voluntary display. In case that an EPC was issued under former legislation, a new display based on this EPC must mention the applied version of the ordinance.

Figure 3. Example of a filled-in display form (anonymised)

According to the provisions of Law 4122/2013, from 9 July 2015, the requirement that all buildings used by the public sector and visited by the public must ensure an EPC is issued and publicly displayed⁵ also applies to buildings with a total area of 250 m² or more. Since no official registry for public buildings exists in Greece, the necessary information on public buildings is difficult to access. A list of 21 public buildings owned by central government organisations with a total useful floor area over 250 m² has been compiled using the framework of Article 5 of EED. No controls are foreseen regarding the issuance and public display of EPCs.

In Hungary, the definition of a public building includes every state-owned non-residential building. Initially, only the larger buildings (exceeding 1,000 m² floor area) were required to display their EPC, making it visible to the public. Since 2015, the EPC is obligatory for all public buildings and large buildings open to the public exceeding 250 m² floor area, and the EPC must be displayed in a visible place. For the display itself, there is no effective control and sanction system in operation.

The cost of an EPC for public buildings must be determined based on real cost reports and is generally between 100 and 1,500 €, depending on the size and complexity of the building.

In Ireland, all large buildings (those with a total useful floor area over 500 m² and, since July 2015, over 250 m²) that are frequently visited by the public should have an EPC on display. This requirement applies irrespective of whether the building is occupied by a public authority.

The Building Control section in each authority is responsible for monitoring and enforcing the requirement to display EPCs in public buildings and large buildings often visited by the public. The number of EPCs published for display in 2019 was 495.

Buildings occupied by public authorities and frequently visited by the public, with a total useful floor area over 250 m², must display an EPC, with the energy class displayed outside the building.

Monitoring the display of EPCs in buildings occupied by public authorities and frequently visited by the public, with a total useful floor area over 500 m² and 250 m² respectively, has not been implemented in Italian regions so far. This is still to be fully covered by the national legislation.

The obligation to issue an EPC for public and large buildings visited by the public is only mandatory if the building owner is the central or local government. State building certifications are still in process. The delay in implementation is due to the fact that the activity to promote energy efficiency in state buildings¹³ had only started at the end of 2016, with the EPC being one of the requested documents. Issuing an EPC is rational and cost-efficient when the building is participating in the aforementioned programme.

For residential buildings and non-residential buildings occupied by public authorities and frequently visited by the public with a surface exceeding 250 m², the EPC must be displayed in a clearly visible place. For residential buildings and non-residential buildings not occupied by public authorities but frequently visited by the public, this obligation applies when the surface exceeds 500 m².

Buildings visited by the public are a useful opportunity to disseminate information regarding EPCs and energy savings in general. In light of this, action is taken to ensure that all buildings larger than 250 m² which are occupied by a public authority and frequently visited by the public have a valid EPC that is clearly displayed to the public. A list of all buildings owned and/or used by the various government ministries is created and includes information on useful floor area and whether or not it frequently visited by the public. There is a planning in place for most of the buildings which satisfy the requirement for issuing an EPC. The plan is currently being assessed to verify if all EPCs that have been issued are on display. The rate of compliance for EPCs in public and private schools and central government buildings is very high. Since the EPCs of such buildings are frequently viewed by the public, the contents and calculations of related EPCs on display are verified for qualitative purposes. This verification process is additional to the independent control system in place, and involves on-site verification of the data. The improvement of the EPCs on display would be beneficial to the reputation of EPCs overall.

The obligation to display the energy performance label has been mandatory since 2008. In 2015, 1,183 public buildings (municipality, province and government buildings) were identified, and 584 of them were checked by the ILT. Of these buildings, 245 had not yet displayed their energy label. Another 380 public buildings were inspected in 2016.

The ILT can give owners of such buildings a financial penalty in case of non-compliance. To date, several owners of public buildings have received a warning of non-compliance with the requirement for public display of the EPC. They are given a 6 month period to become compliant and will be checked again after this period.

The directive’s requirements for public buildings in Norway relate to all non-residential buildings. Thus, the regulation does not distinguish between public and private buildings above 1,000 m².

Since these buildings have an ongoing obligation to obtain and display the EPC, the task of informing the building owner about the EPC obligation has been simpler than for sold or rented non-residential buildings. The understanding among developers of new building projects seems to be well established – in particular among owners who want to construct high quality buildings. A typical example is office buildings with headquarters for well-known companies. The knowledge and practical experience is less developed among owners of existing buildings.

It has been observed that a number of municipalities are lagging behind in certification due to budget constraints.

The certification process for public buildings, or for large buildings visited by the public, falls under the same regulations as for other buildings. According to the Act on the Energy Performance of Buildings, the EPC shall be visible to the public in the case of buildings (> 250 m²) used by justice authorities, the prosecutor's office, or for public buildings to which the public have access.

The template of the EPC for these buildings is the same as the one used for other buildings. EPCs for these buildings are issued by the same group of experts as EPCs for buildings that are being sold. Also, the provisions on quality assurance are the same as those described above.

The EPC data collected within the public central register provides information about the building stock, e.g. energy performance, share of RES, CO₂ emissions, etc.

Since 2014, the Portuguese definition of a public building includes every non-residential building as well as private buildings owned by government bodies. Non-residential buildings larger than 500 or 1,000 m² (depending on the type) are required to display an EPC at the main entrance. Currently, there are more than 2,500 certified public buildings and many more in the process of being certified. The low number of EPCs issued for public buildings shows that this building typology faces many challenges in implementing the EPBD requirements in Portugal, but a clear increase in the number of certified buildings can now be observed.

Energy certification and display is mandatory for buildings used by public authorities with a total floor area of more than 250 m² (until 9 July 2015 it was for more than 500 m²) or for buildings that are frequently visited by the public.

The Slovak Trade Inspection is in charge of checking that EPCs are publicly displayed.

The format and content of the EPC for public and large buildings that are visited by the public are the same as for other buildings. EPCs for public and large buildings visited by the public are valid for 10 years unless the building is renovated and there is a change in the energy use.

As of 2020, Decree 35/2020 introduces an obligation to indicate on the EPC when a building is a public building, both for statistical purposes and for the purpose of recognition in the database.

The public building stock represents 11% (around 600,000) of the entire number of buildings. Most public buildings and large buildings visited by the public have an EPC, primarily due to the obligation defined in the Energy Act and in the new Act on Energy Efficiency (2020), and secondly due to energy renovation planning processes. An energy audit is a precondition for financing the investment, and for each building for which an energy audit is performed there is also an issued EPC. The progress is good due to a number of financing possibilities. In addition, the 3% annual energy renovation rate of buildings owned and used by the central government contributed to a significant increase of the number of EPCs within 2 years, as all the buildings on this list obtained an EPC.

The obligation to obtain an EPC for public buildings when its total useful area exceeds 500 m² dates from June 2013. As of 9 July 2015, the obligation for public buildings stands when the total useful area is greater than 250 m², and from 31 December 2015 when the total useful area exceeds 250 m² and is under lease.

The obligation also stands for privately-owned buildings that are frequented visited by the public, when they are sold or rented.

The registration, control and inspection system for this type of building is the same as for the rest of the buildings, and there are no specific additional measures for compliance.

Public buildings have been included in the certification system since 2008. The regulation follows the area limits provided in the EPBD Directive 2010/31/EU.

Overview

The approach depends on the type of occupier and the building’s floor area (Table 9). Display Energy Certificates (DECs) are issued and displayed in buildings > 250 m² that are occupied by a public authority and frequently visited by the public. EPCs are displayed in commercial premises > 500 m² that are frequently visited by the public and where an EPC has previously been issued.

Table 9: Energy performance display requirements.

EPCs are based on calculated energy consumption. DECs are based on measured energy, normalised to allow cross sector comparison. Annual DECs are only required for public authority buildings with a floor area > 1,000 m² (Table 9).

Format and content of DECs

DECs show the performance of a building based on actual energy consumption for the previous year in the form of an Operational Rating (OR), Figure 13. If available, the building’s performance over the previous three years is shown to illustrate the performance trend. The OR is a numerical indicator of a building’s annual CO₂ emissions on an A to G scale. In its simplest form, the Operational Rating would be expressed as the total annual energy used by the building divided by the area of the building, compared to the energy use per unit area of building typical of its type.

Figure 13: Display Energy Certificate (DEC).

The building’s performance is compared to a benchmark specific to its category. Benchmarks are reviewed periodically to ensure they are adequate. Buildings with zero CO₂ emissions or net energy generators achieve an OR of zero. Buildings, which perform at the benchmark level, achieve an OR of 100 at the D to E boundary. Buildings, which emit twice as much CO₂ as the benchmark, achieve an OR of 200. The approved benchmarks are set out in Energy Benchmarks (TM46)⁴⁷. DECs are accompanied by a Recommendation Report, which includes cost‐effective recommendations and has a maximum validity of seven or 10 years (Table 10). DEC record data from 2008 to December 2019⁴⁸ is included in Table 10 and Figure 14.

Table 10: Display Energy Certificates 2008 to 2019, England.

“not recorded” = invalid DEC data entry^.

Figure 14: Display Energy Certificates, 2008 to 2019, England. Percentages by band.

DEC costs vary greatly. Indicative market costs (based on internet search) for a first year DEC and Recommendations Report range from £130 to £300 (~151 € to ~348 €).

Wales adopted the same approach as England. See England report for details. Display Energy Certificates (DECs) data from 2008 to December 2019 is included in Table 4 and Figure 9.⁶

Table 4.  Wales, 2008 to December 2019, Wales.

“not recorded” = faulty EPC (cancelled, withdrawn, etc.)

Figure 9. Display Energy Certificates (DECs), 2008 to December 2019, Wales. Percentages by DEC band.

Northern Ireland adopted the same approach as England. See England report for details.

Display Energy Certificates (DECs) are required to be displayed in certain public authority buildings which are frequently visited by the public. DECs provide “Operational Ratings” based on actual energy consumption. DECs are accompanied by a Recommendation Report. In Northern Ireland, DECs must be updated annually, and Recommendation Reports are updated every seven years.

DECs data to December 2019 is included in Table 5 and Figure 14.

Table 5. Display Energy Certificates Northern Ireland to December 2019.

Figure 14. Display Energy Certificates Northern Ireland to December 2019. Percentages by DEC band.

Unlike other UK jurisdictions, in Scotland the calculated EPC required on construction, sale or rental is also displayed in public buildings. The requirement applies to two building categories:

• Buildings occupied by public authorities with a floor area > 250 m² and frequently visited by members of the public. Qualifying occupiers must obtain and display an EPC.
• Other non‐domestic buildings with a floor area > 250 m² and frequently visited by members of the public. Qualifying occupiers must display the EPC only if they have one.

Activity levels for the display of EPCs within Local Authority public buildings are monitored by the Scottish Government. Non‐domestic EPCs activity levels are provided above.